P.1 

OAR Box 1787 

Prepped by Ollie Stewart 

Document Number: 

35) ll-B-20 

Docket Number: 

A-90-37 

Printed 11/4/200810:22:19 AM Sheet 35 of 147 
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'.-.-- .^* A- 70 -37 

„^"s'«-. 

I X\?Z2 ? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

%ono^°v REGION IV 

345 COURTLAND STREET 

ATLANTA, GEORGIA 30365 

MEMORANDUM 

DATE: FEB 1 0 i 

SUBJECT: Issues Raised by Alabama Concerning the Implementation of "Top-Down" 

BACT 

(} ^ .. -\ . ,,, 

FROM: Bruce P. Miller, Chief JD>-^-*-*-- \ •- V^Oifv * . : •' *,'_ 

Air Programs Branch, Region IV \ " ' z. - '" " ;'• ,L

 ,EI' ' 

TO: Ed Lillis, Chief /^ 2 b IdJ \\t 

Non-Criteria Pollutant • 

Programs Branch ' -yT" _ 

i, _. i 

As portrayed during Region IV s presentation at the New Source Review 

conference in Denver, Colorado, this year, we have been literally bombarded 

with questions arising out of the "top-down" BACT implementation. Although we 

certainly support the "top-down" BACT procedure and concepts, we also believe 

that many of the questions raised by states are germane issues which clearly 

must be addressed to successfully implement the "top-down" approach. Several 

of these questions relate directly to the BACT procedures themselves while 

others question EPA's authority to implement this new concept. 

Region IV has been accused by our State Agencies as being inconsistent with 

other Regional Offices in its overview of state-issued PSD permits. Based on 

'our discussions with the other Regional Offices and Gary McCutchen during the 

I Denver conference, it does appear that Region IV may be interpreting and 

implementing the December 1, 1987, Craig Potter memorandum ("Improving New 

Source Review Implementation") differently than other Regions. This fact is 

extremely disconcerting in that the goal of the "top-down" approach is to 

ensure consistency and certainty in PSD permits. 

We realize that formal EPA guidance on implementing the "top-down" approach is 

several months away. It is imperative, however, that the states be given more 

specific guidance in the interim if the "top-down" process is to be meaningful 

and realized in the near-term. To this end, we ask that you review the 

attached issues raised by the Alabama Department of Environmental Management 

(ADEM) and respond to us accordingly. We have received four (4) letters fron 

ADEM regarding "top-down" BACT which are attached for your consideration: two 

(2) letters dated December 16, 1988, to Bruce Miller; one (1) letter dated 

January 20, 1989, to Greer Tidwell; and one (1) letter dated January 24, 1989, 

to Winston Smith. To the extent of avoiding duplicate questions, we ask that 

Region IV be given a response to each. We have formulated a Regional response 

to many of the issues raised by ADEM, and these positions are outlined in the 

attached briefing documents. On January 10, 1989, a meeting was held in 

Atlanta between ADEM, the Regional Administrator and Regional program staff to 

discuss some of these issues. Please feel free to carnrtent on these documents 

as well. 
P.3 

» Ji 

-2-

Furthermore, in the January 24, 1989, letter from ADEM a meeting was requested 

between Alabama, Region IV and Headquarters to discuss these issues. We wish 

to arrange this meeting at your earliest possible convenience. 

Please contact me upon your receipt of this memorandum so that a meeting time 

and place may be established. 

Attachments 
P.4 

/ . - K 

<">B<Ot> 

III*I ' •'. 

ALABAMA ^-^~ > 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT ^^ V 

Leigh Pegues, Director January 24, 1989 

Guy Hunt 

Governor 

1751 Cong. W. L. 

Dickinson Drive 

Montgomery, AL 

.36130 

205/271-7700 

Field Offices: 

Unit 806. Building 8 

225 Oxmoor Circle 

Birmingham, AL 

35209 

205/942-6168 

P.O. Box 953 

Decatur, AL 

35602 

205/353-1713 

2204 Perimeter Road 

Mobile. AL 

36615 

205/479-2336 

Mr. Winston A. Smith, Director 

Air, Pesticides, and Toxics 

Management Division 

U. S. Environmental Protection Agency 

Region IV 

345 Courtland Street 

Atlanta, GA 30365 

Dear Mr. Smith: 

ll! 

• tf ^ "i n iy-\ 

?T7—: 

B

; .V;;;.I;,:.:.:V 

ATLANTA, GA. 

i 

••; - '• I 

. * • x : 

•,.,..5i„"E"_-* 

This letter is intended to raise additional issues dealing with 

EPA's significant change in expectations regarding the procedures 

for determining Best Available Control Technology (BACT) pursuant to 

the Prevention of Significant Deterioration (PSD; regulations. While 

I have previously sent letters to the Regional Office identifying 

ADEM's concerns, I will attempt to summarize and expand upon them 

in this letter. 

Alabama's concerns can be suttmarized in four basic questions: 

1. Why is a rule change not necessary to implement such 

a basic change in how a regulation is implemented? 

2. Absent a rule change (with equivalent changes in state 

regulations), why should an internal EPA memorandum change 

the states' long standing interpretations of their regulations 

which are adopted pursuant to state authority? 

3. Given the absence of any meaningful EPA guidance, what 

are the criteria EPA will use to identify acceptable 

state reviews? 

4. Why is affordability/profitability a legitimate criteria 

for routinely deciding the appropriate level of control 

for air emissions? 

I have attached a copy of my December 16 letter which discusses 

in greater detail the issues identified in items 1, 2, and 3 above. 

There are several aspects of the "affordability" issue however 

which I also think warrant consideration. 

1. Since some corporations operate more efficiently than 

others and affordability is essentially the only criteria 

for rejecting the "top" level of BACT, won't the less 

efficient plants be "rewarded" by having to spend less 

for controls? 
P.5 

Mr. Winston A. Smith, Director . - 2 - January 24, 1989 

2. If the "top" controls should be required unless they are 

not affordable, what criteria should be used in determining 

affordability? Is there a certain percentage of a plants 

profits that define affordability or a profit margin 

that is acceptable to EPA? 

3. Assume a greenfield kraft pulp mill is proposed with the 

multiple emission points normally associated with such 

an operation and the normal profit margin. A calculation 

could be performed which identifies the total dollars 

which are "affordable" for air pollution controls. 

a. What factors should be considered in allocating 

these affordable costs among the various emission 

points regulated? Should these include air quality 

Einipacts in the vicinity of the plant, contribution 

to acid rain, ozone formation, or the greenhouse 

effect? 

b. What factors should be considered in allocating 

these affordable costs among the various pollutants 

emitted by the sources? Would it be acceptable 

to EPA for a state to require more than "top" BACT 

for TRS sources in exchange for less than "top" 

BACT for NO since the primary public concern is 

odors from luch operations? 

4. Assume an existing mill with the same profit margin as 

the previous example proposed to replace its recovery 

boiler. The total dollars which are "affordable" would 

be the same as the previous example. If a higher level 

of control was rejected in the previous example because 

of "affordability would it be expected at this plant 

since it would be affordable. 

5. What approaches would EPA suggest in determining affordability 

for utilities whose rates are regulated by the state? 

6. Should expenditures by a plant which are clearly beyond the 

norm for controlling waste water discharges or solid/hazardous 

waste generation (which may affect affordability) be 

considered in the BACT analysis if these controls address 

an environmental impact of greater significance? 

The attempts by EPA to implement "top down" BACT absent meaningful 

guidance have eliminated our ability to process permit applications 

with any confidence that EPA will not object. „I_Ask_ thajt_yoLL_arrange 

a_meeting wj.th_ADEM, your staff, and appropriate headquarters personnel 

to discuss these issues in~tHe^next several weeks. 
P.6 

Mr. Winston A. Smith, Director - 3 - January 24, 1989 

I appreciate your willingness to continue to work with us 

to resolve this issue. If any of the information contained in 

this letter or attachment requires clarification, please contact 

me at 205/271-7861. 

Sincerely, 

// ^ 

cd E. Grusnick, Chief 

Air Division 

REG:un 

Enclosure 

cc: SESARM States 
P.7 

.Ft. 

ALABAMA 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

Guy Hunt 

Leigh Pegues, Director Januar y 20,-.. 198 9 . Governor 

1751 Cong. W. L. 

Dickinson Drive 

Montgomery, AL 

36130 

205/271-7700 TV- '•' . :..-able Greer C. Tidwell 

•'.-:: "iiiistra ter 

L:iv^_..-.i.,-ir_tal Protection Agency 

Field offices: Region IV 

32.5 Courtland Stree t 

unit 806. Building 8 Atlanta,. GA 30365 

225 Oxmoor Circle y-'^L<.t <• 

Birmingham, AL Dear Mrr-TiaweTI: 

35209 

205/942-6168 This is a follow-up to our meeting of January 10, in your 

office regarding the attempts by EPA to implement the "top down" 

p.o. Box 953 approach to making Best Available Control Technology (BACT) 

Decatur, AL judgements under the Prevention of Signifigcant Deterioration (PSD) 

3

5602 regulations. I appreciate the time you and your staff devoted 

205/353-1713 to meeting with us on this issue of significant importance to the 

Region, and at the risk of being slightly repetitious, I would 

2204 Perimeter Road like to summarize the situation from our perspective. 

Mobile. AL 

366,5 I have enclosed flow charts which sutmarize the two approaches 

205/479-2336 identified by EPA for making BACT decisions. EPA's "original BACT" 

approach emphasized the role of the state in balancing the control 

costs, and environmental/energy costs and benefits in deciding 

the level of control which represents BACT. This approach has 

been used by EPA and most states to make BACT decisions for nine 

years. EPA's "top down" BACT approach, however, focuses almost 

exclusively on "affordability" of the controls. I have included 

excerpts from EPA's guidance on the two techniques which clearly 

identifies the contrasts in the approaches. 

EPA's change to the "top down" BACT approach disregards the 

approach used for nine years by EPA and most states in making these 

judgements. Such a radical change should not (and probably cannot) 

be implemented through an internal EPA policy memorandum. 

The difficulties engendered by EPA's proposed change are exacerbated 

by the lack of any meaningful guidance for the crucial decisions 

necessary to implement the approach. A review of the flow diagram 

for '*Top Down BACT" indicates there are three decisions which are 

crucial to this process. These are: 

1. What is "top" level of control which should be considered? 

2. What control costs are "reasonable"? 

3. What control costs are "affordable" (i.e., what level 

of profits are acceptable to EPA)? 
P.8 

The Honorable Greer C. Tidwell - 2 - January 20, 1989 

have 

EPA has provided no meaningful guidance for states or applicants 

to use in identifying any of these three crucial parameters. This 

ambiguity results in second guessing of state permitting decisions 

which were acceptable six months ago and an inability on the part 

of the state to process applications with any certainty that EPA 

vill not object. 

Especially troubling is the fact that several recent applicants 

indicated to us that Region IV's expectations for including 

"affordability" in the BACT justification exceeds the expectations 

fir similar, recent projects in ether EPA Regie-::::. These conments 

have come from several diverse industrial categories and our contact 

with several states in other Regions seem to confirm this allegation. 

In sunmary, I ask that: 

1. You encourage headquarters to implement such a basic 

change in making BACT decisions through a rule change; 

2. Region IV implementation of new BACT procedures be initiated 

upon receipt of meaningful guidance from headquarters which 

identifies the criteria EPA will use in its oversight and 

that information has been provided the states; and 

3. In order to provide additional background, I ask that 

your staff determine whether Region IV's implementation 

of what at this time must be categorized as nebulous 

guidance from headquarters has been consistent with its 

implementation in other EPA Regions. 

As always, I appreciate your willingness to work with us in 

seeking a reasonable solution. If any of the information contained 

in this letter requires clarification, please contact Richard Grusnick, 

Chief of the Department's Air Division or myself at 205/271-7700. 

Sincerely, 

LP/RG:un 

Enclosures 

cc: State Directors 

es, Director 
i/89 

ORIGINA L BAC T 

(12/78 - 12/87) 

Require Previous 

Level of Control 

No 

Evaluate 

Next higher 

Level of 

Control 

Calculate 

Incremental 

Annual 

Dollars/Ton 

Control Costs 

Identify Incremental: 

1. Envirormental 

Improvement/Cos ts 

2. Energy Costs/Savings 

3. Other Costs 

Do Benefits 

'Gained Justify the^ 

Additional 

Costs?*. 

Yes 

•Primarily a state judgement based on a balancing of the factors required to be 

considered by the regulations. 

CO 
T OP DOWN BAC T 

(Potter Memo of 12/1/87) 

1/89 

Require 

Controls 

Identify 

Maxinun 

Level of 

Control 

Calculate 

Annual 

Control 

Costs. 

(dollars/ton) 

Evaluate 

Next 

Lowest Control 

Level 

*If controls are technically infeasible, the option is also rejected. 
P.11 

buiueu.itfs ror ueierftnmng B6St Available 

Control Technology (BACT) 

The attached pages consist of direct quotes from four EPA 

documents that present guidelines for determining Best Available 

Control Technology (BACT). These four documents are: 

1. Guidelines for Determining Best Available Control 

Technology, (BACT), December 1978. The document, published 

by the Office of Air, Noise, and Radiation of the Office of 

Air Quality Planning and Standards of the EPA, was a part 

of the workshop manual used in the EPA's 1980 PSD 

workshops. This workshop manual 1s still part of EPA's 

Self Instructional Course No. 453, Overview of PSD 

Regulations. This guideline is the only formal guideline 

published by EPA for determining BACT. 

r 

« 

2. Best Available Control Technology Guidance Document, EPA 

Region 9, New Source Section, April 1987, DRAFT. This 

guidance document, although presented as a DRAFT document, 

was included In the November 1987 EPA Region IY New Source 

Review Workshop. 

3. J. Craig Potter, Assistant Administrator for Air and 

Radiation, EPA; December 1, 1987, Memorandum on Improving 

New Source Review (NSR) Implementation. This 1s the 

"Potter Memo" which Introduces guidance on the use of the 

"top-down" approach to BACT. 

4. Suggested Approaches for Determining Best Available Control 

Technology (BACT) and Lowest Achievable Emission Rates 

(LAER) (DRAFT), January 1986, prepared by Radian Corp. for 

New Source Review Section Control Program Development 

Division, U. S. EPA, RTP, N.C. This guideline document, 

although presented as a DRAFT document was included In the 

July 1986 EPA Region IV New Source Review Workshop. 

Items 1-3 are presented on the attached table, while item 4 is 

presented on the last page. 
Guidelines for Determining Best Available 

Control Technology (BACT) 

1980 PSD Workshop Manual 

"For each pollutant, the BACT 

permit application should present 

control alternatives which have 

greater control capabilities than 

the system proposed as BACT and 

which have been used or proposed 

for the same or similar 

applications." (p. S) 

1987 Guidance Document 1987 Potter Memorandum 

"...the selection and justification 

of a control alternative as BACT 

should begin with the most stringent 

control alternative, generally 

represented by LAER." (p. 7) 

"LAER will be the starting point In 

any BACT analysis and BACT will be 

presumed to be equal to LAER 

unless circumstances unique 

to the proposed project 

are...justified, (p. 15) 

"The first step in this approach Is to 

determine, for the emission source In 

question, the most stringent control 

available for a similar or Identical 

source or source category." 

2. "Unrealistic alternatives need "...no technically feasible 

not be presented such as placing alternative should be ruled out as a 

In series control equipment which possible BACT candidate." (p. 7) 

Is normally used alone (e.g., an 

ESP followed by a baghouse)." (p. 

6) 

3. "It Is the clear Intent of EPA 

not to require an analysis of the 

full proportion described herein 

for small sources.... In short, 

the BACT analysis should be held 

to a minimum with the depth of 

analysis being dependent on the 

difficulty of the decision." (p. 

2 & 3) 

"A chart should be prepared for each 

pollutant and for each emissions 

unit, or small group of units in the 

BACT analysis." (p. 10) 

"If an applicant selects the most 

stringent control alternative 

available (LAER), then no further 

analysis Is necessary for the 

regulated pollutants." (p. 15) 

"It (top-down BACT) also differs from 

other processes In that It requires the 

applicant to analyze a control 

technology only If the applicant 

opposes that level of control; the 

other processes required a full 

analysis of ^ n possible types and 

levels of co ' ol above the baseline 

case." 
1980 PSD Workshop Manual 

"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 as 

BACT." (p. 13) 

"The guideline does not imply 

that the BACT decision should 

force new projects to the brink 

of cancellation." (p. 15) 

"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: 

4 ratio of total control costs 

to total Investment costs. 

° cost per unit of pollution 

removed (dollars/ton) 

° cost versus additional 

portion of remaining PSD 

Increment preserved for 

future growth. 

° unit production costs 

(mlll/kw-hr, dollars per ton 

of steel, etc.)." (p. 14) 

1987 Guidance Document 1987 Potter Memorandum 

"In evaluating the economics of 

various BACT control options, 

primary consideration should be 

given to the cost effectiveness of 

an option and not the economic 

situation of the source 

applleant....an applicant's ability 

to afford a control option should 

not greatly Influence the choice of 

a control option as BACT, especially 

where these control options have 

been applied to that source 

category." (p. 12) 

"An analysis of the cost of control 

options on the basis of dollars per 

ton of pollutant controlled should 

also be conducted for each pollutant 

subject to BACT. A comparison 

should be made to the costs of 

controls for other source categories 

and other Industries. A complete 

economic analysis should compare 

costs of controls both within the 

specific source category under 

review and as a comparison of costs, 

on the basis of dollars per ton of 

pollutant removed, for other 

Industries." (p. 13) 

"If 1t.ca,n,be shovn that this level of 

control is technically or economically 

Infeasible for tho source In question, 

then the next most stringent level of 

control Is determined and similarly 

evaluated." 

"This process continues until the BACT 

level under consideration cannot be 

eliminated by any substantial or unique 

technical, environmental, or economic 

objections." 

CO 
1980 PSD Workshop Manual 

6. "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 some 

flexibility In emission control 

requirements depending on local 

energy, environmental, and 

economic conditions and local 

' preferences. This flexible 

approach allows the permitting 

authority to consider a number of 

local factors (—, the amount of 

the air quality Increment that 

would be consumed,—)—I n 

deciding on a weighting scheme." 

(p. 4) 

"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." (p. 3) 

1987 Guidance Document 1987 P'-tter Memorandum 

"A stringent BACT will not be 

dismissed because of a low Impact on 

ambient air quality." (p. 17) 

Tl 
1980 PSD Workshop Manual 

7. "The BACT decision should reflect 

policy decisions "to conserve the 

available air quality Increment 

for future growth." (p. 15) 

"...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." (p. 8) 

"The net environmental Impact 

associated with each alternative 

emission control system should be 

determined,—. The analysis 

should be presented In the form 

of the Incremental Impact of 

alternative control systems 

relative to the systems proposed 

as.BACT in the permit 

application." (p. 11) 

"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 as 

BACT." (p. 13) 

"The direct cost for each control 

alternative should be presented 

both on an incremental and on an 

overall basis." p. 14) 

1987 Guidance Document 

"For new major sources, each emission 

point with any emission rate of the 

applicable pollutant Is subject to the 

BACT requirement. For major 

modifications, each emission point at 

which an Increase in the applicable 

pollutant occurs Is subject to BACT." 

(p. 6) 

1987 Potter Memorandum 

« * 

Tl 

EEri 
P.16 

* 

I 

Guidelines for Determining Best Available 

Control Technology (BACT) 

January 1986 Suggested Approaches 

1986 BACT Guidance - 2 Approaches 

"Two similar yet slightly different approaches are 

available for determining BACT and LAER: the "bottom-up" and the 

"top down" approach." p. 3-1 

Bottom-up Approach 

' "The bottom-up approach for determining BACT (and LAER) is 

. discussed In detail in the PSD workshop Manual Issued 1n October 

1980." p. 3-2 

"Each control is then evaluated for Its economic, energy, 

and environmental Impacts" p. 3-4 

"Incremental cost-effectiveness calculated by dividing 

difference In annual costs by difference in emissions reduction." 

p. 3-8 

"The next step involves estimating the energy impacts of 

each PM control alternative...Only direct energy consumption Is 

considered." p. 3-4 

"The environmental Impacts of each alternative must also be 

considered. The applicant must assess the relative ambient air 

impacts of PM emissions by estimating stack parameters for each 

alternative in order to create input for a dispersion model." p. 

3-10 

"To determine BACT, the economic, energy and environmental 

Impacts are evaluated against each other" p. 3-10 

Top-down Approach 

"If It can be proven that the chosen BACT Is not applicable 

or Is technically or economically Infeasible for the source In 

question, the next most stringent BACT Is chosen." p. 3-10 
OMN 9 IDU!) 

ISSUE: Some states in Region IV have questioned EPA's implementation of the "top-down" approach 

for determining Best Available Control Tectuiology (IJACT) in Prevention of Significant 

Deterioration (PSD) permit reviews. Several r.tates hive indicated that they like the old BACT 

process that has been in place for the past several years and did not see a need to change it. 

EPA's implementation of a "top-down" BACT approach without adequate state acceptance and 

support has the potential to cause deterioration of Si.ate/EPA relationships whj.ch could destroy 

the overall success of £he new source review permitting process. This is especially true since 

EPA is pushing the "top-down" BACT approach without adequate guidance on how to implement or 

perform a "top-down" BACT analysis. This briefing paper will address some of the questions 

raised by Alabama and EPA's position on each. 

SIGNIFICANCE OF THE AGENCY; Major. The determination of BACT is a critical aspect of all PSD 

reviews. Furthermore, EPA's relationship with the States is key to a positive working 

partnership for achieving our mutual goals in protecting the environment. 

NEXT CRITICAL DATE; NA 

CURRENT AGENCY POSITION; The Region believes that the "top-down" BACr procedure conceptually 

agrees with the intentions of Congress in defining PSD objectives. We also believe that the 

Region's implementation of the "top-down" BACT procedure is consistent with other Regional 

Offices as well as with national EPA directives. Tlie Region does recognize, however, that 

guidance in implementing the "top-down" BACT procedure is currently limited, and many questions 

have been raised by State agencies which clearly should be addressed by EPA. 

BACKGROUND; As noted in the December 1, 1987, policy memorandum from J. Craig Potter, entitled 

''Improving New Source Review (NSR) Implementation", BACT (and LAER) determinations are perhaps 

the most misunderstood and the least correctly applied of all the NSR processes. Tlie BACT 

alternatives, if presented by the applicant at all, are often poorly documented or biased to 

achieve the decision the applicant desires. To bring consistency to the BACT process, EPA is 

currently requiring the use of the "top-down" approach to BACT. Tlie first step in this 

approach is to determine, for the emission source in question, the most stringent control 

available for a similar or identical source or source category. If it can be shown that this 

level of control is technically or economically infeasible for the source question, then the 

next most stringent level of control is determined and similarly evaluated. This process 

continues until the BACT level under consideration cannot be eliminated by any substantial or 

unique technical, environmental, or economical objections. Thus, the "top-down" BACT approach 

shifts the burden of proof to the applicant to justify why the proposed source is unable to 
-2-

apply the best technology available. It also differs from previous procedures employed to 

determine appropriate BACT levels of control in that it requires the applicant to analyze a 

control technology only if the applicant opposes that level of control. 

EPA's requirement to employ a "top-down" BACT analysis has prompted several questions by state 

agencies. The questions raised by Alabama and our Regional responses are as follows: 

1. Why is a regulatory change not necessary to implement such a basic change in policy? 

EPA Response: The definition of BACT as contained in the Clean Air Act has not changed. 

The "top-down" approach is merely thought to be a better procedure for arriving at an 

appropriate level of BACT. EPA, therefore, believes a regulatory change is not required. 

There have been some legal issues raised by outside parties as to whether EPA can legally 

require this "top-down" approach without going through proper rulemaking. We don't 

believe this is the case, however, this issue rrwy be resolved at some later date as a 

result of a court decision. 

2. How constraining does EPA view this guidance for states which have adopted regulations 

pursuant to state authority? 

EPA Response: States have argued the position that once a state has been delegated the 

exclusive authority to issue PSD permits (through SIP-approved regulations) then EPA 

should not second guess the state's judgement in issuing those PSD permits as long as the 

state implemented the proper procedures and requirements of the Clean Air Act. EPA has 

always held the position that it had authority, under the Clean Air Act, to overview the 

PSD permitting decisions made by SIP-approved state programs to insure they have fully 

considered the appropriate levels of control in making their BACT determinations leading 

to the issuance of the PSD permit. Admittedly, this issue may ultimately be resolved 

through future court decisions. Since we have always maintained a position of overview 

authority of state issued PSD permits, we think it is appropriate for the state to switch 

over to the "top-down" BACT approach without rulemaking. 

3. I/hat urgency required EPA to implement the "top-down" BACT approach before developing 

guidance for its implementation? 
-3-

EPA Response: One of the main factors prompting tlie "top-down" BACT approach stemmed from 

the Agency's concern of consistency and certainty in PSD permits. This came to the 

attention of EPA through its National Air Audit System (NAAS) which started in FY 84. The 

NAAS was a joint effort of the STAPPA, ALAPCO, and EPA to develop audit guidelines and 

questions that would be used consistently on a national basis for reviewing State/Local 

air programs. On the results of these audits, it became apparent that BACP determinations 

were not being done consistently throughout the country. BACT determinati'-ns were 

sometimes incomplete, all control options available were not always considered, and 

several permitting authorities defaulted to the New Source Performance Standards (NSPS) 

for establishing BACf limitations. Due to these major deficiencies which were occurring 

in BACr determinations, the Administrator clearly indicated in the H-Power and North 

County PSD remands a need for the "top-down" approach to BACT determination:;. Thus, in 

his December 1, 1987, guidance memo, Craig Potter noted that the Region sli; iLd immediately 

require that the "top-down" approach be implemented by all permitting aq<••'••< i-:s. The 

requirement for all permitting agencies to immediately adopt this approac'1 '3 designed to 

promote national consistency as well as to prevent the issuance of any fuLi" permits 

containing obviously deficient BACr determinations. It certainly is true t! i_ everything 

being equal it would have been beneficial for permitting agencies to have r.i :cific EPA 

guidance on how to implement the "top-down" approach to BACT before making it a 

requirement. However, EPA believed that the need to prevent the future i fiance of 

clearly deficient BACr determinations in the near term outweighed the ad^ Lage of 

delaying the implementing of "top-down" BACT until final guidance had bet.-' leveloped. It 

should be noted that in the absence of final guidance, EPA has given broa'i flexibility to 

permitting agencies BACT determinations so long as the "top-down" approacli was employed 

and the agency presented a plausible rationale for not requiring a certain level of 

control technology. 

4. Why is incremental cost analyses not the most appropriate basis for making BACF decisions? 

EPA Response: While certainly considered, the use of an incremental cost analyses in 

making BAC1' decisions can be very deceiving and usually tends to influence the selection 

of the least effective control option. The use of an incremental cost analysis does not 

adequately reflect the fact that the "top" level of control may be reasonably affordable 

despite a high incremental cost or that other sources have been required to install the 

"top" control. For these reasons, and for national consistency, the Agency is currently 

advocating a cost analysis which is based on the overall costs for removing a particular 

pollutant. For a more comprehensive discussion of this procedure, please refer to the 

attached briefing document. 
-4-

5. What dollars/ton figure is so high that it should generally result in the rejection of a 

control option as BACT? What is the reasonable range for a dollars/ton figure that should 

result in requiring the control option absent a demonstration of: unique economic 

considerations? What dollar/ton figure is so low that the control option should be 

required even if the costs make construction of the total project uneconomical. 

EPA Response: There currently are no set dollars/ton figures in making the appropriate 

BACT decision. Rather, the agency has been requiring the applicants to present data to 

support arguments of economic infeasibility of a project. Specifically, that the cost of 

the control option is clearly beyond the range of recent costs normally associated with 

BACT for the type of facility in question and BACr control costs in general for the 

pollutant and that the additional costs would be inappropriate for the source. 

Many agencies have indicated that even if they were to employ the "top-down" BACT 

approach, they do not know what the "bench mark" control costs are on either a pollutant 

or source category basis which would trigger the need for an applicant to develop a full 

scale economic analysis in order to reject an otherwise available control option. EPA 

believes expansion of the BACT/LAER clearinghouse data base to include cost analysis data 

will minimize state concerns. 

6. Since EPA's policy will require many decisions to be based on specific plant economics and 

much of this information is required to be kept confidential (if requested by the source) 

how will the public be allowed to meaningfully participate in the BACr decisions? 

EPA Response: At present, we are not aware that this issue has surfaced. Some of this 

information may be the same information which is already being submitted to financial 

institutions for getting appropriate funding for the project. We can speculate, however, 

of other alternatives in providing convincing arguments to justify rejection of a control 

option based on economics. One example may be to use percentages rather than firm 

financial data. The Region will be requesting Headquarters to address this question. 
7. Why should the environmental impact of the various control options be ignored in making 

the BAC1' decisions? 

EPA Response: Environmental impacts relating to a particular option should always be 

considered. As indicated in the North County Remand, the permitting authority should 

consider the effect of controlling unregulated (air toxics) pollutants when making a BACT 

determination for a regulated pollutant. Also, other environmental impacts which should 

be considered in making a BACI' determination might be the impact of a certain control 

technology on generating toxics wastes or polLuting ground water, etc. All of I hese 

impacts should be considered. However, some states and applicants are taking a different 

interpretation of what environmental impacts mean in the definition of BACT. Some state's 

and applicants take the position that "if going from a lesser degree of control to a more 

effective control does not show a modeled difference in ambient impacts (or little 

difference), then the more effective control device may be rejected regardless of its 

affordability, additional pollutant removal, etc. EPA's position is that if the more 

effective control device is clearly affordable, the fact that the modeled ambient 

concentration differences are small cannot be used as the sole basis for rejecting the 

"top" option. If states were allowed to justify the rejection of a control option based 

on merely an "insignificant" ambient impact, such new source growth in rapidly expanding 

areas would undoubtedly still consume significant amounts of available increment. Such 

increment consumption, which could have been economically avoided, will be at the expense 

of future growth and development of the area. 

Tl 

ho 
ISSUE; The criteria that EPA relies upon tor determining whether a pollution control option is feasible 

for a particular industry are not contained in concise written terms. Rather, the Agency relies upon 

case-by-case evaluation using previous determinations, related legal actions, and general guidelines as a 

backdrop for determining the appropriateness ot" pollution controls. Although inexplicit, we believe that 

the criteria and rationale employed by tlie Region in these evaluations are sound and reasonable in the 

absence of specific Agency guidance. 

SIGNIFICANCE TO REGION; The issue is not only significant to the Region, but also of concern to industry, 

state and local agencies, and EPA as a whole. Ihe issue bears strongly upon the public's perception of 

EPA, its consistency and its impartial nature of regulating industry uniformly throughout the nation. 

Environmental benefit through the use of pollution controls must remain in a balance, as intended by 

Congresss, with economic, energy, and other environmental concerns. 

CURRENT REGION POSITION: Ihe primary assertions made by a facility in determining an appropriate level 

of pollution control rely upon an analysis of cost effectiveness and ambient impacts. The Region believes 

that our overview criteria employed in PSD reviews is fair and equitable, and consistent with Agency 

initiatives. 

BACKGROUND: As noted in the December 1, 1987, policy memorandum from J. Craig Potter, entitled "Improving 

New Source Review (NSR) Implementation", BACT (and LAER) determinations are perhaps the most misunderstood 

and the least correctly applied of all the NSR processes. The BACT alternatives, if presented by the 

applicant at all, are often poorly documented or biased to achieve the decision the applicant desires. 

To bring consistency to the BACT process, EPA is currently developing specific guidance on the use of the 

"top-down" approach to BACT. Ihe first step in this approach is to determine, for the emission source in 

question, the most stringent control available for a similar or identical source or source category. If 

it can be shown that this level of control is technically or economically infeasible for the source in 

question, then the next most stringent level of control is determined and similarly evaluated. This 

process continues until the BACT level under consideration cannot be eliminated by any substantial or 

unique technical, envirormental, or economicl objections. Thus, the "top-down" approach shifts the 

burden of proof to the applicant to justify why the proposed source is unable to apply the best technology 

available. It also differs from other processes in that it requires the applicant to analyze a control 

technology only if the applicant opposes that level of control; the other processes required a full 

analysis of all possible types and levels of control above the baseline case. 

Tlie question of the affordability of a "top" control option is probably the most complex and subjective 

aspect in a BACT analysis. It is the Agency's position that if a "top" control alternative is technically 

feasible and affordable, it makes little or no difference what the aiibient impacts of the control may be. 

Also, if the "top" control option is otherwise affordable, the incremental cost effectivenss when compared 

to the next best level of control should not be used as a basis for rejection of the "top" control 

alternative. Consider the following hypothetical examples. Assume that a particular source 

category generally expends about $3,UOO per ton of pollutant removed to control a pollutant subject 

to BACT. If such a source were to make application for a PSD permit in Region IV, and if the 
application indicates that the "top" level of pollution control would cost under $3,000 per ton of pollutant removed the Region would require an extensive justification by the applicant to show why this level 

of control is inappropriate. Arguments presented by the applicant to indicate that the ambient impacts 

between the "top" control option and the next best level of control are insignificant would not be accepted 

as a basis for rejection of the "top" control. Similarly, arguments presented by an applicant to show that 

the incremental cost effectiveness between the two levels of control is excessive would not be accepted 

since the "top" control option may be otherwise affordable and has been accepted by other facilities. In 

order to reject the "top" control option as BACT for economic reasons, the applicant must clearly present 

unique and convincing arguments to prove why the "top" control option would not be affordable in their 

instance. This may be shown, in some cases, by demonstrating that the costs of the "top" control option 

would substantially increase product costs above that which is acceptable for competitive industry. If the 

applicant can demonstrate that these costs will make them noncompetitive in the marketplace or would make 

the project infeasible for economic reasons, Region IV would normally accept these arguments and not require 

the control. As the costs for the "top" level of control increase above the amount normally accepted by 

the particular industry, i.e., above $3,000 per ton of pollutant removed in this example, Region IV generally 

requires increasingly less of a demonstration by the applicant to show why the control is unaffordnblo. In 

many cases, the cost of the "top" pollution control is such that no further demonstration of affordability 

is required at all. 

KEY CONTACT PERSON: Bruce P. Miller, Chief 

Air Programs Branch 

Air, Pesticides, ad Toxics Management Division 

FTS: 257-2864 Commercial: (404) 347-2864 
Leigh Pegues, Director 

ALABAMA 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

December 16, 1988 

XT77 

P.24 

- 7 

V , ; 

Guy Hunt 

Governor 

1751 Cong. W. L. 

Dickinson Drive 

Montgomery , AL 

36130 

205/271-7700 

Field Offices: 

Unit 806, Buildings 

225 Oxmoor Circle 

Birmingham, AL 

35209 

205/942-6168 

P.O. 8ox953 

Decatur, AL 

35602 

205/353-1713 

2204 Perimeter Road 

Mobile. AL 

36615 

205/479-2336 

Mr. Bruce P. Miller, Chief 

Air Programs Branch 

Air, Pesticides, and Toxics 

Management Division 

U. S. Environmental Protection Agency 

. Region IV 

345 Courtland Street 

Atlanta, GA 30365 

Dear Mr. Miller: 

We have had numerous conversations in the past six weeks 

regarding what EPA means by "top down" best available control 

technology (BACT) under the federal Prevention of Significant 

Deterioration (PSD) regulations. I have serious misgivings that 

continue to increase as EPA's policy evolution proceeds. 

Alabama adopted PSD regulations pursuant to state authority 

in January of 1981 which were subsequently approved by EPA. The 

EPA guidance which existed at the time of our adoption indicated 

"State judgement and the Federal emission standards are the foundation 

for the BACT determination". This approach has worked well over the 

years and resulted in improved controls on many new air pollution 

sources. EPA has been satisfied with Alabama's implementation of 

its regulations. 

The creation of the "top down" BACT approach and its recent 

implementation, however, has drastically altered the process. 

EPA is attempting to substitute its judgement for the states' by 

establishing criteria which are so enigmatic that the interpretation 

changes from week to week. 

I have serious concerns about both the direction this policy 

is taking and the lack of a coherent system for implementing the 

change. I have identified my misgivings in the form of the following 

questions. I suspect that a response to these questions will require 

input from headquarters. 

1. Why is a regulatory change not necessary to implement such 

a basic change in policy? 

Comment; Such a major reversal of previous interpretations 

which were the basis for issuing thousands of permits would 

appear to warrant rulemaking. Were these permits improperly 

issued? If not, when did the "grandfathering" end? 
P.25 

Mr. Bruce P. Miller, Chief - 2 - December 16, 1988 

2. How constraining does EPA view this guidance for states which 

have adopted regulations pursuant to state authority? 

Comment; The regulations provide great flexibility in identifying 

the emission limit which represents BACT. EPA is in the process 

of broadly interpreting regulations it adopted pursuant to federal 

statutes. States would anpear to have the same broad flexibility 

cf i-:;-.—racing szz.tz. - = _;•_._.__.ions adopted pursuant to state 

authority. 

3. What urgency required EPA to implement the "top down" BACT 

approach before developing guidance for its implementation? 

Comment: The chaos caused by attempting to implement the 

present guidance has resulted in a high level of frustration. 

We receive different interpretations from different individuals 

within the regional office and from conversations with other 

regions. We have also received revised interpretations from 

the same individual as time progresses. The present approach to 

implementing the policy changes made such confusion inevitable. 

4. Why is incremental cost analyses not the most appropriate 

basis for making BACT decisions? 

Comment: My understanding of the present approach preferred 

by EPA is to identify the most stringent controls possible 

and divide the total tons per year controlled by the annualized 

cost of controls to determine a dollars per ton figure. If this 

dollars per ton figure is too great, then the controls should 

be rejected as BACT. If this figure is within an acceptable 

range, the controls should be required unless the plant can 

demonstrate that unique economic considerations should eliminate 

the option. There is also a minimun dollars/ton figure that 

should be required even if the cost makes the construction 

of the total project uneconomical. 

One recent PSD review we performed illustrates the difference 

this approach would make. The BACT level chosen resulted 

in a 181 ton per year emission reduction at an annual cost 

of $159,000 for a removal cost of $877/ton. The next level 

would have resulted in a total reduction of 183 tons/year 

(2 tons more than the previous example) with a total annual 

cost of $227,000 for an incremental removal cost of $63,784/ton. 

The total removal cost for the second option, however, was 

$l,512/ton which is what I understand to be the acceptable 

range. 

From another perspective, we recently permitted a new recovery 

boiler with an uncontrolled particulate emission rate of greater 

than 62,000 tons per year. Assuming an annualized "reasonable cost" 

criterion of $2,000/ton, control costs approaching $124 MM/year 

would be viewed as reasonable. 
P.26 

Mr. Bruce P. Miller, Chief - 3 - December 16, 1988 

5. What dollars/ton figure is so high that it should generally 

result in the rejection of a control option as BACT? What 

is the reasonable range for a dollars/ton figure that should 

result in requiring the control option absent a demonstration 

of unique economic considerations? What dollars/ton figure 

are so low that the control option should be required even 

if the costs make construction of the total project uneconomical. 

Comment: The current EPA policy of "top down" BACT focuses 

exclusively on economics. It would appear that this basic 

information should be available for E?A to perform the detailed 

oversight expected by headquarters. It seems appropriate 

that everyone understand the guidelines upfront. This would 

also appear essential for achieving the increased consistency 

desired by EPA. 

6. Are the economic criteria used in developing the NSPS applicable 

to BACT decisions for the same source types? 

Comment: EPA has indicated that the emission limits established 

by NSPS are irrelevant to the case-by-case BACT decisions, other 

than to establish a minimun level of control. Many of the NSPS, 

however, contain judgements of feasible dollars/ton of pollutant 

removed, costs/ton of product, etc. It would appear these would 

have some relevance to the BACT decision. 

7. Since EPA's policy will require many decisions to be based 

on specific plant economics and much of this information is 

required to be kept confidential (if requested by the source) 

how will the public be allowed to meaningfully participate 

in the BACT decisions? 

Comment: I presune that unique plant economics include such 

things as profit margins, product costs, sales volunes, and 

other information that envirormental statutes generally require 

to be held confidential (if requested by the source) would 

be necessary to make these judgements. EPA's approach would 

require the regulatory agency to keep the information most 

crucial to making its BACT decision from members of the public 

wishing to participate in the decision. 

8. Why should the environmental impact of the various control 

options be ignored in making the BACT decision? 

Comment: The PSD regulations require the consideration of 

"... energy, environmental and economic impacts and other 

costs..." in determining BACT. It would appear the regulations 

authorize, and perhaps require, that the air quality impact 

of the various control options be given some consideration. 

This also appears rational. 
P.27 

Mr. Bruce P. Miller, Chief - 4 - December 16, 1988 

I am looking forward to your response to these questions with 

appropriate input from headquarters. I trust this exchange of 

views and information will result in a reduced level of frustration 

in the future. 

If this letter requires any clarification, please give me a 

call at 205/271-7861. I would also be willing to meet and discuss 

the issues raised in this letter if you feel this would be productive. 

rr> 

Richard E. Grusnick, Chief 

Air Division 

REG:un 

cc: SESARM States 
P.28 

ALABAMA 

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

Leigh Pegues, Director 

1751 Cong.W. L. 

Dickinson Drive 

Montgomery, AL 

36130 

205/271-77C0 

Guy Hunt 

Governor 

December 16, 1988 

Field Orfic-3s: 

Unit 806, Building 8 

225 Oxmoor Circle 

Birmingham, AL 

35209 

205/942-6168 

P.O. Box 953 

Decatur, AL 

35602 

205/353-1713 

2204 Perimeter Road 

Mobile, AL 

36615 

205/479-2336 

i /"i ) ' r 

inr-- '• 

) 'y / 

:'-••••• -^zyz 

Mr. Bruce P. Miller, Chiei 

Air Programs Branch 

Air. Pesticides, and Toxics 

. i;____ii^.^ti. ..w*. L, ___•* <9 ±Sj*Zii,* 

U. S. Environmental Protection Agency 

Region IV 

345 Courtland Street 

Atlanta, GA 30365 

Dear Mr. 

:

y} 

in) DEC 2HS3S !'•'•' 

tfu hziP^.JTr^-i-:! -"*-*-.«J u (Si'uj 

Ai **--.<-,., y A | 

This is in response to our recent conversation regarding the 

evolving EPA interpretation of what is meant by "top down" best 

available control technology (BACT) under the Prevention of Significant 

Deterioration (PSD) regulations. Many of my conversations with you 

over the past six weeks has resulted in a significant change in my 

perception of what EPA means by "top down" BACT. 

I understand that the present approach preferred by EPA is to 

identify the most stringent control possible and divide the total 

tons per year controlled by the annualized costs of the controls. 

If this cost is in the $2,000-$3,000/ton removed range, then these 

controls should be required absent a showing that the economics 

of the plant could not support this level of control. If these 

annualized costs are much less than $1,000/ton, then plant economics 

are irrelevant and the project probably should not be permitted. 

This is a dramatic change from the approach that has been 

used for every PSD review performed by Alabama and accepted by 

EPA. The approach we have used considered incremental cost of 

increasingly stringent controls and was based on earlier EPA 

guidance. 

You indicated that it was your understanding that for the past 

year or so that the preferred EPA approach was being implemented 

and that any analysis performed by the state which did not use this 

approach was either evaluated by EPA using this approach or was 

approved based on incorrect assessment by EPA. I have enclosed a 

sunmary of the most recent PSD reviews performed by Alabama which 

analyzes the costs using both the incremental costs and total costs. 

I ask that you provide an explanation of EPA's basis for concurring 

with each of these reviews given the criteria you identified in our 

discussion. 
P.29 

* v '-1 

Mr. Bruce P. Miller, Chief - 2 - December 16, 1988 

I would also appreciate seeing examples of reviews done by 

other states in the Region which use the approach presently in 

favor with EPA. 

It is interesting to note that using the $2,000/ton criteria 

the annualized control costs which would be presumed reasonable 

for each of the plants identified in the attacLnant would be: 

Plant Control Costs 

MOEPSI $4MM/Year 

Ciba-Geigy $ .4MM/Year 

Exxon $28MM/Year 

Meade 1 $52MM/Year 

Meade 2 $134 MM/Year 

Champion $2 MM/Year 

Is it EPA's review that these costs can reasonably be incurred in 

complying with the BACT requirement? 

I have serious concerns about the direction EPA is taking in 

the implementation of the "top'down" BACT regulations which I will 

address in a separate letter. I also have concerns about Region IV's 

overly aggressive implementation of this nebulous concept. 

I would appreciate your response to the questions raised in 

this letter. If any of the information requires clarification, 

please give me a call at 205/271-7861. 

Sincerely, 

Richard E. Grusnick, Chief 

Air Division 

REG:un 
P.30 

BACT Determinations in Alabama 

MOEPSI; Permits issued March 11, 1988. In this project, BACT was 

determined for a tail gas sulfur recovery complex. The control technology 

selected as BACT was a SRU/SCOT unit. This would provide 99.86% sulfur 

recovery at a cost of $l,000/ton SO2. The next ievel of control was the 

addition of a AGE unit, which would provide 99.87% sulfur recovery. For 

this, the incremental cost for removing 14 additional tons of SO2 was 

$35,500/ton SO2, and gave a total cost of $1,251/ton SO2. 

CONTROL/OPTION 

SRU/SCOT 

plus AGE 

POLLUTANT 

REMOVED 

TONS/YEAR 

1,956 

1,970 

ANNUAL 

COST 

$1,000 

1,967 

2,464 

INCREMENTAL 

REMOVAL COST 

$/T0N 

1,005 

35,500 

TOTAL 

REMOVAL COST 

$/T0N 

1,005 

1,251 

CIBA-GEIGY; Permits issued November 7, 1988. In this project, process vent 

emissions of VOC's were to be controlled. Two control technologies were 

examined, a flare and an incinerator. The flare was determined to be BACT 

for this process, and would control VOC emissions at a cost of $877/ton. 

The use of an incinerator would control 1.85 additional tons of VOC at an 

incremental cost of $67,784/ton VOC. The total cost for the incinerator 

was $l,512/ton of VOC. 

CONTROL/OPTION 

Flare 

Incinerator 

POLLUTANT 

REMOVED 

TONS/YEAR 

181.3 

183.15 

ANNUAL 

COST 

$1,000 

159 

277 

INCREMENTAL 

REMOVAL COST 

$/T0N 

877 

63,784 

TOTAL 

REMOVAL COST 

$/T0N 

877 

1,512 

EXXON; Permits issued March 8, 1988. In this project, BACT was determined 

for a tail gas sulfur recovery complex. The control technology selected as 

BACT was a SCOT unit. This would provide 99.7% sulfur recovery at a cost 

of $216/ton SO2. The next level of control was a SCOT unit operating at a 

sulfur recovery rate of 99.8%. For this, the incremental cost for removing 

370 additional tons of SO2 was $l,730/ton SO2, and gave a total cost of 

$255/ton SO2. 

% S RECOVERED 

CONTROL/OPTION 

SCOT 99.7% 

SCOT 99.8% 

WELLMAN 99.9% 

POLLUTANT 

REMOVED 

TONS/YEAR 

13,760 

14,130 

14,500 

ANNUAL 

COST 

$1,000 

2,970 

3,610 

6,490 

INCREMENTAL 

REMOVAL COST 

$/T0N 

216 

1,730 

7,784 

TOTAL 

REMOVAL COST 

$/T0N 

215.8 

255.5 

447.6 
P.31 

t..—? ,—•"*.'' 

HEAD COATED BOARD; Permits issued September 15, 1988. In this project, 

BACT was determined for the No. 3 Wood Waste Boiler. The control 

technology selected as BACT was a scrubber that provided an exit 

concentration of 0.100 gr/dscf particulates. This would be accomplished at 

a :ost of $49.90/ton particulate removed. The next higher level of control 

wc.- a scrubber that would remove an additional 45 tons/year. This would be 

ac ..->.iiplished at an incremental cost of $5,756/ton, or a total cost of 

$59.85/ton. 

(gr/dscf) 

CONTROL/OPTION 

Scrubber 0.100 

Scrubber 0.089 

ESP 0.075 

ESP 0.036 

POLLUTANT 

REMOVED 

TONS/YEAR 

25,770 

25,815 

25,870 

26,026 

ANNUAL 

COST 

$1,000 

1,286 

1,545 

2,666 

2,863 

INCREMENTAL 

REMOVAL COST 

$/T0N 

50 

5,756 

20,382 

1,263 

TOTAL 

REMOVAL COST 

$/T0N 

49.90 

59.85 

103.05 

110.00 

HEAP COATED BOARD; Permits issued September 15, 1988. In this project, 

BACT was determined for the No. 2 Recovery Boiler. The control technology 

selected as BACT was an ESP that provided an exit concentration of 0.044 

gr/dscf particulates. This would be accomplished at a cost of $38.09/ton 

particulate removed. The next higher level of control was an ESP that 

would remove an additional 42 tons/year. This would be accomplished at an 

incremental cost of $l,930/ton, or a total cost of $39.36/ton. 

(gr/dscf) 

CONTROL/OPTION 

ESP 0.044 

ESP 0.040 

ESP 0.033 

ESP 0.030 

ESP 0.027 

POLLUTANT 

REMOVED 

TONS/YEAR 

62,457 

62,499 

62,572 

62,604 

62,635 

ANNUAL 

COST 

$1,000 

2,379 

2,460 

2,614 

2,699 

2,808 

INCREMENTAL 

REMOVAL 

J/TON 

38 

1,929 

2,109 

2,656 

3,516 

COST 

TOTAL 

REMOVAL COST 

J/TON 

38.09 

39.36 

41.78 

43.11 

44.83 

CHAMPION INTERNATIONAL; Permits issued November 30, 1988. In this project, 

NOx emissions from a gas turbine were to be controlled. The control 

technology selected as BACT was steam injection. This would be 

accomplished at a cost of $825/ton NOx not created. The next higher level 

of control was an add-on catalytic reduction unit that would remove an 

additional 311 tons/year. This would be accomplished at an incremental 

cost of $5,780/ton, or a total cost of $2,456/ton. 

CONTROL/OPTION 

Steam Injection 

SCR 

POLLUTANT 

REMOVED 

TONS/YEAR 

634 

945 

ANNUAL 

COST 

$1,000 

523 

2,320 

INCREMENTAL 

REMOVAL COST 

$/T0N 

825 

5,780 

TOTAL 

REMOVAL COST 

$/T0N 

825 

2,456 

J