BEST AVAILABLE CONTROL TECHNOLOGY
You may assume that BAT refers only to specifying the use of
specific control equipment or methods of operation. However, in many
cases the Agency permit writer will cite the BAT requirement as a
basis for establishing short and long-term emission limits.
All permit applications require the applicant to submit detailed
emission calculations. The permit writer can use these calculated
emissions as BAT and establish a permit emission limit more
stringent than contained in the applicable regulation or create an
emission limit where no regulatory emission limit exists. Emission
limits based on a BAT determination may adversely impact operational
flexibility and future business growth.
The permit writer may also use operational restrictions contained in
an applicable regulation to establish an hourly and annual emission
limit, even though no emission limit is stipulated in the
regulation. This is typically done with coating operations and may
result in an unreasonable potential to emit which exceeds the major
source threshold. To remain below the major source status a facility
may be forced to accept needless operational restrictions.
The above examples are just two ways in which a BAT determination
can negatively affect your permit terms. It's imperative that permit
terms are properly crafted using a sensible interpretation of BAT to
maintain your facility's operational flexibility. CTI can assist you
in preparing and negotiating the most favorable permit terms
compliant with OEPA air regulations.
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