This document summarizes a case study of a mill project that required a PSD permit. The mill modified its recovery furnace and combination fuel boiler and installed a new steam turbine generator and cooling tower. The project required a PSD applicability analysis which found increases in NOx, PM, and TRS above significance levels. The mill developed a PSD application including BACT and air quality modeling. The permit application process took over a year and required additional NOx reductions to address EPA concerns and new standards. The conclusions were that new standards will slow PSD permitting and force additional emissions reductions.

1. Case Study - NSR 2010
Colin McCall
All4 Inc.
NCASI 2010 Southern Regional Meeting
Charleston, SC
June 29, 2010

2. Agenda
 Overview of Project
 PSD Applicability Approach
 Review Process and U.S. EPA Involvement
 Mill Response and Project Impact
 Conclusions
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3. The Project
 Modify recovery furnace:
• DCE to NDCE
 Modify combination fuel boiler:
• Upgrades for additional biomass/alternative fuels
• Overfire air improvements
• Steamside efficiency increases
 Install new steam turbine generator set and
new cooling tower
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4. Positive Environmental Aspects
 Recovery furnace modifications:
• Low odor conversion
• Eliminates BLOX
• Predicted reductions in SO2, VOC, CO, PM,
PM10, PM2.5, and TRS
 Combination fuel boiler modifications:
• Projected decrease in fossil fuel
• Improved combustion efficiency
• Predicted reductions in NOX, CO
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5. PSD Applicability
 Actual-to-projected actual applicability analysis
• Projected actual emissions (PAE) for modified
recovery furnace for all but NOX and PM, potential
to emit (PTE) for NOX and PM
• PAE developed for combination fuel boiler based on
Mill business projections
• PAE for combination fuel boiler excluded emissions
that it could have accommodated during baseline
• PTE for new cooling tower
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6. PSD Applicability
 PSD Assessment:
• Step 1 – Are project emissions increases
greater than significance levels?
• Step 2 – Are net emissions increases greater
than significance levels?
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7. PSD Applicability
 Step 1 results:
• Project increases alone were significant for
NOX, PM, TRS
 Step 2 results:
• Net decreases from project eliminated TRS
• Project was a PSD major modification for
NOX, PM
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8. PSD Application
 Key PSD application components:
• BACT for NOX on recovery furnace
• BACT for PM on recovery furnace,
combination fuel boiler, cooling tower
• Air quality modeling demonstration for NOX
resulted in predicted annual impacts below
significant impact level (SIL)
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9. Application Review
 Application submitted late 2009
 State agency reviewed and forwarded to
U.S. EPA
 Permit was anticipated by early May 2010
 U.S. EPA commented in early April
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10. Application Review
 U.S. EPA comments:
• If permit not issued by 4/12/10 application
had to address new 1-hr NO2 standard
• Concern w/excluded emissions that boiler
could have accommodated
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11. Mill Issues/Approach
 Project timing critical date - June 2010
 Develop immediate response to U.S. EPA
concerns to expedite permit:
• Determine implications of short-term NOX
impacts
• Revisit use of excludable emissions that the
combination boiler could have accommodated
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12. Mill Issues/Approach
 Short term 1-hour NO2 analysis;
• No SIL, no U.S. EPA guidance
• Short-term project NOX emissions increases
modeled
• Results <10% but >5% of new NAAQS
• Time for full NAAQS study not acceptable
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13. Mill Issues/Approach
 Additional NOX reductions evaluated to:
• Determine impact on short-term model results
• Reduce project NOX increases to below PSD
significance level (<40 TPY)
 Resulted in management commitment of
significant $$$ to reduce NOX from
combination fuel boiler
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14. Mill Issues/Approach
 Eliminate use of excludable emissions for
combination fuel boiler analysis:
• Down-sized new turbine generator set
• Incorporated new test data for PM10, PM2.5
and condensables from ICR testing
• Incorporate NOX reduction technology
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15. Project Status
 Revised approach presented to state
agency and support obtained at all levels
 Formal update to application submitted
and awaiting U.S. EPA review
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16. Project Conclusions
 No grandfathering – be prepared for new
NAAQS and other requirements (SO2, GHG)
 Lack of guidance and tools for new standards
will slow process
 Concern for ability to demonstrate
compliance with new NAAQS will force
additional reductions
 PSD process under NSR Reform continues to
evolve…
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17. Questions?
cmccall@all4inc.com
All4 Inc.
2393 Kimberton Road
P.O. Box 299
Kimberton, PA 19442
610.933.5246 x20
www.all4inc.com
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