BACT analysis under the Clean Air Act's PCD program

Journal Article · Wed Nov 15 00:00:00 EST 2006 · EM

OSTI ID:20838305

Simms, P; Walke, J ^[1]

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1. National Resources Development Council, Washington, DC (United States)

Before a company may build a new major industrial source of air pollution, or make modifications to an existing major source in the USA it must apply for and receive a Clean Air Act (CAA) Prevention of Significant Deterioration (PSD) permit. State environmental agencies typically issue such permits, either under state law or by exercising delegated authority to implement the federal PSD program. To fully comply with the CAA, the emissions limits identified as BACT must incorporate consideration of more than just add-on emissions control technology, they must also reflect appropriate considerations of fuel quality (e.g. low-sulfur coal) and process changes (e.g. advanced combustion techniques) as a means of controlling emissions, and must consider the other environmental and public welfare benefits of the identified emissions control options. Several states including New Mexico and Illinois have already determined that innovated technologies, such as Integrated Gasification Combined Cycle (IGCC), must be considered in connection with the BACT analysis for new coal-fired power plants. Even the notion that BACT is categorically limited in scope to the general type of facility proposed is contrary to EPA precedent. For example, the Environmental Appeals Board (EAB) has explained that permitting authorities retain the discretion under the definition of BACT to require dramatically different facility designs (e.g. a natural gas plant instead of a coal-fired power plant). The best advice for any permit applicant is to include in the BACT analysis a careful and honest examination of better performing alternative processes and/or innovative combustion techniques and to aggressively pursue such options wherever feasible. 17 refs.

• OSTI ID: 20838305
• Journal Information: EM, Other Information: [e-mail]; ISSN 1088-9981
• Country of Publication: United States
• Language: English

Related Subjects

20 FOSSIL-FUELED POWER PLANTS
29 ENERGY PLANNING
POLICY AND ECONOMY
USA
CLEAN AIR ACTS
RECOMMENDATIONS
LICENSES
MODIFICATIONS
CONSTRUCTION
FOSSIL-FUEL POWER PLANTS
COAL
NATURAL GAS
AIR POLLUTION CONTROL
COMBUSTION
MERCURY
EMISSION
ENVIRONMENTAL POLICY
AIR POLLUTION
AIR POLLUTION MONITORING
AIR QUALITY
DATA COMPILATION
US EPA
MEASURING METHODS
POWER GENERATION
MINING
POLLUTION SOURCES
METAL INDUSTRY
COMBINED-CYCLE POWER PLANTS
POLLUTION CONTROL EQUIPMENT
RETROFITTING
POLLUTION REGULATIONS