Utah’s Division of Air Quality examines and requires the implementation of appropriate controls at major point sources of pollution to reduce ozone forming emissions of NOx and VOCs using a Reasonable Available Control Technologies (RACT) approach, as required by the Clean Air Act. This page provides an overview of how this process works.
RACT Overview
Under the Clean Air Act, all areas designated as a moderate or higher nonattainment area for the 2015 8-hour ozone standard are required to implement Reasonably Available Control Technologies for all existing major sources of NOxor VOCs as well as all VOC sources subject to an EPA Control Technique Guideline (CTG). For ozone nonattainment areas, the ton per year (tpy) threshold of NOx and/or VOCsfor this requirement decreases with each subsequent redesignation, with the moderate threshold at 100 tpy, serious at 50 tpy, severe at 25 tpy, and extreme and beyond at 10 tpy.
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 NOx or VOC sources can be taken into consideration. To conduct a RACT analysis, a top-down analysis is used to rank all control technologies. Control measures to reduce emissions from area sources are addressed through a similar, but independent approach, known as Reasonable Available Control Measures (RACM).
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.
- Indirect and other costs, including overhead, administration, taxes, insurance, etc.
- 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.
RACT Submittal Requirements
We are reviewing RACT analyses submittals from certain affected major sources located in ozone nonattainment areas. RACT analyses were due January 2, 2024. We will send operators a letter if any RACT were identified as meeting current RACT requirements.