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RE: P2 and BACT

Title: Helicopter Wash and Engine Flush



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 examples follow--


  • 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 with CO2.


  • 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.




Rodney Sobin
Office of Small Business Assistance
Virginia Department of Environmental Quality
Postal: P.O. Box 10009, Richmond, VA 23240-0009
Street:  629 E. Main St., Richmond, VA 23219-2429
Tel. 804-698-4382       fax 804-698-4264 

Environmental Assistance for Small Businesses http://www.deq.virginia.gov/osba/smallbiz.html

Virginia Comprehensive Assistance Network http://www.deq.state.va.us/osba/vacan/

DEQ Innovative Technology http://www.deq.virginia.gov/innovtech

DEQ Distributed Energy Resources http://www.deq.virginia.gov/innovtech/der1.html
Virginia Environmental Services Network http://www.vesn.biz

-----Original Message-----
owner-p2tech@great-lakes.net [mailto:owner-p2tech@great-lakes.net] On Behalf Of TELIHA, KAREN
Sent: Thursday, November 17, 2005 3:49 PM
To: P2Tech
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 accordingly?


I’m specifically interested in BACT for the following sectors:

Foundry Core Operations

Lithographic Printers

Soybean Oil Extraction

Ethanol Production


Or, interested in any P2 BACT that addresses reductions in criteria pollutants and was accepted over control.

Karen Teliha
Pollution Prevention Branch
Indiana Dept. of Environmental Management
Please complete our customer satisfaction survey at www.in.gov/idem/oppta/survey.html.