The BACT Analysis Guide: EPA Releases BACT GHG Guidance
The EPA has released the much anticipated guidance for permitting of greenhouse gases (GHG) under the Clean Air Act (CAA), including controls to consider when conducting a BACT Analysis for GHG. This includes guidance for state agencies to use for the implementation of the Title V and Prevention of Significant Deterioration (PSD) GHG Tailoring Rule.
At a conference a few weeks ago, the question was asked: “what is BACT for GHG”? The answer is…”it depends”. As detailed in previous posts on this website, and highlighted several times throughout the EPA BACT GHG Guidance, it is important to remember that BACT for any pollutant is determined on a case-by-case basis via a BACT Analysis, including BACT for GHG. That being said, the EPA has provided white papers that outline GHG control measures for several industrial sectors. These include:
- Electric Generating Units
- Large Inustrial/Commercial/Institutional Boilers
- Pulp and Paper
- Cement
- Iron and Steel Industry
- Refineries
- Nitric Acid Plants
The control measures discussed in these documents include energy efficiency, alternative fuel considerations, and carbon capture and sequestration.
If you have any questions regarding BACT and GHG, or permitting of GHG under the CAA, feel free to send me an e-mail at BMogan@Geosyntec.com.