GHG BACT Developments. Justin Fickas Clay Raasch. Overview. Since January 2011, Greenhouse Gases (GHGs) have been evaluated under Prevention of Significant Deterioration (PSD) permitting The GHG BACT process can prove challenging Learning curve for both permitting authorities and industry
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Applicant defines the goals, objectives, purpose, or basic design for the proposed source/modification
BACT process does not typically redefine these basic design elements
When fuel efficiency or overall production process efficiency are considered as an available control option, defining the source/project is a critical step in the BACT process
No significant consolidated database of GHG emissions performance of many industrial source types as there is for criteria pollutants
Typical metrics for comparing available control options for criteria pollutants may not apply to certain GHG controls or may be very difficult to explicitly quantify
For common fossil-fuel fired combustion units, like boilers and engines, GHG emissions performance on a mass pollutant emitted per energy output basis is the most likely basis for comparison (i.e., lb/MW steam or lb/hp-hr engine output)
If energy efficiency is selected as the top control option, what level of energy consumption per unit output constitutes BACT for new and existing sources?