What type of emission units require a
Best Available Control Technology Analysis (BACT Analysis)? There are a number of online resources, such as the EPA’s
RACT/BACT/LAER Clearinghouse (RBLC), available that contain information related to BACT decisions for processes or emissions equipment at facilities across the United States. These will be discussed in future articles. It is important to note, however, that generally the requirement to perform a BACT Analysis is not dependant upon the type of emission unit, but rather the type of pollutant and quantity of emissions from the process or piece of equipment.
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.
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Why might a Best Available Control Technology Analysis (BACT Analysis) apply to my project? The requirement to perform a BACT Analysis applies to significant emissions of New Source Review (NSR) Pollutants from new sources and from modifications of existing sources. The applicable federal regulations are found at 40 CFR 52.21(j). The BACT Analysis requirement is also covered by regulations for State Implementation Plan (SIP) approval of a state Prevention of Significant Deterioration (PSD) program at 40 CFR 51.166(j).
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).
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In the world of air pollution control engineering, the requirement to perform a Best Available Control Technology Analysis (BACT Analysis) is nearly unavoidable. Regulatory requirements associated with the BACT analysis process vary from state to state but the following generally applies:
- Identify all available control systems that have the PRACTICAL POTENTIAL for application to the unit
- Eliminate TECHNICALLY INFEASIBLE systems
- Consider Energy, Economic, and Environmental Impacts
- Reject systems based on the above considerations
Those systems which are considered technically feasible are ranked from those providing the most control to those providing the least control. The emission rate utilizing the most efficient control system is considered the Lowest Achievable Emission Rate (LAER). For example, for the control of nitrogen oxides from a boiler a Selective Catalytic Reduction (SCR) system may provide the highest control efficiency while a Selective Non-Catalytic Reduction (SNCR) system may provide the least. In this case, the SCR would be ranked first and the emission rate associated with the use of the SCR would be the LAER.
In some cases, the control device providing LAER isn’t a feasible solution for pollution reduction from the emission unit. In general, energy, economic, and environmental impacts must be considered when determining a systems feasibility. Control scenarios are eliminated based on these impacts and the most efficient remaining system is the Best Available Control Technology or BACT.
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