gronstal anderson, ingrid, pal case study plant-wide applicability limit for campus air compliance,...
TRANSCRIPT
PAL Case Study: Plant-Wide Applicability Limit for Campus Air Compliance
Ingrid M. Gronstal Anderson, J.D.
University of Iowa
Agenda
• University of Iowa campus overview
• PAL permit basics
• University of Iowa PAL
• Innovation example: Biomass fuel project
University of Iowa
University of Iowa
• Located in Iowa City, IA • Southeast Iowa
• Population 70,000
• Enrollment of 31,000 undergraduate and graduate students
• 1700 acre main campus, 298 major buildings
• Oakdale campus research park • Located 10 minutes away from the main campus in Coralville
• Research facilities
Campus Community
• Many departments and activities on campus contribute to complexity in environmental compliance • University of Iowa Hospitals and Clinics
• Life-safety requirements for generators
• Research facilities
• Classrooms and dormitories • Teaching equipment (e.g. art kiln)
• Museums
• Building maintenance
• Servers/backup power
University of Iowa Utilities Campus Utilities include: Main Power Plant, Oakdale Renewable Energy Plant, 4 Chilled Water Plants, and Water Treatment Plant
Existing air quality programs
• 456 emission sources on campus
• Title V Operating permit for entire campus • Major source
• Main Campus and Oakdale campus treated as one facility
• Construction permits required for all sources unless specifically exempted
• MACT, NSPS, NESHAPS
• GHG reporting
PSD Challenges
• Major facility for PSD
• Difficult to predict permitting costs, timeline
• Equipment modification/replacement uncertainty
• Project aggregation uncertainty
• Synthetic minor status creates operational constraints
• Justification of BACT for state-funded institution is difficult
• Expanding biomass/renewable fuels is a priority
PAL Advantages
• Increase operational flexibility/certainty • Streamlined project management
• Construct or modify sources without going through PSD applicability analysis
• Transition to biomass fuels with fewer permitting hurdles
• Optimal operation of sources based on campus needs while still protecting campus air quality
• Streamlined permitting process
• Option to amend limits previously taken for synthetic minor purposes
PAL Basics • Alternate NSR compliance method
• Part of 2002 NSR Reform rules • 40 CFR 52.21(aa)
• Permit for each criteria pollutant
• Sets cap for criteria pollutant actual emissions. Facility must stay below cap for 10 years
• 10-year permit • renew at permit expiration
• If no renewal, must proportion set cap across existing units
PAL Basics
• Baseline is calculated from a representative 2-year period within the last 10 years from the permit application date • Baseline calculation and emissions cap calculation specified in the rules
• Must stay below facility-wide emission cap • Cap is 12-month rolling average tons/year of each pollutant
• Monthly emissions tracking • Must track monthly emissions from all sources to compare facility-wide
emissions to cap.
University of Iowa PAL permits
• Effective March 24, 2016
• Seven permits total: PM, PM2.5, PM10, CO, NOx, SO2, VOC
Pollutant Abbreviation Capped Emission Level
(tpy)
Particulate Matter (≤ 2.5 µm) PM2.5 85.9
Particulate Matter (≤ 10 µm) PM10 97.72
Particulate Matter PM 111.51
Sulfur Dioxide SO2 1602.97
Nitrogen Oxides NOx 751.84
Volatile Organic Compounds VOC 172.75
Carbon Monoxide CO 444.73
Monthly Monitoring • 99% of emissions come from small
subset of sources. • Prioritize these sources in monthly
monitoring methods. • CEMS, flowmeters, real time data from PI
data historian • Stack testing aligned with existing
requirements
• Small sources • Many sources but small percentage of
emissions • Worked with IDNR to develop emission
factors • Stack test or AP-42/worst case
• Work with IT, Energy Control Center to develop monthly tracking database and emission calculation reports
Additional PAL Considerations
• Unit-specific requirements remain • Construction permit terms
• NSPS, NESHAPS, MACT
• Construction Permitting • Construction permits still required for new sources
• Interaction with Title V Program • Campus air sources that were previously insignificant become significant due
to “applicable requirement”
PAL Collaboration • Collaboration with IDNR key to success of permit process
• Complexity of campus sources and permit novelty required significant time and effort from UI and IDNR to develop permits
2020 Vision - The University of Iowa's Sustainability Targets
1. Achieve Net-negative Energy Growth
2. Green Our Energy Portfolio
Consume less energy on campus in 2020 than consumed in 2010 despite projected growth
Achieve the goal of 40% renewable energy consumption on the campus by 2020
4,000,000 MMBtu per year
4,000,000 MMBtu per year
Biomass Fuel Portfolio
• Industrial byproducts:
• Current: oat hulls • Future: energy pellets, cardboard recycling sludge, scrap from
furniture making
• Wood chips:
• Current/past: timber stand improvement, pallet remanufacture
• Future: opportunity wood, short rotation woody crops
• Energy grasses:
• Current development: Miscanthus
• Future: prairie and switchgrass
Densified biomass
Fuel pellets make use of non-recyclable industrial byproducts
Partnering with UI Chemistry Department to
quantify emissions changes
PROFITABILTY
• ~15% of land within Iowa fields not profitable in corn
ENVIRONMENT
• Planting ~15% of land within Iowa fields to diverse perennials provides disproportionate environmental benefit
ENERGY
• Planting ~15% of land within Iowa fields to perennial high-yielding energy crops provides enough biomass
Slide courtesy of Dr. Emily Heaton, Iowa State University
Science-based Trials of Rowcrops Integrated with Prairie Strips www.prairiestrips.org
Slide courtesy of Matt Helmers, Iowa State University.
(Helmers, M.J., et al., Sediment removal by perennial filter strips in row-cropped ephemeral watersheds. Journal of Environmental Quality, 2012. 41(5): p. 1531-1539.)
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Summary
• Innovative permit unique in the state of Iowa
• Collaboration with IDNR essential to project success
• Increases project planning certainty
• Allows U of Iowa to develop innovative strategies to provide reliable utilities service to campus, ensure campus air compliance, and pursue cutting edge renewable energy solutions
