February 28, 2005

Mr. Steve Page

C404-04

Mr. Dan Deroeck

C339-03

USEPA Mailroom

Research Triangle Park, NC  27711

Subject:  	Analysis of Best Available Control Technology for a

		Non-Specific Coal-Fired Power Project

Gentlemen:

I have recently been asked by a few clients whether an analysis of Best
Available Control Technology (BACT) for a proposed coal-fired power
plant (Anywhere, USA) must include evaluation of coal-fueled processes
which are considered inherently lower-emitting processes such as
Integrated Gasification Combined Cycle (IGCC).  My research indicates
that perhaps a couple of states may require such analysis, a couple of
states do not require such analysis, and most states have not indicated
a position at this time.  I would like to know what the federal position
is on this issue.

As you probably know, the state-of-the-art “conventional” coal-fired
power plant today is the supercritical pulverized coal (SCPC) unit.  The
SCPC unit has a very high efficiency, and fairly low emissions of all
regulated pollutants by incorporating a combination of combustion and
post-combustion controls.  Similarly, an IGCC plant has a very high
efficiency, and fairly low emissions of all regulated pollutants. 
However, operation of an IGCC plant is fundamentally different than an
SCPC unit in many respects.  Many individuals compare an IGCC plant to a
chemical processing plant, and pollution control is accomplished by
reducing pollution at its source rather than post-combustion control
(such as scrubbers, baghouses).

I have taken some time to research available USEPA policy and guidance
documents on the subject of BACT in this context.  In December 1978, Mr.
David Hawkins issued “Guidelines for Determining Best Available
Control Technology (BACT)” to the Regional Administrators.  Mr.
Hawkins states on page 3 of the Guidelines: “The primary purpose of
BACT is to optimize consumption of PSD air quality increments thereby
enlarging the potential for future economic growth without significantly
degrading air quality.”  He further states on page 5 that
“technology selection should consider … processes or techniques
which are inherently low-polluting.”

This statement is echoed in the Draft New Source Review Workshop Manual
(October 1990) on page B.5:  “in some circumstances inherently
lower-polluting processes are appropriate for consideration as available
control alternatives.”  However, this is clarified on page B.13:

“Historically, EPA has not considered the BACT requirement as a means
to redefine the design of the source when considering available control
alternatives.  For example, applicants proposing to construct a
coal-fired electric generator, have not been required by EPA as part of
a BACT analysis to consider building a natural gas-fired electric
turbine although the turbine may be inherently less polluting per unit
product (in this case electricity).  However, this is an aspect of the
PSD permitting process in which states have the discretion to engage in
a broader analysis if they so desire.”

The Montana Top-Down Best Available Control Technology (BACT) Analysis
Process and Procedures Manual (2004 Edition) describes two options for
considering inherently lower polluting processes and practices (refer to
page 7).  The first option is that the Montana Department of
Environmental Quality (MDEQ) will not consider the BACT requirement a
means to redefine the design of the source when considering available
control alternatives.  The second option is that MDEQ will use the BACT
requirement as a means to redefine the design of the source.  In such
cases, MDEQ indicates that redefining the project using an alternative
production process is limited to analyzing an applicant’s proposed set
of raw materials or fuels resulting in a given end product.  The Manual
states:

“For example, under an applicant’s proposal for a coal-fired
electrical power generating plant, the Department considers any process
beginning with coal as a fuel and ending with the production of
electricity to be appropriate for consideration under the top-down BACT
analysis process.  This analysis would include IGCC, CFB, pulverized
coal-fired boiler, etc., but would not include electrical power
generation using solar power, wind, natural gas, etc.”

Would you please provide guidance related to this issue?  Specifically,
would the USEPA require a BACT analysis for a coal-fired power
generating station to include IGCC, CFB, and other potentially
lower-emitting processes?  Or would USEPA not include this requirement,
but rather leave it up to individual states to determine whether it is
appropriate to consider such alternatives to a project’s design?

If you wish to discuss this issue, please do not hesitate to call me
directly at 303.762.7070.

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E3 Consulting

/s/

D. Edward Settle

Director, Renewable Energy

Messrs. Page and Deroeck 					E3 Consulting

US Environmental Protection Agency

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