P.1 

OAR Box 1500 

Prepped by Ollie Stewart 

Document Number: 

55) ll-C-81 

Docket Number: 

A-94-52 

Printed 8/5/2008 1:51:29 PM Sheet 55 of 343 
P.2 

November 20, 1997 

ll-C-6 1 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Emission Standards Division 

Coatings and Consumer Products Gro^ip 

Research Triangle Park, NC 27711 

FACSIMILE COVER SHEET 

Please Print in Black Ink Only 

TO 

Mark Naylor 

OFFICE 

Aker Plastics 

FROM 

Madeleine Strum 

TELEPHONE # 

304 263 2525 

FAX PHONE # 

304 263 8369 

TELEPHONE # 

919 541 2383 FAX 5689 

SUBJECT Test Method for verification of a total enclosure 

COMMENTS 

While the series of various capture efficiency methods is about 40 pages, the verification of the 

Permanent Total Enclosure (PTE) is just 1 page. A PTE verified by this method would allow the 

facility to claim 100% capture. Otherwise, the one or more of the other methods would need to 

be used to measure the capture efficiency. These involve at least the construction of a temporary 

total enclosure and the measurement of VOC concentrations at one or more exhausts to the 

enclosure. 

Do you think you could run through the criteria and send me a fax as to whether or not the 

emissions from your resin operations (spray, roll, cure) could be considered captured to 100% 

based on the criteria of Method 204? Could you make any presumptions about the gel coat 

operations (spray, cure)? I could use the information from the permit to document the control 

device efficiency of 90%. . 

Thank you, 

Madeleine 7iW*i^ 'WL^ rfrC^ 

t)K 
32502 Federal Register / Vol. 62. No. 115 / Monday, June 16. 1997 / Rules and Regulations 

P.3 

if 

/-

information to the U.S. Senate, the U.S. 

House of Representatives and the 

Comptroller General of the General 

Accounting Office prior to publication 

of the rule in today's Federal Register. 

This rule is not a "major rule" as 

defined by 5 U.S.C. 804(2). 

List of Subjects in 40 CFR Part 51 

Environmental protection, 

Administrative practice and procedure 

Air pollution control. Capture 

efficiency, Carbon monoxide, 

Intergovernmental relations, Lead, pt 

Nitrogen dioxide, Ozone, Particulate 

matter. Printing operations. Reporting 

and recordkeeping requirements, 

Surface coating operations, Sulfur 

oxides, Volatile organic compounds. 

Dated: May 30, 1997. 

Carol M. Browner, 

Administrator. 

For die reasons set out in the 

preamble, Appendix M of 40 CFR Part 

51 is amended as follows: 

1. The authority citation for part 51 

continues to read as follows: 

Authority: 42 U.S.C. 7410. 

2. Appendix M, Table of Contents is 

amended by adding seven entries to 

read as follows: 

Appendix M to Part 51—Recommended 

Test Methods for State Implementation 

Plans 

**** * 

Method 204—Criteria for and Verification 

of a Permanent or Temporary Total 

Enclosure. 

Method 204A—Volatile Organic 

Compounds Content in Liquid Input Stream. 

Method 204B—Volatile Organic 

Compounds Emissions in Captured Stream. 

Method 204C—Volatile Organic 

Compounds Emissions in Captured Stream 

(Dilution Technique). 

Method 204D—Volatile Organic 

Compounds Emissions in Uncaptured Stream 

from Temporary Total Enclosure. 

Method 204E—Volatile Organic 

Compounds Emissions in Uncaptured Stream 

from Building Enclosure. 

Method 204F—Volatile Organic 

Compounds Content in Liquid Input Stream 

(Distillation Approach). 

1

 * * * * * 

j 3. By adding Method 204 to read 

v / follows: 

as 

Method 204—Criteria for and 

Verification of a Permanent or 

Temporary Total Enclosure 

1. Scope and Application 

This procedure is used to determine 

whether a permanent or temporary 

enclosure meets the criteria for a total 

enclosure. An existing building may be 

used as a temporary or permanent 

enclosure as long as it meets the 

appropriate criteria described in diis 

method. 

2. Summary of Method 

An enclosure is evaluated against a 

set of criteria. If die criteria are met and 

if all the exhaust gases from die 

enclosure are ducted to a control device, 

tiien the volatile organic compounds 

(VOC) capture efficiency (CE) is 

assumed to be 100 percent, and CE need 

not be measured. However, if part of the 

exhaust gas stream is not ducted to a 

control device, CE must be determined. 

3. Definitions 

3.1 Natural Draft Opening (NDO). 

Any permanent opening in the 

enclosure diat remains open during 

operation ofthe facility and is not 

connected to a duct in which a fan is 

installed. 

3 ?. Pfrmarrpnr Total Enclosure (PE). 

A permanently instated enclosure that 

completely surrounds a source of 

emissions such Uiat all VOC emissions 

are captured and contained for 

discharge to a control devic^T 

~3T3 Temporary Total Enclosure 

(TTE). A temporarily installed enclosure 

diat completely surrounds a source of 

emissions such diat all VOC emissions 

diat are not directed dirough the control 

device (i.e. uncaptured) are captured by 

die enclosure and contained for 

discharge dirough ducts that allow for 

die accurate measurement of die 

uncaptured VOC emissions. 

3.4 Building Enclosure (BE). An 

existing building diat is used as a TTE. 

4. Safety 

An evaluation of the proposed 

building materials and the design for die 

enclosure is recommended to minimize 

any potential hazards. 

5. Criteria for Temporary Total 

Enclosure 

5.1 Any NDO shall be at least four 

equivalent opening diameters from each 

VOC emitting point unless otiierwise 

specified by the Administrator. 

5.2 Any exhaust point from the 

enclosure shall be at least four 

equivalent duct or hood diameters from 

each NDO. 

5.3 The total area of all NDO's shall 

not exceed 5 percent of die surface area 

of die enclosure's four walls, floor, and 

ceiling. 

5.4 The average facial velocity (FV) 

of air dirough all NDO's shall be at least 

3,600 m/hr (200 fpm). The direction of 

air flow through all NDO's shall be into 

die enclosure. 

5.5 All access doors and windows 

whose areas are not included in section 

5.3 and are not included in the 

calculation in section 5.4 shall be closed 

during routine operation of die process. 

6. Criteria for a Permanent Total 

Enclosure 

6.1 Same as sections 5.1 and 5.3 

dirough 5.5. 

6.2 All VOC emissions must be 

captured and contained for discharge 

dirough a control device. 

it 

7. Quality ( 

7.1 The success of diis mediod lies 

in designing die TTE to simulate die 

conditions diat exist widiout die TTE 

(i.e., the effect ofthe TTE on die normal 

flow patterns around the affected 

facility or die amount of uncaptured 

VOC emissions should be minimal). The 

TTE must enclose the application 

stations, coating reservoirs, and all areas 

from die application station to the oven. 

The oven does not have to be enclosed 

if it is under negative pressure. The 

NDO's of the temporary enclosure and 

an exhaust fan must be properly sized 

and placed. 

7.2 Estimate the ventilation rate of 

die TTE diat best simulates the 

conditions diat exist widiout die TTE 

(i.e., the effect of the TTE on die normal 

flow patterns around die affected 

facility or die amount of uncaptured 

VOC emissions should be minimal). 

Figure 204-1 or die following equation 

may be used as an aid. 

CE = -

QG^- CC G Eq. 204-1 

QGCG +QFC F 

Measure the concentration (Co) and 

flow rate (Qo) of die captured gas 

stream, specify a safe concentration (CF) 

for the uncaptured gas stream, estimate 

die CE, and dien use die plot in Figure 

204-1 or Equation 204-1 to determine 

die volumetric flow rate of the 

uncaptured gas stream (QF). An exhaust 

fan that has a variable flow control is 

desirable. 

7.3 Monitor die VOC concentration 

of die captured gas steam in die duct 

before die capture device widiout die 

TTE. To minimize die effect of temporal 

variation on the captured emissions, die 

baseline measurement should be made 

over as long a time period as practical. 

However, die process conditions must 

be die same for the measurement in 

section 7.5 as they are for diis baseline 

measurement. This may require short 

measuring times for diis quality control 

check before and after die construction 

of the TTE. 

7.4 After die TTE is constructed, 

monitor die VOC concentration inside 

die TTE. This concentration should not 

continue to increase, and must not 

exceed the safe level according to 

^ 
P.4 

Federal Register / Vol. 62, No. 115 / Monday, June 16, 1997 / Rules and Regulations 32503 

Occupational Safety and Healdi 

Administration requirements for 

permissible exposure limits. An 

increase in VOC concentration indicates 

poor TTE design. 

7.5 Monitor die VOC concentration 

of die captured gas stream in the duct 

before die capture device widi the TTE. 

To limit die effect of die TTE on the 

process, die VOC concentration with 

and widiout the TTE must be within 10 

percent. If the measurements do not 

agree, adjust die ventilation rate from 

die TTE until they agree widiin 10 

percent. 

8. Procedure 

8.1 Determine the equivalent 

diameters of die NDO's and determine 

die distances from each VOC emitting 

point to all NDO's. Determine the 

equivalent diameter of each exhaust 

duct or hood and its distance to all 

NDO's. Calculate die distances in terms 

of equivalent diameters. The number of 

equivalent diameters shall be at least 

four. 

8.2 Measure the total surface area 

(AT) of the enclosure and the total area 

(AN) of all NDO's in die enclosure. 

Calculate die NDO to enclosure area 

ratio (NEAR) as follows: 

NEAR = -^ - Eq. 204-2 

AT 

The NEAR must be S10.05. 

8.3 Measure die volumetric flow 

rate, corrected to standard conditions, of 

each gas stream exiting die enclosure 

dirough an exhaust duct or hood using 

EPA Mediod 2. In some cases (e.g., 

when the building is die enclosure), it 

may be necessary to measure die 

volumetric flow rate, corrected to 

standard conditions, of each gas stream 

entering die enclosure through a forced 

makeup air duct using Method 2. 

Calculate FV using die following 

equation: 

FV = 

Qo"-Qi Eq. 204-3 

where: 

Qo = die sum of die volumetric flow 

from all gas streams exiting the 

enclosure dirough an exhaust duct 

or hood. 

Qi = die sum of the volumetric flow 

from all gas streams into the 

enclosure dirough a forced makeup 

air duct; zero, if diere is no forced 

makeup air into die enclosure. 

AN = total area of all NDO's in 

enclosure. 

The FV shall be at least 3,600 m/hr 

(200 fpm). Alternatively, measure die 

pressure differential across the 

enclosure. A pressure drop of 0.013 mm 

Hg (0.007 in. H20) corresponds to an FV 

of 3.600 m/hr (200 fpm). 

8.4 Verify that the direction of air 

flow through all NDO's is inward. If FV 

is less than 9.000 m/hr (500 fpm). the 

continuous inward flow of air shall be 

verified using streamers, smoke tubes, 

or tracer gases. Monitor die direction of 

air flow for at least 1 hour, widi checks 

made no more tiian 10 minutes apart. If 

FV is greater than 9.000 m/hr (500 fpm), 

die direction of air flow dirough die 

NDOs shall be presumed to be inward 

at all times widiout verification. 

9. Diagrams 

BILLING CODE 6S60-SO-P 
32504 Federal Register / Vol. 62, No. 115 / Monday, June 16, 1997 / Rules and Regulations 

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m.3 

BILLING CODE 6560-50-C 

4