Air Permit Compliance: Newly Proposed Amended
BACT GUIDELINES Draft Released

Air Permit Compliance Equipment that meets New BACT Guidelines

As an original founding BACT member, Ship & Shore CEO & President, Anoosheh M. Oskouian has been participating in recent South Coast Air Quality Management District (SCAQMD)  committee meetings regarding proposed changes to the  Best Available Control Technology (BACT) Guidelines.
The proposed revisions focus on both Major & Minor Source guidelines as well as some administrative changes. Primarily the changes are aimed towards aligning the BACT Guidelines with current rules. At this time they do not include any emission limits that go above and beyond current SCAQMD rules.
There are two new sections being added to the BACT Guidleines

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Part E – Policy and Procedures for Facilities
Subject to PSD for Greenhouse Gases (GHG)

Facilities are subject to GHG BACT if:

  • New or Modification of existing source increase
    potential to emit by 100 or 250 tons/year depending
    on source category; and
  •  Have potential to emit >75,000 tons/year of carbon
    dioxide equivalent (CO2e)
  • Must be subject to PSD for a pollutant other than
    GHG
  • Tailoring Rule undergoing revision – U.S. Supreme
    Court decision in Utility Air Regulatory Group v.
    Environmental Protection Agency, 134 S. Ct. 2427

Part F – BACT Determinations for
Facilities Subject to PSD for GHG

  • Work in Progress
  • EPA Guidance emphasizes options that improve energy efficiency and possibly biomass
  • Carbon Capture and Sequestration may be considered but likely cost prohibitive Potential impacted sources include:
  •  Electricity Generation
  •  Large industrial/commercial boilers
  • Cement industry
  •  Refineries
  • Iron and Steel industry

The BACT Guidelines will make for more stringent regulations.  Ship & Shore has helped manufacturers navigate air  permit compliance and limits, optimizing efficiency and well as production through the use of air pollution control equipment.  We can often help our clients get rebates or incentives towards the necessary equipment, often and thermal oxidizer or regenerative thermal oxidizer to keep manufactures process compliant and productive.

 
To review  documents regarding proposed changes click here
If you have any concerns, would like to know more about specific BACT rules and how they may affect your business, or just need a little expert advice, please call Ship & Shore Environmental at (562)997-0233