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New Source Review (NSR) Permitting

Best Available Control Technology (BACT) Cost Considerations

Date Title EPA Office Author Issues Addressed
03/31/1988 Transmittal of OAQPS Interim Control Policy Statement OAQPS Seitz, John Final Interim Control Policy for developing compliance schedules that require replacement or upgrading of existing air pollution control equipment. 
06/08/1992 Response to Request for Guidance Concerning Installation of Nitrogen Oxides Continuous Emissions Monitoring Systems SSCD Rasnic, John Whether the application of a Continuous Emissions Monitoring System (CEMS) for nitrogen oxides (NOx), sulfur dioxide (SO2), flue gas flow rate, temperature, and moisture content has been demonstrated or is technically feasible when used with an internal combustion engine (ICE). 
03/24/1997 Calculation of Cost Effectiveness of Emission Control Systems Region 4 Beals, Brian Concerns appropriate method for evaluating control costs when a control device results in reductions of more than one regulated pollutant.

Valero Hydrocarbons BACT Analysis, PSD-TX-746

Region 6 Wayne, Anthony

Provides feedback regarding BACT analysis for a proposed natural gas processing plant, including specific concerns with how the technical, cost and economic analyses were performed.

07/24/1987 Calculating Amortized Capital Costs OAQPS Bauman, Robert Clarifies appropriate criteria to be used in calculating the amortized capital costs of BACT control options, including determining equipment life expectancy using IRS criteria or “useful economic life” used by NSPS.
12/14/1988 Review of Valero Hydrocarbons BACT Analysis OAQPS Basala, Allen Pertains to the adequacy of a BACT analysis, specifically its technical, cost and economic analyses.
01/27/1989 Discounted Cash Flow (DCF) Analysis for Craven County Project New Source Review OAQPS Bunyard, Frank Review of a discounted cash flow (DCF) analysis for an NSR permit application with thermal deNOx controls to assess project feasibility.
01/27/1989 Review of Craven County Wood Energy Project OAQPS Basala, Allen Evaluates economic viability of a pollution control involving non-catalytic ammonia reduction of NOx.
04/23/1987 Appropriateness of Certain Economic Arguments in BACT Analysis OAQPS McCutchen, Gary Considers the appropriateness of certain technical and economic arguments over the use of acid gas controls in a BACT analysis for a municipal waste combustor.

Related Topics: Best Available Control Technology (BACT) ProcedureBest Available Control Technology (BACT) Applicability

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The “Relevant Guidance” index includes a collection of documents issued by EPA organized by topic area. These documents include memoranda, letters, orders, and other types of EPA actions that may provide guidance in one or more forms, such as an adjudication, statement of policy, interpretation of statutes or regulations, or technical information. Each collection is intended to be representative of EPA statements on the topic, but it may not be a complete listing of such statements. The collection does not reflect topic-specific statements that have been expressed by EPA though published rule preambles and Title V petition orders, nor does it include EAB decisions. Each document in the collection speaks for itself, and the inclusion or exclusion of a document in the collection is not intended by EPA to communicate anything more than what is expressed within each document. EPA makes no independent representations on this website as to the extent to which any document in the collection reflects EPA’s current views on the topic, is a final action by EPA, or has any legal effect or precedential weight. Readers are advised to review the documents in the collection and conduct their own assessment of such considerations based on the content of each document and other documents in the collection. Some of the information or views included in the documents may be affected by subsequent changes to the referenced statutory or regulatory language or by court decisions. In addition, many of the statements in these documents are based upon the federal regulations which may differ from rules that govern federally-approved programs. Permitting authorities are advised to consult with their EPA Regional Offices if there is a question as to the relevance of a particular statement to their NSR program.