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Re: BACT for IPA/phenol/formaldehyde vapor

I used to work for 3M Company that used to use a lot of phenolic - formaldehyde resins for sandpaper and similar products. I believe they had used a thermal oxidizer to destroy resins, etc. In this case, I think the thermal oxidizer used a high amount of natural gas to maintain the required combustion temperature. They were also experimenting with scrubbing the exhaust stream about 5 years ago. You could try contacting Paul Severson (651) 778-6278 or (651) 733-1110 (if the first number doesn't work). If he is not the most familiar now, he could tell you who is. They may or may not be forthcoming depending on how proprietary they feel the technology is.

BACT is a regulatory definition and is usually industry/process specific. Someone at the EPA group in Research Triangle Park should know if this exists. I'd start with the Clean Air Tecnology Center [(919) 541-0800 ] unless someone has a better idea.

I think you would need an air permit for such a source unless it is very small. The on-site treatment permit generally refers to treating hazardous waste, which you could have if you scrubbed or condensed the air contaminants. In most states, if the material was recycled back to the process (all in tanks and pipes) it would never become hazardous waste.

As far as condensing and reuse, this is often much more difficult than it appears on the surface. First, you have to get the air stream very cold to condense effectively and this uses a lot of energy. Second, there are always small concentrations of resin materials in the stream that can foul heat exchange surfaces as well as contaminate the recovered solvent.

So, the best thing to do is P2. 3M was switching over to hot melt resins for many of their products. I don't know how much of that is proprietary to 3M but I would guess there is potential for hot melt or other low/non solvent resins for this application. A "Google" search for "hot melt resins" yielded 3,650 results. 

Good Luck!

Kirk Mills
Pollution Prevention Program
Colorado Department of Public Health 
     and Environment
4300 Cherry Creek Drive So.
Denver, Co  80246-1530
Ph: (303) 692-2977
Fax: (303) 782-4969
Email: kirk.mills@state.co.us