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OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

11) IV-B-11 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:46 AM Sheet 11 of 273 
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/W-S2-

H/-&-II 

TO: 

FROM: 

DATE: 

SUBJECT: 

MEMORANDUM 

Keith Barnett 

U.S. Environmental Protection Agency 

Kenneth R. Meardon and Frank Meadows 

Pacific Environmental Services, Inc. 

FEB 2 T ?uH3 

EPA AIR DOCKET 

August 8, 2002 

Comments on Haberlein's "Comparison of Massillon and Proform" 

Per our conversation the other day, the purpose ofthis memo is to summarize the points 

we discussed on Rob Haberlein's July 26, 2002, paper entitled "Comparison ofthe Characteristics 

ofthe A.R.E. Massillon Plant and the Proform LLC West Memphis Plant that affect Capture of 

Emissions." 

1. The paper miscalculates the area ofthe building enclosure that would be used to 

demonstrate that natural draft openings are less than 5%. The paper uses just the floor 

dimensions, when the requirement is based on the sum ofthe floor, ceiling, and four walls ofthe 

enclosure. Correcting this calculation, the total surface area for the barge covers enclosure is 

93,968 square feet. The open area for barge covers is 1,376 square feet, which is 1.5% ofthe 

total square footage ofthe building enclosure. 

2. The paper appears to mis-represent the Method 204 criteria for demonstrating pressure 

differentials inside and outside the enclosure, implying that wind velocity affects the ability to 

meet this criteria. Pressure differential refers to the difference in atmospheric pressure inside and 

outside the enclosure. When measuring the pressures, one is supposed to shield the device to 

protect the sensors from the influence from outside wind and turbulent air that may be caused by 

fans, equipment, or machinery. This is usually done with some type of "snubber" device. 

Regardless, the outside pressure reading is independent of wind; that is, you can have the same 

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pressure reading with no wind and with a strong wind. We agree with the "wind tunnel" effect 

created when simultaneously opening windward and leeward doors. Double sets of doors are 

often used on buildings to prevent this. What may happen, however, is that the actual 

effectiveness ofthe enclosure may be less on windy days versus non-windy days. But, this does 

not affect the ability ofthe enclosure to show compliance with the Method 204 criterium. Ifthe 

criterium is met, the enclosure is still assigned 100% capture. Whether it actually achieves 100% 

or not is not necessarily the critical point for new sources, but whether or not an inspector can 

objectively evaluate the enclosure against the Method 204 criterium. 

3. The paper's strongest point was its ability to lay out differences in the processes 

between Massillon and Proform and then ask whether or not Massillon should be considered 

"similar" to Proform in order to set the floor. 

4. The differences cited in the paper, however, do not address the issue of whether or not 

a new Proform-like facility could be able to build an enclosure that met the Method 204 criteria. 

We discussed briefly the innovative things others have done (e.g., the ship building example) to 

construct compliant Method 204 enclosures and felt that this industry could be equally innovative 

(without a whole lot of effort). 

5. We discussed whether or not we have observed enclosure for parts as large as barge 

covers. We indicated that we had not. We discussed options that facilities could use to overcome 

some ofthe size issues cited in the paper. 

6. We discussed what a new facility would do to address a total enclosure requirement 

when building a new facility - it would first design air flows to meet worker exposure 

requirements, then design walls around the process to meet the Method 204 criteria, and that the 

Method 204 design should not affect the air flow required to meet worker exposure.