Green House Gas (GHG) Best Available Control Technology (BACT) Options for Fired Heaters

The US EPA has determined, and the courts have affirmed, that Green House Gases (GHG) are a hazard to human health, and therefore are subject to regulation under the Clean Air Act. As a result, various regulations have been proposed and/or promulgated by EPA. These regulations and interpretations include the “Tailoring Rule”, BACT Guidance for GHG, and New Source Performance Standards (NSPS). Under these standards, EPA has determined that all available control options must be considered. The three potential strategies for carbon reduction include energy intensity reduction, carbon intensity reduction, and carbon capture and sequestration.

This presentation will provide a case study example of a fired heater that demonstrates how the “Top Down” BACT analysis could be used to select a GHG control technology for air permitting purposes. For this case study all three potential strategies will be considered which are energy efficiency options, fuel switching options, and utilization of carbon capture and sequestration. For all three options an estimated capital cost will be determined. The results will demonstrate the significant difference in capital cost between energy efficiency and carbon capture and sequestration in a BACT analysis for reducing GHG emissions.