1. Case Study - NSR 2010
Colin McCall
All4 Inc.
NCASI 2010 Southern Regional Meeting
Charleston, SC
June 29, 2010

2. Agenda
 Overview of Project
 PSD Applicability Approach
 Review Process and U.S. EPA Involvement
 Mill Response and Project Impact
 Conclusions
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3. 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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4. 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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5. 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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6. 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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7. 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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8. 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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9. 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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10. 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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11. 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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12. 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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13. 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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14. 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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15. 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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16. 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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17. Questions?
cmccall@all4inc.com
All4 Inc.
2393 Kimberton Road
P.O. Box 299
Kimberton, PA 19442
610.933.5246 x20
www.all4inc.com
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