THE BACT ANALYSIS GUIDE

On September 30, 2009 the EPA announced a proposed rule that sets permitting and Best Available Control Technology (BACT) requirements for large facilities that emit over 25,000-tons of greenhouse gases (GHG) per year.  The proposed rule has been titled “Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule” and focuses on emissions of the following group of GHG:

• 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.

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A Best Available Control Technology Analysis (BACT Analysis) for this 385-MW coal fired power plant revealed that the BACT for SOx emissions was a scrubber and the BACT for NOx emissions was a selective catalytic reduction system (SCR). This video summarizes the project, located at Basin Electric Power Cooperative’s Dry Fork Station (currently under construction), and describes the technology behind the state-of-the-art reflux circulating fluid bed dry scrubber.

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For common applications, such as boilers and turbines, a Best Available Control Technology Analysis (BACT Analysis)typically must consider a Selective Catalytic Reduction (SCR) system as a potentially applicable technology for control of NOx. With the relatively recent (October 2004) industrial application of Babcock Power’s Regenerative Selective Catalytic Reduction (RSCR) system, a BACT Analysis that must consider SCR may likely require consideration of RSCR as well, especially for biomass fuel burning equipment.

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.

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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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