The BACT Analysis Guide: Identify Control Technologies
The first integral step in the Best Available Control Technology Analysis (BACT Analysis) process, after determining which pollutants require BACT, is to identify ALL control technologies with the PRACTICAL POTENTIAL for application to the emission unit. It is important to understand that the term ”control technology” is any methodology or technology which will control emissions of the affected pollutant and may include, but is not limited to, the following:
- 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.