Comparison of the Most Recent BACT/LAER Determinations for Combustion Turbines by State Air Pollution Control Agencies

摘要

A survey was conducted of state air pollution control agencies to determine the most recent Best Available Control Technology (BACT) and Lowest Achievable Emission Rate (LAER) determinations for natural gas combustion turbines used in electric power generation facilities. BACT and LAER for both simple cycle and combined cycle modes of turbine operation were evaluated. Any new major stationary source or major modification locating in an area attaining the National Ambient Air Quality Standards (NAAQS) is subject to Prevention of Significant Deterioration (PSD) requirements and must conduct an analysis to ensure the application of BACT. Also, any new major stationary source or major modification locating in an area not attaining the NAAQS is subject to non-attainment new source review permitting requirements and must conduct an analysis to ensure the application of LAER. Air pollution permitting agency decisions on BACT/LAER determinations depend heavily on the most recent BACT/LAER determinations. This most recent data is not always readily available in the US EPA BACT/LAER Clearinghouse. This often results in a delay as applicants and state agencies search for the most recent BACT/LAER determinations. This paper is intended to address the need for current BACT/LAER determinations used by the state air pollution agencies and private industries. The study involved a survey of 23 state air pollution agencies in the eastern half of the United States. Each state was queried on the most recent BACT/LAER analysis for simple and combined cycle combustion turbines; compliance averaging time applicable to these determinations; different types of control technologies required by each state agency; the cost per ton of pollutant removed threshold for economic feasibility; and the total number of BACT/LAER determinations made by each state during the last 12 months for this source group. This investigation primarily focused on the following pollutants: PM_(10), NOx, CO, SO2 and hydrocarbons. BACT and LAER determinations for large combustion turbines vary significantly by state. Similarly, the compliance averaging times also vary significantly. However, both the control technologies selected for BACT and LAER and the average cost per ton of pollutant removed threshold for economic feasibility are more consistent among the states. Finally, only 13% of the most recent BACT/LAER determinations in this survey were included in the RLBC database. U.S. EPA could help states make better BACT and LAER determinations by speeding up the process of incorporating the most recent BACT and LAER determinations in the RLBC database.