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OAR Box 1787 

Prepped by Ollie Stewart 

Document Number: 

22) ll-B-7 

Docket Number: 

A-90-37 

Printed 11/4/2008 10:22:19 AM Sheet 22 of 147 
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.1.; « UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

£ AA'/x d / WASHINGTON. D.C. 20460 

JAN 4 1973 OFFICE OF 

AIR ANO WASTE MANAGEMENT 

SUBJECT: Guidance for Determining BACT Under PSD 

FROM: David G. Hawkins, Assistant Administrator 

for Air, Noise, and Radiation 

TO: Regional Administrators, I-X 

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The 1977 Clean Air Act amendments pertaining to the Prevention of 

Significant Deterioration (PSD) require that the determination of best 

available control technology (BACT) be performed on a case-by-case basis 

considering energy, environmental, and economic impacts and other costs. 

The enclosed document provides guidance to assist you in determining 

BACT in the PSD review. This document has been circulated in draft 

form and reviewed by your staff. 

The purpose of the guideline is to provide the framework for a 

consistent approach in determining BACT. The guidance is rather general, 

focusing on the parameters which should be considered in the analysis 

supporting the proposed control system. Unfortunately, no specific 

criteria can be developed a priori, nor can quantitative factors relating 

to the weighting and evaluation of energy, environmental, and economic 

consideration be prescribed. However, consideration of the same set oi 

parameters should contribute to more consistent decisions among the 

Regions. 

I recognize that the case-by-case BACT determination is a difficult 

task and one which may be resource intensive. To minimize the resource 

requirements, the primary responsiblity for defending the proposed control system must be placed on the .source. The guidelines suggest a 

significant effort by the source to provide data and analysis to support 

a permit application. My office will continue to provide assistance for 

the engineering aspects of control technology selection through operation 

of the OAQPS new source review clearinghouse. 

Enclosure 

cc: Assistant Administrators and Office Directors 

Director, Air and Hazardous Materials Division, Regions I- X 

Director, Facilities Technology Division, Region II 

Director, Enforcement Division, Regions I-X 

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V 

GUIDELINES FOR DETERMINING 

BEST AVAILABLE CONTROL TECHNOLOGY (BACT) 

DECEMBER 1978 

Office of'Afr,"Noise, and Radiation 

Office of Air Quality Planninq and Standards 

U. S. Environmental Protection Agency 
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GUIDELINES FOR DETERMINING BEST AVAILABLE 

CONTROL TECHNOLOGY (BACT) 

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INTRODUCTION 

T he 1977 Clean Air Act Amendments establish more restrictive 

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* conditions for the approval of pre-construction permit applications under 

t he Prevention of Significant Deterioration (PSD) program. One of the 

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• M new requirements is for best available control technology (BACT) to be 

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-% installed for all pollutants regulated under the Act. Under the revised 

•J?%: Act, BACT is to be determined on a case-by-case basis rather than auto-

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..;/| matically applying an applicable Federal New Source Performance Standard 

.£i| (NSPS), as was the case under the previous regulation. Concern has been 

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v*^ expressed that these determinations should be consistent from area to 

" # area. In the context of case-by-case BACT, consistency does not neIt 

-^ cessarily mean that a new facility in one area will have an identical 

J% emission limit as the same type of facility in another area. Consis-

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S<. tency means that a consistent approach is used in determining BACT and 

^ that the impacts of alternative emission control systems are measured by 

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•f$ the same set of parameters, although evaluation of specific parameters 

.*:€ is done on a case-by-case basis. 

:% PURPOSE 

-f; This guideline is intended for use by (1) EPA Regional Offices in 

-'-'• determining BACT during the interim period before the States adopt 

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*Pollutants subject to National Ambient Air Quality Standards, Standards 

of Performance for New Stationary Sources, National Emission Standards 

f or Hazardous Air Pollutants, and Emission Standards for Moving Sources. 

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State Implementation Plan (SIP) provisions for implementing the PSD 

program, (2) by States in writing PSD regulations or determining BACT 

and (3) by individual sources in preparing PSD permit applications. 

The purpose of the guideline is to provide the framework for a consistent approach to determining BACT. The emphasis is on the types 

of data which should be required in a pre-construction permit application and how the data should be used in order to determine BACT. The 

guideline addresses the technological question of whether the emission ••/•*».• 

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i^:: control system proposed in the permit application represents BACT or 

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vj whether a more stringent level of emission<«control is appropriate 

3 | considering available technology and economic, energy, and environmentai impacts. The guideline assumes accomplishment of all other air 

quality review requirements including, for example, the requirement 

that air quality standards and appropriate PSD increments are met, 

3 | stack heights are appropriate, and siting is acceptable. 

.op In accomplishing this purpose, the guideline lists a number of 

;*j factors which can be considered in assessing energy, environmental, and 

economic impacts. While the full list represents the magnitude of the 

analysis that could be required for a very large and complex source, many 

|$ of these factors will not be relevant to the typical BACT review. The 

inclusion of any factor should be based on its relative merit considering such influences as source size, nature of the process and control 

options, and local conditions. It is the clear intent of EPA not to 

require an analysis of the full proportion described herein for small 

sources or for the use of conventional control equipment whose impacts 

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are well established. In short, the BACT analysis should be held to a 

minimum with the depth of analysis being dependent on the difficulty of 

the decision. 

PHILOSOPHY OF BACT 

The primary purpose of BACT is to optimize consumption of PSD air 

quality increments thereby enlarging the potential for future economic 

growth without significantly degrading air quality. The Act places the 

responsibility of determining BACT with the State once a PSD SIP revision 

is approved. The BACT decision is to take into account energy, environmental, and economic impacts and other costs associated with application 

of alternative control systems. This case-by-case approach allows 

adoption of improvements in emission control technology to become widespread 

more rapidly than would occur through the uniform Federal new source or 

hazardous emission standards. In setting the NSPS, for example, emission 

limits are selected which can reasonably be met by all new or modified 

sources in an industrial category, even though some individual sources 

are capable of lower emissions. Additionally, because of resource 

limitations in EPA, revision of new source standards must lag somewhat 

behind the evolution of new or improved technology. Accordingly, new or 

modified facilities in some source categories may be capable of achieving 

lower emission levels that NSPS without substantial economic impacts. 

The case-by-case BACT approach provides a mechanism for determining and 

applying the best technology in each individual situation. Hence, NSPS 

and NESHAPS are Federal guidelines for BACT determinations and establish 

minimum acceptable control requirements for a BACT determination. 

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?* \ Where Federal standards do not exist, guidance on well-controlled sources 

£ ' . is available through the OAQPS clearinghouse (discussed later). 

A critical decision in the BACT analysis is the relative weight 

••£.' assigned to the energy, environmental, and economic impacts. Congress 

{%;. '.. implied that this decision should be made by the State, thus allowing 

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-jl j some flexibility in emission control requirements depending on local 

'm energy, environmental, and economic conditions and local preferences. 

:jf For example, in an area with unusually high unemployment, the economic 

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j,* impacts may be weighted more heavily if the application of a strict BACT 

••% emission requirement would reduce production or jobs. On the other 

'K- hand, if visibility protection is a major value of the area, then 

•fjj: environmental impacts could be Weighted more heavily. This flexible 

^5 approach allows the permitting authority to consider a number of local 

£<f factors (for example the size of the plant, the amount of the air 

quality increment that would be consumed, and desired economic growth 

•3§ in the area) in deciding on a weighting scheme. State judgment and 

:li the Federal emission standards are the foundations for the BACT deter- . 

W-5 mination. Accordingly, EPA does not consider it appropriate to assign 

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•,?l nationally applicable weighting factors in this guideline. 

:U GENERAL GUIDELINES 

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> The recommended approach to determining BACT is to place on the 

4 applicant the responsibility for presenting and defending the technology 

:i selection.* This approach recognizes that the applicant is best 

,"..- suited for assessing the costs, environmental residuals, and energy 

•Preliminary meetings between the applicant and the permitting authority 

are encouraged as a means of promoting efficiency in the review process. 

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„ ry ."* penaltie s associate d wit h alternativ e control option s as the y appl y 

"4?| »• to his processes . Th e permit applicatio n should, contai n the followin g 

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'&- element s relativ e to BACT : 

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H;|-; * . (1) Proposal of a control system representing BACT. 3ACT should 

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* p | _- address control of each emission point at a facility , including fugi-

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: H | . tive process, fugitive dust, and stack emissions. Technology selection 

/ should consider application of flue gas treatment, fuel treatment, and 

processes or techniques which are inherently low-polluting. In no 

circumstance should a system be proposed for any emission point unless 

it is at least as stringent as the applicable SIP or Federal emission 

requirement (whichever is more stringent). I n cases where technologW ical or economic limitations on*the application of measurement techniques 

would make the imposition of an emission standard infeasible, a design, 

operating, or equipment standard may be established. 

(2) Presentation of alternative systems that could achieve a 

||| higher degree of emission control. For each pollutant, the BACT permit 

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'vp£ applicatio n should presen t control alternative s whic h hav e greate r control 

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proposed for the same or similar applications. In some cases, the BACT 

Jy-jj decision may require a trade-off of control among pollutants. That is, 

•j&£; a technolog y ma y do slightl y wors e in controllin g on e pollutant , but do 

Cj? significantl y bette r in controllin g anothe r air , water , or solid wast e 

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'%. residual . Suc h alternative s should not be exclude d from consideration , 

b ut in justifyin g 3AC T for a given pollutan t onl y thos e alternative s 

whic h hav e greate r control capabilitie s for that pollutan t need bepresente d in the permi t application . 

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If no better control technology is available for an emission point, 

then such finding should be stated and supported, and no further analysis 

is required. Other equipment with similar control capabilities need not 

be presented (e.g., a baghouse versus an equivalent ESP at-a particulate 

emitter). Unrealistic alternatives need not be presented such as placing 

in series control equipment which is normally used alone (e.g., an ESP 

followed by a baghouse). In some cases, a better control technology may 

be available for a general type of operation, but unique processing 

equipment or procedures may create a valid technical reason which would 

preclude its selection as BACT. Such situations should be fully supported. 

(3) Defense of the BACT selection. The BACT selection for a particular pollutant is defended by demonstrating that each alternative control 

system (representing a more stringent level of control for that pollutant), 

would cause unreasonably adverse energy, environmental, or economic impacts. 

The rationale for rejecting each alternative should be presented in the 

form of an incremental analysis of the impacts of each alternative 

system relative to the proposed BACT system. Relevant energy, environmental 

and economic impacts are described below. 

IMPACT ANALYSIS 

This section outlines the types of impacts that should be recognized 

by the permitting authority as relevant issues in assessing the energy, 

environmental, and economic impacts of alternative control systems. For 

instance, if an applicant wishes to reject an alternative control system, 

he would do so by demonstrating the adverse impacts which v/ould result 

from the selection of that alternative system. This section lists 

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'.->3jj: '', specific energy, environmental, and economic impacts which may be addressed 

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v^j . % in this impact analysis and explains the data requirements for documenting 

>|£' , an adverse impact. Each of the factors discussed below need not be 

addressed in ewery permit application. Rather this guideline presents a 

set of potential impacts any number of which may be addressed in a 

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'Msk f even though a control system may produce solid waste by-products, such 

%j& impacts need not be presented in the PSD permit application unless the 

applicant wishes to use solid waste impact as an argument against selection 

.$!£ of a particular control alternative as BACT. 

In general, the BACT analysis should focus on the direct (on-site) 

% § impacts of alternative control systems. Indirect energy or environmental 

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jl-sp to be significant and well quantified. Indirect energy impacts include 

j§?§ such impacts as energy to produce raw materials for construction of 

^ss* . control equipment, increased use of foreign oil, or increased oil use in ;ft* " 

fW the utility grid. Indirect environmental impacts include such consider- M 

J0% ations as pollution at an off-sit e manufacturing facilit y which produces 

*•*• $ materials needed to construct or operate a proposed control system. 

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Indirect impacts wil l generally not be considered in the BACT review 

since the complexity of consumption patterns in the economy makes those 

impacts difficul t to quantify. For example, since manufacturers purchase 

capital equipment and supplies from many suppliers, who in turn purchase 

goods from the other suppliers, accurate tracing of indirect impacts may not 

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be possible. Raw materials may be needed to operate control equipment, 

and suppliers of these resources may change over time. Similarly, it 

generally will not be possible to determine specific power stations and 

fuel sources which would be used to satisfy electrical demand over the 

lifetime of a control device. 

Duplicative analyses will not be required in preparing the 8ACT 

permit application. Any studies previously performed for Environmental 

Impact Statements, water pollution permits, State New Source Review, or 

other programs may be used when appropriate to demonstrate an adverse 

energy, environmental, or economic impaet. 

These guidelines are applicable to both new and modified sources. 

Where appropriate, however, the review may consider any special economic 

or physical constraints which might limit the application of 

certain control techniques to a modification project. That is, the level 

of control required for a process undergoing modification or reconstruction 

may not be as stringent as that which would be required if the same process were being constructed at a grass-roots facility. Such findings, 

however, must be made on a case-by-case basis by the permitting authority 

considering the relevant economic and environmental impacts. 

The following discussion, under each of three headings of energy, 

environmental, and economic impacts, lists and briefly describes a number 

of factors which may be addressed in the respective impact analyses. These 

factors are guidelines only and are not intended as an exclusive list of 

considerations for 8ACT. Some of these factors may not be appropriate 

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in all cases, while, in other instances, factors which are not included 

here may be relevant to the BACT determination. The guideline does not 

address the evaluation of each factor nor the weighting of any factor 

relative to another. Such determinations should be made on a case-bycase basis by the permitting authority. For purposes of this discussion, 

terms such as "emission control system" or "BACT system" refer to design, 

equipment, or operating standards and non-polluting processes as well as 

flue gas control equipment. 

I. Energy Impact 

Energy impacts should address energy use associated with a control 

system and the direct effects of such energy use on the facility and the 

community. As noted earlier, indirect energy impacts (such as energy to 

produce raw materials for construction of control equipment) are not 

required but may be considered if the permitting authority determines, based 

on a showing by the applicant, that the impact is significant and that 

t he impact can be well quantified. Some specific considerations for 

energy impacts are presented below. 

A. Energy Consumption 

The amount, type (e.g., electric, coal, natural gas) , and source 

of energy required by each alternative emission control system should 

be identified and compared to the quantities and types of energy required by the proposed BACT system. In analyzing for energy consumption, 

various alternatives can be compared in terms of a ) energy consumption 

per unit of pollution removed (for example, Btu/ton hydrocarbon removed) 

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and b) energy consumption versus the portion of the remaining PSD 

increment which is preserved for future growth. I f such comparisons are 

made, they should be computed on both an overall and an incremental basis 

B. Impact on Scarce Fuels 

The type and amount of scarce fuels (e.g., natural gas, distillate 

oil) which are required to comply with each alternative control requirement should be identified and compared with the 8ACT requirement. The 

designation of a scarce fuel may vary from area to area, but in general 

a scarce fuel is one which is in short supply locally and can better be 

used for alternative purposes, or one which may not be reasonably 

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available to the source either at present or in the future. 

C. Impact on Locally Available Coal 

Alternatives which require the use of a fuel other than locally or 

regionally available coal should be discouraged if such a requirement 

causes significant local economic disruption or unemployment. 

D. Energy Production Impacts (electric utilities) 

The 1977 Act Amendments imposed more stringent BACT requirements, 

which may affect electric utility units that were well along in the 

planning process prior to adoption of EPA regulations in June 1973. 

Where the start-up of the more stringent PSD program would result in 

construction delays for these units, the BACT determination may consider 

such impacts. The impact of delay plant operation should be assessed 

in terms of reserve capacities, system reliability, and additional costs 

implied by such delays. 

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I I . Environmental Inmact 

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The net environmental impact associated with, each alternative 

emission control system should be determined. Both beneficial impacts 

(e.g., reduced emissions attributed to a control system) and adverse 

impacts (e.g., exacerbation of another pollution problem through use of 

a control system) should be discussed and quantified. As pointed out 

above, indirect environmental impacts (such as pollution impacts at an 

off-site plant which manufacturers chemicals for use in pollution control 

equipment) normally need not be considered. The analysis should be 

presented in the form of the incremental impact of alternative control 

systems relative to the system proposed as BACT in the permit application. 

Some specific considerations are presented below. 

A. Air Pollution Impact 

• The impact of air pollutants emitted from a gas stream or a 

fugitive emission source can be assessed terms of quantity of 

emissions, modeled effects on air quality, or both. If application of a 

control system directly removes or releases other air pollutants (or 

precursors to other air pollutants), then the pollutants affected and 

the impact of these emission changes should be identified. The analysis 

can consider any pollutant affecting local air quality including pollutants 

which are not currently regulated under the Act, but which may be of 

special concern locally. 

In the absence of a more systematic technique (e.g., market-type 

systems, etc.) for allocating PSD increments, BACT determinations are 

important for executing such allocations. PSD programs which depend on BAC! 

determinations to implement the allocation of increments should oroject 

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•^ *' desired levels of growth in an area so that BACT determinations for each 

•J% source will serve to insure that the total air impacts of future growth 

;.:¥«; ' ' are no greater than the available increments. In the first years of 

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0i .' the PSD program, many areas may.have neither a functioning market system • •"* • t 

for allocating increments nor accurate projections of desired growth. 

«• During this initial period, it is important that such areas use the BACT 

3HI determinations to conserve the remaining increments as much as possible 

until more systematic allocation mechanisms are put in place. 

B. Water Impact 

Relative quantities of water used and water pollutants produced 

and discharged as a result of use of each alternative emission control 

^ system should be identified. Where possible, the analysis should assess 

~0. their effect on ground water and such local surface water quality 

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'$$ parameters as pH, turbidity, dissolved oxygen, salinity, toxic chemical .-•s* 

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'.£? levels and any other important considerations. The analysis should 

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:;;">; consider whether applicable water quality standards are met and the 

'rM availability and effectiveness of various techniques to reduce potential 

adverse effects. 

C. Solid Waste Disposal Impact 

The quality and quantity of solid waste (e.g., sludges, solids) that 

must be stored and disposed of or recycled as a result of the application of each alternative emission control system should be compared 

with the quality and quantity of wastes created if the emission control 

system proposed as BACT is used. The composition and various other 

^ characteristics of the solid waste (such as permeability, water retention, 

rewatering of dried material, compression strength, leachability of 

dissolved ions, bulk density, ability to support vegetation growth and 

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•','•'$ ' surface waters or aquifers should be considered. All practicable solid 

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recycling) should be investigated and the relative advantages and 

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. disadvantages discussed. 

D. Irreversible or Irretrievable Commitment of Resources 

The BACT decision may consider the extent to which the alternative 

emission control systems may involve a trade-off between short-term 

•;& environmental gains at the expense of long-term environmental losses 

'•?$. and the extent to which the alternative systems may result in irrever-

:;|| sible or irretrievable commitment of resources (for example, use of 

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^ E. Other Environmental Impacts i . 

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Incremental differences in noise levels, radiant heat, or dis-

| sipated static electrical energy should be considered where appropriate. 

III. Economic Impact 

This analysis should address the economic impacts associated with 

|? the incremental costs of installing and operating alternative control 

.•??* systems above the economic impact associated with the system proposed 

-\i as BACT. The review should include a complete explanation of proj% cedures for assessing economic impacts and any supporting data. As 

"h outlined below, economic considerations can address direct economic 

':•[;_ impacts on the firm and impacts on local economic growth. 

•;'j A. Direct Economic Impacts on the Plant 

'-••] Diredt economic impacts on the plant should be examined through 

^] evaluation of the following: 

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1. Direct Costs 

The direct cost for each control alternative should be presented 

both on an incremental and on an overall basis. Investment costs, 

operations and maintenance costs and annualized costs should be presented 

separately. Annualized costs are operations and maintenance costs plus 

depreciation and interest charges on the investment. Costs should be 

itemized and explained. Credit for tax incentives should be included 

along with credits for product recovery costs and by-product sales 

generated from the use of control systems. The lifetime "of the investment should be stated. Where possible, costs should be broken down 

into process change costs (costs of less polluting production process) . 

and direct pollution abatement costs (cost of pollution control equipment). 

The costs of air treatment, water treatment and solid waste disposal 

should be presented separately. The analysis should also include the 

total investment cost of the new facility. 

As a guide in determining when control costs become excessive, 

alternative control systems can be compared in terms of certain cost 

effectiveness ratios. Such ratios may include the following: 

*M ° ratio of total control costs to total investment costs. 

° cost per unit of pollution removed (for example, dollars/ton). 

° cost versus additional portion of remaining PSD increment 

preserved for future growth. 

c unit production costs (for example, mill/kw-hr, dollars/ton 

of steel). 

In some cases, the unit of production output may be difficult to determine, 

as in the case of a plant producing many different products. In such 

cases, unit production costs can be expressed as cost ?er dollar of 

total sales. 

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2. Capital Availability 

Capital availability addresses the difficulty that some sources 

may face in financing alternative control systems. Proof of such 

claims should be fully documented. 

B. Local Economic Impacts 

Local economic impacts address the economic feasibility of alternative BACT requirements and the impact of the production decisions 

of the firm in response to alternative levels of control. For example, 

a BACT alternative may alter the economics of a project to the point 

where the decision would be made to cancel the. construction or expansion of a facility, to relocate a plant, to reduce the scale of operation, or to change the production mix. The local economic impacts of • 

such decisions should be assessed in terms of local employment effects 

including number of jobs, dollars paid in salaries, and changes in 

employee skill levels required. The guideline does not imply that the 

BACT decision should force new projects to the brink of cancellation. 

The BACT decision must be based on sound judgment, balancing environment 

benefits with energy, economic, and other impacts. 

Local economic impacts also can address the effect of various BACT 

alternatives on air quality increment consumption and the subsequent 

impact on future growth potential in the surrounding area. The BACT 

decision should reflect policy decisions to conserve the available air 

quality increment for future growth. 

IV. Other Costs 

Other costs associated with alternative emission control systems 

may be considered where appropriate. 

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ASSISTANCE IN DE^RKIMNG BAC" 

Assistance to tne states arc Regional Offices 

technology will continue tc be proviaec tiirougr th: 

review clearingnouss ;. August 1, 1977 memo, Walter C. Ssroer tc Regional 

Offices, "OAQPS Assistance for 5ACT/RACT/LAER Determinations''.'. Throucn 

its repository of information on past BACT/RACT/LAER decisions, the 

clearinghouse provides a communication link for aavising reviewing 

authorities of eacn other's determinations, thereby Drometing consistency 

in BACT determinations. The degree to which the clearingnouss will be 

effective as a consistency-improving tool will dec-end or; the cegrse to 

which the BACT determinations are repcrtea to OAQPS. All Regione 1 Offices 

are requested tc submit 3ACT findings tc the cl=arincnouse. In adcition 

to tne repository, the clearinghouse, systerr-alsc provides a focal ooint 

•^or answering Questions related to policy issues and control technology. 

With respect to control technclogv, OAQPS can assist in establishing the 

range of alternative controls for a particular orocess, but cannot 

evaluate case-by-case energy, environmental, and economic impacts or 

select BACT emission levels. In s'nort, tne clearinghouse car: be an 

important input to the reviewing authority's decision, rut it cannot 

substitute for the case-by-case analysis required tc select the ctorcr-"":et: 

control technology. 

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