Mark Wenclawiak of All4 Inc. presented the challenges of greenhouse gas (GHG) Prevention of Significant Deterioration (PSD) permitting at the NCASI West Coast Regional Meeting on September 24, 2014. In the presentation, Mark discussed drivers for such projects and five (5) challenges encountered during the application development and agency review.

1. www.all4inc.com
Kimberton, PA | 610.933.5246
Kennesaw, GA | 678.460.0324 GHG PSD Permitting Challenges
Mark Wenclawiak | mwenclawiak@all4inc.com | 678.460.0324 x202
September 24, 2014
Presented at NCASI West Coast Regional Meeting by All4 Inc.

2. 2
Your environmental compliance is clearly our business.
Outline
Project driver
5 challenges encountered
•During application development
•During agency review

3. GHG PSD Permitting Challenges
Project Driver

4. 4
Your environmental compliance is clearly our business.
Boiler MACT compliance project
•Boilers decommissioned
•Boiler modified
•New boilers installed
Major modification in attainment area
Compressed project schedule
•Pre-application meeting
•Expedited permitting process
Background on Project

5. 5
Your environmental compliance is clearly our business.
Emissions inventory
•PSD applicability evaluation
New and modified units
No affected units
•Actual to projected actual emissions
•Step 1 significant increase for multiple pollutants
Netting
•Step 2 significant increase for GHGs only
Background on Project

6. GHG PSD Permitting Challenges
Challenges During Application Development

7. 7
Your environmental compliance is clearly our business.
Challenge #1
•Biogenic emissions
Challenge #2
•BACT for modified boiler changes scope of Mill’s project
Retrofit with economizer
First Set of Challenges

8. GHG PSD Permitting Challenges
Challenges During Agency Review

9. 9
Your environmental compliance is clearly our business.
Initial submittal in early Spring 2014
•Expedited process to issue permit by mid-summer
•2 iterations of requests for more information
Challenge #3
•Netting calculation procedure
Challenge #4
•Regional Haze
Existing Regulatory Matters

10. 10
Your environmental compliance is clearly our business.
June 23, 2014 SCOTUS ruling during agency review
Challenge #5
•PSD for GHG-only – now what?
•State issues implementation policy
Rules of Game Change

11. 11
Your environmental compliance is clearly our business.
Hold on application
•Revise application to remove PSD references
•Boiler MACT extension request to help with budgeting
Current Path Forward

12. www.all4inc.com
Kimberton, PA | 610.933.5246
Kennesaw, GA | 678.460.0324
Questions & Open Discussions
Mark Wenclawiak | mwenclawiak@all4inc.com | 678.460.0324 x202