1. www.all4inc.com Kimberton, PA | 610.933.5246 Kennesaw, GA | 678.460.0324 Strategic Air Planning: Is the Time for a PAL Here? Mark Wenclawiak, CCM| mwenclawiak@all4inc.com | (678) 460-0324 October 24, 2013 Presented to Georgia AWMA by All4 Inc.

2. 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. 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. 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. 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. 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: SO 2 will decrease as well – how does that impact your NAAQS compliance Scrubber project many now be desirable Future Planning

7. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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

17. www.all4inc.com Kimberton, PA | 610.933.5246 Kennesaw, GA | 678.460.0324 Questions? Mark Wenclawiak, CCM| mwenclawiak@all4inc.com | (678) 460-0324