EPA released guidance November 10, 2010, to industry and state and local permitting agencies on how to determine best available control technology (BACT) for greenhouse gas (GHG) emissions from new and modified sources. The guidance advises permitting agencies to use the same five-step process used for determining BACT for traditional pollutants, such as nitrogen oxides and volatile organic compounds.
The five-steps include identifying all available control technologies, eliminating technically infeasible options, evaluating and ranking remaining control technologies based on their effectiveness at controlling emissions, evaluating the cost-effectiveness of controls as well as energy and other environmental impacts, and selecting BACT. The guidance was issued as industry and states prepare for GHG emissions control and permitting requirements scheduled to take effect January 2, 2011, under the Clean Air Act’s prevention of significant deterioration (PSD) and Title V provisions that require new and modified sources to control GHG emissions using BACT.
The guidance (i) describes, in general terms and through examples, the requirements of the PSD and Title V permit regulations; (ii) reiterates and emphasizes relevant past EPA guidance on the PSD and Title V review process for other regulated pollutants; and (iii) provides additional recommendations and suggested methods for meeting the permitting requirements for GHGs.