| Best Available Technology/
Techniques (BACT/BAT) | Regulators across the world frequently require operators to use Best Available Technology/Techniques when addressing their pollution issues.
ERM’s professionals have conducted technology assessments for the range of emissions types.
BACT Review of two oil refineries
ERM was asked by attorneys to review and critique BACT analyses for two refineries owned by one of their major oil company clients. ERM’s critique of the BACT analyses resulted in ERM being awarded a contract to re-assess the BACT decisions previously made, and to re-write the BACT reports for both refineries. In each case, the subject refinery was under a state and/or EPA enforcement action. As a result, the client requested that ERM perform the BACT analysis to a higher standard and level of detail than is normally required by the state or federal agency.
PSD triggering events had taken place at both refineries over the last twenty years. Thus, ERM assessed the BACT for FCCU regenerators, CO boilers, crude unit process heaters, catalyst hoppers, and fugitive emissions. ERM also identified potential control technologies, assessed the feasibility of them, and estimated the costs and cost-effectiveness for each feasible technology. ERM then recommended control technologies for each of the affected process units and incorporated them into a BACT analysis report that was submitted to the state agency of each refinery.
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