The BACT Analysis Guide: Regulatory Applicability
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).