The document discusses strategic air planning for mills and considers whether a Plantwide Applicability Limitation (PAL) permit would provide advantages. A PAL sets an emissions limit based on historical levels, and any physical or operational changes below that limit would not require further permitting. The document outlines mounting air regulation pressures on mills, new source review struggles, and how a PAL could help facilities plan strategically by providing a clear emissions baseline and exempting some projects from permitting requirements. Establishing a PAL would require demonstrating compliance methods and setting appropriate limits.

1. Strategic Air Planning:
Is the time for a PAL here?
John Egan
All4 Inc.
NCASI 2011 Northern Regional
Wausau, WI
May 19, 2011

2. Agenda
 Mounting air pressures
 Mill needs and expectations
 Major new source review struggles
 Importance of strategic planning
 Considerations for an advantage
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3. Air Pressure
 NAAQS
 Boiler MACT/CISWI/NHSM
 Pulp & Paper MACT/Residual Risk
 GHG Regulation
 BART/Regional Haze
 Utility MACT/NSPS
 Multi-pollutant Rules
 Black Carbon
 More…
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4. Air Pressure
 Common theme:
For most facilities future emissions
will decrease from historic actual
levels as a result of new and
developing air regulations and
standards, regardless of growth in
productivity.
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5. Mill Needs
 Ability to change operations/equipment
quickly and as needed
 Long range targets for planning:
• Internal - production/energy/economics
• External - rule driven costs to comply
 Clarity in regulatory requirements
particularly for permitting
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6. New Source Review
 NSR reminder:
• Attainment Area = Prevention of
Significant Deterioration (PSD), allowed
to increase actual emissions but always
a challenge
• Non-attainment Area = Non-attainment
New Source Review (NNSR), project
has to improve area air quality
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7. PSD Implementation
 Quick PSD implementation history for mill
changes:
• Old/old way (pre-reform)
• Old/new way (post-reform)
• New/new way (current & post 1-hr
NAAQS)
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8. Old/Old PSD
 Pre-NSR reform:
• Actual-to-potential test
• New limits to reduce PTE and avoid PSD
• BACT main driver if PSD triggered
• Air modeling a challenge for some
pollutants but manageable
• Implementation evolved over 25 years
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9. Old/New PSD
 Post-NSR reform:
• Actual-to-projected actual test
• Better baseline/no new limits
(supposedly)
• Required to track relative to projections
• Formal guidance evolved but limited
• If PSD - BACT still a driver and air
modeling still a challenge for some
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10. New/New PSD
 Current & post 1-hr NAAQS:
• Still actual-to-projected actual test
• Concern w/excluded emissions
• How to handle project on project
• Watch out for netting
• If PSD - air modeling more critical than
BACT and can alter project design
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11. Future Planning
 Strategic planning for facility future must
consider implications of both new air rule
applicability and air permitting implications:
• New rules likely require facility changes
• No exemption for pollution control
projects
• Permitting issues can impact project
design
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12. Future Planning
 Air issues must be integrated into facility
operations planning
 Result will be same old push/pull for mill
projects whether needed or required:
• PSD applicability analysis
• Potential impacts to project design, cost,
schedule
• Confusion and frustration
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13. PAL Option
 “Plantwide Applicability Limitation” (PAL) is
an available regulatory option that can
potentially ease air permitting PSD cycle
 Federal PSD rule provides for PALs based
on historic actual emissions
 PALs are pollutant specific and could be a
critical part of a Mill strategic plan
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14. PAL Advantages
 For a facility with a PAL permit that
maintains emissions below PAL, physical
changes and changes in method of
operation are not major modifications and
do not require approval under PSD
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15. Why a PAL Now?
 PALs historically worked for relatively
simple industries with limited sources and
where technology was driving emissions
lower per unit of production
 New air quality world we are in is forcing
mills to realization that future emissions will
be lower per unit of production driven by
rules, standards, permitting, technology…
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16. Why a PAL Now?
 Must be able to track and report emissions
against PAL
 Historically mills saw too many sources
and not enough data to justify a PAL
 Data and tools now available for
demonstrating compliance due to other
rule activities (e.g., ICR work)
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17. Establishing a PAL
 Same baseline actual emissions used in
PSD applicability assessment:
• Adjust for current applicable
requirements
• Add PSD significance threshold
• Justify PAL and provide method of
compliance
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18. PAL Concerns
 PAL established for 10 year period
 PAL can be adjusted down to account for
new applicable requirements
 Getting out of a PAL can have serious
ramifications
 State/local air construction permits may
still be required
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19. PAL Planning Approach
 Develop historic mill-wide baseline
emission rates and potential PAL levels
 Address potential NAAQS issues
 Consider new rules, mill operations plans,
potential energy efficiency improvements,
new technologies, low hanging fruit for
emissions reductions
 Weigh value of PAL for each pollutant
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20. Final Thoughts
 For typical mill projects PSD is no longer a
consideration under a PAL
 For planning mill now has a clear bright
line it can manage operations to
 Project timing may result in competitive
advantage
 Future second guessing by agency of PSD
applicability decisions and potential
enforcement issues off the table
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21. Questions?
jegan@all4inc.com
All4 Inc.
2393 Kimberton Road
P.O. Box 299
Kimberton, PA 19442
610.933.5246 x14 and x20
www.all4inc.com
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