The EPA issued the final GHG Permitting Rule, officially known as the “Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas Tailoring Rule”, on May 13, 2010. Unlike the GHG Reporting Rule, which became effective in January of this year, the applicability of the GHG Permitting Rule is not restricted to any specific industry. Regardless of what your facility does, you are subject to the GHG Permitting Rule if the emissions of GHG from your source exceeds the applicable thresholds. The rule defines GHG as the “Sum of Six Well-Mixed GHG”. These are:

• Carbon Monoxide (CO2)
• Methane (CH4)
• Nitrous Oxide (N2O)
• Hydrofluorocarbons (HFC)
• Perfluorocarbons (PFC)
• Sulfur Hexafluoride (SF6)

The EPA has implemented a phased approach for the GHG Permitting Rule. Thus far, there are two (2) phases published in the final rule, with plans for “supplemental” phases in the future.

“EPA has decided not to provide exemptions from applicability determinations (major source and major modifications) under Title V and PSD…” – GHG Tailoring Rule, Pg 70  

PHASE 1 – January 2, 2011

Phase 1 of the GHG Permitting Rule will become effective on January 2, 2011.

The following are the Phase 1 PSD Program Details:

GHG sources will ONLY become subject to PSD for their GHG emissions IF they are required to obtain a PSD Permit or a modification to their existing PSD Permit based on emissions of non-GHG pollutants. In this case, the GHG emissions from a facility are subject to PSD requirements only if they increase emissions by >75,000-tons per year (TPY) of CO2 equivalents (CO2e). These sources will be subject to PSD requirements, including the requirements to conduct a BACT Analysis for their GHG emissions, if:

1) The GHG emissions (or net emissions increase) for new construction (or modification), calculated as the sum of the aforementioned greenhouse gasses, exceeds 0-TPY (no CO2e); And,
2) The GHG emissions (or net emissions increase) for new construction (or modification), calculated as the sum of the aforementioned greenhouse gasses, exceeds 75,000-TPY CO2e.

The following are the Phase 1 Title V Program Details:

Sources required to have Title V Permits for non-GHG emissions will be required to address GHG emissions as a part of their Title V Permitting. Unlike Phase 1 of the PSD Program, there is No limit for the Title V Program! Sources with existing Title V Permits must address GHG requirements when they apply for, renew, or revise their permit. Sources applying for a new Title V permit will be required to calculate potential GHG emissions as a part of their application.

PHASE 2 – July 1, 2011

Phase 2 of the GHG Permitting Rule will become effective July 1, 2011.

The following are the Phase 2 PSD Program Details:

Sources subject to PSD under Phase 1 of the GHG Permitting Rule will remain subject to PSD. In addition:

1)  Sources with the potential to emit GHG in amounts >100,000-TPY CO2e (and >100/250-TPY of GHG) will be considered major sources for PSD permitting purposes.
2) Existing PSD sources that undergo a physical or operational change resulting in a NET GHG emissions increase of >75,000-TPY CO2e (and >o-TPY of GHG).

The following are the Phase 2 Title V Program Details:

Sources subject to Title V under Phase 1 of the GHG Permitting Rule will remain subject to Title V. In addition, a non-Title V source that has the potential to emit GHG in amounts >100,000-TPY CO2e (and >100-TPY of GHG) will be required to obtain a Title V Permit for their GHG emissions.

Given these new regulations, it may be a good idea to begin developing a GHG emissions inventory so that you are prepared when your facility becomes subject to these rules, or to demonstrate that your facility is exempt from these rules. If you have any questions regarding the GHG Permitting Rule, feel free to call me at (800) 286-2469 ext. 6115. Alternatively, you may use the contact form.

In general, the BACT Cost Analysis for each control device must include:

• Total Capital Investment (TCI)
• Indirect Annual Cost
• Direct Annual Cost

The Total Annualized Cost (in current dollars) is divided by the amount of pollutant removed (in tons/year). This value is known as the “Cost Effectiveness” value and for the purposes of a BACT Analysis; it is used to determine whether a control scenario is economically feasible or infeasible. For economic reasons, it is important that your BACT Cost Analysis takes into account ALL of the costs associated with the installation and use of the control scenarios in question. There are a few resources available for estimating these costs (EPA software, vendor quotes, etc.). However, none of these resources should be considered completely accurate.

For common control devices, the EPA’s Air Compliance Advisor (ACA) software can be used to estimate these costs. However, the equations that are used to generate these estimates are valid only for certain operational ranges, do not consider site specific aspects for installing and operating the control technologies, and may provide unacceptably low cost effectiveness values. For some BACT Analysis projects, relying on the ACA software may mean that a BACT is selected that is not, in fact, the best available control technology (taking into account energy, environmental, and economic impacts). This could potentially cost the facility hundreds of thousands, if not millions, of dollars in unwarranted control device requirements.

In order to accurately estimate the cost of each control device to be considered in your BACT Cost Analysis, it is important to understand each line item:

• TCI = Indirect Capital Costs + Direct Capital Costs + Contingency Costs + Inventory Capital
  • Indirect Capital Costs (installation and erection)
    • General Facilities Costs
    • Engineering and Office Costs
    • Process Contingency Costs
  • Direct Capital Costs
    • Cost of purchased equipment
• Indirect Annual Costs
  • Capital Recovery Costs
  • Property Taxes
  • Insurance
  • Administrative Charges
  • Overhead
• Direct Annual Costs
  • Fuel
  • Reagent (as required)
  • Electricity
  • Water
  • Maintenance
  • Labor
  • Parts Replacement (e.g., catalyst replacement)

Understanding the equations and parameters used to perform the BACT Cost Analysis is very important, especially if you are relying on the EPA’s ACA software. Here are some examples of how minor changes to the equations and parameters used in the BACT Cost Analysis can affect the result of your Economic Impact Study:

Example 1
A BACT Cost Analysis found the Cost Effectiveness value for a SCR used to control NOx emissions from a wood-fired boiler to be $14,175/ton NOx removed. However, this value was calculated assuming an interest rate of 7%, when a more realistic interest rate may have been 10%, bringing the Cost Effectiveness value to $16,871/ton NOx removed.

Example 2
Within certain operational ranges, a high-temperature catalyst (catalytic oxidation) can be used to control CO emissions from a fuel burning source, which has a purchase price of approximately $300,000 (actual vendor quote form BACT Analysis project). Upon further investigation, it is determined that the exhaust temperature is lower than required for the efficient destruction of CO in a high-temperature catalyst. As such, a catalyst containing precious metals must be used to allow reactions at lower temperatures. This low-temperature catalyst costs $600,000, bringing the Cost Effectiveness value from $12,497/ton CO removed to $13,426/ton CO removed.

Things to remember:

• Many control device cost estimation resources provide cost values in historical dollars. These values need to be updated, using an inflation factor, to reflect current dollar amounts.
• Vendors are a good source for direct capital costs (i.e., equipment costs). However, vendors know what a BACT Analysis is and may attempt to give you a “conservative” (low) estimate in hopes that their product is chosen as BACT. Furthermore, unless they have performed a site inspection, they can’t account for site specific factors, which may alter the cost provided in their quote. Finally, if you do use a vendor as a source for your cost estimate, be prepared to wait weeks (or sometimes even months) for them to get back to you with a quote.
• Each regulatory agency has a different opinion about the maximum economically feasible cost effectiveness value, and many (e.g., CTDEP) will not tell you what that value is. Just because you or your client believe that the control device is economically burdensome does not mean that the permit reviewer will agree. As such, it is always safer to make sure that your BACT Cost Analysis is as accurate, and site specific, as possible.

If you have any questions concerning, or would like assistance completing, a BACT Cost Analysis or any other portion of your project, feel free to contact me at any time.

• Carbon Dioxide (CO2)
• Methane (CH4)
• Nitrous Oxide (N2O)
• Hydrofluorocarbons (HFC)
• Perfluorocarbons (PFC)
• Sulfur Hexafluoride (SF6)

The EPA is proposing that the GHG emissions from facilities be estimated using carbon dioxide equivalents (CO2e), which is the international standard. This metric uses the global warming potential of gases other than CO2 to translate them into CO2e.

Under the Title V program (40 CFR part 70), facilities would be considered a major source if they emit greater than 25,000-tons/year of CO2e and would be required to obtain a Title V operating permit. Under the New Source Review (NSR) Prevention of Significant Deterioration (PSD) program, a new source, or major modification at an existing source, would be considered major if it emits greater than 25,000-tons/year of CO2e and would be required to obtain a PSD permit. Modifications at existing major sources resulting in CO2e emissions increases of 10,000-tons/year to 25,000-tons/year (the exact number has not yet been decided) would be required to obtain a PSD permit.

The facilities with GHG emissions that trigger the PSD permitting requirements would be required to perform a BACT Analysis and incorporate BACT to control GHG emissions from their facility. Facilities that may be subject to this proposed rule include: power plants, refineries, and municipal solid waste landfills. Small facilities such as farms and restaurants will not be subject to the proposed rule.

The BACT for Carbon Monoxide (CO) from many of these large facilities is an oxidizer (or incinerator). These devices control CO emissions by converting them into CO2. Under this new rule, a facility could be required to obtain a Title V or PSD permit due to the secondary emissions from their CO control device (i.e., without the control device they would not have to be permitted for their CO2e emissions). Furthermore, the same facility may be required to install BACT for GHG emissions. This could pose a great financial burden on facilities subject to this rule. One possible solution to this issue is that the EPA could allow that only primary CO2 emissions (not those generated during CO control) be included when comparing CO2e emissions with the GHG permitting threshold.

SCR systems require a minimum temperature of approximately 575°F for the destruction of NOx. For applications where the process or equipment burns biomass fuels, a particulate control device is usually needed upstream of the SCR for it to function properly. However, by the time the flue gases pass through the particulate control device their temperature range is much less than required (between 57 and 61 percent) for the SCR to operate effectively. The traditional solution would be to install a natural-gas or oil fired burner between the SCR and particulate control device to re-heat the air to the appropriate temperatures. The economic burden of the capital costs associated with this control scenario, as well as the cost of the fuel required to operate the burners, is not cost effective given the amount of NOx removed.

As a solution, Babcock Power teamed with Pro-Environmental, Inc. (PEI) to combine Babcock’s SCR expertise with PEI’s Regenerative Thermal Oxidation (RTO) technology, capable of achieving heat recovery efficiencies of greater than 95 percent, to produce the RSCR technology. In 2005, a RSCR system installed at a 50MW power plant fired by wood and construction/demolition waste achieved a NOx emission rate of 0.07-lb/mmBTU. This emission rate equates to an 86% reduction in NOx emissions from wood waste combustion (AP-42 Chapter 1.6, Table 1.6-2 “Dry wood-fired boilers”).

If you would like more information on RSCR techology, visit Babcock Power’s website.

If you would like help completing your BACT Analysis, or any portion thereof, feel free to contact me.

According to the 1990 EPA NSR Workshop Manual, in order to show that a control scenario is technically infeasible you must “clearly document and show, based on chemical, physical, and engineering principles, that technical difficulties would preclude the successful use of the control option on the emission unit under review”.

Here is an example:

Our client wanted to install a 6-MW Biomass Boiler to supply process heat for the greenhouses at their facility. Because of the potential emissions from the proposed emission unit, our client was required to perform a BACT Analysis for PM, PM10, NOx, and CO.

One of the control devices identified for the control of particulate matter (PM and PM10) from the boiler was a fabric filter, also known as a baghouse. Although baghouses are used to control particulate emissions from biomass boilers, they are typically installed on larger units at facilities which have full-time boiler staff (1). If left unmonitored, burning cinders, temperature excursions, and/or operating upsets could result in a fire (2). Our client did not have a full-time boiler staff and therefore using a baghouse to control particulates from the proposed boiler was deemed technically infeasible.

If you have questions regarding the technical feasibility of the control technologies that you have identified, feel free to contact Brandon Mogan at 800-850-2348 ext. 6115, or click here for more information.

(1) Resource Systems Group, Inc.
(2) Hog Fuel Boiler RACT Determination. Washington State Department of Ecology. Doc. No. 03-02-009

• Control Devices
• Alternative source operating scenarios
• Alternative fuel combustion techniques
• Control technologies that have been applied to similar emission units

The list of potentially applicable control technologies should be comprehensive. It should include every control scenario from that which provides the most pollutant control (typically LAER) to that which provides the least pollutant control. When generating this list, one must consider all sources of information, including but not limited to:

• EPA’s RACT/BACT/LAER Clearinghouse
• EPA/State air quality permits
• Federal/State air emission inventories
• Control equipment vendors
• Manufacturer’s and trade associations
• International and foreign environmental agencies
• Inspection/Performance test reports
• Technical papers and journals
• Pollution prevention resources

The process of identifying applicable control technologies is a tedious and in-depth process. There are, however, some on-line resources available that offer a good starting point for this purpose. The following is a review of some more commonly referenced sources for identifying control technologies.

EPA’s RACT/BACT/LAER Clearinghouse

The Environmental Protection Agency’s (EPA’s) RACT/BACT/LAER Clearinghouse (RBLC) is a database of best available control technologies that have been applied to reduce emissions of air pollutants. As seen below, it is set up in a very user friendly fasion:

RBLC Database Search

This image is of a “find lowest emission rate” search for carbon monoxide (CO) emissions from a commercial size wood-fired boiler. This search results in the following results:

RBLC Database Search

From this search we have identified two different facilities which have applied best available control technologies for carbon monoxide emissions from their wood-fired boilers. To get more information about the type of control technology, the user must simply click on the “create report” button.

From project experience, I have found that the RBLC is very incomplete and limiting your search to control technologies found in the RBLC is not acceptable to most regulators.

South Coast Air Quality Management District (SCAQMD)

The South Coast Air Quality Management District (SCAQMD) of southern California posts their BACT decisions online and is a good resource to use to identify control technologies applicable to the emission unit, or similar emission units. Simply follow the above link to their website and search through the BACT decisions.

SCAQMD BACT Database Search Result

In this example, the emission unit (or process) is a system for manufacturing fiber-impregnated material. The control technology that was considered BACT in this case was a baghouse for the control of particulate emissions from the process coupled with the use of zero-VOC materials.

Bay Area Air Quality Management District (BAAQMD)

BAAQMD BACT Workbook Search Result

The identification of applicable control technologies is often a difficult and time consuming task. The reason for this is that, in many cases, the expectations of the regulator go beyond simple online database and resource searches. If you are required to perform a BACT Analysis, I suggest you discuss available resources with your permitting engineer because in most cases they will be the one accepting or denying your analysis.

If you would like assistance with completing your BACT Analysis, I have the project experience and proprietary tools that make the process as quick and seamless as possible. Please feel free to contact me at any time for a FREE BACT Analysis Consultation.

The BACT Analysis requirement is common for the utility industry (e.g., a turbine at an electrical generating facility). Here are a few more uncommon cases where a BACT Analysis was required:

Tub-Grinder with 325-HP Diesel Engine

This Tub-Grinder, used to grind municipal waste at a landfill,
was subject to a BACT Analysis because of its potential 
emissions of nitrogen oxides (NOx).

Fuel Cell Test Stand

 Fuel cell test stands requiring a BACT Analysis for their potential
hydrogen emissions.
www.eutech-scientific.de

 It is important to consider all applicable regulations when determining whether or not you must perform a BACT Analysis. Again, the requirement is not dependant upon the process or equipment, but the type and amount of pollutant being emitted from the process or equipment. If you require assistance determining whether or not your project is subject to a BACT Analysis, or you need help with the BACT Analysis process, click here.

Natural Gas Fired Boiler

The BACT Requirement applies to new sources, or modifications of existing sources, which emit the following NSR pollutants:

• Pollutants with a National Ambient Air Quality Standards (NAAQS), also known as criteria pollutants, which include:
  • Ozone
  • Carbon Monoxide
  • Particulate Matter
  • Sulfur Dioxide
  • Lead
  • Nitrogen Oxide
• Other pollutants including sulfuric acid mist, hydrogen sulfide, etc.
• Note that some states, such as Connecticut require BACT for ANY pollutant

The federal regulations require that “Major Sources” and “Major Modifications to existing sources” perform a BACT Analysis. However, some states have more stringent requirements. The following are a few examples:

• Connecticut
  • Potential emissions greater than the threshold for major sources and major modifications
  • Potential emissions greater than 15-tons per year from ANY new emission unit or modification to existing emission units (not just major sources)
• South Carolina
  • Any new construction when the net VOC emissions increase is greater than 100-tons per year

For your state’s specific BACT requirements, you should check with your local regulator (City, County, State).