7-15 Air

7-15     BACT/LAER Selection

            EFSB Application, Appendix B, Major Source Permit Application, Section 4.1, Page 23 states that “A BACT Determination is a top-down process in which all available control technologies for that pollutant and emission source are identified.  Each control technology is then evaluated for its technical feasibility and those demonstrated to be technically infeasible are eliminated from consideration.  The remaining control technologies are then ranked in descending order of control effectiveness.  The most effective remaining control technology is deemed to be BACT unless it is demonstrated that technical considerations, or the associated energy, environmental, or economic impacts justify a conclusion that the control technology is not available for the source.”  Subsequent text within the application document indicates that “Appendix B contains a listing of the recent BACT determinations considered for this analysis.”  While Appendix B-BACT/LAER Documentation of the Major Source Permit Application does contain a summary table of emission rates and/or emission factors, no documentation of the full and complete “top-down” process, such as the ranking of control technologies “in descending order of control effectiveness” is provided in Appendix B.  Please provide.