Case Study - NSR 2010

NCASI 2010 Southern Regional Meeting

Charleston, SC

June 29, 2010

Colin McCallAll4 Inc.

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Agenda Overview of Project PSD Applicability Approach Review Process and U.S. EPA

Involvement Mill Response and Project Impact Conclusions

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The Project

Modify recovery furnace:• DCE to NDCE

Modify combination fuel boiler:• Upgrades for additional

biomass/alternative fuels• Overfire air improvements• Steamside efficiency increases

Install new steam turbine generator set and new cooling tower

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Positive Environmental Aspects

Recovery furnace modifications:• Low odor conversion• Eliminates BLOX• Predicted reductions in SO2, VOC, CO,

PM, PM10, PM2.5, and TRS Combination fuel boiler

modifications:• Projected decrease in fossil fuel• Improved combustion efficiency• Predicted reductions in NOX, CO

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PSD Applicability Actual-to-projected actual applicability

analysis• Projected actual emissions (PAE) for modified

recovery furnace for all but NOX and PM, potential to emit (PTE) for NOX and PM

• PAE developed for combination fuel boiler based on Mill business projections

• PAE for combination fuel boiler excluded emissions that it could have accommodated during baseline

• PTE for new cooling tower

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PSD Applicability PSD Assessment:

• Step 1 – Are project emissions increases greater than significance levels?

• Step 2 – Are net emissions increases greater than significance levels?

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PSD Applicability Step 1 results:

• Project increases alone were significant for NOX, PM, TRS

Step 2 results:• Net decreases from project eliminated

TRS• Project was a PSD major modification

for NOX, PM

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PSD Application Key PSD application components:

• BACT for NOX on recovery furnace• BACT for PM on recovery furnace,

combination fuel boiler, cooling tower• Air quality modeling demonstration for

NOX resulted in predicted annual impacts below significant impact level (SIL)

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Application Review Application submitted late 2009 State agency reviewed and forwarded

to U.S. EPA Permit was anticipated by early May

2010 U.S. EPA commented in early April

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Application Review U.S. EPA comments:

• If permit not issued by 4/12/10 application had to address new 1-hr NO2 standard

• Concern w/excluded emissions that boiler could have accommodated

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Mill Issues/Approach Project timing critical date - June 2010 Develop immediate response to U.S.

EPA concerns to expedite permit:• Determine implications of short-term NOX

impacts• Revisit use of excludable emissions that

the combination boiler could have accommodated

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Mill Issues/Approach

Short term 1-hour NO2 analysis;• No SIL, no U.S. EPA guidance• Short-term project NOX emissions

increases modeled• Results <10% but >5% of new NAAQS• Time for full NAAQS study not acceptable

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Mill Issues/Approach Additional NOX reductions evaluated

to:• Determine impact on short-term model

results• Reduce project NOX increases to below

PSD significance level (<40 TPY) Resulted in management commitment

of significant $$$ to reduce NOX from combination fuel boiler

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Mill Issues/Approach Eliminate use of excludable

emissions for combination fuel boiler analysis:• Down-sized new turbine generator set• Incorporated new test data for PM10,

PM2.5 and condensables from ICR testing

• Incorporate NOX reduction technology

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Project Status

Revised approach presented to state agency and support obtained at all levels

Formal update to application submitted and awaiting U.S. EPA review

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Project Conclusions No grandfathering – be prepared for

new NAAQS and other requirements (SO2, GHG)

Lack of guidance and tools for new standards will slow process

Concern for ability to demonstrate compliance with new NAAQS will force additional reductions

PSD process under NSR Reform continues to evolve…

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Questions?

cmccall@all4inc.com

All4 Inc.2393 Kimberton Road

P.O. Box 299Kimberton, PA 19442

610.933.5246 x20

www.all4inc.com