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: email@example.com [mailto:firstname.lastname@example.org] 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
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