Air Permit Compliance: Newly Proposed Amended BACT GUIDELINES Draft Released

Air Permit Compliance Equipment that meets New BACT Guidelines

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.