Strategic Air Planning: Is the time for a PAL here?
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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.
Strategic Air Planning: Is the time for a PAL here?
- 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 2
- 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… 3
- 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. 4
- 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 5
- 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 6
- 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) 7
- 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 8
- 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 9
- 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 10
- 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 11
- 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 12
- 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 13
- 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 14
- 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… 15
- 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) 16
- 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 17
- 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 18
- 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 19
- 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 20
- 21. Questions? [email protected] All4 Inc. 2393 Kimberton Road P.O. Box 299 Kimberton, PA 19442 610.933.5246 x14 and x20 www.all4inc.com 21