strategic air planning: is the time for a pal here?

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

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Page 1: Strategic Air Planning: Is the time for a PAL here?

Strategic Air Planning:Is the time for a PAL

here?

NCASI 2011 Northern Regional

Wausau, WI

May 19, 2011

John EganAll4 Inc.

Page 2: Strategic Air Planning: Is the time for a PAL here?

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Agenda Mounting air pressures Mill needs and expectations Major new source review struggles Importance of strategic planning Considerations for an advantage

Page 3: Strategic Air Planning: Is the time for a PAL here?

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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…

Page 4: Strategic Air Planning: Is the time for a PAL here?

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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.

Page 5: Strategic Air Planning: Is the time for a PAL here?

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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

Page 6: Strategic Air Planning: Is the time for a PAL here?

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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

Page 7: Strategic Air Planning: Is the time for a PAL here?

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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)

Page 8: Strategic Air Planning: Is the time for a PAL here?

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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

Page 9: Strategic Air Planning: Is the time for a PAL here?

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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

Page 10: Strategic Air Planning: Is the time for a PAL here?

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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

Page 11: Strategic Air Planning: Is the time for a PAL here?

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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

Page 12: Strategic Air Planning: Is the time for a PAL here?

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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

Page 13: Strategic Air Planning: Is the time for a PAL here?

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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

Page 14: Strategic Air Planning: Is the time for a PAL here?

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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

Page 15: Strategic Air Planning: Is the time for a PAL here?

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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…

Page 16: Strategic Air Planning: Is the time for a PAL here?

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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)

Page 17: Strategic Air Planning: Is the time for a PAL here?

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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

Page 18: Strategic Air Planning: Is the time for a PAL here?

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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

Page 19: Strategic Air Planning: Is the time for a PAL here?

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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

Page 20: Strategic Air Planning: Is the time for a PAL here?

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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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Questions?

[email protected]

All4 Inc.2393 Kimberton Road

P.O. Box 299Kimberton, PA 19442

610.933.5246 x14 and x20

www.all4inc.com