www.all4inc.comKimberton, PA | 610.933.5246Kennesaw, GA | 678.460.0324

Strategic Air Planning: Is the Time for a PAL Here?

Mark Wenclawiak, CCM| mwenclawiak@all4inc.com | (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| mwenclawiak@all4inc.com | (678) 460-0324