I passed your question on P2 as BACT to
some of our folks. The initial response was “no” but on
digging further I found a number of cases of P2 conditions in our Title V (major
source) air permits. In some of these cases, P2 approaches may apply to some
emissions units while others may be subject to end-of-pipe control. I
think sometimes P2 is being integrated into permitting without people thinking
about it explicitly. Still there’s scope for much much more. Some
- While many printers do have
stack controls, some are controlled solely by VOC limits in inks and
solvents, enclosure, and covering of containers.
- Low VOC, water-based materials,
and “reasonable precautions” for pressure sensitive label
manufacture; low VOC inks, lubes, cleaners, glues for labels, markings.
- Floating roofs and vapor
recovery units for petroleum tanks and distribution.
- Low S fuels, low NOx burners,
exhaust gas recirculation for boilers.
- Low S fuels and combustion
controls for engines.
- Chilled air blankets, freeboard
ratio requirements, reduced room draft, closed containers, allowing item
to drain before removing, etc. for vapor degreasing.
- Brewing and bottling: Spill
minimization, “defill” recovery, and control of VOC from a
“conditioning” unit through vessel closure and keeping under pressure
- Polystyrene board manufacture
limits on VOC in materials and throughput limits.
- Brine-cooled condensers to
recover VOC in LYCRA® manufacture (plenty of end-of-pipe
controls too in plant)
- Refrigeration/condensation and
distillation of perc in dry cleaning (there’s a dry cleaner with a
Title V in Northern VA).
There are probably more cases in our minor
source permits where VOC and HAP limits in materials and P2-related good
housekeeping practices are required.
I hope this is useful.
From: firstname.lastname@example.org [mailto:email@example.com] On Behalf Of TELIHA, KAREN
Sent: Thursday, November 17, 2005
Subject: P2 and BACT
Does anyone have examples
of cases where your state has selected a P2 technology as BACT over a control
technology? Or more specifically, has anyone seen where a state
recognizes the other impacts of control (NOx emissions, etc) and adjusts BACT
interested in BACT for the following sectors:
Foundry Core Operations
Soybean Oil Extraction
Or, interested in any P2
BACT that addresses reductions in criteria pollutants and was accepted over
Pollution Prevention Branch
Indiana Dept. of Environmental Management
Please complete our customer satisfaction survey