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).

• 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.