www.all4inc.com Kimberton, PA | 610.933.5246 Kennesaw, GA | 678.460.0324

GHG PSD Permitting Challenges

Mark Wenclawiak | mwenclawiak@all4inc.com | 678.460.0324 x202

September 24, 2014

Presented at NCASI West Coast Regional Meeting by All4 Inc.

2 Your environmental compliance is clearly our business.

Outline

Project driver

5 challenges encountered

• During application development

• During agency review

GHG PSD Permitting Challenges

Project Driver

4 Your environmental compliance is clearly our business.

Boiler MACT compliance project

• Boilers decommissioned

• Boiler modified

• New boilers installed

Major modification in attainment area

Compressed project schedule

• Pre-application meeting

• Expedited permitting process

Background on Project

5 Your environmental compliance is clearly our business.

Emissions inventory

• PSD applicability evaluation

New and modified units

No affected units

• Actual to projected actual emissions

• Step 1 significant increase for multiple pollutants

Netting

• Step 2 significant increase for GHGs only

Background on Project

GHG PSD Permitting Challenges

Challenges During Application Development

7 Your environmental compliance is clearly our business.

Challenge #1

• Biogenic emissions

Challenge #2

• BACT for modified boiler changes scope of Mill’s project

Retrofit with economizer

First Set of Challenges

GHG PSD Permitting Challenges

Challenges During Agency Review

9 Your environmental compliance is clearly our business.

Initial submittal in early Spring 2014

• Expedited process to issue permit by mid-summer

• 2 iterations of requests for more information

Challenge #3

• Netting calculation procedure

Challenge #4

• Regional Haze

Existing Regulatory Matters

10 Your environmental compliance is clearly our business.

June 23, 2014 SCOTUS ruling during agency review

Challenge #5

• PSD for GHG-only – now what?

• State issues implementation policy

Rules of Game Change

11 Your environmental compliance is clearly our business.

Hold on application

• Revise application to remove PSD references

• Boiler MACT extension request to help with budgeting

Current Path Forward

www.all4inc.com Kimberton, PA | 610.933.5246 Kennesaw, GA | 678.460.0324

Questions & Open Discussions

Mark Wenclawiak | mwenclawiak@all4inc.com | 678.460.0324 x202