Carbon Management Technology Conference,
7-9 February 2012,
Orlando, Florida, USA
The electric power generation industry is under an ever changing, ever
increasing, ever tightening regulatory climate that requires consideration of
Best Available Control Technologies (BACT) for any new or modified Prevention
of Significant Deterioration (PSD) and Title V requirements.
In principle, carbon capture and storage (CCS) could provide reduction of
greenhouse gases and therefore should be considered. However, since CCS is
neither a proven commercial technology nor is it mandated (as of yet), it seems
that requiring consideration now is confusing at best.
EPA guidance states that permit applicants and permitting authorities should
consider all “available” GHG control options that have the potential for
practical application to the source under consideration. The guidance further
suggests that once permitting authorities gain experience with GHG BACT
determinations, useful information on GHG permitting decisions will be
The expression of regulatory decisions and permitting based on “future tense”
terms makes planning, operational, and strategic decisions very difficult for
the electric generation sector. This paper will endeavor to discuss and
navigate specific details in the PSD requirements for power generation as they
apply to carbon capture and storage.
Under revisions to the Clean Air Act, beginning on January 2, 20101, any
emission source that is required to obtain or modify a prevention of
significant deterioration (PSD) or Title V permit must now consider greenhouse
gases (GHGs) as an emission source. New major stationary sources or
modifications under the Clean Air Act, new source review (NSR) and national
ambient air quality standards (NAAQS) respectively, must obtain a permit under
the PSD provisions. This means that power plants must now consider carbon
dioxide (CO2) emissions as part of the permitting, construction, modification,
and operations of the facility.
The process to determine what technologies are most applicable under PSD for a
facility is known as best available control technology, or BACT, analysis.