# Reasonably Available Control Technology (RACT) Process Moderate Area Ozone SIP

## RACT Overview

Under the Clean Air Act, all areas designated Moderate nonattainment for the 2015 8-hour ozone standard are required to implement RACT for all existing major sources of VOCs or NOx (100 tons per year of either pollutant) as well as all VOC sources subject to an EPA Control Technique Guideline (CTG). A RACT analysis requires implementation of the lowest emission limitation that an emission source is capable of meeting by the application of a control technology that is reasonably available, considering technological and economic feasibility. A RACT analysis must include the latest information when evaluating control technologies. Control technologies evaluated for a RACT analysis can range from work practices to add-on controls. As part of the RACT analysis, current control technologies already in use for VOCs or NOx sources can be taken into consideration. To conduct a RACT analysis, a top-down analysis is used to rank all control technologies.

## Top-Down RACT Analysis Steps

Step 1. Identify All Reasonably Available Control Technologies
Step 2. Eliminate Technically Infeasible Control Technologies
Step 3. Rank Remaining Control Technologies Based on Capture and Control Efficiencies
Step 4. Evaluate Remaining Control Technologies on Economic, Energy, and Environmental Feasibility
Step 5. Select RACT

All available and prevalent control technologies must be included in a RACT analysis for all VOC and NOx sources, with a thorough description and discussion of technological feasibility.

## RACT Economic Feasibility

To determine the economic feasibility of a control technology in Step 4 of the top-down RACT analysis, the following can be included:

• The capital cost of each control technology, including the cost of device or equipment and materials. Vendor bid documentation should be included.
• One-time costs including delivery, engineering, labor, installation, and startup costs.
• Annual operation and maintenance costs, including equipment replacement and monitoring costs.
• Interest rates used should be the current bank prime rate. The date of the bank prime rate used in the RACT analysis should be documented. If appropriate, an alternative rate may be used and documented.

A total annualized cost should be calculated to determine a $/ton cost for each control technology based on the above costs, using the following equations: ### {Equation 1} $$A = {B+C \over D}$$ Where: • A = Annualized cost expressed in$⁄(ton of pollutant removed)
• B = Annualized control technology cost in \$⁄yr {Equation 2 below}
• C = Annual operating, maintenance, and indirect costs
• D = Emission reduction from installation and operation of control technology in tons⁄yr

### {Equation 2}

$$B = PV \left\{ {i \over 1-(1+i)^{-n}} \right\}$$

Where:

• PV = Present day value of the control technology or cost of the control
technology today
• i = Interest rate at which the source can borrow money
(example 7% entered into equation as 0.07)
• n = number of years of the life of the equipment

For more help in evaluating economic feasibility for a RACT analysis, the EPA provides an Air Pollution Control Cost Manual that can be referenced.

## UDAQ RACT Submittal Requirements

The DAQ is requesting RACT analyses submittals from certain affected major sources located in or impacting the Uinta Basin ozone nonattainment area or affected major sources impacting the Wasatch Front. RACT analyses will be due to the DAQ by March 31, 2021. At this time, the DAQ is not requesting a RACT analysis from sources located in the Wasatch Front ozone nonattainment area that were evaluated as part of the PM2.5 Serious SIP, which required Best Available Control Technology (BACT) analyses for NOx and VOCs. Operators will receive a letter from the DAQ describing the applicable RACT requirements for their facilities.

## UDAQ Ozone RACT/RACM Email Alerts

Join the DAQ ozone RACT/RACM email list and stay up to date with all information pertaining to Utah’s ozone RACT/RACM process. Relevant information for affected sources, operators, and consultants will be periodically emailed out. Sign up for email alerts here: