The standard used for BACT is mid-range pollution control, used by the EPA in the New Source Review (NSR) program. It is more restrictive than Reasonably Available Control Technology (RACT) and much less stringent than Lowest Achievable Control Technology (LACT). The EPA requires one of these three standards based on current air quality.
What Are The EPA Standards for an New Source Review (NSR) Permit?
When a company plans to build or change a facility in a way that may increase pollution, an NSR permit is required. In locations that have lower air quality, no new emissions are allowed that diminish the progress in improving the quality. In areas with good air quality, emissions that could deteriorate the quality are not permitted.
Regions or areas are classified in two ways by the EPA:
- Attainment areas are those that meet the quality requirements set by National Ambient Air Quality Standards (NAAQS).
- Non-attainment areas are not meeting the quality guidelines in one or more of six criteria pollutants.
When an NSR permit is issued, the standard required is normally determined by a state or local agency on a case-by-case basis. A BACT is the standard required for locations that are considered attainment areas. RACTs are reserved for modifications to facilities in non-attainments locations. LACT is mandatory for new or modified facilities in non-attainment locations.
How Are BACT Guidelines Met?
Guidelines are used to determine if the proposed control systems meets BACT. The appropriate control level is based on:
- Total source emissions
- Regional environmental impact
- Energy consumption
- Economic costs
These factors are used after other review requirements have been met. Small sources and those with existing quality emissions control systems have a reduced need for full analysis.
The Texas Commission on Environmental Quality (TCEQ) provides a set of guidelines for determining the BACT for a variety of sources. For example, in chemical processing, basic or acidic gases and soluble hydrocarbon is subject to a minimum of 99 percent recovery.
The BACT for dry bulk fertilizer handling controls are normally achievable through a baghouse or choke feeding. In mechanical transfers, the minimum control is an enclosed conveyor or similar method. All mixing must be performed in an enclosure.
The experts at Talon/LPE are ready to help you develop the compliance methods needed to meet the level of emissions control set by an NSR. We have experience working with state and local regulating agencies. Contact us and let us assist you through every portion of air permitting requirements, from advice to implementation and reporting.