Plantwide Applicability Limit (PAL)

• A PAL is based on actual emissions.

A plantwide applicability limit (PAL) is an optional approach that will provide owners or operators of major NSR stationary sources with the ability to manage source-wide emissions without triggering major NSR applicability. The basis for a PAL is baseline actual emissions. A PAL is an annual (source-wide) emission limitation (12-month total rolled monthly) under which the source can make any changes without triggering major NSR applicability for that pollutant. A PAL is pollutant specific and a PAL is approved for a ten (10) year term.

A source with a PAL permit may modify the emissions unit or add new emissions units, without triggering major NSR applicability, as long as the PAL limit is not exceeded.

Obtaining a PAL

The PAL emissions limit is based on the sources baseline actual emissions for the PAL pollutant. Baseline actual emissions are calculated on a unit specific basis using the same 24-month period for each emissions unit. The PAL emissions limit is determined as follows:

1. add the calculated baseline actual emissions for each unit
2. add the potential to emit for any emissions units that began actual construction after the 24-month baseline period
3. subtract the actual (or PTE) emissions for any units shutdown after the 24-month baseline period chosen
4. add the major NSR significant level for the PAL pollutant

The owner or operator must then submit a permit application for a PAL.

The department will reduce the PAL level, in tons per year, in the PAL permit to become effective on the future compliance date of any applicable federal or state regulatory requirement that the department is aware of prior to issuance of the PAL permit.

PAL Permit Application (326 IAC 2-2.4-3)

As part of a permit application requesting a PAL (326 IAC 2-2.4-3 [PDF]) the owner or operator of a major stationary source must submit the following information:

1. a list of all emissions units at the source designated as small, significant or major based on their potential to emit.
2. all federal or state applicable requirements, emission limitations or work practices that apply to each unit.
3. calculations of the baseline actual emissions with supporting documentation including emissions associated with startup, shutdown and malfunctions.
4. the calculation procedures that the owner or operator proposes to use to convert the monitoring system data to monthly emissions and annual emissions based on a twelve (12) month rolling total for each month for five (5) years.
   • A small emissions unit is a unit that emits or has the potential to emit the PAL pollutant in an amount less than the significant level for the PAL pollutant.
   • A significant emissions unit is a unit that has the potential to emit the PAL pollutant in an amount that is equal to or greater than the significant level for the PAL pollutant but less than the amount that would qualify the unit as major.
   • A major emissions unit is a unit that emits or has the potential to emit one hundred (100) tons per year or more of the PAL pollutant in an attainment area.

As part of a PAL application the owner or operator must use current emissions or other current direct measurement data to demonstrate that the monitoring system accurately determines emissions from each unit subject to the PAL. Data will need to be collected from all units subject to the PAL, including those that may be unregulated at the present time. If the owner or operator does not have current emissions data, or if the emissions unit's operation has changed since collection of that data, current accurate data will need to be obtained. This can be done by conducting performance tests or other direct measurements before submission of a complete permit application to obtain a PAL.

PAL Monitoring Requirements

A PAL permit must contain enforceable requirements for a monitoring system that accurately determines plantwide emissions for the PAL pollutant in terms of mass per unit time. All units operating under a PAL must have sufficient monitoring to accurately determine plantwide emissions for a 12-month rolling total. The PAL monitoring system must employ one (1) or more of the four (4) general monitoring approaches and must be approved by the department. The generally acceptable monitoring approaches for a PAL permit are the following:

1. Mass balance calculations for activities using coatings or solvents: If not otherwise accounted for the owner or operator must assume that the emissions units emit all of the PAL pollutant contained in or created by any raw material or fuel used in or at the emissions units. This approach can only be used for processes using coatings or solvents.
2. Continuous Emission Monitoring Systems (CEMS): CEMs must sample, analyze, and record data at least every fifteen (15) minutes while the emissions unit is operating and must comply with the applicable performance specifications found in 40 CFR Part 60, Appendix B.
3. Continuous Parameter Monitoring Systems (CPMS) or Predictive Emissions Monitoring Systems (PEMS): CPMS or PEMS must be based on current site-specific data demonstrating a correlation between the monitored parameters and the PAL pollutant emissions across the range of operation of the emissions unit. While the emissions unit is operating, each CPMS or PEMS must sample, analyze, and record data at least every fifteen minutes, or at another less frequent interval approved by the department. Users of parameter monitoring must show a correlation between predicted and actual emissions across the anticipated operating range of the unit.
   • Establishing parameter monitoring is a resource-intensive effort, requiring extensive up-front testing, analysis, and development.
4. Emission factors: Emission factors may be used for demonstrating compliance with a PAL as long as the factors are adjusted for the degree of uncertainty of limitations in the factors development. If using emission factors the emissions unit must operate within the designated range of use for the emission factor. The owner or operator of a significant emissions unit that relies on an emission factor to calculate PAL pollutant emissions shall conduct validation testing using other monitoring approaches (if technically practicable) to determine a site-specific emission factor within six (6) months of PAL permit issuance unless the department determines that testing is not required.
   • Use of monitoring systems that do not meet the minimum requirements approved by the department will render the PAL invalid.
   • A source owner or operator with five (5) units must be able, at any time, to quantify the baseline actual emissions for the past 12 months for each of the five (5) units.
   • The monitoring system data used to demonstrate the emissions unit operation must be re-validated to show that it accurately determines the emissions unit operation at least once every five (5) years for the life of the PAL. Data must be revalidated through a performance test or other scientifically valid means that is approved by the department.

PAL Recordkeeping Requirements

The owner or operator shall retain a copy of all records necessary to determine compliance with the PAL, including a determination of each emissions unit's twelve (12) month rolling total emissions, for five (5) years.

The owner or operator shall retain a copy of the PAL permit application, any applications for revisions to the PAL, each Part 70 annual certification of compliance, and all data relied on in certifying the compliance for a period of fifteen (15) years.

PAL Reporting Requirements

The owner or operator shall submit semiannual monitoring reports within thirty (30) days of each reporting period. The reports shall include reports of any deviations or exceedance of the PAL requirements, the results of any revalidation test or method within three (3) months after completion of the test method.

PAL monitoring, recordkeeping and reporting requirements can be more stringent than monitoring, recordkeeping and reporting requirements contained in current Part 70 permits.

PAL Effective Period and Renewal

A PAL is effective for a period of ten (10) years. A timely application must be submitted to the department by the source owner or operator to request renewal of a PAL. A timely application is one that is submitted at least six (6) months prior to, but not earlier than eighteen (18) months from, the date of PAL expiration. If the owner or operator submits a complete application to renew the PAL within this time period, then the PAL shall continue to be effective until the revised permit with the renewed PAL is issued. The PAL may be renewed at the same level or the department may set the PAL at a level it determines to be more representative of the source's baseline actual emissions.

Increasing a PAL

The department may increase a PAL emission limitation during the PAL effective period only if the source complies with the following:

1. The owner or operator must submit a complete application to request an increase in the PAL limit identifying the emissions units contributing to the increase.
2. Demonstrate that the sum of the baseline actual emissions of the small emissions units plus the baseline actual emissions of the significant and major emissions units, assuming application of BACT or LAER equivalent controls, plus the sum of the new or modified emissions units exceeds the PAL.
3. Obtain a major NSR permit for all emissions units contributing to the increase regardless of the magnitude of the emissions increase resulting from the unit.
4. The PAL permit shall require that the increased PAL level shall be effective on the day any emissions unit that is part of the PAL major modification becomes operational and begins to emit the PAL pollutant.
   • The PAL limit already includes the significant level for the pollutant. By causing an increase above the PAL the new or modified emissions units are causing an increase greater than the significant emissions threshold.

Termination or Revocation of a PAL

The owner or operator may at any time submit a written request to the department to terminate or revoke a PAL prior to the expiration or renewal of the PAL. The owner or operator may submit a proposed allowable emission limitation for each group of emissions units by distributing the PAL allowable emissions for the source among each of the emissions units that existed under the PAL.

The department shall decide whether and how the PAL allowable emissions will be distributed and issue a revised permit incorporating allowable limits for each emissions unit, or each group of emissions units, as the department determines is appropriate.

• Distribution of the PAL allowable emissions may be based on the emissions limitations that were eliminated by the PAL.

The source shall continue to comply with a source-wide, multi-unit emissions cap equivalent to the level of the PAL emission limitation until the department issues a revised permit incorporating allowable limits for each emissions unit, or each group of emissions units.

• During public review, any person may propose a PAL distribution of allowable emissions for the source for consideration by the department.

Applying for a Plantwide Applicability Limit

Sources that want to apply for a Plantwide Applicability Limit (PAL), revise a PAL, renew a PAL, or terminate a PAL must submit a complete application, including applicable basic forms and the appropriate PAL form (PAL-01, -02, -03, or -04) (available on the IDEM Agency Forms page).

Find information about the application process online. You can also contact IDEM for assistance.