The BACT Analysis Guide: Technical Feasibility
After identifying all of the control technologies with the practical potential for application to the emission unit, the BACT Analysis proceeds with eliminating technically infeasible control scenarios. For the purposes of a BACT Analysis, a technically feasible control scenario is one that has been used in the “real world”. By this I mean that just because a professor at some university has developed an experimental device for controlling NOx from a biomass boiler doesn’t mean you have to consider it as a technically feasible control device in your BACT Analysis. However, if a control device is commercially available and has the practical potential to control emissions from your source, then you must consider it to be technically feasible and include it in your BACT Analysis.
According to the 1990 EPA NSR Workshop Manual, in order to show that a control scenario is technically infeasible you must “clearly document and show, based on chemical, physical, and engineering principles, that technical difficulties would preclude the successful use of the control option on the emission unit under review”.
Here is an example:
Our client wanted to install a 6-MW Biomass Boiler to supply process heat for the greenhouses at their facility. Because of the potential emissions from the proposed emission unit, our client was required to perform a BACT Analysis for PM, PM10, NOx, and CO.
One of the control devices identified for the control of particulate matter (PM and PM10) from the boiler was a fabric filter, also known as a baghouse. Although baghouses are used to control particulate emissions from biomass boilers, they are typically installed on larger units at facilities which have full-time boiler staff (1). If left unmonitored, burning cinders, temperature excursions, and/or operating upsets could result in a fire (2). Our client did not have a full-time boiler staff and therefore using a baghouse to control particulates from the proposed boiler was deemed technically infeasible.
If you have questions regarding the technical feasibility of the control technologies that you have identified, feel free to contact Brandon Mogan at (803) 422-5251, or click here for more information.
(1) Resource Systems Group, Inc.
(2) Hog Fuel Boiler RACT Determination. Washington State Department of Ecology. Doc. No. 03-02-009