www.all4inc.comKimberton, PA | 610.933.5246Kennesaw, GA | 678.460.0324
Strategic Air Planning: Is the Time for a PAL Here?
Mark Wenclawiak, CCM| [email protected] | (678) 460-0324October 24, 2013
Presented to Georgia AWMA by All4 Inc.
2 Your environmental compliance is clearly our business.
Air permitting to support growth• Plantwide Applicability Limit (PAL) permitting• Not new concept but time for a kick start?
Mounting air pressures Facility needs and expectations Major New Source Review (NSR) struggles Importance of strategic planning What is a PAL, how it can be smart strategic
decision
Agenda
3 Your environmental compliance is clearly our business.
National Ambient Air Quality Standard (NAAQS) NSR Greenhouse Gas (GHG) Regulation National Emission Standards for Hazardous Air
Pollutants (NESHAPs)• Boiler MACT
Project happening again• Significant capital expenditures and complicated
permitting efforts• Balancing these pressures with economic recovery and
growth
Air Pressure
4 Your environmental compliance is clearly our business.
In years past, actual emission increases predicted and realized from projects
Common theme of this new day and age has emerged:
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.
Preserve those historically high emissions!
Air Pressure (continued)
5 Your environmental compliance is clearly our business.
Ability to change operations quickly & as needed Long range targets for planning:
• Internal - production/energy/economics (more production at lower costs)
• External – new rules driving up costs to comply • You – caught in the middle
Energy study – modify process line to generate steam savings and increase in production• Emissions from boiler decrease – good thing• But…still need that PSD applicability analysis
Facility Needs
6 Your environmental compliance is clearly our business.
Strategic planning for the future must consider implications of both new air rule applicability and air permitting implications:• Lots of rules/lots of issues/lots of confusion• New rules likely require facility changes• No exemption for pollution control projects• Permitting issues can impact project design
Do you install scrubber to control HCl for MACT?• Co-benefit: SO2 will decrease as well – how does that
impact your NAAQS compliance • Scrubber project many now be desirable
Future Planning
7 Your environmental compliance is clearly our business.
Air issues must be integrated into facility operations planning
Result will be same old push/pull for projects whether needed or required:• PSD applicability analysis• Potential impacts to project design, cost, schedule• Confusion and frustration
System for evaluating projects must be established and adhered to
Compliance with NAAQS is critical
Future Planning (continued)
8 Your environmental compliance is clearly our business.
“Plantwide Applicability Limitation” (PAL) is an available regulatory option that can potentially ease the PSD permitting cycle
Federal PSD rule provides for PALs based on historic actual emissions
PALs are pollutant specific and could be a critical part of a facility strategic plan…Why????• Preserve that baseline!
PAL Option
9 Your environmental compliance is clearly our business.
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
Decisions regarding process and air pollution control technology now remain with the source, not the agency (e.g., BACT)
PAL Advantages
10 Your environmental compliance is clearly our business.
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 facilities to realization that future emissions will be lower per unit of production driven by rules, standards, permitting, technology, etc.
Emerging in complex plants like cement, pulp and paper
Why a PAL Now?
11 Your environmental compliance is clearly our business.
Air permitting complicated enough Largely avoided up until now
• Must be able to track and report emissions against PAL• Historically facilities saw too many sources and not
enough data to justify a PAL However, data and tools now available for
demonstrating compliance due to other rule activities
So how do you establish a PAL?
Why a PAL Now? (continued)
12 Your environmental compliance is clearly our business.
One or more pollutants (including GHGs) Based on 12-month rolling total (tons/yr) Same baseline actual emissions used in PSD
applicability assessment:• 24-month consecutive period during the prior
10 years of operation• Add PSD/NNSR significance threshold
Establishing A PAL
13 Your environmental compliance is clearly our business.
PAL established for 10 year period PAL can be adjusted down to account for new
applicable requirements, NAAQS compliance concerns
Getting out of a PAL can have serious ramifications (e.g., BACT)
State/local air construction permits may still be required
PAL Concerns – Big Picture
14 Your environmental compliance is clearly our business.
Effort associated with developing PAL application• Ahead of the game more than you think
Developing methods to demonstrate compliance• Also likely in place
NAAQS are a driver – know where you stand• Modifications under a PAL will not trigger modeling
But NSR reform rules appear to be working • Could have accommodated• Even non-applicability evaluations not simple
SIP permits, NSPS, NESHAPs, RACT, etc. still apply
PAL Concerns – Specifics
15 Your environmental compliance is clearly our business.
Develop historic facility-wide baseline emission rates and potential PAL levels
Major planning sessions• Consider new rules, facility operations plans, potential
energy efficiency improvements, new technologies, low hanging fruit for emissions reductions
Address potential NAAQS issues Weigh value of PAL for each pollutant
• PM and VOC from coating operations
PAL Planning Approach
16 Your environmental compliance is clearly our business.
Allows you to implement projects quickly For typical facility projects, PSD is no longer a
consideration under a PAL Economic and competitive advantage over
competitors For planning facility now has a clear bright line it
can manage operations to (12-month emissions) Future second guessing by agency of PSD
applicability decisions and potential enforcement issues off the table
Parting Thoughts
www.all4inc.comKimberton, PA | 610.933.5246Kennesaw, GA | 678.460.0324
Questions?
Mark Wenclawiak, CCM| [email protected] | (678) 460-0324