United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Parit NC 27711
EPA-450/3-91 -005
November 1990
¦©EPA Cost and Feasibility of the
Temporary Total Enclosure
Method for Determining
Capture Efficiency
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EPA-450/3-91 -004
Cost and Feasibility of the
Temporary Total Enclosure
Method for Determining
Capture Efficiency
Final Report
Novemoer 1990
Prepared for
Karen Catlett
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Prepared by
Stephen Edgerton
Midwest Research Institute
Cary, NC 27513
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DISCLAIMER
This report has been reviewed by the Emission Standards Division,
Office of Air Quality Planning and Standards, Office of Air and
Radiation, U.S. Environmental Protection Agency (EPA), and approved
for publication. It is issued by EPA to report information of interest to
a limited number of readers. Copies are available free of charge to
Federal employees, current contractors and grantees, and non-profit
organizations - as supplies permit - from the Library Services Office
'"MD-351 "7.3. Environmental Protection Agency, Research Triangle
Pars, JC 27711, or may be obtained, for a fee, from the National
Technical Information Service, 5285 Port Royal Road, Springfield, VA
22161.
This report was furnished to EPA by Midwest Research Institute, Cary,
>TC 27513. in fulfillment of assignments under EPA Contract 6S-02-
41573. The concents are reproduced 'lerein as received irom c;ie
Contractor. The opinions, findings, and conclusions expressed are those
of the authors and not necessarily those of EPA. Mention of company
or product names does not constitute endorsement by EPA.
Publication No. EPA-450/3-91-004
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COST AND FEASIBILITY OF THE TEMPORARY TOTAL ENCLOSURE
METHOD FOR DETERMINING CAPTURE EFFICIENCY
Final Report
£?A vjntrac: .'o. 68-02—1379
Work Assignment 26
ESQ Project No. 87/07
MRI Project No. 8952-26
September 5, 1990
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TABLE OF CONTENTS
Page
SECTION 1.0 INTRODUCTION 1
1.1 BACKGROUND 1
1.2 OBJECTIVES OF PHASE 1 2
1.3 ORGANIZATION OF THIS REPORT 2
SECTION 2.0 SUMMARY OF COST AND FEASIBILITY ANALYSES 2
2.1 AMERICAN NATIONAL CAN COMPANY 7
2.2 WESTVACO CORPORATION 8
2.3 KENYON INDUSTRIES 9
2.4 ATLANTA FILM CONVERTING COMPANY AND
PRINTPACK, INC 11
SECTION 3.3 3I2CJSSICN.. -2
3.1 ISSUES 12
3.1.1 Drying Ovens Required to Meet the TTE
Criteria 12
3.1.2 Choice of Emission Test Method 15
*.1.3 Direct-"Jrsd Irving Ovens 15
3.1.4 TTE Criteria 3overning distances From
NOO's to VOC Sources and Exhausts 16
3.1.5 Sizing of Fugitive Exhausts 17
3.2 SPECIFIC PROBLEMS ASSOCIATED WITH THE
FACILITIES VISITED 18
3.2.1 Recycle Streams with Solvent
Destruction 18
3.2.2 Nonaffected VOC Sources 18
3.3 CRITERIA FOR SELECTING TEST SITES 19
3.3.1 Proposed TTE Meets Procedure Design
Criteria 19
3.3.2 No 01rect-F1red Drying Ovens 21
3.3.3 Degree of Difficulty of CE Determination 21
3.3.4 Length of Process Runs . 23
3.3.5 Facility Cooperation 23
3.3.6 Cost 23
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TABLE OF CONTENTS (continued)
Page
SECTION 4.0 CONCLUSIONS 24
4.1 FEASIBILITY 24
4.2 COST 24
4.3 FUGITIVE EXHAUST RATE 25
4.4 CHOICE OF TEST METHODS 26
4.5 TEST SITES . 26
SECTION 5.0 RECOMMENDATIONS 26
5.1 FURTHER ACTION ON ISSUES 26
5.1.1 Drying Ovens Required to Meet the TTE
5.1.2 Choice of emission Test Method 27
5.1.3 Direct-Fired Drying Ovens 27
5.1.4 TTE Criteria Governing Distances from
NDO's to VOC Sources and Exhausts 27
5.1.5 Sizing of Fugitive Exhausts 27
5.: reliction :f plant: -or testing.. zs
.5.2.1 First Test—Westvaco Corporation Cofer
Road Facility 28
5.2.2 Second Test—ANC or Kenyon Industries.... 28
APPENDIX A. DETERMINATION OF CAPTURE EFFICIENCY, DRAFT PROCEDURE
APPENDIX B. SITE VISIT REPORTS
APPENDIX C. COST AND FEASIBILITY ANALYSES
111
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LIST OF TABLES
Page
TABLE 1. FACILITIES SURVEYED FOR PHASE I STUDY 3
TABLE 2. SUMMARY OF COSTS FOR CONSTRUCTION AND TESTING
ACCORDING TO THE CE/TTE PROCEDURE 5
TABLE 3. SUMMARY OF DESIGN PARAMETER COMPLIANCE WITH PROCEDURE
CRITERIA 6
TABLE 4. MATRIX FOR SELECTION OF TEST FACILITIES 20
1 v
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1.0 INTRODUCTION
This document presents a summary of the findings of Phase I of a
project to investigate the temporary total enclosure (TE) procedure for
measuring capture efficiency (CE) (Determination of Capture Efficiency.
Draft Procedure, April 1988). The procedure is presented in Appendix A.
In Phase I, cost and feasibility studies were conducted at several coating
and printing facilities. This report summarizes those studies and
identifies issues that need to be addressed before actual testing is
conducted. Conclusions are presented regarding whether the construction
of TTE's and the subsequent testing according to the draft procedure are
^chrricaTy feasible the Titles visited. Recommendations for
candidate test facilities are included. More detailed information cr. -sen
facility 1s presented 1n the site visit reports and cost and feasibility
analyses appended to this report. The site visit reports are included in
Appendix B, and the cost and feasibility analyses are 1n Appendix C.
3AC:
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procedure and conducting a CE test were examined in this study, which is
the first phase of an overall study to evaluate the CE/TTE procedure.
During Phase II, testing issues related to the CE/TTE procedure will be
resolved, and a test program will be conducted. In Phase III, revisions
will be made to the CZ/TTE procedure as necessary based on the rindinnt Ce-
phases I and II.
1.2 OBJECTIVES OF PHASE I
The primary objective of Phase I was to evaluate the cost and
feasibility of using the draft CE/TTE procedure. Site visits were
conducted to gather data for site-specific analyses of the design,
construction, testing, and dismantling issues and costs associated with
measuring rE using the draft procedure. No attempt was made aurina this
study to <2VaiUa'cs cr.s ^rocadure itself. The secana cDjectr e zr
was to recommend candidates for Phase II testing from among the facilities
visited during Phase I.
1.3 ORGANIZATION OF THIS REPORT
'..i Section 2.2, --'idings of the cost wd f°?.sibi'1 inaly:-': br-
each facility are summarized. The issues and site-specific orcciams
raised by the analyses are discussed further in Section 3.0. The
conclusions of the study are presented in Section 4.0, and recommendations
for the succeeding phases of the project are made in Section 5.0.
2.0 SUMMARY OF COST AND FEASIBILITY ANALYSES
Detailed cost and feasibility studies were completed on the following
three facilities: American National Can Company (ANC) 1n Hammond,
Indiana; Westvaco Corporation 1n Richmond, Virginia; and Kenyon Industries
1n Kenyon, Rhode Island. In addition, two simplified cost and feasibility
studies were completed for Atlanta Film Converting Company and Prlntpack,
Inc., both 1n Atlanta, Georgia. The latter two facilities were visited at
the beginning of the project, before the cost and feasibility study
guidelines were established. Therefore, some of the Information necessary
for a detailed cost and feasibility study was not obtained. Table 1
summarizes the facilities visited, their locations, and the type of
coating or printing processes used.
The facilities chosen for the cost and feasibility study were
referred by the Industry commenters and also bv EPA Regional Offices.
2
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TABLE 1. FACILITIES SURVEYED FOR PHASE I STUDY
Facility/location Type of facility
1.
American National Can Company,
Hammond, Ind.
Metal sheet coater, printer (litho)
for 3-piece cans
2.
Westvaco Corporation,
Richmond, Va.
Rotogravure printing/box
manufacturing
3.
Kenyon Industries, Kenyon, R.I.
Fabric coater
4.
Atlanta Film Converting
Company, Inc., Atlanta, Ga.a
Flexible packaging, flexographic
presses
5.
Printpack, Inc., Atlanta, Ga.a
Flexible packaging, flexographic
presses
1Less aetai iecr cost: ana 2as~ b• ' : ty dnaiyses -»ere jone on :r;ese -.'-c: '
because they were visited before study plans had been formulated.
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Some facilities had interest in the draft procedure because of the
possibility that they might be required to demonstrate compliance using
the procedure at some point in the future.
For process descriptions and details of the plants' layouts, the site
visit reports ror sacn of che facii:iss -nou id ce :snsui tac.
the proposed TTE designs and testing plans are presented in the cost and
feasibility analyses for the facilities. The site visit reports and cost
and feasibility analyses are included as appendices to this document.
A TTE that meets the Intent of the criteria outlined in the CE/TTE
test procedure could be constructed at each of the facilities surveyed. A
breakdown of estimated costs at each facility for TTE construction and
testing according to the CE/TTE procedure is presented in Table 2. The
estimatsa :csts zf constructing ana dismantling ;ne T"5!s,
design, materials, equipment rental, and labor, range from about $5,000 to
$10,000. The estimated costs of testing range from about $15,000 to
$23,000. The total estimated costs of conducting a CE test using the TTE
procedure ~mge -*~ojn about 520.GOO to $30,000, excluding the
associates with any lost production tnat results from the construction yr
dismantling of the enclosure.
Production losses could occur at plants that operate continuously 1f
TTE construction or dismantling were to interfere with the operation of
the process. No production losses would be expected at plants that
operate less than 24 hours per day, 7 days per week; at such plants,
activities that would disrupt production could be accomplished during
scheduled downtime. At the facilities studied, estimates of lost
production time range from 0 to 11 hours. No dollar values are assigned
to lost production 1n this report because this information is claimed
confidential by the facilities.
Table 3 summarizes the compliance status of the TTE's at each
facility relative to the specific design criteria contained 1n the CE/TTE
draft procedure. Construction of the TTE and testing at each facility
studied are discussed 1n more detail 1n the following sections. The
general Issues and problems specific to individual facilities Identified
1n Table 3 and 1n the site-specific discussions should be addressed before
the testing phase of the CE/TTE study 1s Initiated. These issues and
oroblems are discussed more 'n "action 2.0.
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TABLE 2. SUMMARY OF COSTS FOR CONSTRUCTION AhO TESTING Ai
(Dollars, Unless ml.arwlse Indii
i nRDING TO THE CE/TTE PROCEDURE4
a i ed)
Facility
Designb
ruction
and .
dismantling c
Lost
^.'oductign
(Hours)
Testing
costs
Total
costse '
1.
American National Can Company
Hammond, Ind.
500
o.700
u CO ll9
17,100
24,300
2.
Westvaco Corp., Richmond, Va.
500
c.700
8
22,600
29,800
3.
Kenyon Industries, Kenyon R.I.
500
y, 400
0
15,000
24,900
4.
Atlanta Film Converting
Company, Inc., Atlanta, Ga.
500
4,600
0
15,000
20,100
5.
Printpack, Inc., Atlanta, Ga.
500
(1,800
() to 79
15,000
22,200
i*Costs have been rounded to the nearest $100.
"Includes labor rate of $40 per hour (Including its and ov/erl.cdd).
^Includes materials, equipment rental, and labor.
Lost production 1s presented 1n terms of hours ratiiur than dcllai^ to protect Information considered by
some facilities to be confidential.
^Excluding lost production costs.
Totals may not match Individual Items due to Independent rounding.
^Range results from variable plant operating schedule; production may be lost if the CE test is
scheduled when the plant 1s operating 7 days per
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TABLE 3. SUMMARY OF DESIGN PARAMEItK COMPLIANCE W11H PROCEDURE CRITERIA
FaciIity
Average
face velocity
through NOO's
>200 ft/min
1. American National Can
Conpany, Haamond, I nd.
Yes
Distance of
VOC sources
from NOO's
>4 equivalent
diameters
Yes
T'ibtance of
lifO's from
exhausts
M equivalent
ai ameters
IcS
u.i ,l area of
Niki's <51
ui iota I TTE
tui I ace area
Comments/potem i a I
problems meeting protocol criteria
oven ex i t
Face velocil/ ai drying
slot may ba less than
200 ft/mii., jverage for all
NOO's will mudt face velocity
criterion.
2. Westvaco Corp., Yes
Richmond,Va.
3. Kenyon Industries, Yes
Kenyon, R. I.
4. Atlanta Film Converting Yes
Company, Inc.,
Atlanta, Ga.
Yes \oa ib.
Yes iLi Yc-
Yes • os i'o
May be some Jiificulty literally
meeting tl.is distance criteria
using the revised definition of
equivalent diameter. When
orientation . f NDO's is
considered effective compliance
is expected io be achieved.
Redesign c( 1TE to literally
meet all criteria is possible.
5. Printpack inc.. Yes Yes i\-s
Atlanta, Ga.
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2.1 AMERICAN NATIONAL CAN COMPANY
The ANC facility In Hammond, Indiana, coats and prints metal sheets
for three-piece cans. The process evaluated for this study is a sheet-fed
roll coating line. The drying oven is heated by direct recirculation of a
portian :f "the -xhaus* jases '""m 'the line's incinerator. The TTE
proposed for this facility would enclose the operator's normal working
area from the sheet feeder to the front of the drying oven. The drying
oven entrance would be within the TTE; the remainder of the oven would
function as a component of the total enclosure around the process.
Additional detail on the process and proposed TTE can be found in the
appended site visit report and cost and feasibility analysis.
The cost and feasibility study performed for the ANC facility
indicates :nat :"e ^cnszrjction of a 771 ana :ne -.luosequent aetanrnnaz'scn
of CE according to the procedure are feasible, although some minor
problems are present. These problems, which are not anticipated to be
significant to the overall capture efficiency determination, include the
ar'factj :f the incinerator ^xnaust '•scycle stream and the coater's
nonaffaciad aoubie-scraper cleaning system on una CI jeternnnation, in
the case of the Incinerator recycle stream, the recycled VOC can be
measured and accounted for 1n the CE computation. In the case of the
nonaffected coater cleaning system, emissions would be expected to be
small relative to emissions from the coating process, although no data on
these emissions are known. Also, 1t 1s not clear that this cleaning
system would not be considered part of the affected facility for
compliance purposes at this facility and others like 1t. The Incinerator
recycle stream and coater cleaning system are discussed further 1n
Sections 3.2.1 and 3.2.2, respectively.
Because the portion of the drying oven that 1s not enclosed by the
proposed TTE functions as a component of the total enclosure for the test,
the CE/TTE procedure requires that the oven meet the criteria for a TTE.
The cost and feasibility study for ANC Indicates that the exit from the
drying oven might not meet the minimum face velocity criterion of 200 feet
per minute (ft/m1n) required for natural draft openings (NDO's). However,
this statement resulted from a misinterpretation of the Intent of the
procedure. When the temporary enclosure structure and drying oven are
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evaluated against the criteria as a unit, as intended, the drying oven at
ANC no longer presents a problem. This issue is discussed in more detail
in Section 3.1.1.
The cost of determining CE is estimated to be about $24,000, not
.'c;.:aing cne cost c? ^reduction lest during construction and dismantling
of the TTE. At this facility, production would be expected to be lost
only if the test were scheduled during a period of heavy demand,when the
plant was operating 7 days per week. At such times, it is estimated that
up to 11 hours of production could be lost.
Three test locations are necessary for the determination of CE at
this facility. Four additional test points are included in the sampling
plan for verification of airflow rates and ambient conditions.
The jr'ift ^roc2aur3 inc;udes m optional procedure that a 1'cv»s ".".a -I
to be determined by testing the captured emissions first with a TTE in
place and then again without the TTE in place. This "with/without" option
eliminates the need for testing a "fugitive stream" from the TTE. The
motion /Is 'ntended rjr ;sa only it facilities that generate amissions at i
constant rate. The jse of the wien/without test option is not reccnunenasc
at this facility because the normal production run durations are too short
to conduct both sets of test runs during a single production run.
2.2 WESTVACO CORPORATION
Westvaco's Plant II 1n Richmond, Virginia, prints paperboard for use
1n consumer product boxes, such as cigarette cartons and fast food
containers. Each process line consists of a web-fed, eight-color
rotogravure press and an in-line cutter creaser that stamps out the
appropriate forms to be folded subsequently Into boxes. The Ink for each
line 1s mixed 1n an area beside the line. Each of the eight rotogravure
print stations that make up a press has a dedicated dryer situated
immediately on top of 1t. All but one of the process lines at this
facility, Including the line evaluated for this study, have direct-fired
dryers. The TTE proposed for this facility would enclose the entire
process line, including the dryers and the Ink mixing area located beside
the line. Additional detail on the process and proposed TTE can be found
1n the site visit report and cost and feasibility analysis appended to
this report.
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The construction of a TTE and the subsequent determination of CE
according to the procedure are feasible at this facility. The proposed
TTE configuration does not require any deviations from the procedure
criteria. The use of direct-fired dryers interferes with CE determina-
:ion, bu: this prosiam : r:ot unique to the Ct/TTE procedure. Under any
procedure where the captured VOC stream is measured, the combustion of a
portion of the captured VOC in a direct-fired dryer will cause the
measured CE to understate the actual value. The problems associated with
direct-fired dryers are discussed further in Section 3.1.3.
It 1s estimated that the CE test would cost about $30,000 on the
process line selected for analysis. In addition, up to 8 hours of
production could be lost because this facility operates continuously.
>:our tast point: *ou;;: :a .isec! -or the CE determmacicn. ^n daavciona'
four test points are included in the sampling plan to monitor forced
airstreams Into the TTE and the ambient VOC concentrations Inside and
outside the TTE. The with/without test option may be applicable at this
facility because :he -^reduction -uns *Dpear to be long ancugn '¦.a 4:.ue
requisite test runs :o oe csnaucrea during a singie process run.
2.3 KENYON INDUSTRIES
The Kenyon Industries facility 1n Kenyon, Rhode Island, finishes,
dyes, and coats fabric on a commission basis. The process line selected
for evaluation 1n this study 1s a web-fed fabric coating line that
consists of four floating-knife coaters and four drying ovens alternating
in series. The proposed TTE would actually consist of four small TTE's,
each enclosing a coating station. Except for the exit from the final
drying oven, all the drying ovens' entrances and exits would be within one
of the small TTE's. The remainder of each oven would function as a
component of the total enclosure around the process. Additional detail on
the process and proposed TTE can be found 1n the appended site visit
report and cost and feasibility analysis for this facility.
The proposed TTE design at this facility deviates slightly from the
procedure criteria, although no significant effects on the CE determina-
tion are expected to result. The proposed TTE design allows for
considerable use of existing structures to support the TTE's while
avoiding some of the obstructions a larger TTE would encounter. However,
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because of the small size of the TTE, the criteria governing the distance
between NDO's and either VOC sources or exhaust ducts might not be met.
Using a revised definition of equivalent diameter ([4 x area/ir]0,5), the
separation between some NDO's and some VOC sources or exhausts would be in
the range z? r.«o -qufvilent diameters rather than the four equivalent
diameters required by the draft procedure. Note that the proposed TTE's
would meet the"criteria if the original definition of equivalent diameter
(4 x area/perimeter) were used. In any case, the orientation of NDO's to
VOC sources and exhausts is such that the potential problems that the
criteria are intended to prevent would not occur despite the fact that the
distances would not fully meet the criteria. The relationship between the
letter of the distance criteria and their intent is discussed further in
iec-:on i.
As with ANC, in the cost and feasibility study for this facility, the
TTE criteria were incorrectly applied to the drying ovens (which function
as part of the proposed total enclosure), resulting 1n an apparent problem
¦'n fleeting the criteria. However, when the TTc criteria ir* aoc! ;ed
correctiy, :ners ;s net a prooiem. The issue of drying ovens is atscussea
more fully 1n Section 3.1.1.
The cost of determining CE at the facility is estimated to be
approximately $25,000. No lost production would be expected at this
facility because the plant operates a maximum of 5h days per week.
Two measurements would be used to determine CE. Eight additional
points are Included 1n the sampling plan to monitor the ambient VOC
concentrations inside and outside each of the small TTE's. The
w1th/w1thout test option 1s not applicable to this facility because the
production runs are typically too short to attain long periods with a
constant emission rate.
A large TTE that would enclose the entire coating line could be built
to meet the procedure criteria. It 1s not clear whether the expense would
be greater than for the four small TTE's proposed. More plastic sheeting
would be required, and more obstructions to the TTE walls would be
encountered, possibly requiring additional construction labor hours.
However, the complicated and expensive fugitive exhaust system Included 1n
the proposed TTE configuration to combine the fugitive streams from the
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four small TTE's could be simplified at a cost savings. The test program
would be more complicated and expensive if the nonaffected direct-fired
curing oven that follows the final drying oven could not be excluded from
the large TTE.
Atlanta o:nvert:;jg company «.no .-rinfpack, •.nc.
Both these facilities are located in Atlanta, Georgia. These
facilities were visited at the very outset of this project, before the
cost and feasibility study plan had been formulated; thus, the data
gathered at these two facilities are less detailed than were gathered
during the later site visits to the facilities discussed previously. As a
result, the cost and feasibility analyses for Atlanta Film Converting and
Prlntpack are not as detailed as those for the other facilities.
•io-cn :nesa *ict : :i:es print piastre .• ilm ;cr .-"•'axibie pacxag-ng u3"ng
flexographlc presses. The TTE's proposed for both facilities would
enclose the entire process line selected for analysis. The site visit
reports and cost and feasibility analyses appended to this report present
additional detail on the arocssses and oronosed ' --¦
Although the TTE designs and sampling plans are less detailed for
these facilities, it 1s expected that the determination of CE according to
the draft procedure is feasible. No deviations from the criteria
established 1n the draft procedure are necessary 1n the TTE designs. Note
that the direct-fired dryers used at Atlanta Film Converting and Printpack
do present a problem, although 1t is not unique to this study or to the
CE/TTE procedure. Direct-fired dryers are discussed 1n more detail 1n
Section 3.1.3.
The CE determination using the draft procedure 1s estimated to cost
about $20,000 at Atlanta Film Converting. No lost production would be
expected because the plant operates 5 days per week. The sampling plan
Includes measurements at two points for the CE determination, at one point
to quantify a forced alrstream Into the TTE, and at two points to monitor
the ambient VOC concentrations Inside and outside the TTE. The typical
production runs are too short to allow use of the w1th/w1thout test
option.
The cost of determining CE at Prlntpack 1s estimated to be
approximately $22,000. In addition, up to 7 hours of production could be
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lost during construction and dismantling of the TTE, depending on the
facility's operating schedule at the time of the test. This plant
operates 5, 6, or 7 days per week, depending on demand. Two measurements
would be used to determine CE. Three additional points are included in
cne jamp:;ng pi an co quantify d forcad ai-stream :ne TTE iri to
monitor the VOC concentrations inside and outside the TTE.
3.0 DISCUSSION
This section presents a discussion of the issues and site-specific
problems regarding the determination of capture efficiency using the draft
procedure. Following the discussion of the issues and problems, the
criteria for selecting test sites are discussed.
3.1 ISSUES
iome genera: issues rag arcing ;rse pr-xsaure nave came up jur^ng :;?e
course of the cost and feasibility study. These issues are discussed
below.
3.1.1 Drying Ovens Required to Meet the TTE Criteria
The CE/TT nrncadur* w'.su'Uta* -."t.m.
to function as a structural componfiflt Of a total enclosure must ueet tne
total enclosure criteria. The intent of this provision is not completely
clear from the existing wording. As a result, the cost and feasibility
studies for the two facilities that fall under this provision (ANC and
Kenyon) were prepared under the mistaken assumption that the drying ovens
were to be evaluated against the criteria Independently. However, the
Intent of this provision is that the temporary enclosure structure and the
drying oven are to be evaluated against the criteria together as a unit.
As discussed 1n the cost and feasibility studies for ANC and Kenyon,
evaluating the drying ovens Independently at these two facilities raised
two concerns related to the oven exit as it functions as an NDO 1n the
enclosure. First, 1n attempting to apply to the drying oven alone the
criterion that specifies the minimum separation between NDO * s and VOC
sources, the area 1n the oven Interior where VOC's are evaporated was
considered a "VOC source," resulting in the perception that the oven exit
NDO will virtually never attain the required separation. Second, face
velocity measurements with a hand-held anemometer at the ANC drying oven
Indicated that the oven might not meet the minimum face velocity reaulred
:y :ne procaaura -'or i :oz2i snciasure.
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Reconsideration in the light of the intended interpretation of the
provision on drying ovens largely dispels these concerns. For purposes of
the distance criterion, "VOC sources" are meant to include the emission
points in the application and flashoff areas where fugitive emissions may
be generated, not enr'^ons within the drying oven that u.-a already
contained for delivery to the control device. The mistaken treatment of
the drying oven Interior as a VOC source resulted from trying to force the
criteria to fit an oven in isolation instead of considering,the entire
total enclosure (made up of the drying oven and the temporary enclosure
structure) as a unit.
The concern with oven exit face velocity arose similarly. The CE/TTE
procedure stipulates that the average face velocity across the all the
NOQ's in the enclosure -i :z ;e :aicuiataa rrom cne r'yrcaa dirf"ows -.zc
and out of the enclosure. This calculation procedure was developed with
the understanding that the actual face velocities at the various NOQ's
would vary somewhat around this average value; therefore, direct
measurement at an individual MOO is not appropriate. When the entire,
integrated tocai enclosure is considered, cne average face velocity
normally will meet the requirement even 1f the value at the oven exit is
somewhat lower. The large fugitive exhaust volume (required to maintain
the VOC concentration in the temporary portion of the enclosure at an
appropriate level for the workers) typically will more than counterbalance
a lower flow at the oven exit. Where necessary, the fugitive exhaust rate
and/or the size of the other NDO's can be adjusted to assure that the face
velocity criterion 1s met. In any case, concern regarding the face
velocity at the oven exit 1s misplaced. Unlike the haphazard airflow
patterns typical of application and flashoff areas (which are the basis of
the face velocity requirement), drying oven airflow patterns typically are
engineered so that the VOC released in.the oven will be contained. Also,
1t should be noted that the face velocity measurements at ANC were taken
when the coating line was not 1n production; 1t 1s not known whether the
values observed are representative of conditions during normal production.
In consideration of the discussion above, the statements 1n the cost
and feasibility studies for ANC and Kenyon that the drying ovens
technically do not meet the TTE criteria are incorrect. However, the cost
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and feasibility studies for these two facilities have not been corrected
because the level of effort required to do so is not justified. Should
testing be conducted at either of these facilities, an evaluation of the
integrated total enclosure will be made at that time. It is not
anticipated that incorporation of the drying even as a structural
component of the total enclosure will result in any difficulty in meeting
the TTE criteria when the provision governing such situations is applied
as intended.
Nevertheless, some issues remain regarding whether the drying oven
and the temporary enclosure structure should be evaluated as a unit. As
mentioned above, different airflow conditions prevail Inside the two types
of enclosure components; it may be more reasonable to apply different
criteria to ".nese components ~han to cry zc jpDlj j single <&¦: ;r-~2r•*
to the combined enclosure. Also, while the fugitive exhaust rate and
NDO's 1n the temporary enclosure structure can be adjusted to compensate
for a low face velocity at the drying oven exit, such adjustments may
affect the ooentlon nf +;he TTE. Consideration of the intsqratsd
enclosure as a unit disc might aiiow the NGQ's in the temporary structure
to greatly exceed 5 percent of that component's surface area, particularly
when the drying oven 1s very large. This situation may not be
desirable. Finally, because the entrance to the drying oven functions as
a capture device during normal operations, the airflow patterns around
this opening should not be disrupted during the CE test; the oven entrance
should be treated as a "hood or exhaust" for purposes of the criterion
governing the separation of these devices from NDO's. However, 1f the
drying oven and the temporary enclosure structure are evaluated together,
the oven entrance (which will be located Inside the temporary structure)
1s only an opening between two sections of the total enclosure, and Its
function during normal operations may be overlooked. Based on the Issues
discussed above, further evaluation of the appropriate treatment for total
enclosures that incorporate the drying oven as a structural component is
warranted.
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3.1.2 Choice of Emission Test Method
The choice of which test method to use to measure VOC concentration
is an issue. The draft procedure lists EPA Methods 18, 25, 25A, and 25B
as acceptable test methods. The two most likely candidates are Method 25,
"-eterraination of Total Gaseous Nonmethane Organic Emissions as wdrbon,
and Method 25A, "Determination of Total Gaseous Organic Concentration
Using a Flame Ionization Analyzer." The method chosen should be selected
on a case-by-case basis, and the selection will depend primarily on the
concentration of VOC in the stream and whether the stream will undergo any
process that changes the VOC composition (such as partial combustion).
Method 25A may be more desirable because measurement results are obtained
continuously during samDlina, allowing Dersonnel to make adjustments
during ;he test period, if necessary. Also, Methoa .ISA nas i -ower
detection limit than Method 25. Low concentrations are expected in the
fugitive exhaust ducts (less than 100 ppm). However, Method 25 is
preferred for partially combusted streams (such as in incinerator
sff^elancy letarminations) or ?n other cases *here cas streams vit-h
significantly different VOC compositions must be compared.
In the absence of partial combustion, the compositions of the
fugitive and captured streams typically would not be expected to differ
enough to significantly affect the CE determination. However, the
possibility of varied VOC compositions should be considered during the
planning phase. When multiple-solvent systems are involved, the fugitive
stream from the application and flashoff areas could be enriched with the
high-vapor-pressure components relative to the captured stream that
originates 1n the drying oven. Also, 1n processes where cure volatHes
are formed as the coating cures in the drying oven, the gas streams will
differ to some degree.
3.1.3 D1rect-F1red Drying Ovens
Two Issues are associated with performing a CE test on a process
employing direct-fired drying ovens. The first 1s that there 1s
destruction 1n the drying ovens that will not be accounted for In the CE
determination. When direct-fired burners are used to heat the drying
ovens, some VOC's that are present 1n the ovens will be completely or
partially combusted. The amount of combustion that occurs depends upon
15
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the oven configuration and the circulation currents within the oven. Any
VOC that is oxidized to C02 or CO will not be measured as having been
captured. This combustion of VOC poses a technical problem outside the
scope intended for this study. For this reason, facilities without the
complication of indeterminate irrcarnai incineration wn; be ^'.actec; for
the testing phase of this project.
It should be noted that this problem with direct-fired drying ovens
is common to any compliance demonstration method that involves measurement
of the captured or recovered VOC. Whether the captured gas stream or
recovered liquid solvent 1s measured, the value obtained will not account
for VOC combusted in the direct-fired drying ovens.
The second issue concerns the selection of an approDriate test method
wnen determining ZZ for i unit .vith a ci"~3Ct-r ar^ng :ven. ^.evr.zz
1s appropriate for measuring partial combustion products created 1n the
ovens. However, the low-concentration (<100 ppm) fugitive exhaust stream
that also must be measured would suggest that Method 25A 1s the preferred
uethod. A -snflict exists because the determination of capture ^ff.r-rlency
must involve the use of the same type of measurement (i.e., ail
measurements by Method 25 or all by Method 25A).
3.1.4 TTE Criteria Governing Distances From NDO's to VOC Sources and
Exhausts
The TTE criterion specifying that NDO's must be a minimum of 4 NDO
equivalent diameters from each VOC source 1s intended to minimize the
effects of the enclosure on the normal air vectors around the VOC
source. The criterion requiring NDO's to be at least 4 exhaust equivalent
diameters from each exhaust hood or duct 1s intended to prevent air
entering through the NDO from being channeled directly Into the exhaust.
The Intended effects of these criteria are Important to the success of the
CE determination. However, as written, the criteria do not take Into
account the relative orientation of the NDO's and VOC sources or
exhausts. This aspect of NDO placement 1s as Important as distance 1n
determining the Interaction of these points 1n the TTE.
With the NDO's making up no more than 5 percent of the TTE surface
area, the TTE will function as a plenum, essentially equalizing the static
pressure differential across all points of the NDO's. As a result, the
16
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inward flow through the NDO's will occur in the direction perpendicular to
the plane of the opening. Thus, for the undesirable effects that the
distance criteria are intended to prevent to occur, the VOC source or
exhaust (or the associated air currents) must be directly in front of the
NOO.
As discussed in the summary of Kenyon Industries (Section 2.3),
reliance on distance criteria alone can be a problem, particularly when
small TTE's are desirable. In such cases, a process-imposed NDO or
existing exhaust may dictate separations that cannot be attained. At the
same time, the orientation of the NDO's and VOC sources or exhausts may
assure that the success of the CE determination is not endangered despite
the failure to meet the distance criteria.
A reiatea issue concerns *netfter cne distance critar*a. irs ^rctaczv/e
enough when the NDO is directly aligned with the VOC source or exhaust.
Additional information on the distance air drawn through an opening will
carry is necessary to resolve this issue.
3.1.5 Sizing of Fugitive Exhausts
For the cost and feasibility analyses that have been performed, cn»
fugitive exhaust was sized based on theoretical considerations. In a
sizing procedure analogous to that included 1n the draft TTE/CE procedure,
the estimated fugitive emission rate and the applicable threshold limit
value (TLV) were used to estimate the fugitive exhaust rate necessary to
prevent the TLV from being exceeded inside the TTE. These calculations
resulted 1n fugitive exhaust rates of about 7,000 to 13,000 cubic feet per
minute (ft3/m1n). The costs of the required exhaust systems exceeded all
other components of the TTE. There 1s some question that such high
exhaust rates would actually be needed to maintain a healthful atmosphere
within the enclosure. For example, a CE test was carried out at an Arrow
Group coll coating facility using the w1th/w1thout test option with no
supplemental fugitive exhaust. During the portion of the test with the
TTE 1n place, the VOC concentration Increased but did not approach the
TLV.
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3.2 SPECIFIC PROBLEMS ASSOCIATED WITH THE FACILITIES VISITED
3.2.1 Recycle Streams with Solvent Destruction
Three facilities examined in the study have recycle streams
associated with their drying systems. At ANC, a portion of the
incinerator exhaust straam is recycled back to the drying oven. Because
the incinerator is not 100 percent efficient in destroying VOC, some VOC
is recycled back to the oven. The recycled VOC biases the amount captured
high, which is to the facility's advantage in a compliance determina-
tion. This issue could be resolved by measuring the incinerator outlet
(both VOC concentration and gas flow rate), assuming that the VOC
concentration in the exhaust equals the concentration in the recycle, and
subtracting the exhaust volume from the inlet flows to obtain, by
difference, the amount ;f VOC's going to recyc:*;. i.c Viestvaco ana
Prlntpack, a portion of the drying oven gases are recirculated past the
direct-fired burner. Suitable points for determining the destruction of
VOC at these plants are not available.
1.2.2 Nonaffectgd VCC ^our":as
At ANC, a "aouble-scraper" solvent cleaning system for ;he ccanng
equipment cannot be excluded from the TTE, although it is not considered a
part of the affected facility according to a company representative. The
coater cleaning system is an integral part of the coating equipment;
emissions from this system would be expected to be captured by the coater
hood and floor sweep 1n the same proportions as the coating emissions that
occur at the coater. Thus, the cleaning system emissions would Increase
the VOC 1n both the captured and fugitive.streams. The effect of these
emissions on the CE determination would depend on the amount of fugitive
and captured VOC's generated at each emission point in the process. If,
as expected 1n this Industry, the large majority of coating emissions
occur within the drying oven and are captured there, the cleaning system
emissions would add a smaller percentage to the VOC 1n the captured stream
than to the fugitive stream. This effect would bias the capture
efficiency determination low, which would be disadvantageous to the
facility 1n a compliance test. At present, this problem has not been
resolved, and 1t is not known whether the amount of VOC's released from
the system could significantly affect the CE determination. Emissions
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from the coater cleaning system would be expected to be small'relative to
coating process emissions, but ANC has been unable to provide any data to
confirm or disprove this expectation.
Nonaffected emissions that enter the affected gas streams also would
affect other comDliance determination procedures such as the liquid/gas
method. However, in a procedure where the captured gas stream or
recovered liquid solvent 1s measured, but fugitive emissions are not, a
nonaffected source such as this one would be advantageous to the source.
In such cases, only the VOC added to the captured stream would be
detected.
In any case, it appears that, in principle, the coater cleaning
system should be considered part of the affected facility. The system is
intimately associated with the coating equipment ana essential :o proper
operation. It 1s not known whether this emission source is considered
nonaffected 1n other jurisdictions.
It should be noted that the presence of the nonaffected source in
this case will not affect-the ootantiai usefulness of che facility for
testing. The purpose of tne test program is to demonstrate tnat cne
procedure can be carried out, not to determine the actual CE at the test
facilities. Thus, the coater cleaning system could be considered part of
the affected facility for purposes of the test program.
3.3 CRITERIA FOR SELECTING TEST SITES
In Phase II of this project, two CE determinations are to be
conducted using the draft TTE procedure. In the sections that follow, the
criteria for selecting test sites are discussed, and the potential sites
are evaluated relative to the selection criteria. A summary matrix of the
site selection criteria and facilities is presented in Table 4. Note that
a second Westvaco facility that has not been visited 1s included 1n the
matrix. Matrix entries for this facility are based on telephone contacts
with a company representative.
3.3,1 Proposed TTE Meets Procedure Design Criteria
This selection criterion must be met for a successful demonstration
of the CE/TTE procedure. However, one objective of this project 1s to
revise the procedure as necessary (Phase III). Thus, revisions to the
draft procedure that have been decided upon prior to actual testing should
oe jsed wnen considering chis selection criterion.
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TABLE 4. MATRIX FOR SEliCTION OF TEST FACILITIES
FaclIIty
Meets
design
cr i ter i a
Direct-
f ired
drying
ovens
Degree of
diff iculty
expected
Test
,,v»intsa
Typic.
proce.,
run
lengli.
how _
FaciIi ty
cooperat i ve
Estimated
cost, S
Estimated
lost
production,
hours
American National Can
Yes
No
Dlff icult
4-5
Uncertai n
24,300
0-1 r
Westvaco Corp.
Plant 11
Cofer Road Plant0
Kenyon Industries
Yes
Yes
Yes1
e
Yes
No
No
Di ff icult
Moderate
Difficult
24
24
Unlikely
Unlikely
Likely
29,800
22,200d
24,900
Atlanta FiIn Converting Yes
Yes
Moderate
Likely
20,100
PrIntpack
Yes
Yes
Moderate
4-6
Uncerta i n
22,200
0-7
^Includes ambient measurements inside and outside TTE.
"Production loss expected only during periods of continuous pro< operation.
^Facility has not been visited; matrix entries based on telepho..^ contacts.
Estimated assuming TTE costs identical to Plant II and minimum rating costs.
eMay be some difficulty in literally meeting distance criteria >.ith the proposed Tit configuration under the revised definition of
equivalent diameter. When orientation of NOO's is considered, effective compliance is achieved (see Sections 2.3 and 3.1.4).
.Literal compliance could be achieved with an alternative TTE d.^igii.
Includes four points for ambient measurements inside small TTE':..
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As Indicated in Table 4, all the facilities meet this selection
criterion. Although the cost and feasibility studies for ANC and Kenyon
indicate that the use of the drying ovens as components of the total
enclosure would cause problems in this regard, that judgment was based on
an Incorrect interpretation of the provisions of the procedure (see
Section 3.1.1). The TTE proposed for Kenyon may have difficulty literally
meeting the distance criteria when the revised definition of equivalent
diameter 1s used. However, when the orientation of the NOO's, exhausts,
and VOC sources is considered, the intent of the TTE design criteria is
achieved (see Section 3.1.4). In addition, the TTE configuration could be
modified to meet the letter of the design criteria at Kenyon, although
desiqn SDecificatlons and estimated costs have not been prepared for a
different 7TE configuration.
3.3.2 No Direct-Fired Drying Ovens
Direct-fired drying ovens introduce complications to the CE
determination that are not desirable for the testing phase of this project
see Section 3.1.3). Facilities using direct-fired drying ovens wi"P not
be selected for testing.
This selection criterion eliminates Prlntpack and Atlanta Film
Converting from consideration for testing. In addition, the Westvaco
facility that was visited (Plant II) 1s eliminated on this basis.
However, Westvaco has a second facility 1n Richmond that does not use
direct-fired dryers. According to a company representative, the process
and air handling systems at the Cofer Road facility are essentially the
same as those at Plant II. For this reason, the Westvaco Cofer Road
facility 1s considered a candidate for testing pending a site visit. The
ANC drying oven, which 1s heated with Incinerator effluent, could be
considered direct fired. However, unlike most direct-fired drying ovens,
this system affords sampling locations that will allow the VOC destruction
to be accounted for 1n the CE determination.
3.3.3 Degree of Difficulty of CE Determination
This selection criterion will be applied differently 1n selecting the
two test sites. For the first test, a site where the CE determination 1s
expected to be relatively easy 1s desired. A test at such a site will
allow the project team to gain experience with the procedure under
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favorable conditions. In addition, the procedure itself can be evaluated
without confounding variables.
For the second test, more difficult conditions are desired. This
situation will allow a demonstration that the procedure can be
succassfu1'y conducted j.tder poor conditions as well as favorable ones.
Among facilities that have not been eliminated by the use of direct-
fired drying ovens, the Westvaco Cofer Road facility is expected to offer
the least difficult test conditions. The TTE at this facility could be
quite large but should not be overly complex. The process lines are
believed to be spaced with ample clearance to avoid interference between
lines. These tentative conclusions about this facility must be verified
bv a site visit orior to the final selection of test sites.
The ANC ficility "S representative of more difficult conditions. f'.-.e
process line selected for analysis is between two others, and the aisles
between lines are commonly used by the operators of both lines. Such
cramped conditions have often been cited by industry as an impediment to
the ;se of the "t srocadura.' The multiole gas streams and incinerator
recycle at cnis facility make testing complicated, as well.
The Kenyon facility also represents a more difficult site for a CE
determination. While the clearance between process lines 1s ample, the
process layout, with four separate coating stations, presents a challenge
to enclose. The proposed configuration of four small TTE's requires a
complex fugitive exhaust system; the system will have to be balanced 1n
the field to maintain acceptable VOC concentrations in all the TTE's.
Alternatively, the TTE could be redesigned as one large enclosure
surrounding the entire process. With this configuration, complications
would Include multiple obstructions to be pieced around and the handling
of the final curing oven.
Table 4 Includes a rating of the degree of difficulty expected 1n
setting up the TTE considering the constraints at the facility and the
complexity of the TTE and fugitive exhaust system. The number of test
points 1s Included 1n the matrix as an Indicator of testing complexity.
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3.3.4 Length of Process Runs
If possible, one facility with long process runs should be included
in the test program. This would allow the with/without test option to be
conducted. In addition, long periods of constant emissions would allow
some experimentation with test parameters to validate tha test
procedure. For example, the captured VOC stream could be measured before
and after the TTE was constructed to assess the effect of the enclosure on
the performance of the existing capture system. Only Westvaco typically
has process runs of 24 hours or longer.
3.3.5 Facility Cooperation
Conducting the CE determinations would be much easier with the full
cooperation of the facilities involved. A rating of the expected level of
cooperation for =ach facility Dased on conversations witn company
representatives is included 1n Table 4.
3.3.6 Cost
The final selection criterion 1s cost. Resources for testing are
"Printed; minimizing tosts will -illow the most extensive testing Droaram.
The estimated cost of a CE determination using the FTE procedure is listed
1n Table 4 for each facility. Note that the costs presented do not
Include the cost of any lost production experienced as a result of TTE
construction and dismantling. A column has been Included 1n Table 4 to
Indicate the likelihood that production would be lost during the test
period. The prospect of lost production 1s likely to figure prominently
in the degree of cooperation shown by the facilities.
The estimated cost of a CE determination ranges from a low of about
$20,000 at Atlanta Film Converting to a high of about $30,000 at Westvaco
Plant II. Estimates of lost production range from 0 hours at Atlanta Film
Converting and Kenyon to a high of 11 hours at ANC. Loss of production at
ANC and Prlntpack would occur only 1f the testing were scheduled at times
of high demand when the facilities were operating continuously. The
actual cost to EPA of the tests may be higher than indicated because data
beyond that which 1s strictly necessary for a CE determination may be
collected.
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4.0 CONCLUSIONS
4.1 FEASIBILITY
The construction of a TTE and the subsequent testing according to the
intent of the CE/TTE procedure are feasible at the facilities surveyed.
Note that such factors as the contributions of recycle flows and the
effect of direct-fired ovens can cause the determination of CE to be less
than straightforward despite the feasibility of the procedure. Such .
complications generally will affect any CE determination method, however.
At the two facilities where the proposed TTE would not enclose the
entire drying oven, the cost and feasibility studies indicate that the
drying ovens do not meet all the TTE design criteria. However, this
conclusion was based on a misinterpretation of the provisions of the
procedure that apply to this situation (see Section 3.1.1). When the
provisions are applied correctly, there 1s not a problem with meeting the
criteria.
The proposed TTE at one facility could have difficulties 1n meeting
the desiqn crjtar-^ icvernina the senaraticn of NOO's from VOC sources and
exhausts when the revised definition of equivalent diameter is usee, "his
situation could occur at other facilities where small TTE's are desired.
As discussed 1n Section 3.1.4, these criteria specify distance alone; no
consideration 1s given to orientation. It should be noted that a TTE that
would meet every requirement of the draft procedure could be built at this
facility. The costs for the larger TTE that would be required to do so
have not been calculated during this study.
4.2 COST
All cost estimates calculated for this study are based on the
s1te-spec1f1c conditions at the facilities that were visited. Costs at
other facilities could be higher or lower than those presented 1n this
report, but lower costs would be expected to predominate. Most facilities
selected for study were referred by industry commenters at the NAPCTAC
meeting at which the draft procedure was presented. These commenters
expressed the belief that the procedure would be difficult and expensive
to conduct; the facilities suggested by the commenters are likely to be
among the least favorable for the procedure. In addition, the most
difficult process line to enclose was chosen for analysis at each
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At the facilities studied, the estimated total cost of conducting a
CE determination using the draft procedure ranges from about $20,000 to
$30,000, excluding the costs associated with lost production. Estimates
of the amount of production time that could be lost during construction
md i"! ^mantling of the TTE range from none to 11 hours. The estimated
dollar value of lost production is not Included in this report because
this information is considered confidential by the facilities. Estimated
costs are summarized by facility in Table 2.
In all cases, the largest cost component of the CE determination is
the testing itself. Testing costs are estimated to range between about
$15,000 and $23,000.
Construction and dismantling costs (excluding lost production) for
¦:ne :roDoseti "TE's ars estimated co range from dDOUt $5,GC0 co ilu.JCu.
The greatest expense associated with the construction of the TTE 1s the
fugitive exhaust system. These systems account for over half the cost of
constructing the TTE's.
¦1.3 FUGITIVE EXHAUST RATE
"he¦proceaure requires :hat ;ne rtecassary fugitive exnaust rat^ ue
determined when designing the TTE. Engineering calculations based on
expected VOC emission rates, estimated capture efficiencies, and allowable
ambient concentrations are used to determine the flow rate. For the
facilities analyzed, estimates of capture efficiency were derived from a
number of sources. For ANC, the value accepted by the local air pollution
control agency for compliance purposes was used. At Westvaco, capture
efficiency was back-calculated from the typical recovery efficiency
achieved by the plant's solvent recovery system. At Kenyon, the capture
efficiency was estimated. The value used for Atlanta Film Converting had
been estimated for the company by a consultant, and the Prlntpack value
was based on a previous I1qu1d/gas CE test.
The fugitive exhaust rate calculations yielded very high flow rates
(about 7,000 to 13,000 ft3/m1n) which, 1n turn, resulted 1n the expensive
fugitive exhaust systems discussed above. There 1s some uncertainty that
such high flow rates are actually necessary. At least one facility has
conducted the CE/TTE procedure using the with/without option with no
supplemental fugitive exhaust. The VOC concentration within the TTE did
25
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not reach unhealthful levels. The steps taken to determine the flow rate
need to be documented and validated prior to or during the test program.
4.4 CHOICE OF TEST METHODS
Guidance will need to be established regarding which EPA test method,
Method 25 or Method 25A, should be used in specific cases.
4.5 TEST SITES
The test site selection criteria are presented and discussed in
Section 3.3. A summary matrix is presented in Table 4.
Based on those considerations, the best site for the first CE
determination is the Westvaco Cofer Road facility. However, this
conclusion 1s based on information received from a facility representative
over the telephone; the facility has not been visited. Confirmation that
cne conaicions &z ;ne r'aciiicy are as aescnoea ;s neeaea. r>
problem with testing at this facility is that the company may not wish to
host the test.
Either ANC or Kenyon would be acceptable for the second test.
However, some problems are associated with testing at these facilities,
it' is uncertain wnerner .-
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5.1.1 Drying Ovens Required to Meet the TTE Criteria
As discussed previously, this requirement was misinterpreted when the
cost and feasibility studies were prepared. At a minimum, this provision
should be revised to clarify that the drying oven and temporary enclosure
structure are ;c be evaluated against the TTE design criteria as a unit.
Further consideration should be given to more sweeping revisions that
would subject drying ovens to different criteria more tailored to their
unique characteristics. In any case, the procedure should Include a
provision to verify that the drying oven does, in fact, contain the VOC
vaporized within it for delivery to the control device.
5.1.2 Choice of Emission Test Method
Additional consultation with the Emission Measurement Branch is
neeaed on :m's issue. Method 25A snould be tne r'irsc choice for CE
determinations, particularly at facilities that do not use direct-fired
drying ovens. However, some method of verifying that the gas streams to
be tested have the same relative VOC proportions might be desirable. One
oossibiMt-.y would be to collect n small "iamole from each gas stream durinq
the site survey for subsequent analysis by gas chromatograph. Such
analyses should be adequate to determine whether there are significant
variations 1n the VOC constituents among the gas streams.
5.1.3 01rect-F1red Drying Ovens
As discussed previously, facilities using direct-fired drying ovens
should not be selected for testing. The resolution of the difficulties
presented by these facilities 1s outside the scope of this project.
5.1.4 TTE Criteria Governing Distances from NDO's to VOC Sources
and Exhausts
These criteria should be reevaluated to determine whether the
relative orientation of the NDO and VOC source or exhaust should be
Incorporated. If a decision 1s reached before the test program begins,
any revisions should be formulated for use during the testing.
5.1.5 Sizing of Fugitive Exhausts
The theoretical basis for the existing sizing methodology and any
available data from CE determinations that have been conducted should be
evaluated prior to testing. During testing, data should be gathered for a
subsequent examination of the relationship between the expected VOC
•rsncantrati'on n ~ne *TE ina :he actual concentration ¦¦experienced.
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5.2 SELECTION OF PLANTS FOR TESTING
Recommended test sites are presented below. These recommendations
are based on the site selection criteria discussed in Section 3.3 and on
the conclusions presented in Section 4.5.
3.2.1 First Test—Westvaco Corporation Cofer Road Facility
The Westvaco Cofer Road facility appears to be the best candidate for
the first CE determination based on information received by telephone. A
site visit should be conducted to confirm this conclusion.
5.2.2 Second Test—ANC or Kenyon Industries
Either ANC or Kenyon is recommended as the second test site. Each
site has potential drawbacks that should be weighed before a decision
between the two is made.
At Kenyon, the proposed TIE may not meet tne NOG aisranca crrcer;a
when the revised definition of equivalent diameter 1s used. If the
criteria are not modified prior to the second test, the TTE at Kenyon will
have to be redesigned. It is recommended that modifications to the NDO
distance criteria be considered md f^nal1-:ed oHor ro the second fc.asf..
It 1s uncertain whether ANC will agree to serve as a test site. This
Issue will be pursued with ANC representatives. Another drawback to ANC
as a test site 1s the complexity of the testing required to determine
CE. This complexity 1s the result of the Incinerator recycle stream and
1s unrelated to the construction or use of the TTE.
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APPENDIX A.
DETERMINATION OF CAPTURE EFFICIENCY, DRAFT PROCEDURE
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DETERMINATION OF CAPTURE EFFICIENCY
The Environmental Protection Agency is currently developing procedures
for determining the efficiency with which a device or combination of devices
contains volatile organic compounds for treatment by a control device.
Attached is a draft preamble and regulation to be reviewed at the meeting
of the National Air Pollution Control Techniques Advisory Committee on
May ' 7-13, '
Attachment
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6560-50
ENVIRONMENTAL PROTECTION AGENCY
40 CFR 52
Getermi nacion of Capture Efficiency
[AD-FRL- ]
AGENCY: Environmental Protection Agency (EPA).
ACTION: Proposed revisions of existing rule.
SUMMARY: "ne EPA is proposing to rovise 40 CFR part 52 to clarify
Appendix G setting forth a procedure for determining the efficiency with
which a device (or combination of devices) contains volatile organic compounds
(VOC5 "or treatment by a control device. This procedure will be available
for enforcement of <0C regulations • r. otite .i.ipsdneficuf.or. .-^v
are deficient with respect to such procedures, or for plans promulgated by
the Administrator. Promulgation of this procedure will not, of itself,
require a change to any SIP.
OATES: Comments must be submitted within 60 days after [insert date 60
days after publication in FEDERAL REGISTER],
Addresses: Send Comments to: Central Docket Section (LE-131), U.S.
EPA, Attention: Docket No. A-87-13, 401 M Street, S.W., Washington, D.C. 20460.
Docket No. A-87-13 containing material relevant to this rulemaking, is
located in EPA's Central Docket Section, South Conference Center, Room 4,
401 M Street, Washington, D.C. 20460. The docket may be inspected between
8:00 a.m. and 4:00 p.m. on weekdays. A reasonable fee may be charged for
copying.
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2
FOR FURTHER INFORMATION CONTACT: Questions regarding the procedures for
determining capture efficiency should be directed to James C. Berry, EPA,
Research Triangle Park Nortn Carolina 27711, telepnone (commercial) 919-541-
:cuo or (.-75) j^9-b605. -or i-^ornation regarding SIPs and enforcement of
SIPs contact Steven J. Hitte, EPA, Washington, D.C. 20360, telephone (202)
382-2829.
SUPPLEMENTARY INFORMATION:
INTRODUCTION
The EPA is proposing a procedure for determining the efficiency with
¦niicr, j uevics zn :3yic^S; -ipc:-i."2b >r ^
how well the device (or devices) prevents VOC from escaping treatment by an
abatement control device. Such a so called "capture device" may be an enclosed
room, nooa, "floor sweep" or other means of containing or collecting VOC in
order to direct it to a control device such as a carbon adsorber.or incinerator.
"Volatile organic compound" (VOC) is defined in 40 CFR 60.3 as "any organic
compound which participates in atmospheric photochemical reactions; or which
is measured by a reference method, an equivalent method, an alternative
method, or which is determined by procedures specified under any subpart."
Some SIP's, Subparts of 40 CFR Part 52, define VOC in terms of vapor
pressure. Certain SIP's also give specific exemptions for compounds that
have been determined by EPA's Administrator to be negligibly photochemically
reactive. The efficiency of this procedure is not affectd by the definition
of VOC that is used.
The EPA has previously provided guidance on determining "capture
efficiency" in select subparts of 40 CFR Part 60; each of which contains
regulations for new or significantly modified or reconstructed sources in a
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3
specific industry. This proposal, however, describes a general procedure for
determining the efficiency of any capture device serving a discrete, new or
existing line, operation or part thereof that produces VOC emissions, regardless
rf the industry. The procedure will aid in the enforcement of VOC regulations
in SIP's that do not contain an appropri ate method or procedure for determining
capture efficiency.
This procedure will not of itself require a change to any SIP. It will
merely provide a procedure for determining capture efficiency in the event
that a SIP is determined by its respective State or EPA to be deficient with
•-ssac- -uch -rocsdur^s. ir for *he Mmini strator's use if a Federal olan
must be promulgated for a State. Comments and recommendations for improving
this procedure or suggestions for another procedure are encouraged, but any
comments or suggestions should be explained in detail.
nijw ^rcposea •isroin : _ .-svi 5" zr, :z -•') J"-. ;ar ..1 «n ;;n ynz ¦ r-::
EPA's long-term position that evidence of violation is not to be solely
limited to test results, but violations may be proven by any evidence admissible
under Federal Rules of Evidence.
BACKGROUND:
The Clean Air Act (CAA) includes requirements that EPA establish national
ambient air quality standards (NAAQS) for various pollutants which may reasonably
be anticipated to endanger public health and welfare. Ozone, which is formed
by complex atmospheric reactions between VOC and oxides of nitrogen in.the
presence of sunlight, is one such pollutant. The CAA requires that States
implement a comprehensive plan (SIP) that will reduce the ambient ozone
concentrations to below the NAAQS for those areas that exceed it and that will
provide for maintenance of the NAAQS for those areas that have attained it.
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4
Numerous VOC regulations nave been included in SIP's. They vary in
stringency and complexity depending on many factors including wnether the
source is new or existing and whether it is or will be located where the
air complies with the NAAQS for ozone, i.e., an attainment area. Either of
two approaches may be taken by a source to comply with regulations. One
would alter the process or raw materials to lower emissions. An example
would be to substitute low-solvent coatings such as waterborne, powder, or
higher solids where coatings with high solvent content have'traditionally.
been used. The other approacn would be to reduce VOC emissions from the
:y -..-^ati ntj '.'r.s ixrsaust .as :t.-«dins. Most "tata ! -it: ens : • 1 ow :
source to use either or some combination of the two approaches. .
If a source's compliance strategy includes installation of a control system
to treat the exhaust gas, a determination of the reduction achieved by that
system .nust part or cne compliance cast, iucn a determination ; s
easy when the VOC is recovered and the reduction can be directly -;ermined via
a liquid material balance, i.e., measurement of VOC entering and recovered from
the facility. Typically, however, such direct measurements are extremely
difficult. For example, the design of the control system or plant operating
procedures might not be conducive or it might not be possible to conduct a
liquid material balance over the averaging period for which compliance is
required by the applicable regulation. In situations where the liquid material
balance is not available or is not adequate for determining compliance, the
efficiency of the control system must be determined by measuring the efficiencies
of the two major components of the system, the capture and control devices.
The capture device collects or contains the VOC, permitting it to be
directed to the control device which, depending on its design, may recover
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0
or destroy the VOC. The efficiency of the capture device(s), "capture
efficiency," is the fraction of all VOC emissions generated by an affected
facility that is contained and directed to a control device.
The control device receives emissions from the capture device ana eitner
incinerates them or recovers them, as in tne case of adsorbers and condensers.
The efficiency of the control device is the ratio of the quantity of VOC
destroyed or recovered to the quantity delivered to it.
The efficiency of the control system is equal, to the product of the
efficiencies of the capture and control devices and is the ratio of the
emissions destroyed 'or recovered) to the 'otal of all VOC emissions aenerated
at tne arfected facility. The efficiency of the control system is a measure
only of the capabilities of the capture ana control devices to collect or
contain, and then destroy or recover the VOC emitted at the affected facility.
'av vyc, "lowever, "»r: iicr :ne ?:"nc:ancy .y ^mcn „)urr.-'
VOC emissions attributable to the affected facility, the so-called "overall
control efficiency." For example, if a manufactured product has absorbed a
substantial amount of VOC from the process, the efficiency of the control
system (the capture and control devices' efficiencies) could be quite high
yet the overall control efficiency would be lower since the absorbed VOC
could later evaporate from the product.
Conditions that Preclude the Need for Measuring Capture Efficiency
If a source is located inside a "total enclosure" and all emissions are
directed to a control device, the requirement to measure the efficiency of
capture is waived, and presumed 100 percent. By definition then, a "total
enclosure" precludes fugitive emissions. Such an enclosure can be described
as a structure that completely surrounds or enshrouds and affected facility
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6
such that all VOC emissions are contained and directed through an exhaust
stack or into an oven. An entire building can function as a total enclosure
if the conditions above are satisfied.
For "egu!atory purposes, enclosure wi 11 oe presumed "total" ! f ere
following criteria are met:
1. Access doors and windows in the total enclosure must be closed during
routine operation of" the process;
2. The interior of the total enclosure must operate at a lower pressure
than its surroundings so that air flows into the enclosure at all "natural
r" .-smnus - \ir.:.;r.:i; ,r\r~ .'jam"'.: IJO; ' :
opening that is not connected to a duct in which a fan or a blower is installed.
Examples of NDO's are the entrances and exits to the enclosure which accommodate
raw materia! and product flow. Air will flow inward through the NOO's on^y
if forced make-up air, if any, is introduced to the total enclosure at a rate
less than the rate at which air is exhausted.
3. The average velocity through all NDO's must be at least 3,600 m/hr
(2UO ft/min). This velocity would be calculated by dividing the difference
between the rate of any forced make-up air and exhaust rate (cubic meters per
hour) by the total cross-sectional area of all NOO's (square meters). If tne
calculated average velocity is between 3600 and 9000 m/hr (200-500 FPM),
however, it will be necessary to verify that the flow through the NDO's is
continuously into the enclosure. An average velocity greater than 9000 m/hr
(500 FPM) will be considered adequate to ensure that the direction of air
flow through the NDO's is continously inward unless there is obvious evidence
to the contrary.
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7
This set of criteria was selected for the following reasons. Two
autnori tatsve references recommend the value of 3, 600 m/hr (21)0 ft/min)
through enclosure openings, Industrial Ventilation, A Manual of Recommenaeq
?ractice, 18th Edition, 19b4, published by the Americl Conference of Governmental
Industrial Hygienists, and the Air Pollution Engineering Manual, Publication AP 4Q
2nd Edition, 1973, publisned by the EPA. These references present 3600 m/nr
(200 ft/min) as the higher end of the range of capture velocities for contami-
nants released at low velocity into moderately still air and the lower end of
the range for capture of contaminates released into air in rapia motion. It
i
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8
machine passing by an NDO. The effectiveness of velocities througn trie NDO
of between 36QO and 9000 m/hr in preventing air from being drawn out of an
enclosure because of exterior influences is not as'well documented; consequently,
when this range of velocities is encountered, the continuity of tne direction
of air flow should be established. Techniques for making this determination
include: observation of streamers attached to the perimeter of the NOO's,
smoke released from smoke tubes just inside NOO's, or tracer gas analyses.
4. Any source of VOC emissions inside the enclosure must be at least
four equivalent diameters (4 times the opening area divided by the perimeter)
"GJ- ' '1 "'"UUi . "3rnSHr. i \Z T :fT,
through an NDO from immediately impinging on the source of emissions, causing
turbulence that can force air and VOC from the inside to the outside of the
enclosure >5ack through the NDO.
o. The total area of ail .NDO's snaii oe iess tnan 5 percent or ;ne
surface area of the total enclosure's four walls, floor, and ceiling. This
requirement will ensure that the area of N00 will always be small compared to
the size of the total enclosure.
If the conditions for presuming that the enclosure is "total" are satisfied
and all emissions from the total enclosure are directed to a control device,
capture efficiency may be presumed to be 100% and no performance test of capture
efficiency will be required. If any of the five requirements listed above for
a total enclosure is not satisfied, the source must measure the efficiency of
the capture device(s) as explained below.
The Determination of Capture Efficiency in the Absence or" a Total Enclosure
When the source relies on a hood, open-faced booth, floor sweeps, partial
enclosure, or combinations thereof to capture emissions, the efficiency of the
:aptura uevi cas; oa Jatannineci.
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•)
On several occasions tne EPA nas attempted to use traditional liquia-gas
material balance techniques to measure the capture efficiency at surface coating
facilities. The liquid VUC measurements were based on coating consumption
and a VOC analysis using Metnod 24. Gas-phase measurements were made of the
VOC concentration by Method 25 and gas flow rate of all emisions from an
enclosure by Method 2. Attempts to oalance the liquid VOC contained in the
coating with tne total gaseous VOC (that delivered to the control device ^lus
the would-be fugitive losses from the affected facility) gave results that
varied by as much as +_ SO percent.
In evaluating tnese tests and their results to understand why traditional
several factors that may contribute to the poor correlation between such
liquid and gas phase measurements:
'D Method 2<±, the reference method for determining VOC f-oin coat iocs -jives
an accurate measure of tne mass of VUC released under pianc cona;:;ons .
for those coatings cured in low temperature ovens by evaporative drying and
have no volatile organic byproducts. Those coatings that cure by a condensation
reaction release additional VOC that may not have been detected by Method 24,
and whose contribution to the total VOC may vary depending on the reaction
conditions but will rarely exceed 10% of the total. Method 24 exposes a
coating to a maximum of 110 degrees. Many industrial ovens operate at signif-
icantly higher temperatures which can cause evaporation of additional VOC for
which Method 24 is not sensitive. The magnitude of this additional VOC is
unknown and indeed would likely be zero for many coatings out could be signif-
icant for others.
(2) In many plants it is difficult to measure the net total coating
delivered to the process for any of several reasons:
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1U
0 difficulty of determining the net quantity of coating used by some
processes
0 difficulty of measuring and recording intermittent solvent additions
to a process
° physical constraints of the process and associated operational
capaDiii ti es
° physical properties of the coating
(3) Method 25, the most commonly used reference method for determining the
VOC content of a vapor, does not measure VOC mass but rather the concentration
of carbon atoms. Organic compounds that contain other atoms besides carbon
. ¦; eius in ijoarsrT: -ass :r.at ' 7wer "an ".it :~t=c"c
Method 24. Consequently, results of Method 25 tests must be subjected to a
correction factor based on the concentration and the ratio of carbon to
! ir weight of each compound in the stream being sampled. This is
oir:icu i t oecause* cne VOC wOmpcs; c:on ;s
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11
These complicating factors suggest that a liquid-gas material balance
based on Methods 1, 2, 24 & 25 approacn to measuring capture efficiency (e.g.,
a (jravimetric measurement of the net VUC available for capture ana a gas
phase measurement of VUC delivered to the control device would have the
greatest chance for success if:
(1) The affected facility uses a single known solvent or very simple
known solvent blend.
(2) No VOC is generated as a reaction by-product during the process.
(3) The tester is able to accurately quantify the total amount of VOC
¦vnich evaoorates within trie afracted facility (the net of liquid feed
and any that can oe accounted for in the product, waste water, etc.)
To positively confirm tne results of such a liquid-gas test, the Agency
will require an ana'ysis that identifies and quantifies all VOC species
•' -very jas ."r^ciin. zr, • ; ..-.2 <.jsu :.
balance.
The Agency has also investigated tne potential of direct measurement
techniques such as use of tracer gases, tracer solvents, smoke guns, and
ambient air analysis. None of these hold promise as a quantitative means of
measuring capture efficiency.
As a result of the experience with liquid-gas material balances using
the Agencies' Reference Methods identified above and the costs associated with
speciating the exhaust gases, EPA is nerein proposing a gas phase method of
determining capture efficiency founded on containing essentially all vapor
emissions from a process, so tnat they can be withdrawn in a controlled manner
and measured by identical Reference Methods thereby avoiding the need to
measure feed rate of VOC or know the composition of the exhaust gases.
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12
The EPA has promulgated (or proposed) a variation of this procedure in
several subparts of 40 CFR Part 6l).
1. Subpart RR -- Standards of Performance for Pressure Sensitive Tape
ir.d '.-is' turfOperati ons: 50.444(c) (4) (: ^
2. Subpart TT -- Standards of Performance for Metal Coil Surface Coating:
60.463(c)(2)(i)(8).
3. Subpart FFF — Standards of Performance for Flexible Vinyl and
Urethane Coating and Printing 60.683(d)(4)(i) and (ii).
4. Subpart SSS -- Standards of Performance for Magnetic Tape Coating
r -c: ' :: , .*c,ur .'DC.
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This procedure 15 insensitive to downstream emissions sucn as 70C wnich
subsequently evaporates from wastewater treatment facilities or from the
product. Promulgation of tnis procedure is not intended to imply that such
emissions are automatically exempt from regulation.
"u : :our,2 nay snclose an affected faci 1'tv i•: :ne of two ways--ty
either constructing a total enclosure around it, or by converting the room
that houses the. affected facility into a total enclosure. Both will be
discussed below.
The source may choose to construct either a permanent enclosure or merely
rig a temporary one for the duration of the test. A variety of coating
so-called gloveboxes (large enough only to insert hands and arms) to a room
larye enough to house not only the coater, but the entire line or process
• ir: I jai "(j come!ete access f:r "laintsn.'.nca.. 'lome sources have i rconorttad
residential garage'and patio doors for quic:<, convenient access :c prov;ce
for entry of heavy equipment. Others discharge all ventillation air from the
plant through a control device, thereby making an entire building a total
end osure.
The advantages of a permanent total enclosure are:
1. If all exhaust is vented to a control device, the source will qualify
as having 100 percent capture without being required to measure it.
2. Properly designed permanent total enclosures improve capture efficiency
and tend to simplify testing should the source elect not to direct all'exhaust
to a control device.
A temporary total enclosure, on the other hand, is built solely for the
purpose of measuring the fugitive emissions that ordinarily escape the capture
device(s) that serve the affected facility. Because it is constructed only
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for the purposes of conducting a test and subject to subsequent removal, tnis
type of enclosure Invokes tne followiny additional requirements:
1. The process must be operated under conditions that would generate
tne hiqhest fugitive emission rate routinely exoected. cor examole. i * ™rma'
methyl ethyl ketone (MEK) were used in producing one product, but toluene'in
another, and the solids content and solids use rate were the same for ootn
products, the rate of fuyitive MEK emissions would be significantly greater
than toluene emissions. The difference in this case would be due to differences
in vapor pressure, but other factors, such as production rate or process
- u r r --a -»«, y ' ¦-» - r-r
2. The VOC concentration within the enclosure snould stabilize before
each test period commences. If a constant concentration is not achieved
ana tfte enclosure's atmosphere is at risk cf exceeding the lower explosive
limit, or tne tnresnoid 1i mi *. /atue ,• one jr more or tne ro ilowing correct;-:
actions should be taken:
(i) The permanent capture devices within the enclosure should be more
strategically located to ensure more of the VOC is captured, leaving less to
aggravate the conditions within the enclosure.
(ii) The location of the temporary enclosure evacuation points should be
reexamined to assure that they do not permit channeling of air directly from
the NDO's, thereby thwarting the capture device which then fails to properly
ventilate the enclosure.
(iii) The amount of air discharged to the control device or the amount
discharged to the atmosphere, or both, should be increased.
It is recognized that construction of a temporary enclosure may well
influence the effectiveness of the permanent capture devices. One of the
*i]!owinq procsdures must be f o11 owed to oreclude measurement; that unaer•
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15
estimate the true value and minimize the magnitude of overestimates.
1. If the evolution of VOC inside tne temporary enclosure will occur
a relatively constant rate djriny the test period, the mass flow rate of
captured emis:;:nc ~:y 'c? .«••>.* z.-ii Vv3 12«io ^ r • ry enclosure
in place.
If the temporary total enclosure is ventilated otner than by the perma-
nent capture devices, the new exhaust stream must be tested to determine the
fugitive emissions. Capture efficiency may be calculated as tie ratio of
the mass flow rate of captured VOC emissions without the temporary enclosure
with the temporary enclosure in place. A Capture efficiency greater than
100% is obviously incorrect and suggests the test was not valid. There are
* wo ccta.nt: .i! causes e*.r rh: < ""suit: \} "ha -.-rncsss was tot «:ead/
state conditions; more emissions were jeneraced when che enclosure «as
in use than when it was, and/or (2) tne imprecision of the gas phase test
yielded the wrong average values of one or more of the captured or fugitive
VOC mass flow rates.
The first problem can be addressed by evaluating the process conditions
during the test and either retesting in the same manner or using the protocol
described below for non-steady state. The second problem can be avoided by
taking multiple measurements and using statistical techniques.
2. If tne evolution of VOC is not con.stant, e.g., the source .s a toll
coater with varying formulations and production rates, the procedure is more
involved since measurement before and after construction of the temporary
enclosure may be meaningless because of changes in operating conditions.
In tnese cases, it is important that care be taken to characterize the rate
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at which fugitive emissions are generated in order to properly size the draft
to be exhausted from the temporary enclosure.
Based on an estimate of the effectiveness of the permanent capture
device(s), the maximum VOC evolution rate allowed by the ooerating permit,
and acceptable VOC concentration to be tolerated in the enclosure, the
ventilation rate required to remove fugitive emissions from the temporary
enclosure can be determined and the enclosure may be designed and sized.
A quick graphical method was devised for estimating the required venti-
lation rate of a total enclosure. Figure 1 of the proposed procedure presents
i Mrm . , ;r r:: .soc, ;urves isner icao ""2 ..iner-: -:r .
f - ^c ^c
c Cc Qc * cf ^f
which can be rearranged to the form,
•
Uc Cf
where: Ec = Capture Efficiency
Q = the volumetric gas flow rate at standard conditions (m-Vhr),
C = the VOC concentration at stnadard conditions (ppmv),
the subscript "c" denotes parameters of the captured emissions
stream, i.e., the one directed to the control device, and
the subscript "f" denotes parameters of the would-be fugitive
emission exhaust stream.
The sum of the ventilation rates for the fugitive and captured emission
streams and the requirement that the average air velocity through NDO's be at
least 360U.m/hr (1 m/s), determines the allowable area of all NDO's. The
minimum size of the temporary enclosure is then fixed by the requirement that
the total area of the NDO's oe less than five per cent of the total surface
area of the enclosure.
r:ne ".amQorary enclosure tan trien be designed and zonstructad. theraoy
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1/
allowing the mass flow rates for captured and fugitive VOC to be measured.
The capture efficiency is then calculated as tne ratio of the mass VOC flow
rate in the stream to the control device (captured emissions) and the sum of
all of the gaseous emissions from tne enclosure (tne captured ana fugitive
emi ssi ons).
It may be possible to conduct a capture efficiency test without construc-
ting a total enclosure if the operator can close the room or building that
houses the affected facility and alter the ventilation air exhaust to permit
measurement of all exiting gases. To properly conduct the test, there can be
no sources of VOC within tne room during tne test other than those from tne
affected facility. The mass flow rates of VOC in tne captured ana ruguive
emission streams must then be measured. Capture efficiency is calculated as
the ratio of the mass flow rate of VUC delivered to the control device to the
' cw -vc* . r .awCu.-i'i ..;C.
The utiiicy of using cne exisciny structure is a temporary enclosure
frequently limited because of practical limitations in measuring emissions
from a large number of building or process vents simultaneously.
Cost of Determining Capture Efficiency via Gas-phase Measurements
The cost of conducting a capture efficiency test using direct, gas-phase
measurement of all emission streams, fugitive as well as captured, depends
largely on the approach that a source chooses to measure the fugitive emissions
If a source uses the room or building that houses the affected faci1ity as a
total enclosure, the cost will be a function of the number of exhaust stacks
that convey VOC from the affected facility and/or building to the atmosphere,
and the number of ducts that convey VOC from the affected facility to the
control device. The cost is expected to be about $2,500 per test point in
addition to travel and set-'ip expenses of the test contractor.
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If the room or building has numerous exhaust stacks, the construction of
a total enclosure around the affected facility will likely reduce the cost of
the test because although the cost of a temporary total enclosure is estimated
at $5,000 - <13,000; it would hive only one exhaust stack to be t?et.ar!. /T^o
VOC flow in the duct to the control device must be measured in any event.) 3y
effectually reducing to. one the multiple exhaust stacks that otherwise would
have to be tested, construction costs of a temporary enclosure would likely
be completely offset.
Although the cost of a permanent total enclosure could be double that of
i .ne, :ven iOui>: :s • i.-nosc .;r
as the capture efficiency test would be waived; no additional test costs
would be necessary if it meets conditions for 100 percent capture efficiency
-5 sciici in -.iis orouosal. Because faci i i ties that usa VOC are considered
susceptible to fires, the source may also realize some savings in fire .
insurance premiums if the affected facility is properly isolated from other
parts of the plant.
Regulatory Impact
Under Executive Order 12291, EPA must judge whether a regulation is
"major" and therefore subject to the requirement of a regulatory impact
analysis.
This action does not require revision of existing SIP's or changes to
•ny SIP regulations. Its purpose is to establis.h the test procedure that EPA
and the States use to determine capture efficiency when enforcing SIP
regulations where test methods or procedures do not exist in the aoplicalbe SIP.
This proposed regulation is not a major rule because it will not result
in an effect on the economy of $100 million or more, nor will it result, in an
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19
increase in costs or prices to industry. There will be no adverse impact on
tne ability of U. S.- based enterprises to compete witn foreign-oased encer-
prises in domestic or export markets. Because this amendment is not a major
regulation, no regulatory impact analysis is being conducted.
Regulatory Flexibility Act
Pursuant to the Regulatory Flexibility Act, 5 U.S.C., Section 601 et
seq., whenever an Agency is required to publish a general notice of rulemaking
for any proposed or final rule, it must prepare and make available for public
comment a regulatory flexibility analysis which describes the impact of the
-•j-c :n j;"d: ,~a.. . "is , "na. r^n; :::: . y.;
governmental jurisdictions). The Administrator may certify, however, that
the rule will not have a significant economic impact on a substantial number
- " -~,"i I ! an C f ! SS .
This amendment will have no adverse economic impact on smail entities.
Its only purpose is to ensure that EPA and the States have an appropriate
procedure to enforce SIP VOC regulations. No new SIP regulations are being
proposed, although the States whose SIP's do not contain a procedure or test
method for determining capture efficiency will be required to use this method.
Since this amendment does not significantly change the status quo for such
entities, I hereby certify that this regulation will not have a significant
economic impact on a substantial number of small entities. This regulation
therefore does not require a regulatory flexibility analysis.
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20
Paperwork Reduction Act
This rule does not contain any information collection requirements
subject to the Office of Management ana Budget review under the Paperwork
deduction Act of 1980, 44 U.S.C., 3bUl et seq.
List of Subjects in 40 CFR Part 52
Air pollution control, Ozone, Sulfur oxides, Nitrogen dioxiae, Lead,
Particulate matter, Carbon monoxide, Hydrocarbons.
Oate
Lee rt. Thomas
Admi ni strator
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21
The EPA Proposes to Amend Title 40, Chapter I, Part t>2 of the Coae of
Federal Regulations as Follows:
1. The authority citation for Part 52 continues to read as follows:
Authority: Section 110 of tne Clean Air Act as amended, 42 U.S.C. 7410.
2. Section 52.12 is amenaeu oy revising paragrapns (c) introductory
text and (c)(1) to read as follows:
§ 52.12 Source Surveillance.
* ~ ~ ~ *
(c) For purposes of Federal enforcement f the following test procedure
snail be used:
(1) Sources suoject co «i cr.er State implementation plans zr.^c -y;
specify test procedures or plans promulgated by the Administrator, will be
tested by means of the appropriate procedures and methods prescribed in
will u.e tne method or methods whicn are most consistent with the applicaole
provisions of the plan.
~ * * * *
3. Section 52.23 is amended by revising paragraph (b) to read as follows.-
§ 52.23 Violation and enforcement.
(a) * * *
(b) The promulgation of test methods under Parts 52 and 60 is not
intended as a limitation on the use of evidence that would be otherwise
admissible under the Federal Rules of Evidence.
* * * * *
4. A new Appendix G is added to Part 52 as follows:
Appendix 6 - Procedures for Plan Enforcement by EPA
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The procedures in tms Appendix are referred Co in § 52.12(c)(1) and (2)
(Source Surveillance) of 40 CFR Part 52, Subpart A (General Provisions).
These procedures shall be used in the determination of compliance with SIP
~auu i at i ons when the SIP fails to specify a test method or procedure or wnsn
EPA promulgates SIP regulations. This requirement may be waived if tne
source is either able to demonstrate compliance by an alternative procedure
or is able to measure capture efficiency by an alternative method or procedure
to the satisfaction of the Administrator
Procedure G-l -- Determination of Capture Efficiency
The procedure descriDed below prescribes how EPA Reference Methods for
gas phase measurements of volatile organic compounds (VOC) mass flow rates are
•." :3ed to determine the effectiveness of a device or combination of
devices ciiac contain ana ;2i;ver /DC co a control aevice.
1.0 Principle and Applicability
1.1 Pri nci pl'e
This procedure is founded on the principle that in a material balance
around a source of VOC emissions, the VOC that evaporates, and is either
captured or allowed to escape, is equal to the net VOC in tne liquid feed
that is available for capture, ie., the whole is equal to the sum of its
parts. By construction of a suitable total enclosure, all VOC emissions
generated at an affected facility are directed through ducts suitable for
measuring both gas flow rate and .concentation of VOC. Capture efficiency is
then determined by calculating the ratio of: (1) the emissions delivered to
the control device to (2) tne total emissions, i.e., the sum of emissions to
the control device plus those exhausted to the atmosphere.
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23
1.2 Applicabi1ity
This procedure is generally applicable to all sources of VOC tnat are
served by a capture device and which can be segregated by a temporary or
permanent total enclosure.
This procedure by itself may not be adequate for determining compliance
if the applicable regulation holds the affected facility liable for emissions
that occur downstream. Examples would be evaporative losses from process
wastewater, scrapped process feed, and final product. In such case, information
on those emissions would be required in addition to this procedure to certify
'omol i a.nr.e.
2.0 Definitions
2.1 Affected facility means any process, line or operation that is
subject to a regulation or standard.
-.av'c:; leans ;nc: —.nm. ' .jar :«e«o "
means of containing or collecting VOC and directing those VOC into a duct.
2.3 Capture efficiency means the fraction of all VOC generated by and
released at an affected facility that is directed to a control device.
2.4 Control device means any equipment which reduces the quantity of
VOC that is emitted to the air. The device may destroy the VOC « secure it
for subsequent recovery by regeneration or disposal. Examples of control
devices are incinerators, carbon adsorbers, and condensers.
2.5 Control device efficiency means the ratio of the VOC destroyed or
recovered by a control device to the VOC delivered to the control device,
usually expressed as a percentage.
2.6 Control system means any combination of capture and control devices.
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24
2.7 Control system efficiency means the fraction of gaseous VOC that
is generated at an affected facility that is prevented from entering tne
atmosphere as a result of the performance of its capture and control devices.
Mathematically ;v
one or more fans to replace aif that has been exhausted.
2.11 Fugitive emissions (F) means all emissions that escape an affected
Mc.i ? 1 *:y*« cloture ievics^s) and subseauently escaue to the atmosuhere.
1.12 ' natural graft opening means sny permanent openi ny ;,i a room, cu;.::ny
or total enclosure that remains open during operation of the facility and is not
connected to a duct in which a fan is installed. The "natural draft," rate and
direction, across the opening is a consequence of the difference in pressures
on either side of the wall containing the opening.
2.13 Overall control efficiency means the fraction of all the VOC
generated by an affected facility that is prevented from entering the
atmosphere as a result of the performance of the control system that serves
the affected facility. The overall control efficiency may be less than that
of the control system because of additional VOC emissions downstream of the
affected facility such as subsequent evaporation of VOC from spray booth
wastewater or of solvent that leaves the process in the product.
2.14 Temporary total enclosure means a total enclosure that is constructed
•'or "."a -sois -juroose :r measurinq fugitive emissions from an affected facility.
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2.15 Total enclosure means a structure that completely surrounds a
source of emissions so that all VOC emissions are contained for discnarye.
With a total enclosure there will be no fugitive emissions, only stack emis
sions. The only openings in a total enclosure are forced maxe-up air and
exhaust ducts and any NOO's such as those that allow raw materials to enter
and exit the enclosure for processing. All access doors or windows are
closed during routine operation of the enclosed source.
2.16 Volatile organic compound (VOC) means any organic compound whicn
participates in atmospheric photochemical reactions or which is measured by
"^ference method, or which is determined fcv procedures SDecified under any
subpart. Some suoparts of 40 CFR Part tne oiP's, uerine cne cerm oy
vapor pressure. Certain SIP's also give specific exemptions for compounds
that have been determined by EPA's Admini strator to be negligibly photo-
: . y • ---_t~""r> "" * .^c. ; r : v,;:: ¦. mcz.:C! :v ,.p
of VOC that is used.
3.0 Applicable Reference Methods
Method 1 Sample and Velocity Traverses for Stationary Sources, 4U CFR
Appendix A.
Method 1A Sample and Velocity Traverses for Stationary Sources with
Small Stacks or Ducts, (proposed 48 FR 43955, October 21, 1983)
Method 2 Determination of Stack Gas Velocity and Volumetric Flow Rate
(Type S pitot Tube) 40 CFR 60, Appendix A.
Method 2A Direct Measurement of Gas Volume Through Pipes and Small
Ducts, 40 CFR 60, Appendix A.
Method 2B Determination of Exhaust Gas Volume Flow Rate from Gasoline
Vapor Incinerators, 40 CFR 60, Appendix A.
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¦ Method 2C Determination of Stack Gas Velocity and Volumetric Flow Rate
from Small Stacks or Oucts (Standard Pitot Tube), (proposed 48 FR 48956,
October 21, 1983).
iietnoo 2D Measurement if Gas Volume Flow Rates in Smal1 Dioes and
Oucts, (proposed 48 FR 48957, October 21, 1983).
Method 3 Gas Analysis for Carbon Dioxide, Oxygen, Excess Air, and Dry
Molecular Weight, 40 CFR. 60, Appendix A.
Method 4 Determination of Moisture Content in Stack Gases, 40 CFR 6U,
Appendi x A.
^zr.r.z ,j . . ,-ii<50US c ,~:nuour:a:: .y ..i:.
40 CFR 60, Appendix A.
Method 25 Determination of Total Gaseous Nonmethane Organic Emissions
:S 'arnnn. U) "FR 50, ^noendi x 4.
.ietnca 25A Jet arm rtac i on or" 7o"a! Gaseous Organic Joncsncraci ons
A Flame Ionization Analyzer, 40 CFR 60, Appendix A.
Method 25B Determination of "'otal Gaseous Organic Concentration Using a
Nondispersive Infrared Analyzer, 40 CFR 60, Appendix A.
4.0 Procedures
4.1 Initial Qualitative Assessment of the Existing Capture Device(s)
The affected facility's permanent capture device(s) should be evaluated
to determine if it (they) may be presumed to be 100 percent effective. If the
permanent capture device is a total enclosure and all emissions are delivered
to a control device, a test of the capture efficiency is presumed 100% and a
test is not necessary. The criteria for waiving the test are: (1) the average
face velocity of air through all NDO's of tne enclosure shall be at least
3,600 m/hr (200 FPM); its direction should be demonstrably continuous into
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27
the enclosure at all openings; ^2) any source of VOC shall be a minimum or
four equivalent diameters from each natural draft opening; (3) tne cumulative
area of all NDO's shall be no greater than five percent of the surface area
)f the total enclosure; (4) all gas streams from the total enclosure snail be
directed to a control device; (5) all access doors and windows, except wnen
used as NDO's, must be closed during routine operation of the process.
Any oven or dryer that is intended to function as a total enclosure or
as a structural component of a total enclosure must also meet the same criteria.
4.1.1 Average Face Velocity at the Natural Draft Openings
The averiae face velocity tnrouah the NDO's, n. is calculated as the
quotient of the volumetric flow rate of natural draft air drawn into cne
enclosure and the combined areas of tne NDO's. The volumetric flow rate of
air drawn into the enclosure is equal to the net volumetric flow rate of
4.1.1.1 Net Forced Exhaust Air Rate
The flow rate in each duct or stack through which forced air is supplied
to or exhausted from the enclosure (including the oven when a part of the
enclosure) shall be measured using EPA Methods 1-4. Each flow rate must be
normalized to standard conditions.
The net forced exhaust air rate (QForced) then calculated by:
m n q
Weed » . E, Qfi * X % " I , \
1=1 j = 1 k = 1
Wnere: , ®Cj and ^ak = the volumetric gas flow rates (m^/hr),
i = each stack that forceably exhausts fugitive emissions
from the enclosure (or oven) to the atmosphere
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28
j - each exnaust duct from the total enclosure (or oven)
to the control device,
k = each forcea make-up air duct to the enclosure (or
oven); and
m, n, and q = the number of i, j, and k stacks or ducts,
respecti vely.
4.1.1.2 Average Face Velocity at the Enclosure's Natural Draft Openings
m n q
z
x~
Where: A = area (m2)
I = each NDO, and
: ; "3 vimoer :f "OJ':
4.1.1.3 Direction of Air Flow
If Qporced < tr,e ai r f'ow through NOO's is from the inside of the total
enclosure to the outside and the criteria for a total enclosure is not satisfied.
If Qforced > the test for direction of air flow through NOO's is dictated
by the average velocity that is calculated from the net forced exhaust air
rate from the enclosure.
If "^0 > 9U00 m/hr (500 ft/min) the direction shall be presumed to be
into the enclosure at all times (unless there is some obvious indication that
backdrafts are occurring).
If 360U <_ £ 9000 m/hr (200 < < 500 ft/min) the direction of airflow
shall be monitored for a one hour period during which the forced exhaust air and
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29
make-up air rates are determined. During the one-hour test typical process
conditions shall exist and normal plant activities shall take place.
4.2 Determination of Capture Efficiency
4.2.1 Basic Requi rements
In order to determine the efficiency of a capture device at an affected
facility, two basic requirements must be met:
a. All captured and fugitive VOC emissions from the affected facility
snail be contained and exhausted through stacks suitable for yas phase .neasure-
ments by the appropriate metnods specified in Paragraph 4.2.4.
b. Ounnq a jerformance test, the owner or operator of an affected
facility collocated with other sources of VOC snail isolate tne arractea
facility from the other sources.
These two requirements shall be accomplished using either of the procedures
¦. „ "i •?: " '..."ions - !" - ... J .
4.2.2 (Recommended Option) Build an Enclosure Around the Affected Facility
4.2.2.1 General Design and Ventilation Requirements for All Total Enclosures
a. Air flow through any NDO must be into the enclosure at a minimum
average velocity of 3,600 m/hr (200 ft/min). If the average velocity is less
than 90U0 m/hr (200-500 ft/min), the direction of flow will have to be verified
according to paragraph 4.1.1.3.
b. Any source of VOC shall be a minimum of four equivalent opening
diameters from each N00.
Any N00 shall be a minimum of four equivalent duct or hood diameters
from each respective duct or hood through which air from the enclosure is
exhausted unless the enclosure is a permanent installation.
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30
d. The total area of all NDO's snail be a maximum of five percent of
the total surface area of the enclosure.
e. The VOC concentration inside a temporary enclosure must lot continue
to increase but snail reach a constant level before each test period commences.
A continuing increase of VOC concentrations within the enclosure that place
the enclosure's atmosphere at risk of exceeding the lower explosive limit (or
the threshold limit value for employees if that is the design criteria),
indicate one or more of the following corrective actions should be taken.
(i) The permanent capture . ices should be more strategically located to
tr1 v.• jr;r> :f :r:a 'OC "
(ii) The location of trie temporary enclosure evacuation points snould be
reexamined to assure that they do not permit channeling of air directly from
"he v,nCs. thereby failing to uroperly ventilate the enclosure.
,: i i; i'*ie amount jf ii!* ::ccr.aroaa :s -:ne ;sntrci *avica, :r :na
discharged to the atmosphere, or both, should be increased.
4.2.2.2 Determination of Capture efficiency When the Process is
Generating Fugitive VOC Emissions at a Constant Rate
a. Step 1: Determine Mass Flow Rate of Captured Emissions
The gas flow rate and VOC concentration shall be measured in all exhaust
ducts that direct VOC emissions to a control device via the appropriate
analytical methods listed in paragraph 4.2.4. The captured emissions mass
flow rate (5") snail be calculated as follows:
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31
n
T . I % x c
j » 1
J
Where: Qc = the volumetric gas flow rate at standard conditions
\,c - zr.c iui concencrac; on a c JCdnua rd >. J nc ; c 1 c n s p pn v t
j = each exhaust from the total enclosure (and oven) to
a control device, and
n = the number of exhaust ducts from the total enclosure (and
oven) to a control device.
Note that the VOC concentration, Cc, here and in subsequent equations, is either
an average based on the number and duration of bag samples that are taken
: nteg"3t2G a\<2^93 "ucuc .. "jr'rjr1-. :• • - :
the period of the test.
b. Step 2: Construct a Temporary Enclosure with or without Additional
result of installation of additional fans or an increase in the capacity of
an existing fan ei* >r of which is contemporaneous with construction of the
enclosure.
c. Step 3: Determine Fugitive Emissions
(i) If additional ventilation is used, the air flow rates and VOC
concentrations shall be measured in all ducts, stacks or vents that do not
exhaust to a control device. The fugitive emissions mass flow rate shall be
calculated as follows:
Adcitionai ventilation ;s any exnausted from cne enclosure as a
m
F
1-1
Where: Of = the volumetric gas flow rate at standard conditions (m^/hp)
Cf = the VOC concentration at standard conditins (ppmv),
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32
i = each fugitive emission exhaust stack from the temporary
total enclosure (and oven), and
m = the number of fugitive emission exhaust stacks
from the temporary total enclosure (and oven).
(ii) If no additional ventilation is selected, tnen proceed directly
to Step 4.
d. Step 4: Determine Mass Flow Rate of Captured Emissions with the
enclosure in place.
The gas flow rate and VUC concentration shall be measured again in all
exhaust ducts that direct VOC emissions to a control device via the appropriate
analytical methods listed in paragraph 4.2.3. These measurements snail oe
made with the temporary enclosure in place and functioning. Simultaneously
the mass flow rate of fugitive emission (if any) must also be measured.
--&D iusUUiute IuUlUT-? -Iff-5 '11 :->flC7 • iS r,:i -;WS:
c
Where the subscript "e" denotes the mass flow rate of captured emissions
determined with the enclosure in place.
If no additional ventilation is used, F = 0, and the capture efficiency
equation becomes:
C
f. If Ec > 1.0 either the process was not at the same steady state with
and without the enclosure, or the imprecision of the individual gas-phase
had not been overcome by a sufficient number of measurements. If this situa-
tion occurs, the operator should either revaluate the process conditions and
repeat the test making more gas-phase measurements of both captured and
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33
fugitive emissions, or conduct the test according to paragraph 4.2.2.3.
4.2.2.3 Determination of Capture Efficiency wnen the Process is not
Generating Fugitive Emissions at a Constant Rate
a. Step 1: Determine Mass Flow Rate of Captured Emissions
Without the enclosure in place, the gas flow rate and VOC concentration
shall be measured in all exhaust ducts that direct VOC emissions to a control
device via the appropriate analytical methods listed in paragraph 4,2.4.
Measurements shall be made wni la tne process is emitting VOC at or near its
maximum rate. A minimum of three tests from 30 minutes to 3 hours in length
should be conducted for each set or process conditions. The mass flow rate
of captured emissions (C) snail be calculated for eacn set of process >.:na; ; or.s,
as foI lows:
n
- , r Qr, X CC;
Jhere: Qc = the average volumetric gas flow rate at standard condition
(m3/hr),
Cc = tne average VOC concentration at standard condition (ppmv)
j = each exhaust from the total enclosure (and oven) to
a control device, and
n = tne number of exhaust ducts from the total enclosure
(and oven) to a control device.
l>. Step 2: Determine Ventilation Rate and Size of Temporary Enclosure
(i) Estimate the highest total solvent vapor evolution rate expected
to occur inside the enclosure for eacn production or operating period during
the tes.t.
(ii) Identify the values of Qc and Cc that were measured for the
same process conditions in Step 1.
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34
(iii) Estimate the cumulative capture efficiency of the existing
capture devices including the oven.
(iv) Choose or estimate the maximum desired concentration of
fugitive emissions in the enclosure's fugitive exhaust duct or stack.
(v) Determine the ventilation rate from Figure 1 or calculate it by
the following equation.
n 1-EC* 0C Qc
0f" ~p4 x
c
where: Ec* = the estimated capture efficiency
- -u 'ii1 ^"npTf " ¦ ~ ''\t r.* ;r :t?nnu.rT! ' ^no~rv *
C = the VOC concentration at standard conditions (ppmv),
the subscript "c" denotes parameters of the captured-emissions stream,
i.e., the one directed to the control device, and the subscript "f"
lanotss -nr'meter* ~>f the 'uaitive emissions exhaust it.-sam.
^vi; Determine tne maximum cumulative area cf tne tempo* -y ;oxai
enclosure's NDO's by the following equation:
a . Qf (m^/hr) _ Qf (ft^/min)
n<^° 3600 m/hr 200 ft/mi n
Where: AncjQ = Maximum cumulative area of the temporary enclosure's
NDO'S, m2 (or ft2),
Qf « ventilation rate determined in (v), and
(vii) Determine the minimum surface area of the temporary total enclosure,
Ae, by the following equation:
Ae = 20 An(j0
c. Step 3: Construct a Temporary Total Enclosure
The temporary enclosure must meet all design and ventilating requirements
calculated in Step 2 or otherwise specified 1n paragraph 4.2.2.1.
Step 4: Determine Fugitive Emissions
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Concentration of VOC in Fugi !<¦.¦** Emission i . dust Stream
Concentration ot VOC in Gas ..i i eaoi Deliver.: i to the Control Device Cc
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35
The air flow rates and VOC concentrations shall be measured in all ducts,
stacks or vents that do nto exhaust to a control device, via the appropriate
analytical methods listed in paragraph 4.2.4. The fugitive emissions mass
flow rate, F, shall be calculated as follows:
m
Of. x Cf
1
F = Y. x
i = 1
Where: Of = the volumetric gas flow rate at standard conditions.(m^/hr),
Cf = the VOC concentration at standard conditions (ppmv)
i = each f'laitive emission exhaust -tack from the femoorar"
:nc:j3ur? ina ;ven>,
m = the number of fugitive emission exhaust stacks
from the temporary total enclosure (and oven), and
d. Step 5: Determine Mass Flow Rate of Captured Emissions with the
•i«c: r-.iir? n :•: ace -na ;,:ncT.: na js fn i 1 cws:
The gas flow rate and VOC concentration shall be measured again in
all exhaust ducts that direct VOC emissions to a control device via the
appropriate analytical methods listed in paragraph 4.2.3. These measurements
shall ^e made simultaneously with the measurements for determining the fugitive
emissions mass flow rate. The captured emissions mass flow rate, E", shall be
calculated by the following equation:
n
j
T » YL ^c-i x Cci
a 1 J J
Where: Qc = the average volumetric gas flow rate at standard conditions
(m3/hr),
Cc = the average VOC concentration at standard conditions (ppmv),
j » each exhaust from the total enclosure (and oven) to
a control device, and
n = the number of exhaust ducts from the total enclosure
ana )ven i :o 3 "nntroi levica.
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36
The subscript "e" again denotes the captured emissions mass flow rate
determined with the enclosure in place.
e. Step 4. Calculate Capture Efficiency (Ec) as Follows:
ce
F 1- Ce
4.2.3 (Alternate) Use tne Room that Houses the Afranted Facility as
a Temporary Total Enclosure
a. Step I: Determine Fugitive Emissions Mass Flow Rate.
Shut down other sources of VOC within the room. Using the appropriate
metnods specified in paragraph 4.2.4, measure the air flow rates and VOC
concentrations in all outlets to the atmospnere such as tne Duiiumg
ventilation system, windows, tne discharge vents from process ovens, etc.
m
C = Qf . * C f ,
Where: Qf = tne volumetric gas flow rate at standard conditions
(m3/hr),
Cf = the VOC concentration at standard conditions (ppmv),
i = each fugitive emission outlet or stack to the
atmosphere, and
in = the number of fugitive emission outlets or stacks
to the atmosphere.
b. Step 2: Determine the Mass Flow Rate of Captured Emissions.
The gas flow rate and VOC concentration shall be measured in all exhaust
ducts that direct VOC emissions to a control device via the appropriate
analytical methods listed in paragraph 4.2.4. Measurements shall be made
simultaneously with the measurements of fugitive emissions in Step 1 above.
The captured emissions mass flow rate (C*) shall be calculated as follows:
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37
C = I % x Cc
j = 1 J J
Where: Qc = the volumetric gas flow rate at standard conditions
(nr/hr),
Cc = the VOC concentration at standard conditions (ppmv),
j = each exhaust from the room serving as the total
enclosure and from the oven to a control device, and
n = the number of exhaust ducts from the room serving as
the total enclosure and from the oven to a control device.
e. Step 4. Calculate Capture Efficiency (Ec) as follows:
C
F + C
4.2.4 Analytical Procedures
The mass flow rate of VOC shall be determined for each emission stream
:r.a iovnnq i.?* necnoas :S ;atai :*a ' - Aouenai \ - :r :irr
(i) Method 1 (or 1A) for sample and velocity traverses.
(ii) Metnod 2 (or 2A, 2B, 2C, 2D as appropriate) for velocity and volumetric
flow rates.
(iii) Method 3 for gas analysis.
(iv) Metnod 4 for stack gas moisture.
(v) Any of Methods 18, 25, 25A, or 25B as appropriate for VOC concentration
5.0 Development of Baseline for Monitoring and Recordkeeping
During the performance test (or inspection of an enclosure to determine if
the capture efficiency test can be waived), the amperages on the fans that
evacuate the capture devices (or the total enclosure) as well as operating
parameters of the line such as speed, coating feed rate, etc., shall be
recorded. Subsequently, an inspector may compare these baseline values to
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contemporaneous operating values to ensure: (1) that the capture device(s)
(or total enclosure) continues to De operated at the conditions unaer wnicn
the performance test or evaluation was conducted, and (2) the affected facility
is not operating at rates that would generate fugitive emissions in excess of the
rate when the performance test or evaluation were conducted.
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APPENDIX B. SITE VISIT REPORTS
American National Can Company
Westvaco Corooration
-anyon ;.-;austr>!5s
Atlanta Film Converting Company
Printpack, Inc.
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AMERICAN NATIONAL CAN COMPANY
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MRI&
MIDWEST RESEARCH INSTITt
Suite
401 Harrison Oaks Boule
Cary, North Carolina 2"
Telephone (919) 677-f
FAX (919) 677-
Oace: rtay id, 1989
(Finalized October 20, 1989)
Subject: Site Visit—American National Can Company, Hammond, Indiana
Investigation of the Temporary Total Enclosure Method for
Measuring Capture Efficiency
EPA Contract No. 68-02-4379, Work Assignment 26
ESQ Project No. 87/07; MRI Project No. 8951-26
From: Stephen W. Edgerton ^ ^1-
v irrjn ~
d?A/C?3/CAj
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
I. Purpose
"ii!: :;'ta 'is" was :anauctaa :a garner -nronnat-:on rnr racarfn rrirs
;r.e cast ma aasibii'ty of ^snauc~ing -i :aptur« =f?^c:sncy *.asz re ::r-:
facility using the temporary total enclosure (TTE) protocol.
II. Place and Date
American National Can Company
Hammond Plant
2501 165th Street
Hammond, Indiana
February 8, 1989
III. Attendees
American National Can Company (ANC)
Robert Gere, Manager of Environmental Affairs
James E. Meadows, Litho Coordinator
Hugh Orr, Safety Coordinator
U. S. Environmental Protection Agency (EPA)
Karen Catlett, ESO/CPB
Candace Sorrel!, TSD/EMB
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2
Midwest Research Institute (MRI)
Stephen Edgerton
Roy Neulicht
Van R. Vogel
IV. Discussion
The visit began with a meeting among the attendees to discuss the
purpose of the visit and to go over the questionnaire sent to ANC in
advance of the visit. The meeting was followed by a tour of the
production facilities and an extended period of data gathering. During
this period, the operation of the process was observed, potential
measurement points were identified, the physical dimensions of the process
equipment and ductwork were measured, the plant layout and ductwork were
sketched, and VOC concentrations at various points in the plant were
measured using an OVA Model 128. A brief closing meeting was held to
discuss the proposed TTE design for the facility and additional data
The subsections that follow summarize the information gained from
the meetings and from observations made in the plant. Subsection A below
discusses process information. Subsection B presents information
pertinent to the use of the TTE protocol.
The ANC Hammond Plant primarily produces coated metal sneers that
are processed elsewhere into three-piece food cans. A minor portion of
the production is coated metal sheets used to make cans for automobile
servicing fluids (e.g., brake and transmission fluids), but this portion
of the business is decreasing as plastic containers replace metal cans.
The plant has coating lines and printing lines. (The number and type of
process lines and the plant operating hours are contained in item No. 1 of
the Confidential Addendum to this report.) At the time of the site visit
the norm was 5 days per week, and only three of the printing lines and
four or five of the coating lines typically were operated. However,
demand 1s somewhat seasonal, picking up in the summer when vegetables are
harvested.
The printing lines print the product logo on one side of the metal
sheet that will later be processed Into cans. These printing lines use
paste Inks that do not contain volatile organic compounds (VOC). However
a VOC-based varnish topcoat typically is applied over the ink; the varnish
application station 1s a VOC source. The VOC emission control system for
the printing lines is very similar to that of the coating lines. Because
the printing lines are shorter and less crowded than the coating lines and
do not present any additional impediments to conducting the TTE protocol,
it was agreed with ANC that the cost and feasibility study for this plant
would concentrate on the coating lines.
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3
The coating lines at the plant are located side by side. The can
stock enters the coating process as discrete sheets rather than being
unwound from a continuous coil. The size of the sheets varies from run to
run. The sheets typically are about 1 yard by 1 yard, but can vary up to
nearly 1.5 yards. At the time of the site visit, the average run at the
;lant lasted about 4 to 5 hours. The shortest run would normally take
about 1 hour. Catup 'z'r>z between -uns /-.r'as ibcut 1 2 /.cur-:.
(Additional Information on the average run at the time of the site visit
is contained 1n item No. 2 of the Confidential Addendum.)
A schematic of a coating line is presented 1n Figure 1. The sheets
to be coated are introduced to the process in stacks or "loads" of 1,200
to 2,000 sheets. The load of sheets is pushed along rollers to an
automatic feeder. The entire stack of sheets is placed in the feeder,
which parcels the sheets out horizontally one at a time to the coater.
A schematic of a roll coater is presented in Figure 2. The roll
:-atar ;2Dl\ ratine ts the side of the sheet destined to be the
.ncenor of cne can. "lie fzc: : -iy uses -ioouc 50 ¦¦if
formulations. The coatings are formulated to protect the can's contents
based on the chemical properties of the product to be contained 1n the
can. The coatings typically contain about four or five different
solvents.
:2at:nq • •• rumoea r-nm a :5-iailon irjm -.2 :^s roirtt :z
:na szaei .nersr^ng -*:! I '.na -.r.a r.ae! -ransr^r m s 1 'neet. ;ao :r.at •
set between these rolls determines the tnickness of the coating. A crip
pan beneath these rolls catches the coating that 1s not applied; this
coating 1s recirculated to the supply drum. From the transfer roll, the
coating 1s passed to the rubber application roll. The metal sheets pass
horizontally between the application roll above and the impression roll
below, picking up the coating from the application roll.
Because the process 1s sheet fed, a cleaning system is necessary to
remove the coating that is applied to the impression roll between the
sheets. Cleaning solvent 1s pumped from a bucket to a felt wick on the
underside of the impression roll. The .solvent, now containing the coating
that was applied to the roll, is scraped from the roll by a doctor blade
before the roll contacts the underside of another sheet. The cleaning
solvent drips Into a pan underneath the impression roll and drains back
into the supply bucket through a tube.
The coated sheets pass horizontally to the entrance of the drying
oven. As each sheet enters the oven, 1t is lifted from the underside by a
wicket and turned to rest on its leading edge in a nearly vertical
orientation. The coated sheets travel the length of the oven in this
vertical position separated by about 1.5 Inches.
The drying ovens have five independently controlled heating zones
with a total length of about 125 feet, followed by a 30-foot cooling
section. In addition, one section of the wicket return area (located
-ieneatn trie drying chamber of the oven) is heated to preheat the
-------
Incinerate. ¦*
Flasholl
Area '
HH
Supply
Cleaning
Solvent
Supply
Ducket
Coating
Supply
Drum
Wiclu i.
Fugitive Emissions
vaaa
JUUU
Wicket
Return
tlntranco
Figure 1. Schematic .1 a coating i ine.
(Modified to remove material claimed . mfldential i j ANC. The original
figure 1s contained in the Confl-i .i ial Addendu.., see item No. 3).
-------
Coating
Figure 2. Schematic of a i .-.t-fed roll jater.
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6
wickets. For each coating formulation, a particular "oven curve" is
specified to ensure that the coating is properly dried and cured. The
oven curve specifies the proper temperature of the metal sheet at each
point as the sheet passes through the drying oven. Thus, the temperature
settings for each zone of the oven must be adjusted for each coating.
The VOC emissions from each drying oven are controlled with a
deaicatec incinerator, (rtaaitional information on trie types :na .lumoer^
of incinerators at the facility is contained in item No. 4 of the
Confidential Addendum.) The exhaust gas from each oven's incinerator is
recirculated to the oven to provide the heat for all but the final heating
zone of the oven. The oven temperature is regulated by controlling the
amount of recirculation. The final heating zone has an individual gas
burner. The cooling section draws in ambient air from outside the plant
and exhajusts it to the atmosphere again. A schematic of a drying
oven/incinerator air handling system with an explanation of the
temperature control system is contained in the Confidential Addendum (see
Item No. 5). This material was supplied by ANC. It is general in nature
-liSer ^an '¦'ansnona int.
After leaving the drying oven, the dried sheets are stacked
horizontally on pallets. The coated sheets then may be printed on the
reverse surface or shipped to a canning plant for use.
3. Observations Pertinent to the "TE Protocol
.'he iffsc-au :z ilr ;c ration r-yxi i.it:ens .ds v ;
each coating line. In the past, the plant was under a compliance buoble,
but this 1s no longer the case. The VOC emission limitation is 2.8 pounds
of VOC per gallon of coating less water or 4.52 pounds of VOC per gallon
of coating solids. The plant complies through the use of complying
coatings and the use of add-on controls. Ouring the winter months when
the formation of ozone is reduced, no control is required. There are
three primary VOC emission points in each coating line: the coater, the
flashoff area, and the drying oven.
The coater includes two independent systems that generate VOC
emissions. The first of these is the coating supply and application
system. As discussed previously, the coating is pumped to the roll coater
from a 55-gallon drum, and the excess coating is continuously recycled to
the supply drum. Emissions from this system can occur at the roll coater
and at the supply drum, which is partially open. The supply drum 1s
located next to the coater on the right side of the line. (Throughout
this report, left and right will refer to the side of the line as viewed
from feeder end.)
The second coater system that generates VOC emissions is the
impression roll cleaning system. This system also has continuous recycle
and generates emissions from the area in the coater where the cleaning is
performed and from the supply bucket, which is completely open. The
supply bucket 1s located to the right of the coater next to the coating
supply drum. Whether the cleaning system is considered part of the
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7
affected facility 1s not entirely clear. For instance, it 1s unlikely
that the required formulation for a complying coating takes emissions from
the cleaning system into account.
The facility has a capture system for the VOC emissions from the
-cater. Air is drawn from the coater through two ducts from the hood on
top of cne coater and rrza c jzr .weep *2 lew -r.a zzzzzr. ricna'.
information on the coater capture system is contained 1n item No. 6 of the
Confidential Addendum.)
The coating and cleaning solvent supply containers adjacent to the
coater are sources of fugitive emissions. Some fugitive emissions also
are generated 1n the flashoff area, the portion of the line between the
coater and the entrance to the drying oven. This area 1s about 10 feet
long; it takes about 1 second for a sheet to pass from the coater to the
oven. Capture of emissions in this area is achieved only to the extent
that they are drawn into the drying oven entrance.
Trie drying oven .s :r.a ."nai .aurca of inns;tens - ;~3 ±v-'iqzzq
facility. The openings 1n the oven are the entrance, the exit, and a
series of gasketed access doors down the left side. The access doors
typically are kept closed during operation; the first access door may be
opened occasionally to extract sheets for quality assurance (QA)
'ctiv-ftias. The oven entrance is about 51 inches wide by about 22 inches
¦inn: :rrs ix:t ;ia :ns '.ist taattna iacrion is 'artier :ac2usa t:3 :naets
ir? i; y rz~.zzi is -.nay 2xit. cms ax it is tot ."•stbitf .zaczusa
of the cooling section, it must be about 4.5 feet by 4.5 feet. The access
doors are roughly 4.5 feet high by 2 feet wide.
The oven 1s operated at negative pressure to the surrounding room.
Face velocity measurements were conducted on one drying oven while the
coating process was down but the oven was opertlng. The inward velocity
through the oven entrance varied between 75 and 150 feet per minute at
various points across the opening when measured with the first oven access
door open. With the access door closed (as would typically be the case),
the maximum inward velocity at the oven entrance was 180 feet per
minute. No velocity measurements at the oven exit were possible.
Mr. Gere and Mr. Meadows Indicated that 1t 1s very obvious when air
handling system upsets cause the oven to be at positive pressure because
solvent odors are apparent. It appears that during normal operation no
fugitive emissions escape from the drying oven.
The primary sources of nonaffected VOC emissions 1n proximity to
each coating line are the other coating lines. The lines are separated by
a minimum of about 8.5 feet. The most serious potential problem with
Inability to Isolate affected emissions from nonaffected emissions comes
from the coater cleaning system. Emissions from this system cannot be
separated from affected emissions. Also, there are a number of other
cleaning solvent containers along the right side of the line, but these
containers are tightly closed and do not appear to present a problem
regardless of their affected/nonaffected status.
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8
A schematic of the process showing all emission sources and gas
streams has previously been presented in Figure 1. Figures 3 and 4
present more precise renderings of the process layout from top and side
views. These figures may not be completely accurate in every particular
but are close enough for realistic design of a TTE in the process area.
Not pictured are the coating supply drum, cleaning solvent supply bucket
and other cleaning solvent containers that are located along the right
side of cne i ¦ ;::q
lin^nrthrief"t!ncould5be rol'led^over'into'the half of-the aisle next to
the line being tested.
Durina changeover from one product to another between runs, the full
width of both aisles on either side of the coater must be used. The
I? L- :r« :ranaea -nm --a :£'nq :ns ;v<»rraaa :ru-n
."he :;eamr.g :yzzaa rsnoonnnzs ira ;nanaea .:ue -cm -jnr.
side.
A TTE would not pose any significant problems with personnel traffic
oatterns in the process area. The only personnel normally between the
itnSrire the operators. As indicated above, the operator for each line
riC?d SSke dl with half of each aisle. There 1s a larger, more generally
mcpH aisle running perpendicular to the coating lines at the feed end, but
the use of a TTE the process area would not affect traffic in this
aisle.
The flow of materials within the process was discussed earlier in
the subsection on process information. There are limited f ows to and
the suoseciion ur H supply drums are brought to the line one at a
vS as needed! 'The new drum 1 s brought to the 'feed end of the line by a
fnrw lift The drum 1s transported with a dolly down the right aisle to
1?r.pJ"irlISe location to the right of the coater. The spent drum 1s
then transported back up the.right aisle with the dolly. A drum of
coating lasts an hour or more..
i *j/i( nf chppts are brought to the feed end of the line by a
* nm Placed on the rollers leading to the feeder. Normally, two
1 oads are 1 °ned up on the rollers waiting for use. The forklift
comes to iSe line approximately every 15 to 20 minutes to bring a load to
replace the load being used.
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9
Top View
<3
o
Incinerator
Bumar
Combustion
Air Qua
T
:d«m rsr
^sin
Column
6
0 3 6
1 I I
Feet
48'
ri'nur° 3. Top view of line No. 22,
-------
Side View of Line 23
Feel
»nfidential l.y ANC. The original
figure is contained in the Confhkui la 1 Addendum -see Item No. 7).
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11
To change out rolls between runs or to replace a roll damaged during
a run, the rolls are transported to and from the coater on a wheeled cart
in the left aisle. Removal and replacement of the rolls is accomplished
using the overhead chain hoist.
The "Mnes adjacent to the one being tested would have identical
personnel and material trarfic patterns. These patterns generally would
not affect the use of a TTE that enclosed half of the aisle on each side
of one line. A possible exception would be encountered if the rolls on
the line to the right or the cleaning system on the line to the left must
be changed out during the test period. In either case, the entire aisle
adjacent to the line being tested would be required, possibly requiring
the TTE to be breached for the duration of the changeout.
The plant 1s required to meet OSHA standards regarding exposure of
personnel to solvent vapors; these standards would have to be met within
the TTE 1f workers were to remain inside during the testing. The
isnt-.r.-ras ina iODrnximata rjantitiss rf '".he solvents leased ? tt.s ':*3
TTE cne fugitive emissions; can oe usea co determine cne TTE
exhaust rate necessary to ensure that the atmosphere within the enclosure
meets the OSHA standards.
The plant 1s also subject to f1re-prevent1on requirements. The
~?cu7r**!]ent3 on maximum solyent vanor concentrations will not come "'ntc
::ay *-sr ".rse is :onq is ::*a 3SHA -itanaaras. ..men -ire nucn -orr»
stringent, are .net. The piant iiso :s r-jquirea cc use only i.xptcsion-
proof equipment 1n the coating room. Any equipment associated with the
TTE would have to meet this requirement. A sprinkler system 1s 1n place
at the plant near celling level. If the sprinklers were outside the TTE,
fire extinguishers would have to be placed Inside.
Hearing protection is already required 1n the coating room. It 1s
not expected that the TTE would appreciably affect the noise level in the
area. The temperature 1n the vicinity of the ovens sometimes reaches
100°F 1n the summer. The potential for elevated temperatures in the TTE
should be considered during the design of the TTE to allow for adequate
heat removal.
For purposes of testing, emissions from the coater cleaning system
cannot be isolated from other coating process emissions. If the cleaning
system 1s not considered part of the affected facility, this mingling of
solvent vapors could present a problem. However, the problem should not
be severe. The quantity of emissions from the cleaning system is likely'
to be small, possibly small enough to be Insignificant relative to the
solvent content of the coating. Emissions from this small source are very
unlikely to appreciably affect the capture efficiency measurement.
Nonaffected emissions also' could enter the enclosure 1n the makeup
air drawn 1n through the natural draft openings (NDO's). During the site
visit, ambient readings around the process area were 1n the range of 10 to
20 ppm as propane. Higher ambient levels around an adjacent line would be
'ikeiy. vnen tiia "Mne "'s cleaned between -uns. To avoid drawing In
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12
significant quantities of VOC at these times, NOO's should not be located
on the sides of the TTE near the coater, where the bulk of cleanup solvent
is used.
In order to measure capture efficiency, a minimum of three gas
streams would have to be tested simultaneously: the inlet to the
incinerator, the incinerator burner combustion air duct, and the exhaust
set up Co vent ens i i n ȣS > rem is 11E. i ne cdptui'so ciman ions nou iu
be the sum of the VOC in the incinerator inlet (drawn from the drying
oven) and the combustion air duct (drawn from the coater hood and floor
sweep); the fugitives exhaust duct would contain the fugitive emissions.
The incinerator inlet duct and combustion air duct are illustrated in
Figures 5 and 6, respectively. (Figure 6 is contained in the Confidential
Addendum—see Item No. 8.) Potential test points for each also are
illustrated. These ducts are suitable for VOC measurements and should be
suitable for volumetric flaw rate measurements, provided that cyclonic
flow is not present.
TthST* TUS "T.7*32JT1S I1' int u3 ^cT2d "'d:"*3.11'' ""r ^' **"**2ri
Because cm incinerator provioas :i:e rn3 'OC :cu 1 a :e tuctrsczsa :Hs ;i:.inf:r.v
neasursa -n :ne "•¦lyi'.r.'es jtrgam jotrun :na net ;CC r'ygi-r/es ..arsrira"
within the enclosure. The drying oven cooling section exhaust might be
checked to determine whether VOC is escaping from the final heating
section of the oven into the cooling section. All these gas streams
likely would be tested only for the VOC concentration that is present;
suitable test locations are sure to be available.
There is no indication that any compounds are present in the gas
streams that would Interfere with any EPA Methods for measuring VOC.
Thus, any suitable Method could be used.
Mr. Gere has supplied available test data from this facility and
data on the compositions of the most frequently used coatings. The
quantity of fugitive VOC generated by the process can be approximated from
the test results and an assumed capture efficiency of 90 percent. The
allowable VOC concentration within the TTE can be determined based on the
solvents that are used. From the approximate mass emission rates and
identities of the solvents, the appropriate fugitive exhaust rate can be
determined to ensure that the atmosphere within the TTE is safe for
personnel.
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<>
Incinerator
A/-
Drying
Oven
Catwalk
I
t
\
Figure 5. Incinerate inlet duct.
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14
V. Conclusions
It appears that a TTE' can be built at this facility. Midwest
Research Institute has proceeded with preparation of a detailed cost and
feasibility analysis for one coating line.
bl805—3/CBI
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WESFVACO CORPORATION
-------
MKI@
MIDWEST RESEARCH INSTIT'JT
Suite 3:
401 Harrison OaKS Bouleva
Cary, North Carolina 275
Telephone (919) 677-02-
FAX (919) 677-OC.
Date: May 12, 1989
vrinai.zed Jczcoer iu, i9c9)
Subject: Site Visit—Westvaco Corporation, Virginia Folding Box Division,
Plant 2, Richmond, Virginia
Investigation of the Temporary Total Enclosure Method for
Measuring Capture Efficiency
EPA Contract No. 68-02-4379, Work Assignment 18
ESD Project No. 87/07; MRI Project No. 8951-18
I. Purpose
:if.3 • iiit .'.as -lanductsd "3 gather nrornai:-:on -or ¦yjtzsrr.irr -r.
;:i3 -:zzz ma ; ity of csnauct":ng i caoturs irf ic: 3ncv :2sz -x :.w
facility using tne temporary total enclosure (TTE) capture efficiency
protocol.
II. Place and Date
Westvaco Corporation
Virginia Folding Box Oivislon
Plant 2
Richmond, Virginia
February 16, 1989
III. Attendees
Westvaco Corporation (Westvaco)
John Murphy, Plant Engineer
Commonwealth of Virginia (Virginia)
Pamela Faggert, Dept. of Air Pollution Control
Katherine Miller, State Air Pollution Control Board
From: Stephen W. Edgerton JS£-~
U - - - y
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
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2
U. S. Environmental Protection Agency (EPA)
Karen Catlett, ESD/CPB
Gary McAlister, TSD/EMB
Roger Shigehara, TSD/EMB
Cjnd&cs Sorr?1! ,
Midwest Research Institute (MRI)
Stephen Edgerton
IV. Discussion
At Westvaco's request, the visit began with a meeting among the
attendees (except the representatives of EPA/TSO/EMB, who arrived later)
to discuss compliance and testing issues. Ms. Catlett explained her
earlier comments on Westvaco's proposed liquid/gas capture efficiency test
i io_ - mr • .-.r- \r.d worlds'';.Z2d
autnority in compi lance matters dna cnat cneir comments on cnese .Tiattsrs
were general in nature and not authoritative. After this meeting, the
representatives of Virginia departed, and the EPA representatives of
TSD/EMB arrived a'short time later.
At this time, a meeting was held amcnq the remaining attendees to
'izccsi ".ns :ur?ose :r :na "".it ;na :o ;ver :r.a zuesfiannairr? -.ant 'c
ieszvaco n ^jvancs -:f :na /mi. . .'vs r,esz:rg ms tcwea zy i zur ;r
the production facilities and an extended period of data gathering.
During this period, the operation of the process was observed, potential
measurement points were identified, the physical dimensions of the process
equipment and ductwork were measured, and the plant layout and ductwork
were sketched. A brief closing meeting was held to discuss the proposed
TTE design for the facility.
The subsections that follow summarize the information gained from
the meetings and from observations made in the plant. Some additional
information and clarification have been obtained from telephone
conversations with Mr. Murphy. Subsection A below discusses process
information. Subsection B presents information pertinent to the use of
the TTE protocol.
A. Process Information
The Westvaco plant prints and cuts paper to manufacture boxes for
packaging. Products Include flip-top boxes and cartons for cigarettes,
boxes for cosmetic products, and boxes for fast foods. At the time of the
site visit, the plant had six operational production lines (Nos. 10
through 15); a seventh line (No. 9) was being Installed. The plant
operates 24 hours per day, 7 days per week.
The production lines are located side by side in a large room. The
basic process is very similar on all the lines. The paper 1s fed to the
process as a continuous web from the unwind equipment, passes through an
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3
eight-color rotogravure press, and is cut in line to the desired shape for
the finished boxes. The maximum web widths that can be accommodated by
the lines are contained in Item No. 1 of the confidential addendum to this
report. Line speeds vary by product and line. The range of line speeds
is contained in Item No. 1 of the confidential addendum. The lines were
installed between 1959 ana the present, with some modifications to some
equipment over the years. At the suggestion of Mr. Murphy, Line No. 13
was selected for in-depth study as the most difficult of the lines to
enclose because it is crowded 1n between the lines on either side.
The facility is a "job shop" that produces boxes in the design and
quantity specified by the customer. Product runs vary 1n duration from as
little as 15 minutes to as long as a week. A typical job requires about
1 day.
Setup time between jobs can be as little as 2 hours when only ink
:3lfor"i ir i :2UDle of the -otoaravurs cylinders rcust he changed.- lri
^xampia of iucn 4 cnange «outa ie switcning r'rom c.garstte ooxes :z ;a
sold in the U. S. to boxes destined for Hong Kong. A change from one
product to a completely different product can require as much as 12 to
18 hours. This period would Include changing all the rotogravure
cylinders, preparing inks and Ink delivery systems, preparing the die that
stamps out the boxes from the continuous web, adjusting the "delivery
Hjuisment'1 -.hat handles the cut Soxes far the dimensions af the -saw
;roaucr, ina i startup ;er?oa of aajusting cne various pracsss car.unetsra
until an acceptable product is produced.
The percentage of the time a line normally runs once 1t 1s up and
running properly is contained 1n Item No. 2 of the confidential
addendum. The line 1s stopped occasionally as necessary to correct any
problems that develop. The most frequent cause of down time is a problem
with the cutting die.
Attachment 1 is an equipment manufacturer's Illustration of an
eight-color packaging gravure line supplied by Westvaco. This
Illustration includes all available 1n-l1ne features; all these features
are not Included on all lines at Westvato. In the process description
that follows, the primary focus will be on the details of Line No. 13.
The unwind equipment used at the plant 1s of the "turn-over" type
pictured 1n Attachment 1. This configuration allows a replacement spool
of paper to be mounted on the equipment while the active spool is in
use. On Line No. 13, the maximum spool diameter 1s about 6 feet. From'
the unwind, the web passes through a "butt splicer" with which the end of
one spool Is spliced to the beginning of the next. On some lines at
Westvaco, a "festoon" follows the butt splicer. This equipment accumu-
lates a length of web to allow spool splicing to take place without
stopping the line. Line No. 13 does not have a festoon. The final unit
of the web feed equipment 1s a web guide/tension control. This apparatus
prevents the web from slipping laterally during operation and imparts the
proper tension to the web.
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4
From the feeding equipment, the web passes into the printing
equipment. All the lines at Westvaco have eight-color rotogravure presses
that consist of eight discrete print stations, each of which can apply a
single color ink or other coating. Some or all of the stations can be
active on any given job, depending on the number of colors or other
coatings that must be applied.
An equipment manufacturer's drawing of a typical print station
supplied by Westvaco is presented as Attachment 2. The lower portion of
the station is the printing deck. In rotogravure printing, the ink is
carried by indentions or "cells" engraved into the gravure cylinder.
There are typically 22,500 cells per square inch. The ink is actually
applied as dots but flows together on the surface of the web. The area of
coverage is determined by the pattern of the cells. Westvaco produces
about half of their gravure cylinders and purchases the other half.
The facility performs two types of printing. In "line" work, solid
:alor"? are used. a.nd the ^reas of coveraae have sharo
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5
After the gravure cylinder emerges from the ink pan, the cylinder
passes under a doctor blade that scrapes the excess ink from the surface,
leaving ink only in the engraved cells. The ink is transferred from the
gravure cylinder to the web as the web passes between the gravure cylinder
below and the imoression cylinder above.
From the printing deck, the web passes into the print station's
Individual drying oven located on top of the printing deck. The
configuration of the drying oven is illustrated 1n Attachment 2. At this
facility, the drying ovens on six of the lines are direct fired with
natural gas burners; the dryers on the seventh line are heated with
electrical elements. The dryers contain a series of impingement tubes
through which heated air .is blown onto the printed surface of the web to
dry it. Part of the air is recirculated past the heat source; part of the
air is exhausted to a common carbon adsorption emission control system.
"he ''01 time nf the exhaust itrsanr *s letarmined :-v *n automat-•-
damper controlay a /OC concentration sensor. Hie camper centre; i :
set to maintain the VOC concentration at 30 percent of the lower explosive
limit (LEL). However, the concentration frequently varies from this
value. When the print station is applying very light coverage (I.e., very
little of the web surface receives the color being applied by that
station), the VOC concentration will be well below the target value
because i .uinimum exhaust -ita nust oe maintained "a ,
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6
B. Observations Pertinent to the TTE Protocol
The affected facility to which air pollution regulations apply is
each production line. According to Mr. Murphy, each affected facility
includes the associated mixing area, which is located in the pressroom
adjacent to the line. The newest line is required to achieve the "lowest
achiavable emission rate" (LA£R). In Virginia for this type of operation,
LAER is defined as an emission reduction of 73 percent. The remaining
lines are required to meet "reasonably available control technology"
(RACT) guidelines. The required RACT control level for this process is
normally 65 percent control, but Westvaco has accepted a requirement of
68 percent control to offset the annual emission increase associated with
the newest line.
The facility complies with these emission limits through the use of
a carbon adsorption system to control emissions. Compliance is demon-
strated through weekly and monthly liquid material balances across all the
Mnes combined, "n iccount^na system has bean instituted to track all VOC
introaucaa C3 cr.e ocas'rig . 'nss ina a,; . .uC ¦accv^r'sa yj --2
adsorption system. All drums of coating and solvent are assigned a unique
identification number. These drums and the quantity they contain are
logged into and out of storage; records are kept on the VOC input to the
process by line and job. The VOC content of the inks consumed is computed
from formulation data. Solvent lines from bulk storage tanks to each line
ir° uetared. "he recover®*! solvent ?s tnckad throuqh beards "f il"
iaait-.ons. - ana ,»itn3rawais -rasn :^e recovers ;civent itoraqe :anxc.
Recovered solvent is analyzed by gas chromatograph 'to determv.ie ;ne irncunc
of each individual solvent that is recovered.
The cutoff for the weekly material balance .is 7:00 a.m. each
Wednesday. At that time, each line is inventoried to determine the
quantity of ink and solvent present at the line, and the bulk solvent
meter readings are recorded. The recovered solvent storage tank records
are compiled. The records of VOC input and recovered for the week are
compared to determine the recovery efficiency. This value is compared to
a target recovery value for each week that 1s computed as a weighted
average according to the solvent used on the LAER and RACT lines. Weekly
data are compiled to compute the monthly material balances and target
recovery values.
Included in the material balance is a solvent destruction credit of
8 percent for the lines with direct-fired ovens. This destruction credit
was established through a liquid/gas material balance that compared the
liquid solvent entering the process to the quantity of carbon dioxide and
carbon monoxide 1n the exhaust. After accounting for the combustion of
the natural gas Input during the test period, the quantity of solvent
combusted in the drying ovens was back-calculated from the amount of
carbon dioxide and carbon monoxide in the exhaust.
Mr Murphy indicated that the weekly and monthly material balances
(Including the solvent destruction credit) typically yield plant wide
overall control efficiencies 1n excess of the 73 percent required to meet
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7
LAER. However, the example weekly balance provided by Mr. Murphy
indicated a plant wide level of about 69 percent.
The primary VOC emission points in each line are the eight print
stations and the ink mixing area. Within each print station, emissions
can occur from the p-'-ting Jack, tha r'i£hcfr :raa, :r.d t!-.a Jry'ng w/ar..
Emissions from the printing deck are most likely to occur from the
area where the ink.is applied to the surface of the gravure cylinder.
This area includes the point where a cascade of ink flows over the
cylinder surface, the ink pan or sump, and the point where the doctor
blade removes the excess ink. Some emissions are possible from the ink
supply tank located on the floor by the print station, but these emissions
should be minimal because these tanks were observed to be well covered
during operation. After the ink is transferred to the web, there is a
short flashoff area prior to the entrance of the drying oven immediately
above the orintina equioment.
There is no capture system per se for the emissions from the
printing deck and flashoff area. However, as shown in Attachment 2, the
entrance and exit slots of the drying oven are located just above these
areas, and the airflow at these slots is inward into the oven. Capture-
through entrainment 1n this dryer makeup air is enhanced at this facility
':v ^ior-'-: -raped so as to causa the .uakeuo air to be drawn or 1 marl',- '-on
:r.a «ner>? emissions ^ccur.
The drying ovens are the primary emission points from the printing
lines. Generally, the only openings in the drying ovens are the entrance
and exit slots. The first two dryers on Line No. 13 are exceptions; cne
top sections of the dryer hoods on these dryers are open as well. The
drying ovens are exhausted to the carbon adsorption system. The exhaust
rate is varied depending on the VOC concentration, but a minimum exhaust
rate is maintained to ensure that the direction of air flow at the dryer
openings 1s inward. For this reason, it is unlikely that fugitive
emissions escape the drying ovens. A possible exception would be the
first two dryers on Line No. 13. However, these drying ovens are not
equipped with automatic dampers; presumably the dampers have been set so
that an adequate exhaust rate is maintained to avoid fugitive emissions
from these dryers.
In addition to the emission points on the printing line itself,
emissions occur 1n the ink mixing area adjacent to each Une. At this
facility, this equipment is considered part of the affected facility. Ink
and solvent drums are held in this area for mixing the inks in use for the
current job. Metered solvent lines also serve each printing line's mixing
area. Orums are placed on copper grounding boards as a fire prevention
precaution. Agitators for mixing the Inks are Inserted Into the drums and
attached to supports that extend upward from the grounding boards. The
drums 1n which mixing occurred during the site visit were not covered
during mixing. Emissions 1n the mixing area are not controlled except to
the extent that they contribute to the ambient pressroom VOC concentration
and are drawn into the drying ovens 1n the makeup air. A floor sweep that
•ents ¦•O ;Me itaiosoner? j iocatea :n• eacn mixing area.
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3
The only sources of nonaffected emissions noted during the site
visit were the other printing lines in the pressroom. Presumably,
cleaning solvents are used to clean the presses between jobs. These
emission sources also are not expected to be part of the affected
faci1ity.
A schematic r-cv^2d ;tsrn
presented in Attachment 3. This schematic is not intended to present the
plant layout accurately. The mixing equipment is not included in the
schematic, although the floor sweep is pictured. Another airflow that is
not included in the schematic .is a fire prevention system. The lines each
have electrical control boxes. In order to avoid a potentially hazardous
concentration of VOC from contacting the electrical equipment, each line's
control boxes are kept under positive pressure by an individual ventila-
tion system that draws air from a low-concentration area of the
pressroom. While these systems simply recirculate air within the room,
this airflow could figure in TTE design.
- 'Karen :r ' ivcuz .. :*3 'o. t :nsenr2a " /..n .,
purpose of"the sketch is to present the features to be considerea in
designing a TTE for the facility. For purposes of clarity, the large
quantity of ductwork, pipe, electrical conduit, light fixtures, and
support structures located above the print stations and aisle to its left
has not been pictured. (Throughout this report, left and right will refer
<•3 s-;jg nf i**ng a* v-'awed tha unwind and. 1 However, !t
;p,\' ;C~3n"!0T. z zvrx „ '-liX.ens ^ • '..r. t o'j,
02 very divficuic ana «ouia require d great aeai of piecing cc icccrcmcaa-ca
these obstructions. Some representation of the ducts, etc., has been
included at the ends of the line to indicate the obstructions for the TTE
end walls. At the unwind end of the line, the obstructions are fairly
accurately presented in number and location, but at the cutter end, the
obstructions shown are meant only to be indicative of the profusion of
obstructions actually present. The line is equipped with an automatic
carbon dioxide fire suppression system that has not been pictured. The
outlet nozzles for this system are located on each print station and above
the mixing equipment. A water sprinkler system extends throughout the
pressroom near celling level. Also not pictured are large I-beam roof
supports that run parallel to the printing line at the top of the I-beam
columns shown 1n the sketch.
The press operating crew typically consists of an operator and two
apprentices. These Individuals handle the unwind and feed equipment, the
print stations,' the cutter creaser, and the mixing equipment. In addi-
tion, there are typically two or three "Inspectors" that receive the cut
boxes, check for flaws, and stack the cut boxes in larger cartons for
shipping.
The operator and apprentices work 1n the aisle to the left of line,
between the printing line and the mixing equipment. A wide aisle is
maintained because the print stations are accessed from this side. The
qravure cylinders are changed out in the aisle, so the aisle must be
sufficiently broad to accommodate the breadth of the cylinders plus allow
¦materials and equipment to be moved into and out of the area.
-------
Automatic DnmjM.f
Controfois
[
is Lino 13 A r- Cokimn
y a y y jj
CiiUd>lk
Cutting and
Slacking
U U a U AJ AL
nmnoDj
\
Cokimn
8 Print Stations
i i
ly.j. Duels. -J Eloclrical -1 Worit
taiiiW, Elc. Control Box Table
Calwolk—\ ..
i— 11<». i
Supply Alt I fociangular Dud
I tfllil Flutmo
24'
lli>.. 13 Mixing Drums _-p|pe Eloc. CoiwinH
Cabinal (loot
Swoop Column
Exhaust Solvonl
Unas
to:
—^ 1 AuI.ii.iiik. Ci
ilunnl—I lof E«i.l"*itl I
llna U
Contiollois
Dampers on
- Column (I Boam)
120*
flight
Cutter End 4-
10*
201.
-+¦ Unwind End
tail
Figure 1. Top view of Line No. 13, We^i.jco Corp., Ri.nmond, Virginia.
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10
During operation, the operator and apprentices need access to the
unwind equipment to mount new paper spools, to the butt splicer to splice
the new spool to the old (the line is stopped for this process on Line
No. 13), and to the web guide/tension control to make any necessary
adjustments. Access to the print stations during operation is necessary
to replenish the ink supply tank and to make any adjustments required for
proper color registration, in addition, soire operators prefer tc monitor
and correct ink viscosity manually rather than relying on the automatic
viscosity adjustment system. Access also is needed at the postpress web
guide and at the cutter creaser when adjustments are required for proper
registration of the cuts with the printed colors. Finally, the operator
and apprentices need access to the mixing equipment to prepare the inks
and to transfer ink to the printing equipment.
The inspectors need access to all areas of the delivery equipment
during operation. Jams must be cleared from time to time, and minor
adjustments are sometimes made. The operation crew and the inspectors
need visual access to one another to sianal when Drocess adjustments are
,-eeaea.
Except for workers who need to move ink drums, spools of paper, and
finished goods to and from the presses as described below, there is little
need for individuals other than those assigned to a particular line to
have access to the line. Workers from adjacent lines do not need to enter
the area Jn the -:ur^e if their -*qular duties. The ?xcect"cn to th:s
is * s mat ~rcs ^acn ;ay :.~s automatic; aaraoer :sntrc i osxas ;r ~xcr. ' r-a
must be checked. These control ooxes are accessed r'rom a catwaik running
parallel to the print stations immediately to their right. In the case of
Line No. 13, the space between lines is so restricted that the mix
equipment for Line No. 13 is located beneath the catwalk for Line
No. 12. The only other personnel entering the immediate area of a line
would be supervisors that occasionally check on the operation.
The personnel access and traffic patterns do not appear to present
any major problems for construction of a TTE around Line No. 13. Because
the mixing equipment is considered part of the affected facility at this
plant, the TTE would be expected to include the press, the mixing equip-
ment, and the aisle between. Thus, the operator and apprentices would
generally remain within the TTE during testing, and access to the
equipment would not be hindered. Also, the doors into the TTE would
seldom be opened during a test run.
The flow of materials within the process was discussed earlier in
the subsection on process information. There are limited flows to and
from the process. Ink and solvent drums are brought to the.line one at a
time as needed. The drums are transported to the mixing area with a
dolly. Spools of paper are brought with a fork lift through the large
aisle that runs along the unwind end of the lines to the vicinity of the
unwind equipment. From there, the spools are maneuvered into place by
hand. A.spool typically lasts about 1 hour. At the cutter end of the
line* the cartons of cut boxes are loaded by hand onto a pallet; when the
pallet is full, it is taken to storage with a dolly. A pallet is filled
about everv £5 minutes.
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11
The flow of materials in the plant does not appear to present major
problems with constructing a TTE. Depending on placement of the TTE,
doors may have to be opened occasionally to accommodate flows to and from
the line, but such occurrences should be brief and infrequent. Material
flows on adjacent lines will not imoact the use of a TTE.
The plant is required to meet OSHA standards regarding exposure of
personnel to solvent vapors; these standards would have to be met within
the TTE. The identities and approximate quantities of the solvents
released into the TTE (I.e., the fugitive emissions) can be used to
determine the TTE exhaust rate necessary to ensure that the atmosphere
within the enclosure meets OSHA standards.
The plant is subject to the City of Richmond fire safety
requirements. These requirements are drawn from NFPA guidelines. In
addition, the facility's insurance carrier holds the plant to the Factory
"'ijtual rira >afaty "?auir,»ments. discussed ibove. the U2S a.
piancwiae sprinxier system, a localized caroon dioxide system, and a
drying oven alert/shutdown system for fire safety. The TTE would have to
be built so as to not interfere with the functioning of these systems.
Despite the care taken to ground the equipment, fires do
occasionally occur at this facility. Mr. Murphy Indicated that the
"~*auency /ar:ss rcnsideraol./ :ut iverages ircund ^ncs :er -ncnth. "hasa
r-'ras ira cypicai \j axr^rgu-; •tned .-aoidly ay trie carnon dioxide systanj.
Mr. Murphy expressed concern for the workers in a TTE if the carbon
dioxide system were triggered, primarily 1n regard to having adequate
oxygen to breathe. However, it 1s unlikely that this would be a major
problem at this facility because the volume enclosed by the very large TTE
required to include the mixing equipment would not differ greatly from the
situation 1n the absence of the TTE.
Hearing protection 1s not required 1n the plant; it 1s not expected
that the presence of the TTE would appreciably affect noise levels. Heat
buildup is not expected to be a major problem despite the fact that the
drying ovens must be enclosed 1n the TTE; ambient heating in the vicinity
of the dryers was not noted during the*s1te visit. Again, the large
enclosure needed at this facility would not be expected to trap heat much
1n excess of normal. A possible exception could occur during the hottest
part of the summer when large room ventilation fans are sometimes used.
For purposes of testing, there are no nonaffected emission points in
such close proximity to the process line that they must be Included in the
TTE. Nonaffected emissions from the adjacent lines could enter the
enclosure in the makeup air drawn 1n through the natural draft openings
(NDO's). According to Mr. Murphy, the ambient level 1n the plant is
normally about 25 parts per million. T.o minimize the quantity of VOC
entering through the NDO's, the NDO's should be located toward the ends of
the line rather than along the sides where the printing and mixing
equipment of the adjacent lines would be 1n closer proximity.
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12
The number of gas streams that would have to be tested to determine
capture efficiency would depend upon the extent of the TTE. In any case
the "captured emissions" would be measured in the common exhaust from the
drying ovens of the line to the carbon adsorber. Also, the floor sweep
exhaust from the mixing area would be expected to be within the TTE and
would have to be tested. It is likely that the pneumatic scrap conveyina
system p'^kupc »1jO ^rvjlri be w'th^n the TT^. if e0> gJ£ str^m vct'ld
need to be tested. If a supplemental fugitive emission exhaust is~
required to meet OSHA exposure standards, this stream also would have to
be tested. The sum of the emissions in whichever of the latter three gas
streams originate inside the TTE would comprise the fugitive emissions for
the capture efficiency calculation. The captured and fugitive emission
measurements would have to be made simultaneously.
The ducts involved appear to afford suitable measurement points for
VOC concentrations and volumetric flow rates. The common duct from the
Line No. 13 dryers to the main carbon adsorber duct is a round duct with
diameter of 24 or 28 inches; this duct has a straight run of about 16 feet
;rs :ne ;Unt —sr. "r.e "":or :'.*eec rjcr '"is i :i.imetar of '.2 •' -r-3c;
ports are already present at a level about 12 feet above the floor
accessible from the catwalk on Line No. 12. The fan for the floor sweep
1s located at the top of the duct above the plant roof. The supplemental
fugitives exhaust, 1f needed, would be constructed to be testable. The
suitability of the pneumatic scrap conveying duct is not so certain. This
duct was not examined during the site visit because it was considered
.,ii:keiy :ne ::c:cuc vftu;c :e .•*izn-.r, :r.s However. —
of the TTc criterion -'or reparation of cne NOO's from emission pcints."-ovv
make Inclusion of the pickup likely. A suitable test point is probably
available; if not, modifications could be made to provide one.
Other gas streams also might be tested or periodically monitored.
The VOC concentration within the TTE must be monitored to ensure that
steady-state conditions are reached and that OSHA standards are not
exceeded. The ambient VOC concentration outside the NDO's might also be
monitored to determine the significance of VOC entering through these
openings. Finally, the volume and VOC concentration of the air forced
into the line's electrical control boxvmight be measured or monitored to
determine the significance of this gas stream on VOC measurements and the
velocity of the air drawn inward through the NDO's. It 1s expected that
suitable testing/monitoring points can be found for all these gas streams.
There are no indications that any compounds are present 1n the gas
streams that would Interfere with any EPA Methods for measuring VOC.
Thus, any suitable EPA Method could be used.
The use of recirculating, direct-fired drying ovens at this facility
presents a complicating factor 1n determining the true capture efficiency
at this facility. Normal gas-phase measurements will not account for VOC
destroyed as dryer air 1s recirculated near the burner flame. This may be
significant at this facility where a past I1qu1d/gas material balance
Indicated that 8 percent of the total solvent Input Into the process was
destroyed 1n the drying ovens. However, it should be noted that destruc-
-------
13
tion of VOC in direct-fired drying ovens is not normally accounted for by
any capture efficiency determination method. In fact, the TTE protocol,
in which only gas-phase VOC measurements are made, will minimize the error
resulting from solvent destruction compared to methods that use liquid
mead .res of the VOC available for capture by the capture system.
V. Conclusions
It appears that a TTE can be built at this facility. Midwest
Research Institute has proceeded with preparation of a detailed cost and
feasibility analysis for Line No. 13.
It should be noted that conducting a caoture efficiency test using a
TTE at this facility would be somewhat difficult because of the size of
the area that must be enclosed, the number of obstructions about which the
TTE walls would have to be pieced, and the number of gas streams that
would have to be tested. For this reason, a liquid material balance might
2^ : 2 '"*7- "2^31 n 1 re 'crno 1 inc2 : ~ ~ 2 7 ~ d "
all parties (Westvaco, the State of Virginia, and EPA Region III) could De
developed. The shortcoming of this approach is that line-by-line control
efficiencies cannot be obtained because the solvent recovery system serves
all the process lines. Thus, unless some method of differentiating the
recovered solvent by line of origin can be developed, the compliance
status of the "Hne subject to LAER cannot be determined 'ndividual'y as
:y :ne err'orcsnient ;oi:cy -'sr .lonat'ainnjent iraas:
3 Attachments
b2605-l/ESD
-------
-------
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Attacninent 2
Bobst Champlain Gravure Unit
and Dryer System
STANDARD
LENGTH DRYER
DRYER HOOD
IDLER
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IMPINGEMENT TUBES
TO
COLOR UNIT 8
DOCTOR
BLADE
PRINTING DECK
PHOTOELECTRIC SCANN:
IMPRESSION ROLLER
INK APPLICATOR
ENGRAVED CYLINDER
FROM
COLOR UNIT 6
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-------
KENYON INDUSTRIES
-------
MRII$)
MIDWEST RESEARCH INSTTTU
Suite .
-01 Harrison OaKs Bouiev
Cary, Nonn Carolina 27
Teleonone (919) 677-C
FAX (919) 677-C.
¦3ata: May 12, 1989
(Finalized April Z7t 13SG)
Subject: Site Visit—Kenyon Industries, Inc., Kenyon, Rhode Island
Investigation of the Temporary Total Enclosure Method for
Measuring Capture Efficiency
EPA'Contract No. 68-02-4379, Work Assignment 18
ESD Project No. 37/07; MRI Project No. 8951-18
(Finalized under Work Assignment 26; MRI Project No. 8952-26)
From: Stephen W. Edgerton
EPA/CPB/CAS (MO-i:)
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
I. Purpose
"i:ita Hsi~ *as -isnoucrad :c gather 'nfarwation .^r latanrlni-Kj
cne cost ana feasibi i rcy of c3naucc:ng \ .zapvurs afflClancy tast xz ~.rr.~
facility using the temporary total enclosure (TTE) capture efficiency
protocol.
II. Place and Date
Kenyon Industries, Inc.
Kenyon, Rhode Island 02836
February 28, 1989
III. Attendees
Kenyon Industries. Inc. (Kenyon)
Pete Nielsen, Vice President—Engineering
U. S. Environmental Protection Agency (EPA)
Karen Catlett, ESO/CPB
Candace Sorrel 1, TSO/EMB
Midwest Research Institute (MRI)
Stephen Edgerton
'drun '"atlatt
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2
IV. Discussion
The visit began with a meeting among the attendees to discuss the
purpose of the visit and go over the questionnaire sent to Kenyon in
advance of the visit. The meeting was followed by a tour of the
production facilities and an extended period of data gathering. During
this period, the operation of the process was observed, potential
measurement points were laencified, cne physical dimensions of tne process
equipment and..ductwork were measured, the plant layout and ductwork were
sketched, and photographs of the process area were taken. A brief closing
meeting was he>ld to discuss the proposed TTE design for the facility.
The subsections that follow sumtiarize the information gained from the
meetings and from observations made 1n the plant. Subsection A below
discusses process information. Subsection B presents information
pertinent to the use of the TTE protocol.
A. Process Information
The Kenyon plant performs faDric rinisning, drying, printing, ana
coating. The coating lines generate emissions of volatile organic
compounds (VOC) and were the objects of the site visit. The facility has
six coating lines. The plant operates 24 hours per day and 5 to 5.5 days
per week.
oe :nree widest ma i*ssz :car:nq :ines Hos. 1. .ma :* ir**
located sice oy iide .n one rcora of cne ptant. The .arger , ines v'tas. -r,
5, and 6) are located side by side 1n the main coating room. All the
coating lines consist of floating knife coaters followed by infrared
drying ovens. Line 3 has only one coater and drying oven. Lines 1, 2,
and 6 each consist of two coaters and two drying ovens. Lines 4 and 5
each have four coaters and four drying ovens. On the lines with multiple
coaters and ovens, the fabric web 1s alternately coated and dried as 1t
passes sequentially through a coater, a drying oven, then to the next
coater and drying oven, and so on until it has passed along the entire
line. Because lines 4 and 5 are the largest and most complicated of the
coating lines, these two lines were most closely observed. The balance of
this report will concentrate on these two lines.
Kenyon is a commission coater, coating its customers' fabric to
order. As a result, coating runs vary in length and tend to be rather
short. Much of the production is for use in outdoor products such as
tents, backpacks, and parachutes. These are specialty items for which
aesthetics (color, finish, etc.) and performance are very important. Runs
vary between about 3,000 and (rarely) 100,000.yards, with shorter runs
predominating. Normally, the maximum duration of a run for a single order
would be about one shift. Sometimes orders can be grouped for longer
runs.
The fabrics that are coated are mainly synthetics such as nylon and
polyester. The coatings are solvent-based polyurethanes that contain
about 50 percent solvent by weight. The solvent blend used 1n the
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3
coatings is predominantly toluene with a small amount of isopropyl
alcohol. Very small amounts of other solvents (e.g., methyl ethyl ketone)
are sometimes used to adjust the drying rate. The typical line speed is
10 to 11 yards per minute. The maximum web width is 70 inches.
A schematic representative of lines 4 and 5 is presented in
Figure 1. The continuous web is unwound at one end of the line and passes
through an accumulator. As one roll of fabric nears its end, this device
accumulates a_.length of web so that the end of the roll can be spliced to
the beginning of the next roll without stopping the line. From the
accumulator, the web passes under a low catwalk about 1 foot off the
floor. This catwalk affords the operator access to the coater from the
front. After the catwalk, the web is routed vertically upward and then
horizontally through the first coater. These coating lines use floating
knife coaters in which the fabric is held against the coating knives by
the tension created in the web as it is pulled through the coater. From
the coater, the web oasses into the first drying oven near the top.
.ns~aa a .vqn, :ne coataa veo •aaices "wo .lorirontai trying :assas.
forward near the top of the oven, then back toward the coater at the
mldlevel of the oven. After the second drying pass, the web is turned
again and passes forward to the second coating station. On line 5, the
final forward pass to the next coating station occurs within the drying
oven near the bottom as illustrated in Figure 1, but no heating elements
ire positioned f^r drying during this aass. On line 4, the dryina :vens
iave jesn nocnr^a :a znat :he oven -"aor sieyatea iDove :ne :;am:
floor. The web exits the front end of the oven after the second drying
pass and 1s then routed under the oven to the next coating station. The
coating and drying process is repeated in series down the line until, upon
exiting the final drying oven, the coated web is directed to a direct-
_f1red propane curing oven located at ceiling level and then to the rewind
'station.
Coating is delivered to the web directly 1n front of the coating
knife, either by pump from a 450-gallon "tote" or 55-gallon drum or
manually poured from a pall. The coating 1s manually poured when the run
is too short to justify pump cleanup time or when the coating is too thick
to pump. The supply totes and drums are 'located 1n the aisle to the left
of the line. (Throughout this report, left and right will refer to the
side of the line as viewed from the unwind end.) The coating in a pail is
replenished from a 55-gallon drum in the left aisle.
The forward motion of the web holds the bank of coating against the
knife; adjustable barriers or "dams" contain the coating on the sides.
The coating is periodically replenished as 1t 1s used. When the coating
is pumped, the pump is adjusted to maintain a fairly constant quantity of
coating at the knife to ensure that the coating 1s applied evenly.
Lines 4 and 5 have very different emission control systems. These
systems are discussed Individually below.
The four drying ovens on line 4 operate under a nitrogen atmosphere
ana ;rs sacn centra ilea with m individual recirculating, condenser.
-------
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-------
5
schematic of one oven on line 4 supplied by Kenyon is presented 1n
Attachment 1.
The ovens on this line have been extensively reworked to enhance the
operation of the control system. The roll Inside a drying oven that most
fluently must be adjusted or replaced is typically located just inside
the oven entrance slot. Gaining access to this roll in a typical inert
atmosphere oven necessitates first purging the oven, resulting in a loss
of solvent and. nitrogen. On this coating line, each oven has been
shortened on the front end so that this roll is outside the oven
entrance. As-mentioned earlier during the description of the coating
process, the ovens on this line have been modified to elevate the oven
floor above the floor of the room. These two changes to the ovens have
reduced the size of these ovens and have lowered their nitrogen use and
energy requirements.
The shorteninq of the ovens on the front end also has increased the
sngtr. or cne r"! isncr* iraa (;.a.. :ha iraa oatween -rsa :satar ins -ra
drying oven entrance) by an equivalent amount. To capture emissions from
the flashoff area, a "vestibule" has been built between the coater and the
oven. The vestibule is constructed of sheet metal and encloses
approximately the same volume that was inside the drying oven before the
oven was shortened. The coated web enters the vestibule about 1 foot
if tar -Sa tnat-fnq '
-------
6
supplies fresh makeup air to the room in the vicinity of this coating
line.
On this line, each of the four flashoff areas is enclosed in a sheet
metal box that 1s flush with the oven wall and extends beneath, to the
sides, and above the flashoff area. The top of the flashoff area
enclosure 1s hinged and counterweiqhted so that it can be lifted for
visual and pnysical access to the bacic of tne coating Kmfe ana the rlasn-
off area. The-front surface of this enclosure lid closes onto the top of
the coating knife, leaving a slot about an Inch high between the top of
the knife and the lid. When the enclosure I1d is closed, the makeup air
drawn into the drying oven through the web entrance slot (which is within
the enclosure) enters at a velocity of about 300 feet per minute as
measured by Kenyon with a handheld velometer. This airflow is designed to
capture any emissions from the bank of coating on the front of the coating
knife; the emissions are carried into the drying oven with the makeup
air. When the enclosure lid is open, the cross-sectional area of the
ooening into the enclosure is much larger, greatly reducing the inward
iirf'ow velocity; :.ta nwars it *ucn tines f—;m ths ;nt,
sides, and top. No test data are available on tne capture efficiency of
this system. The Incinerator has been tested by the Rhode Island
Oepartment of Environmental Management at a destruction efficiency of
94.5 percent.
9. Ibs&r'ztlcns ?<*rt:nent to the TTE P~otccol
As mentioned in the previous subsection, line 4 is iuiiaoie for d
liquid/liquid material balance system of tracking emission reduction
efficiency. For this reason, this subsection win concentrate on line 5,
where a capture efficiency determination might reasonably be expected to'
be conducted.
The affected facility to which air pollution regulations apply is
each coating line. According to Mr. Nielsen, the curing oven 1s excluded
from the affected facility because the solvent has been dried from the
coated web before 1t enters the curing oven. The VOC emission limitation
is 2.9 pounds of VOC per gallon of coating (less water). The plant
complies on line 5 through the use of a thermal incinerator to destroy
emissions. There are three primary types of emission points on the line:
the coaters, the flashoff areas, and the drying ovens.
Line 5 has four coating stations. As discussed previously, at each
station the coating is pumped or poured onto the web immediately 1n front
of the coating knife. Emissions can occur at the coating knife and at the
coating supply vessel, which may be partially open. Much of the VOC
emitted at the coating knife is likely to be captured 1n the oven makeup
air drawn into the flashoff area enclosure through the slot immediately
above the coating knife. Emissions from coating supply vessels are
fugitive emissions that are captured only to the extent that they are
carried Into the drying ovens with the ambient room air as oven makeup
air.
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7
The flashoff areas on line 5 are each contained 1.n an enclosure as
described 1n the previous subsection. Virtually all emissions in these
areas would be expected to enter the drying ovens with the makeup air
drawn in through the enclosures. An exception could occur during the
brief periods that the operators open the enclosure lids.
The drying ovens are the primary emission points from the coating
line. The openings in the ovens on line 5 are the entrance and exit web
slots (each about 4 inches by 70 inches) and a row of seven 3-inch holes
in the back wall of each oven. The side walls of the ovens also have a
series of access doors, but these doors are typically kept closed during
operation.
Emissions of VOC within the drying ovens are vented to the
incinerator. As indicated 1n Attachment 2, the first three ovens are each
exhausted at a rate of 1,200 cubic feet per minute, and the final oven is
exhausted at a rate of 2,400 cubic feet per minute. These exhaust rates
are sufficient ".3 maintain in nwara iirf'ow mtociiy it :r.s :ven .-canr-rs
averaging 1n excess of 200 feet per minute. It 1s very unlikely that any
fugitive emissions escape the drying ovens.
The primary sources of nonaffected emissions 1n the vicinity of
line 5 are the other coating lines. The nearest coating line, line 4, is
over feet *rom line 5. Presumably, cleaning solvents ire jsed to clean
:he rsatars ma ;umps between -uns. li though this *as not :aser"ed•curlriq
the site visit. Also, the facility rtix room 1s located at one end of tne
coating room; some fugitive emissions from the mix room are likely to
enter the coating room through the open door between the rooms. Emissions
from cleaning and mixing operations generally are not Included in the
affected emissions from a coating line.
The fugitive emission points of line 5 are Illustrated 1n Figure 1,
and the exhaust system 1s Illustrated 1n Attachment 2. Not pictured 1n
these Illustrations 1s a forced makeup air system for the plant that
brings in 60,000 cubic feet per minute from outdoors. This system
provides makeup air for the entire plant 1n addition to the coating
room. In fact, a strong airflow can be felt flowing out of the coating
room toward the rest of the plant 1n the corridor connecting the coating
room to the plant. One of the two supply ducts of this system extends down
the left aisle of line 5 parallel to the line.
Sketches of the coating stations on line 5 from the side, front, and
top are presented 1n Figures 2, 3, and 4, respectively. These figures may
not be completely accurate in every detail but are close enough for
realistic design of a TTE. Not pictured 1n the figures 1s a water
sprinkler system that extends throughout the coating room just below the
level of the celling trusses. A series of photographs taken at the plant
1s presented 1n Attachment 3.
The coating line has an operator for each coating station. These
operators need routine access to the coaters and flashoff areas during
coating, 'eating occasionally nust oe dacted, frequently jy manually
-------
I 1 1
RowificM — Unwind 0 2(1 V
Figure 2. Side view of third coating station (typical of all coating stations).
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Plant Roof
VVVAA/W \7VY
MUn \ I
Duel lo linhMlJ 1 I
Ceiling Truss
Left-4-
-~ Right
aft
•wt
Figure 3. Front view of first coating station ondosure (generally typical of all stations).
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Drying Oven #1
Own Exhaust ~
Oven Exhaust
Oven
Exhaust
a* Vh
O
§
=3
E
n
o
o
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hv
\
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Coaling
Supply
Tote
Right
Rewind 4-
->¦ Unwind
Utl
Figure 4. Top view of first coating static (generally epical of all stations).
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11
pouring it from a pail, and the dams must sometimes be adjusted to adjust
the coating width. The back side of the coating knife must be cleaned of
dried coating occasionally to avoid streaks in the coating surface, and
the flashoff area must be observed after the dams are adjusted to check
the actual coating width downstream from the knife. From time to time
during a coating rjn, * :ample cf the product 1s t'ksn tc test the .eating
solids application rate. Based on the results, the coating knives and
tension rollers may have to be adjusted during the run.
"Bow rolTs" are located at various points along the lines. The bow
rolls are used-to vary the tension on the web from the edges to the
center, which compensates for variations 1n the web caused by the weaving
machines. This compensation is necessary to assure uniform coating and to
keep the web from "walking" from side to side on the rollers as it passes
along the line. Some bow rolls are located 1n the ovens; consequently,
the ovens must be opened to adjust or replace these rolls.
*n :ne svenr zr i jraas curing a -un, iccass £ :32asa :r:rrrjgncu::
the coating operation for cleanup and rethreading the web. Between runs,
access 1s needed to the coaters for cleanup. When starting a run, the
final adjustments to the coater and rollers are typically made during the
first 15 minutes that the line 1s running and the coating 1s being
delivered to the coaters. For very thin fabrics to which relatively heavy
coats are to be loolied. this adjustment
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12
drums are moved with a hand truck. The rolls of fabric to be coated are
stored on a "stmage," or lone;, low rack, parallel to the line in the
right aisle. As they are neeaed, the rolls are placed onto a rolling cart
with a power hoist and rolled into place at the head of the line. The
coated rolls of fabric are handled with a rolling cart or a fork lift when
they are removed from the end of the line.
The flow of materials in the plant does net appear to present major
problems for JTE construction and use. Depending on placement of the TTE
(or TTE's), doors may have to be opened occasionally to accommodate flows
to and from tW line, but such occurrences should be brief and
infrequent. Material flows on adjacent lines will not impact the use of a
TTE.
The plant 1s required to meet OSHA standards regarding exposure of
personnel to solvent vapors; these standards would have to be met within
the TTE. The identities and approximate quantities of the solvents
released into the TTE (i.e., the fugitive emissions) can be used to
:at2rwins :na " sxnaust -ira ::: insure that ".ha ,r~c
within the enclosure meets OSHA standards.
The plant 1s required to meet Factory Mutual fire safety
requirements. As discussed above, the facility has a plantwide sprinkler
system. If these sprinklers were outside the TTE, fire extinguishers
would have to be olaced fnside. The plant currently has fire
jxclnqmsnerr: sapioyea -n *ne —gnt si* sacn -:3at1nq
addition, tne drying ovens on iine 5 are equipped with automatic careon
dioxide f1re-suppress1on systems. Finally, all electrical equipment
(e.g., lighting and control boxes) 1s required to be explosion proof, as
are the fork lifts used to transport coating supply totes. Any equipment
associated with the TTE also would have to meet this requirement.
Hearing protection is not required 1n the plant; it Is not expected
that the presence of the TTE would appreciably affect noise levels. Heat
buildup 1s not expected to be a problem. The plant uses Infrared heating
elements, and very little heat escapes the drying ovens.
v
For purposes of testing, no nonaffected emission points are in such
close proximity to the coating line that they must be Included 1n the
TTE. Nonaffected emissions from the other coating lines in the room and
from the mix room could enter the enclosure in the makeup air drawn in
through the natural draft openings (MOO's). To minimize the quantity of
VOC entering through the NOO's, the NDO's should be located along the
right side of line 5, away from the other coating lines.
Two gas streams would have to be tested to determine capture
efficiency. The "captured emissions" would be measured 1n the common
exhaust from the drying ovens to the Incinerator. The "fugitive
emissions" would be measured 1n a duct set up for that purpose. If the
coating stations were individually enclosed, a common exhaust duct and fan
would be provided to limit the measurement of fugitives to a single
duct. The captured and fugitive emission measurements would have to be
Tiade simultaneously.
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13
The ducts involved appear to afford suitable measurement points for
VOC concentration and volumetric flow rate. The fugitives exhaust duct
installed. f„or the test would, of course, be constructed to be testable.
The existing' drying oven exhaust duct to the incinerator is a square duct
approximately 2.5 feet' by Z-5,f,eet that contains a straight run of about
*«et. """his section of duct was u-sed for the destruction efficiency
test performed on the incinerator, and measurement ports are present.
Other gas.streams would aiso fie tested or monitored. The VOC
concentration within the TTE must be monitored to ensure that steady-state
conditions are-reached and that OSHA standards are not exceeded. The
ambient VOC concentration outside the NDO's also might be monitored to
determine the significance of VOC entering through these openings. Each
dryer exhaust has a bypass to the atmosphere for use with water-based
coatings, although Kenyon has not found any water-based coatings suitable
for their purposes. Prior to testing, the absence of flow through the
bypass stacks should be verified. Finally, the forced makeup air system
•usx :a -sr ¦ scrae *ay because :ame outlets ir-2 ,®r>* '•''-a!.-
be within the TTE. Face velocity measurements across any included
openings could be made during the test, but a more likely course would be
to seal off these openings r'or tne duration of the test period.
There 1s no indication that any compounds are present in the gas
¦streams that would interfere with any EPA Methods for measuring VOC.
"vjs. inv iLKtaoie £?A *ernoa :suia je jsea. Mo other ccmo i -'Cafinq
conditions are known to exist.
V. Conclusions
It appears that a TTE can be built at this facility. Midwest
Research Institute has proceeded with preparation of a detailed cost and
feasibility analysis for the individual coating station enclosures on
line 5.
3 Attachments
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Attachment 3
PHOTO LOG
KENYON INDUSTRIES, INC.
Note: "Left" and "right" refer to the side of the coating line as viewed
from the unwind end looking in the direction of process flow to the
rewind end.
A Aisle to the left of Line 5 (Line 4 for far left).
B Aisle immediately to the right of Line 5.
C View of electrical bus and conduit over the aisle immediately to
the right of Line 4—representative of Line 5 also.
D Aisle farther to the right of Line 5.
E line 5—Coating Station No. 1 from the left aisle. The final
;or--on zf .na accumulator s t3 :ne "gnc zf :ns g'cz-rs.
F Line 5—supports above Coating Station No. 1 from the left aisle.
G Line 5—Coating Station No. 3 from the left aisle.
H Line 5—Coating Station Mo. 2 from the r*qht aisle.
I Line 5—supports above Coating Station No. 3 from the right
aisle. The drying oven exhaust 1s 1n the background.
J Line 5~ex1t from the final drying oven. The bottom of the
elevated curing oven 1s at the top of the picture.
K Line 5—view from the rewind end along the "left" aisle. (Line 5
is to the left of the picture).
L Duct from Line 5 to the Incinerator.
M Bypass exhaust (24 1n. x 25 1n.) from one drying oven on Line 5.
N Rolling ladder available for access to elevated structures.
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ATLANTA FILM CONVERTING COMPANY
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MRI®
MIDWEST RESEARCH INSTIT
Suit-
401 Harrison Oaks Bou'-
Gary. North Carolina «;
Teleonone (919) 67~
FAX <9191 677
February 17, 1989
Site Visit—Atlanta Film Converting Company, Inc., Atlanta,
Georgia
Capture Efficiency
EPA Contract No. 68-02-4379, Work Assignment 16
ESD Project No. 87/07
MRI Project No. 8951-16
Stephen W. Edgerton ^ 0
EPA/CPB/CAS (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
n'jr^cse
rhe purpose of the visit was to investigate the feasibility of
constructing a temporary total enclosure around a printing line suitable
for conducting a capture efficiency test by the draft gas/gas procedure.
II. Place and Date
Atlanta Film Converting Company, Inc.
1132 Pryor Street, S.W.
Atlanta, Georgia 30315
September 13, 1988
III. Attendees
Atlanta Film Converting Company, Inc. (AFCQ)
Jerry Mitchell, President
John Thompson, Executive Vice President
Flexible Packaging Association (FPA)
Marjlna Kaplan, Director of Marketing and Communications
Edward Weary, Director of Technology
Date:
Subject:
From:
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2
U. S. Environmental Protection Agency (EPA)
James Berry, EPA/CPB
Karen Catlett, EPA/CPB
Midwest Research Institute (MRI)
Stephen EJgertor,
IV. Discussion
The visit began with a meeting among the attendees. The meeting was
followed by a tour of the facility. A short meeting was held after the
facility tour. The discussion that follows summarizes the information
gained from the meetings and tour.
A. Facility Description
TVs Cic11*ty manufactures feeble oackaaina. It is a servics-
jrientea operation :nax: jcmpatas .•«;en ^rgar ;ampam2s yj ;r?/-;; ,c.,
turnaround on orders and a higher level of service than larger companies.
The facility operices two six-color flexographic presses and one
laminator. The flexographic presses were the focus of the visit and are
described below. The volatile organic compound (VOC) emissions and
controls are discussed in the section following the flexographic presses
:riC2ss :ascr'ntir:n.
1. Flexographic presses. The two six-color flexographic presses
were manufactured in the 1960's. One is a "stack" press; the other is a
"central Impression" (CI) press. The printing process is similar in both
presses in that a continuous plastic film is fed through a sequence of six
printing stations with dryers between. A schematic of a typical CI press
is presented in Figure 1.
On both presses, the web is unwound, passes upward and then
horizontally over the central bay, and enters the first printing station
The web then passes sequentially through the printing stations and
intervening "between-color dryers," alternately being printed upon and
then exposed to a between-color dryer. At each succeeding printing
station, a new ink color is applied over the earlier coats until the final
image is produced. For the final product to be acceptable, each color
must be laid down in exactly the correct position relative to the
preceding ones. This positioning process is termed "keeping register."
After the web leaves the final printing station, it passes
horizontally through the "overhead dryer" located above the path traveled
by the unprlnted web over the bay. The dried web then travels downward to
the rewind station.
Solvent-based inks are pumped to the printing stations from 5-gallon
buckets. The ink 1s delivered to one end of a narrow trough or "fountain"
that extends across the width of the web. At the other end of the
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Figure 1. Schematic of a six-color, central i,,.,.. ess ion flexu graphic press.
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4
fountain, ink is drained back into the supply bucket. Thus, the ink is
continually circulated through the fountain.
A "metering roller" is partially submerged in the fountain. This
roller conveys the appropriate amount of ink to the "anilox roller," which
then passes the ink to the "plate cylinder." This cylinder rolls the ink
onto the web as it passes through the printing station. During the
application of the ink, the web is supported from the back by the
"impression cylinder."
The chief difference between the presses at this facility is in the
impression cylinders. The stack press has a small impression cylinder for
each printing station. In the CI press, these individual impression
cylinders are replaced by a single large central impression cylinder
around which the printing stations are arrayed.
In the stack press, the web enters the first printing station at a
height of about 8 feet and passes vertically downward through the first
three orintina stations. After the direction is reversed on a roller near
riser i eve i, :r.e passes /ert:ca \'.j -ipwarn -nrcugn :r.s m inr-jg
printing stations and into the overhead dryer.
The stack press at this facility is of obsolete design. It was
designed for use with a cellophane web, but today's plastic films are much
thinner. These thinner webs vibrate as they pass through the printing
stations, '-isultlnq :r> 'ower-iuai -r-cuct. Tn \ddition. -.his "jpass
^annc1: .;seo ngiurar . ne iseeas n axcass 27 ioour 123 :ar
minute. To be truly competitive in the flexible packaging business, Mne
speeds of about twice that are required. In spite of the'drawbacks with
the stack press, the facility is able to find a market for some products
that can be produced on the press. The stack press is operated one shift
per day.
In the CI press, the web is supported in back by the large central
impression cylinder at all times. The web enters the first printing
station near the top of the central cylinder at a height of about 8 feet
and passes around the cylinder, first down the surface facing the central
bay, then up the far surface and into the overhead dryer.
The bulk of the facility's production is produced on the CI press,
which operates 24 hours per day. The line speed was about 250 feet per'
minute during the visit, but this press is capable of competitive line
speeds of 350 to 400 feet per minute. This press typically processes
about three runs per day, but it is not unusual to have as many as eight
runs 1n a day.
Current plans call for a new CI press to be purchased to replace the
stack press within the next 3 months. The new press will have much
greater production capacity than the existing presses, and most of the
production will be shifted to the new press.
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5
2. Volatile organic compound emissions and controls. This facility
presently operates no add-on control devices to reduce VOC emissions to
the atmosphere; the exhausts from the dryers are vented to the atmosphere.
Until recently, the facility was not required to reduce emissions because
annual uncontrolled emissions were below the State's regulatory cutoff of
100 tons. However, persistent nonattainment of the national ambient air
quality standard for ozone in the Atlanta area has led the Georgia
enforcement agency to lower the cutoff to 25 tons per year, bringing AFCO
under the regulations.
In order to comply, the company intends to vent the dryer effluent
from the new CI press discussed above to an incinerator. The existing CI
press will be either converted to water-based inks or also will be vented
to the incinerator. The facility would not be able to comply using only
the existing presses because these presses do not achieve adequate capture
efficiency. The "captured" VOC's are those contained in the effluent from
the overhead dryer and between-color dryers. A consultant has indicated
¦ ^ -fC3 *h8 :r?<3 tinxurss 2Q w.3 15 ^srcsnt ~.f uh2 •"olv^nt .-nci
ana tnat tne existing CI press captures 40 to 45 percent. The new CI
press is expected to achieve a capture efficiency of 60 to 65 percent.
All the dryers at this facility are direct-fired natural gas
units. The makeup air for the overhead dryer on the CI press is drawn
f-om outside the building. The makeup ilr for the overhead drysr on the
r,2c:c :riss ina -"or ;r:3 :etween—:aior -iryers on sotn trasses -s jnwn
witmn tne room nous-.ng cne presses.
None of the exhaust from the existing dryers 1s recirculated. Much
of AFCO's production is food packaging, so the customers specify very low
levels of retained solvent. Recirculation of dryer exhaust makes it more
difficult to achieve these low levels of retained solvent. Nevertheless,
the new press is designated to meet customer specifications while
recirculating 50 percent of the exhaust air.
Each overhead dryer is box-shaped with slots at either end through
which the web passes into and out of the dryer. Heated air is supplied to
the dryers with a forced-draft fan and drawn out of the dryers with an
induced-draft fan. The dryers are operated at a negative pressure
relative to the room to contain all the VOC evaporated by the dryers.
Figures supplied by AFCO for the CI press indicate that the Input volume
for the overhead dryer 1s about 1,000 scfm and that the exhaust volume is
about 1,100 scfm.
As Implied by their name, the between-color dryers are located,
between the print stations and dry the web sufficiently that the next
color can be applied. A drawing of a between-color dryer is presented in
Figure 2. These dryers extend across the width of the web just above its
surface. A burner located 1n a common manifold supplies heated air to all
the between-color dryers on a single press. The heated air Impinges on
the printed web from two slots 1n each dryer running across the width of
the web. Two intake slots situated to the outside of the Impingement
*lots ire operated under vacuum: an unknown quantity of the solvent-laden
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To Exhaust Manifold
From Heated Mr Manifold,
Figure 2. Between-coloi
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7
impingement air is drawn onto the intake slots. The effluent from these
dryers (i.e., the solvent-laden air [SLA 1 picked up by the intake slots)
is combined in a single manifold and exhausted to the atmosphere.
As in the overhead ovens, more exhaust is pulled from the between-
color dryers than is supplied- This is especially imoortant for these
dryers because, if the heated air were forced out of the dryers instead of
being picked up by the intake slots, the heated air would impinge on the
ink rollers and dry the ink on the plate. Figures supplied by AFCO for
the between-color dryers on the CI press indicate that the total input
volume is about 1,100 scfm and that the total exhaust volume is about
1,200 scfm.
Fugitive VOC emissions at the presses are possible from several
points. The ink supply containers are not sealed. Most of the fountain
and rollers in the printing station are covered during operation, but the
plate cylinder is not. After the ink is applied, the web travels a few
HCH9S ZSTOT"""? * ^ "*1C3 -T 09CV/S — H — !CT*
Solvent may oe emitted from the plate and from the web in the area Detween
the printing station and the dryer. Also, the effectiveness of the
between-color dryer intake slots at capturing the solvent-laden impinge-
ment air is unknown; these dryers may generate fugitive emissions. After
the final printing station, there is a run of about 6 feet before the web
enters the overhead dryer. Mr. Mitchell believes that the greatest ocr-
"on ;f -.r.e v:tni::ve :aivent .-'.isnes -iff between "Me r:rsai :r?nf:r!g.
station ana the overhead dryer and in the areas between the printing
stations and between-color dryers.
B. Observations Pertinent to the Draft Gas/Gas Capture Efficiency
Test
1. Operator access. Access to the presses is required constantly
during operation. The operators periodically check the ink level 1n the
supply containers and check and adjust ink viscosity. The print quality
is constantly monitored, and register is manually adjusted at the press as
needed. When necessary, the operator must stop the press to clean dried
ink from the plates or to reapply a plate to Its roller. Access is needed
from all directions to change out unwind rolls, rewind rolls, and plate
cylinders. A chain hoist that moves along an overhead beam 1s used to
change out the unwind rolls and plate cylinders.
Consideration should be given to enclosing the entire press,
including unwind and rewind stations, in the temporary total enclosure.
Access to the unwind area is required periodically to replace.the spent
roll. If the enclosure did not include the unwind area, operators might
have to pass in and out of the enclosure during a test run, possibly
disrupting design airflow patterns or allowing fugitive emissions to
escape the enclosure. In addition, 1t 1s possible that there are some
emissions from the web after it exits the overhead dryer. However, this
1s unlikely considering the typical specifications for very low retained
solvent discussed previously. Furthermore, the web 1s quickly rewound
after leaving v.hs overhead dryer, and the sscape of any retained solven
rrom cfce rewound *eD in che vicinity of the press is uniixeiy.
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3
2. Press dimensions and layout. The existing presses vary in
size. As estimated by pacing off distances, the CI press would require an
enclosure 18 feet by 36 feet to contain the entire press. The new CI
press to be installed will be longer than the existing one.
The two presses are housed together in a large room. The presses
are parallel to one another and quite far aoart. By pacing off the
distances, it appears that the distance from the outside wall to an
enclosure around the stack press would be about 18 feet. The enclosure
itself would be about 10 feet wide and would be separated from an
enclosure around the CI press by about 10 feet.
About half the room currently has no equipment in it and is being
used for storage. The new CI press will be installed in this area.
3. Ceiling-level obstructions. The ceiling is supported by steel
trusses 1 to 2 feet high with open interstices. There are few other
obstructions at ceiling level.
4. Qirect-fired aryers. The use of airect-firea oryers enat araw
combustion air and makeup air from the room may present problems in
quantifying capture and overall destruction efficiencies because some
VOC's will be destroyed in the burners before emissions enter the duct to
the incinerator. Measurements to quantify VOC's destroyed by the burners
could be complex if they are possible at all.
5. neat ouiiaup. Mr. rtitcneii inaicatea cnat neat out ;juq ;n -^e
temporary enclosure may be a problem because the overhead and between-
color dryers will be within the enclosure. During the visit, the inlet
temperatures for the between-color and overhead dryers were 250°F and
190°F, respectively. However, it was not noticeably warmer in the
vfcinity of the dryers than elsewhere. In any case, air flow patterns and
volume could be engineered in a temporary total enclosure to achieve
adequate heat removal.
C. Enclosure Design Options
Based on observations during the site visit, three preliminary
design options for a temporary total enclosure were identified:
1. Dropping polyethylene enclosure walls from the plant ceiling
thereby using the plant celling as the temporary total enclosure ceiUnq-
2. Dropping polyethylene enclosure walls fV-om the bottom of the
ceiling support trusses. The plant ceiling would function as the
temporary total enclosure ceiling. The open spaces between the top of the
walls and plant ceiling would be considered natural draft openings as
defined 1n the draft gas/gas test procedure; and
3. Constructing a wooden frame to which polyethylene would be
fastened to form the temporary total enclosure walls and a ceiling
spanning the press area.
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9
Option 2 likely would be the least labor intensive and, therefore,
the least expensive. Details on how the polyethylene would be fastened
to the ceiling support trusses remain to be worked out. The applicability
of this approach also hinges on meeting the temporary total enclosure
criterion governing the allowable area of natural draft openings.
The use of Option 1 would avoid any problem with the natural draft
opening criterion but would require contending with the trusses and
obstructions near ceiling level. The exact methods of closing the areas
near the plant ceiling and fastening the polyethylene to the ceiling
remain to be worked out. Even with these difficulties, this approach
would likely be less costly than Option 3, which would require
considerable carpentry to ensure the stability of the enclosure frame.
Whichever the chosen option, every effort should be made to develop
a design that will allow the polyethylene to be added quickly after the
preliminary test runs without the enclosure have been conducted. For
""Ticnn * ind - 'z'r.2 *hoiild
roiled up at ceiiing ievei. Once trie preliminary test runs nave oeen
conducted, the polyethylene could be unrolled, and the temporary total
enclosure test runs begun. For Option 3, the wooden frame should be
constructed before any testing is conducted, with the polyethylene walls
and ceiling added only when the temporary total enclosure test runs are to
begin.
V. Cone iusions
This facility appears typical of a small flexible packaging
manufacturer. No conditions seem to exist that would make construction of
a temporary enclosure more difficult at this facility than at other web
coating and printing facilities. In fact, the amount of unused space in
the press room and between the presses could make construction of an
enclosure easier at this facility than at others where space constraints
might be a factor.
It does not appear that noise would be a problem in an enclosure at
this facility. Noise levels at the facility were not high, and no
existing noise abatement measures were apparent.
The necessity of including the dryers in the enclosure could result
in heat buildup. However, as discussed previously, it is believed that
this potential problem can.be avoided with proper enclosure design.
The use of direct-fired dryers at this and other facilities presents
a possible problem with the draft gas/gas capture efficiency test
procedure. (This problem was discussed in Section IV.B.4 above.) However,
the same is true of other capture efficiency test methods.
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printpack, inc.
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MRII0)
MIDWEST RESEARCH IN3TITL
Suite
•101 Harrison Oaks Bcuie
Cary. Norm Carolina 2"
Teieonone 1919) 877-
FAX (919) 67^.
Date:
Subject:
From:
To:
I. Purpose
"lis ^urnose of this site visit was to invesiiaata the ^asibi1 *ty it
•.ms- -ic. i ity ir ccnsur-jcr^na i lamoorary ~3tar -inciosurs drouna :
printing line suitable for performing the draft gas/gas capture erficiency
test.
II. Place and Date
Prlntpack inc.
4335 Wendell Drive SW
Atlanta, Georgia
September 12, 1988
III. Attendees
Prlntpack inc. (Prlntpack)
Doug Cook, Senior Specialist, Corporate Environmental Affairs
Flexible Packaging Association (FPA)
Marjina Kaplan, Director of Marketing and Communications
Edward Weary, Director of Technology
U. S. Environmental Protection Agency (EPA)
February 17, 1989
Site Visit—Printpack inc., Atlanta, Georgia
Capture Efficiency
EPA Contract No. 68-02-4379, Work Assignment 18
ESD Project No. 87/07
MRI Project No. 8951-18.
Stephen W. Edgerton
Karen Catlett
;:d/c?s/c.;s
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
James Berry, ESD/CPB
Karen Catlett, ESD/CPB
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2
Georgia Department of Natural Resources
Michael Fogle, Unit Coordinator
Midwest Research Institute (MRI)
Stephen Edgerton
IV. Discussion
The visit began with a meeting among the attendees. The meeting was
followed by a facility tour concentrating on the printing lines and the
emission control system. The discussion that follows summarizes the
information gained from the meeting and tour.
A. Concerns With Draft Gas/Gas Capture Efficiency Test Procedure
and Retrofitting Permanent Total Enclosures "
Mr. Cook exDressed two chief concerns about the draft caDture
srf"Ciency .asz procacura: :zzz ma icc-racy. Tiace :r:a m
points related to the cost of conducting the test. A major cost would be
the lost manufacturing time during construction and removal of the
temporary enclosure required for the test. Another significant cost would
be the labor required to build the enclosure. This facility has large
presses that would require complicated enclosures taking several days to
rcnstrjct. 'he na.lcr erst ''tsm the tast would 'zs the "'-icrsase^
;:ne jsnmi-.ment ;3sr.:~g rsntr.icrcr': :srry -:r;a :asz.
contractors have indicated to Mr. Cook that the cost of performing the
test would be about three times the cost of the liquid/gas capture
efficiency test now in use. The primary reason for this increase in test
contractor charges is that the test crew will be onslte significantly
longer for the draft gas/gas procedure than for the liquid/gas
procedure. The test procedure requires that the exhaust to the control
device be tested before the temporary enclosure is constructed. After
this preliminary measurement is made, the test crew will be idle during
construction of the enclosure, a significant period 1f construction takes
as long as Mr. Cook projects. The costs of materials for constructing the
enclosure would be small in comparison to the other costs associated with
the test.
Mr. Cook expressed the following opinions on the accuracy of and
support for the the draft test method. He has no confidence that the
draft gas/gas capture efficiency test improves upon the accuracy of the
I1qu1d/gas test. The draft test procedure has not been performed enough
times to establish its value, and the data from the tests that have been
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¦j
run have not been made available to industry for evaluation.a Mr. Cook
believes that it is EPA1s responsibility to develop and validate the test
procedure. The costs to industry of regulatory development are too great
to justify, particularly when there is a method (liquid/gas) that industry
believes to be adequate. If the gas/gas method eventually proves to be a
better method and if the costs can be contained, it should be adopted.
The cnief concern Mr. Weary expressed about the draft gas/gas
capture efficiency test procedure is that the results obtained with the
temporary enclosure in place will not accurately reflect operation in the
absence of the enclosure. He feels that the enclosure will alter such
parameters as the quality of the product and the rate and pattern of the
airflow in the vicinity of the line. To compensate for these effects,
conditions (e.g., line speed) might have to be varied from those that
prevail during normal operations.
Mr. Fogle expressed reservations concerning the fact that the
minimum detection level for Method 25 is 50 oditi as carbon. Thus, this
¦netnoa .nay -ox :s ipprior: axa "zr -isasur^ment or ;r.s :as ixraam :?.¦*
temporary enclosure that carries the VOC normally emitted as fugitive
emissions. However, at facilities using incineration control, Method 25
is necessary to obtain accurate destruction efficiencies.' These facts
raise the possibility that capture efficiency and control device
efficiency might have to be determined using different EPA Methods, which
¦«ould Increase ^stinq :asts. *r. 'ogle also fndlcatad :sncarn 'hat zr.n
cast ;f :r.a jas/qas :ast *ou:a ae .especially aursensome zn :mai 1
facilities chat do not have the personnel or expertise to design and
construct a suitable temporary enclosure.
Mr. Fogle stated that he has been satisfied with the results
obtained using the liquid/gas capture efficiency test. He believes that
problems with reconciling the liquid and gas measurements may stem from
using Method 25A instead of Method 25 to make the gas measurements.
Mr. Cook believes that permanent total enclosures may be reasonable
for new plants but are not practical for retrofit situations. Space
constraints in existing plants are a prime impediment to permanent
enclosures. Also of concern 1s the possibility of greatly increased
airflow to the control device from the enclosed line 1n order to meet OSHA
limits on exposure of personnel to VOC vapors. Such an increase could
exceed the capacity of a control device designed to control only the
effluent from the dryers. Mr. Cook agreed with Mr. Berry that, because of
aA similar comment was made by FPA at the meeting of the National A1r
Pollution Control Techniques Advisory Committee (NAPCTAC) at which the
draft test procedure was discussed (May 18, 1988). The EPA believes
that these comments are premature. The procedure was developed based on
engineering rationale. The procedure was distributed widely and
presented at the NAPCTAC meeting in order to solicit recommendations
based on available expertise 1n the public and private sectors. The
development of the method Is continuing.
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4
the increased control over the airflow patterns that is possible with a
total enclosure, it is not clear that a permanent enclosure would require
an increase in airflow volume. However, the ventilation volume currently
used in the plant is high in order to meet the OSHA regulations.
Printpack believes that the impact of enclosures on solvent concentrations
and air volumes in relation to OSHA regulations must be precisely resolved
prior to proposal of a total enclosure capture method.
B. Facility Information
1. Printing operations. The Printpack facility currently operates
several central impression flexographic printing lines to produce flexible
packaging products. The facility is permitted for an additional line, but
that line has been moved to another facility. The primary webs used are
polypropylene and polyethylene, with some metalized polyester. A very
small portion of the printing is done on paper. The company uses
essentially all solvent-based inks. Printpack "experimented with" water-
based inks but was not able to achieve the quality products demanded by
their customers.
The facility operates 24 hours per day and 5, 6, or 7 aays per weeK
depending on demand. Typical printing runs average about 4 to 6 hours. *
About 60 percent of the presses are actually running at any given moment.
The facility has six-color presses and eight-color presses. The
«ight-color iressas irs *he newest. These cresses ar? "larger. caster, and
:an icccrnmoaata •: ^nsr .md :
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Figure 1. Schematic of a six-color, ceni.jl Impression ilexographic press.
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6
the presses cannot be operated at maximum mechanical speed during produc-
tion. The actual printing speed is determined by drying capabilities and
the ability to keep register. The printing speed of the presses varies
between about 350 and 700 feet per minute, depending on the product and
the press.
The facility performs two types of printing, "line" and "process."
Line printing is the traditional flexoaraDhic printing method. In this
method, the ink is picked up by a roil rotating in a tray of ink and"
passed to the anilox roll, which transfers the ink onto the raised
printing surface of the plate cylinder. Each color is applied to the web
to completely cover specific areas. The industry is now moving more to
process printing. In this method, the ink is pumped to a doctor blade
against the anilox roll. The ink is applied to the web as fine dots; the
sum of the various color dots appears as the final image. This printing
method produces the "graphics" type packaging that is becoming more
prevalent. Process printing uses higher viscosity inks, and much less ink
is applied to the web. Thus, less VOC is emitted from process printing
than from line printing. All presses at Printpack can do line work. All
?ignt-olor 2r*»ssas ins "~a **:c -:G?;:r /: ;rrt
2. VOC emissions and control system. The Printpack facility
operates a catalytic incinerator manufactured by Pillar for control of VOC
emissions from the presses. The solvent-laden air (SLA) from the between-
color dryers flows into the center of an annular catalyst bed; the VOC's
are oxidized as they pass through the bed to the outside. The system is
sauiDDea :r-mary -aat ^xcnange: :rsa -LA : rrrjnearaa :v -.ns
incinerator exnaust gases. The incinerator nas a capacity of
25,000 scfm. It is equipped with a variable-speed, induced-draft fan
controlled by a static pressure sensor on the main SLA mixing plenum
located on the roof. All the SLA vented to the incinerator is effluent
from the between-color dryers.
The inks applied to the web are dried with direct-fired natural gas
dryers. Mr. Cook has agreed to provide schematics of the various lines'
air handling systems. All of the effluent from the overhead dryer is
recirculated, with a portion diverted to the between-color dryers and
replaced by fresh makeup air. Dan rs tn the ductwork on the roof and
inside the plant allow the makeup air to be drawn from either source. The
dampers within the plant were observed for two of the presses; these
dampers were partially open. It is not known if additional makeup air was
concurrently being drawn from outside. The overhead dryers on the eight-
color presses consist of three distinct chambers supplied with heated air
from a common burner tempered with room air; the effluent from the three
chambers is also combined.
As implied by their name, the between-color dryers are located
between the print stations and dry the web sufficiently that the next
color can be applied. A sketch of a between-color dryer 1s presented 1n
Figure 2. These dryers extend across the width of the web just above Its
surface. A common manifold and burner supply heated air to all the
between-color dryers on a single press. In each dryer, the heated air
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To Exhaust Manifold
From Heated Air Manifold
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3
impinges on the printed web from two slots running across the width of the
web. Two intake slots situated outside of the impingement slots operate
under vacuum; an unknown quantity of the evaporated solvent is drawn into
the intake slots. The effluent from these dryers (i.e., the SLA picked up
by the intake slots) is combined in a single manifold and ducted toward
the incinerator. On some presses, ductwork and dampers are in place on
the roof to allow some of the between-color dryer effluent to be
recirculated to the overhead dryer or discharged to the atmosphere.
A total of about 6,000 scfm of SLA is generated by the dryers at
each press, but with recirculation of the overhead dryer exhausts, only
about 2,000 to 2,400 scfm from the between-color dryers is vented to the
incinerator from each press. The airflow from these dryers is variable
because press operators frequently adjust the flow to obtain proper dryinq
characteristics. Mr. Cook indicated that he will supply the systems' duct
flow rates when EPA requests them in writing.
Most of the recirculation and incinerator ductwork is on the
facility's roof. Each final dryer exhaust is equipped with a bypass to
:ne itmosonera -or jsa -.nen ^.i-ar-oases ;riX3 ira • ss: :aa. " = .
bypass damper is controlled from a remote location with an actuator motor
that is connected to the damper shaft by a control rod and an adjustable
locking collar. The collar is locked onto the damper shaft in whatever
position is required to achieve full closure given the location of the
actuator motor and control rod. Because the collars are not operated
according to convention (i.e., are not aligned with the dangers), it was
-¦cz :ossiDie ~z iscartaTn ¦-"m jxranai ^sar^aticn .merrier :na':vcas:;
dampers were fully closed. If a gas/gas capturs efficiency ;est were"co
be conducted at this facility, full closure of the bypass dampers should
be verified prior to testing.
Fugitive emissions are possible at a few points in the printing
process. Ink is pumped to the printing stations from "kits," 5- or
15-gallon containers. These kits are not sealed, and fugitive emissions
are likely from these sources. Most of the printing station is covered
during operation, but the final roll that actually applies the ink to the
substrate is not covered. After the ink is applied, the web travels a few
inches before it passes under the face of the between-color dryer.
Solvent may be emitted from the final roll and from the web in the area
between the printing station and the dryer. Also, the effectiveness of
the between-color dryer intake slots at capturing the solvent-laden
impingement air is unknown; these dryers may generate fugitive
emissions. After the final printing station, there is a run of about
6 feet before the web enters the overhead dryer. Fugitive emissions are
likely 1n this area. On some of the older presses, a piece of metal has
been installed over the web in this area to aid 1n directing solvent
emitted in this area into the overhead dryer with the web.
The odor of solvent was strong in the room containing the presses.
The odor extended Into the visitor reception area, which is separated from
the press room by at least three doors and 40 feet.
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9
Mr. Cook stated that when all covers are in place and dryer airflows
are properly balanced to achieve a good negative pressure, he believes
that 99 percent of the fugitive emissions are from the "kits." Emissions
at other points in the process will be drawn into the dryers and
subsequently vented to the incinerator.
The capture efficiency, lias been determined at this facility using a
liquid/gas material balance protocol. One capture efficiency test was
performed for two presses at a cost of $12,000. Another test of capture
efficiency for two presses and of the incinerator destruction efficiency
was performed for a total cost of $18,000. The capture efficiencies
determined by this test method have ranged between 66 and 71 percent for
the older presses and have been in the mid-to-high 70's for the newer
(eight-color) presses when newly installed.
C. Observations Pertinent to the Draft Gas/Gas Capture Efficiency
Procedure
.. ];srr.:r -c~3S2. vo :perators ire issignea :c aacn .jrsss.
additional two persons are assigned to the eight-color presses as a
floating changeout team. Access to the presses is routinely required
during operation. During operation, the operators check the ink level and
viscosity in the kit supplying each printing station about every
30 minutes. The ink viscosity is tested using a Zahn cup, adjusted as
-scassary through -client iddltion. and retestad. This who la process
;aKes iDCUt : ninuEas. "lie jasratars liso .mist 3e ;o ia.3Usz -na
printing stations as needed. Because frequent access to the printing
equipment 1s required, a temporary total enclosure at this facility would
need to be constructed so that operating personnel can safely remain
within 1t during the test period.
Consideration should be given to enclosing the entire press,
including unwind and rewind stations, in the temporary total enclosure.
Access to the unwind area is required about every 45 minutes of operation
to replace the spent web roll. The same operators that monitor the
printing equipment perform the replacement using an overhead power
crane. If the enclosure did not include the unwind area, operators might
have to pass 1n and out of the enclosure1* during a test run, possibly
disrupting design air flow patterns or allowing fugitive emissions to
escape. In addition, it is possible that there are some emissions from
the web after it exits the overhead dryer. However, this is unlikely
because much of the production at this facility 1s food packaging with
specifications for very low retained solvent. Furthermore, the web is
quickly rewound after leaving the overhead dryer, and the escape of any
retained solvent from the rewound web 1n the vicinity of the press is
unlikely.
2. Press dimensions and layout. The presses vary somewhat 1n
size. As estimated by pacing off the distances, one six-color press would
require an enclosure 15 feet by 45 feet to contain the entire press. An
enclosure for another six-color press was estimated at 27 feet by
<54 feet. The ceiling in the room housing these presses is approximately
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10
20 feet high. The eight-color presses are larger. An enclosure large
enough to contain one of these presses would have to be approximately
33 feet by 66 feet. The ceiling in the room housing this press is about
30 feet high.
The presses are housed together in two large rooms of the plant. In
most cases, there are aisles between the presses wide enough for a fork
lift to pass through. Cr.e 3xc2Et:or. t.: this separation between cresses
was noted where one eight-color press is located next to a five-color
press/laminator. At their nearest point, these presses are separated by
only about 3 feet. Mr. Cook indicated that a plant floor diagram showinq
the locations and dimensions of the presses can be obtained, with a written
request from EPA.
3. Ceiling-level obstructions. In the 1 to 1.5 feet just beneath
ceiling level in both rooms housing the presses are a number of
obstructions. These include ventilation ducts, electrical conduit,
piping, and support beams. In the room- housing the eight-color presses
the ceiling is suooorted bv steel trusses 1 to 2 feet high with open
ntarcfrcas -
4. Direct-fired drying ovens. The use of direct-fired,
recirculating ovens may present problems in quantifying capture and
destruction efficiencies because some VOC may be destroyed in the burners
before emissions enter the duct to the incinerator. The configuration of
"-.he :ven. burner", md iuctlna will fzctor^ *n whether \ orcbiem
:? "."3 rerrantage- :r ;0C :nat :eszr2yea is :na "acr.-cj :dzaa
air passes through the burners can be determined and if the ducts leaaing
to the burners are suitable for gas-phase VOC testing, the test problems
may be overcome. It should be noted that combustion of VOC in direct-
fired drying ovens is a potential problem for the Hquid/gas capture
efficiency test procedure as well as for the gas/gas test procedure.
D. Enclosure Construction Options
Based on observations during the site visit, three preliminary
design options for a temporary total enclosure were identified:
1. Dropping polyethylene enclosure walls from the plant ceiling,
thereby using the plant ceiling as the temporary total enclosure ceiling*
2. Dropping polyethylene enclosure walls from the bottom of the '
ceiling support beams or trusses. The plant ceiling would function as the
temporary total enclosure ceiling. The open.spaces between the top of the
walls and plant ceiling would be considered natural draft openings as
defined in the draft gas/gas test procedure; and
3. Constructing a wooden frame to which polyethylene would be
fastened to form the temporary total enclosure walls and a ceiling
spanning the press area.
Option 2 likely would be the least labor intensive and, therefore,
the least expensive. Details on how the polyethylene would be fastened*to
the celling support beams remain to be worked out. The applicability of
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11
this approach also hinges on meeting the temporary total enclosure
criterion governing the allowable area of natural draft openings.
The use of Option 1 would avoid any problem with the natural draft
opening criterion but would require contending with the numerous
obstructions near ceiling level. The exact methods of closing the areas
near the plant ceiling and fastening the polyethylene to the ceiling
remain to be "worked out. Even with these difficulties, this approach
would likely be less costly than Option 3, which would require
considerable carpentry to ensure the stability of the enclosure frame.
Whichever option is chosen, every effort should be made to develop a
design that will allow the polyethylene to be added quickly after the
preliminary test runs without the enclosure have been conducted. For
Options 1 and 2, the polyethylene should be fastened in place but remain
rolled up at ceiling level. Once the preliminary test runs have been
conducted, the polyethylene could be unrolled, and the temporary total
=rr1 ~"ur¦u.2sf. n2f."i^n'3.. tha v'Oodan *~i!ne ~a
constructed oefore any nesting is conauctea, witn cne poiyetnyiene *di,i
and ceiling added only when the temporary total enclosure test runs are to
begin.
It might be possible to avoid the cost of lost production during
enclosure construction and dismantling if the test could be scheduled at a
time 'iien :na --.ci1 :~.y : -st aerating ~ iays ~ar
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APPENDIX C. COST AND FEASIBILITY ANALYSES
American National Can Company
Westvaco Corporation
'anyon Industries
Atlanta Film Converting Company
Printpack, Inc.
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AMERICAN NATIONAL CAN COMPANY
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MRIf§l REPORT
FINAL COST ANO FEASIBILITY STUDYs AMERICAN NATIONAL CAN COMPANY
EPA Contract No. 68-02-4379
^or* Assignment -5
ESQ Project No. 87/07
MRI Project No. 8952-26
Prepared for:
Karen Catlett
Chemicals and Petroleum Branch
Emission Standards Division
Office of A1r Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
Prepared by:
Stephen W. Edgerton
Midwest Research Institute
401 Harrison Oaks Boulevard, Suite 350
Cary, North Carolina 27513
October 20, 1989
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FINAL COST AND FEASIBILITY ANALYSIS
FOR
AMERICAN NATIONAL CAN COMPANY
I. Summary of Analysis and Findings
Hne American National Can Company ^ANC) facility in Hammond,
Indiana, prints and coats metal sheets for subsequent processing into
three piece cans at other locations. The facility uses sheet-fed
lithographic presses and roll coaters. A site visit report, dated May 16,
1989, contains detailed information on the process and the facility
layout.
A. Temporary Total Enclosure (TTE) Configuration
In conjunction with Mr. Gere of ANC, Midwest Research Institute
(MRI) determined that the coating lines present a greater challenge^to
•nclcse ".han io the 1 'thoaraohic tr^'ntina 1 *nes. Coating ""'is N'o.. CI «.i«
ieieczaa for m-oeptn analysis as cne uiosz difficult of cne coating iir.es
to enclose based on the relatively close proximity of adjacent coating
lines on either side. Potential TTE configurations were identified and
evaluated considering the layout of the process, the locations of affected
and nonaffected VOC emission sources, the locations of permanent
structures that could aid or obstruct TTE construction, operator access
¦-eauirranents. •sa'teriai -"ows. leaitii ana -safety requirements, ana :na
criteria inciuaea ;n che TTE protocol. Jne configuration was ieieciaa ::r
further analysis. The proposed TTE would enclose the normal work area of
the coater operator from the automatic feeder to the front end of the
drying oven and from the midpoint of the left aisle to the midpoint of the
right aisle. The TTE roof would pass just over the area light fixtures to
allow adequate lighting and to utilize the fixtures for support. The
exhaust duct for the fugitive emissions would run from the TTE roof up
through an existing vent in the plant roof. The exhaust fan would be
located on the roof. Additional detail on the proposed TTE configuration
can be found in Section III.
B. Materials of Construction
After observing curtains in the plant suspended from cables strung
between roof support columns, a similar system was selected for the TTE.
Support cables for the TTE would be hung using a combination of the
existing columns and 2x4's dlamped to existing catwalk railings. The
material selected for the walls and roof of the.TTE is 6 mil poly-
ethylene. More detail on construction is presented 1n Section III.
C. Testing
The gas streams, sampling locations, and EPA Method for measuring
volatile organic compounds (VOC) for the capture efficiency determination
were tentatively Identified. (Final Identifications will be made in the
testing phase of this project should testing be carried out at this
facility.) Measurements would be conducted on the incinerator *nlet duct,
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2
Huct arid the fugitives exhaust duct using
c5! in^hn^ai°throuqh 4 (M1-M4) for'the volumetric flow rate measurements
5 EJhnd 25A (M25A) for the VOC concentration measurements. It appears
and Method 25A (MZ5 ) volumetric flow rate measurements
Sl&S lc? ^IMcat^s! provided cyclonic flow is not present.
Measurement of the flow rite and VOC concentration of the
, , «hJ.ist usinq M1-M4 ana M25A wouid also be conoucted to
1nc1«r«tor exhwst ustng nJ.c«trrt1on of t(w gas recycled t0 the oven-
determine the amount measure the gas velocity at the oven inlet
An anemometer would be used to measure ^ ^ presence Qf the
to determine whether t VQC concentrat1on inside the enclosure
enclosure. Finally, the amoient detem1ne whether steady-state
would be measured enclosure. The ambient VOC
conditions have bee enclosure would be measured with an OVA-1 meter
concentration outsid drawn in through natural draft openings
(NOO s) to affect the capture efficiency determination.
'4-?5.a -easur^ent- -ould ':a .nace -sntinuously :ver 2
'r 1*' wnVia volumetric riow measurements wouia oe caKen wun d
1-hour Pe^' w"^ after each test and monitored with a 1-hour continuous
traverse fJe£ore f"jLment a 1-hour continuous measurement of oven inlet
#1?1!t5°i2irSUJSSi^ ?or each test run to detect any variation in
velocity would be req nvA-1 measurement of VOC concentration
Sild * made on a 1-hour continuous basis, while the
!llr ?r -nc-"t"-on rucnae :r.e snclosura wouid oe Tieasur-a ^efors
ana after each test« Aaaitionai detail on zesting considerations ;s
presented in Section II, Part D.
0. Specifications
cnprifications have been prepared for the TTE, including drawings of
ttf ctrnrture and a list of the materials and equipment necessary to
construct the TTE. The deifications are presented in Section III.
E. Cost Analysis
TUa aeenciated with performing a capture efficiency
J * I !f5nn usina the TTE protocol have been estimated based on the TTE
detenj nat on using the nt selected. Constructing and
specifications and p 9 des1gn# fflaterials, equipment rental, and
dismantling the TT , J7 2oo. Additional costs of about $17,100 would
labor would ^aL"e!esting. During most of the year, no production would
be nT^^« m conItSion and dismantling; the total cost of the
efficiency determination would.be approximately $24,300. However,
capture efficiency de ummer months when the plant operates
during Pea* de™J" t(Lal test cost could increase significantly due to lost
continuously, the to capture efficiency determination
S°SSJltStiSi ll coJ?a?ne5 in the confidential addendum to this
report.
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3
II. Options Considered and Rationale for Selections
A. Production Line to be Evaluated
The facility contains both coating lines and lithographic printing
lines. The lithographic presses use very thick paste inks that contain
Insignificant amount: -f VCC; the VOC emissions from the printing lines
are associated with a coater that applies a VOC-based varnish over the
printing Ink. The VOC emission points and control system associated with
the varnish application operation are very similar to those of the coating
lines. After discussion with Mr. Gere of ANC, it was determined that the
coating lines would be more difficult and costly to enclose than would the
printing line varnish coaters because the coating lines are closer
together and are operated more frequently.
The coating lines are nearly identical, as are the VOC emission
sources and control systems. The coating lines are located side by side
in one area of the ccatinc r^cm: the widths of the aisles separating the
lines vary scmewnat is i -esuit of :he placement of structural csiumns.
Line No. 23 was selected for in-depth evaluation because it has the
minimum separation from the adjacent coating lines, thereby representing a
worst-case situation.
B. TTE Configuration
"The aeclstan :c oe .uade in considering, tne TTE configuration
is whether the drying oven can be considered part of the total enclosure
or must Itself be enclosed. For the drying oven to be considered part of
the enclosure, VOC emissions must not escape the drying oven as fugitive
emissions. All VOC emissions must be vented through ducts or stacks. As
a means of determining whether this condition 1s met, the draft TTE
protocol requires that the drying oven meet specified criteria for a total
enclosure.
At the ANC plant, it appears that the drying oven does not meet the
criterion requiring an average Inward face velocity of at least 200 feet
per minute (ft/min) across the openings. Measurements with a hand-held
anemometer at the oven entrance showed a maximum of 180 ft/m1n. A
measurement at the opening of the wicket return chamber (located beneath
the exit from the cooling section) Indicated an inward velocity of
75 ft/m1n. However, these measurements were taken while the oven was
operating but the coating process was not.- Therefore, it 1s not certain
whether the measurements are-fully representative of periods of process
operation. An automatic controller system adjusts oven airflows depending
on heating requirements, so the face velocities could be different-during
process operation.
In any case, these openings are not the crucial ones. The oven
entrance would have to be within any TTE 1n order to capture emissions
from the flashoff area, so any losses through the oven entrance would be
contained by the TTE. The wicket return chamber receives some VOC at a
preheat section heated with recirculated incinerator exhaust, but this
-------
4
^ -„+¦ anA nf the oven about 100 ft from the
section is located at the froin . It extremely unlikely that any
entrance to the w^ck®ttu® "icket return entrance even with a face velocity
VOC would escape from the picket oyen exit realistically remains
of only 75 ft m n• ™us, jnly^ emissions from the drying oven,
as a potential source
o*it of the final oven heating section
The face velocity aero:5S iection makes the exit inaccessible.
was not measured oecaus- tr>ethe drying oven in a vertical position, so
l£ dried and cuired shtjt-^ * e drying during operation the
the oven exit is restively large. n because the great
effective area of the opening is actuiiny ^y^ ^ ^ ^
majority o* Wh11e the face velocity across this small
are spaced 1.5 inches apart), wn cr1terion could be met with a
opening 1s not known, the face veio
relatively low volumetric now
e _ M-r<. face velocity inward through the drying oven
Regardless of the e . .ficant VOC escapes through the exit. The
exit, it 1s u"l1kel^!*f *J?ess must be thoroughly dried of VOC to avoid
coatings idcI-m -n -••s rjrocM ^ in _ne „ns raor,iat8a ,rom
contaminating ;ne ?rJ°u"r®^K the drying process is largely complete
bSoStS sheets * apR th^ f lo^of' gases^i thi r^the drying ovenlt
toward^th^entrance^ecause'the exhaust pickup is at the front of the
oven.
aoove, it *as oeternnneo :r.at :r,e quantity
For '-ne r«asons.d,sS"5!vinfl oven, if any, would be insignificant,
of fugitive VOC escaping the drying by the TTE. Thus, the emission
and the drying oven need not be e ^ would fae the CQater (including
Sl"2atlSS and ^ c 1 ean i ng° sol vent supply vessels) and the flashoff area.
The smallest enclosun= that could contal,-these sources^ m
inmedlately around the be outside such a small TTE.
drying oven entrance. The op several reasons. The TTE would hamper
This configuration was rejected for se e required frequently
operator access to the coating WlP«£; beMd1ff,cult to size
during operation. With sue criter1i of the protocol, particularly -|f
and locate the NOO's to meet tM cr^ loeat10ns for op„ator access..
openings must be Pro Mnn'< so close to the emission points could
Also, location of the NDO sso £ patterns, changing the rate of
sign flcantly alter the normalalrf w P Finally, the TTE
i^have"^"^largely freestanding; llStle use could be made of
existing structures for support.
Instead of the ^"^^^opeStoAarUlected!" Th1s°configuration
The attachment Pres*nt? the enclosure during the test. The side walls
operator ^ul VTtheMidpoint of the aisles on either side of the coatlnj
would be placed at tne
-------
5
line, affording adequate room for the operators of all the lines. The
walls would have to be fitted, around the power hoist monorail that runs
perpendicularly across all the lines above the coaters. Covered doors
would be placed in the walls on either side of the coater. These doors
would not be used during a test run but would be needed for equipment
changeout between production runs should it occur during the period of the
test program.
The end wall at the feeder end of the line would be placed to enclose
the feeder. The end of the section of rollers leading to the feeder would
protrude through this wall through an NDO large enough for a load of sheets
to pass through. This placement would allow the loads to be delivered to
the rollers with a forkllft as is normally done. Covered doors would be
located 1n this end wall on either side of the line to allow personnel
access as necessary. The bottom portion of these doors likely would be
left open as NDO's so that the aisle areas would be swept of VOC. It is
not expected that the doors would be used frequently; the operator
typically would get from one aisle to the ether by cutting across 1
at d point w renin erse 771. operator *as ooservea :cmr: :c :::a
site visit.
At the other end of the TTE, walls would extend from the side walls
to the sides of the drying oven to enclose the front of the oven, including
the oven entrance. The walls would be placed to Include the first access
door to the oven interior through vhich the operator 'emetines ?xzric-3
csatea sneers r'or QA aczrmias. Covered j.cors wouic; ,:e "ocaraa in-
walls on either side of the oven to allow personnel to pass in dna out is
necessary. The bottom sections of these doors might also be left open to
function as NDO's.
The roof of the TTE would pass just over the line's light fixtures.
The lights would be inside the TTE to ensure adequate lighting and would
function as supports for the roof. The roof would be fitted to the front
of the drying oven above the entrance and would be joined to the side and
end walls.
Four dampered pickups for the fugitive emissions exhaust are included
1n the specifications for the TTE for maximum flexibility in adjusting
airflow patterns, although fewer might be sufficient. The locations of the
pickups and the damper settings could be varied as necessary to control the
VOC concentration within the enclosure and to minimize the effect of the
TTE on capture efficiency. The dampered pickup ducts would extend downward
from the TTE roof to a height of 1 to 2 ft above the floor. Above the TTE
roof, the pickup ducts would be joined Into a single exhaust duct which
would extend upward through the existing vent 1n the plant roof. Primary
support for the fugitives exhaust ducting would be provided by clamps at
the level of the facility roof. Additional support for the pickup ducts
may be provided by a conveniently.located electrical bus that extends
across the line above the TTE roof level. The exhaust fan and fugitives
test point would be located on the roof.
-------
6
As an alternative, the fugitives exhaust could be run from the TTE
end wall down the aisle between the drying ovens and exhausted Into the
plant. However, in the latter case, the fan would be required to be
"explosion-proof" for fire protection, increasing its cost.
C. Materials of Construction
Plastic sheeting (6 mils thick) was chcsen fcr the .val's ana iha -
of the enclosure because it is lightweight, inexpensive (I to 3 cents/ft^P
area), and offers some visibility from outside the enclosure. It 1s eas
to work with 1n that 1t can be cut and resealed and can be easily moved if
necessary. Also, the TTE could be vacated quickly in case of emergency
Cables were selected instead of a wooden frame to support the plasti
sheeting for a number of reasons. A wooden frame would be more costly in
materials and labor to construct and dismantle. Cables are already used
the plant to hang curtains; therefore, facility personnel are familiar Suu
the Installation of such cables. It is likely that the TTE could be bull*
by olant oersonnel rather than necessitating an outside contractor. The
caDies couia oe sprung from existing roof supper: csijmns ;na ;3r.yaik
railings so less fabrication would be required. Less space would be take
up between coating lines by the cable-draping method because a wooden fr»nL
would be wider and any additional bracing required by the frame would tak*
up room 1n the narrow passageways. e
0. Testing
Figure 1 is a schematic of the proposed sampling points for the
capture efficiency test. Table 1 presents the suggested measurements t*
methods, and frequencies for each sampling point. Capture efficiency*wouiw
be calculated by dividing the sum of the VOC mass flow rates from test
locations 1 (combustion air) and 2 (incinerator Inlet) by the sum of the
VOC mass flow rates from test locations 1, 2, and 3 (fugitives exhaust)
The contribution of VOC from the incinerator recycle stream is not
accounted for 1n this calculation. Calculations provided in the attachme
based on data provided during a followup telephone conversation with
Mr. Gere show that the VOC contribution from the recycle is a maximum of
7 percent of the total VOC concentration entering the Incinerator. This
value becomes relatively insignificant to the determination of capture
efficiency because the Incinerator Inlet stream 1s Included in both the
numerator and denominator of the equation. However, measurement of the
Incinerator exhaust before and after each test run has been Included In th
test plan to allow determination of the amount of combustion gases recycle!!
to the oven during the test period and, subsequently, the Impact of the inr
contained 1n the recycled gases on the capture efficiency measurement.
In addition to measurements at test locations 1, 2, and 3 that will
be used to calculate capture efficiency, measurements at test locations 4
5, 6, and 7 have been Included 1n the tentative test program. As d1scuss*w
above, the measurement at test location 4 will provide an Indication of ts
effect of the recycle stream. Measurements at test locations 5, 6, and 7
will Indicate whether the TTE affects airflow into the oven, whether the
-------
FUGITIVES E XHAU j I
3
* ROOF
M C I N fc n At 0 I
SHEET FEEDER
OVEN
ENCLOSURE
Figure 1. Sampling points at African National Can Company.
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TABLE 1.
SAMPLING PLAN
FOR AMtKICAN NATIONAL CAN COMPANY
Test
location
Measurement
Method
Frequency
1.
Combustion a1ra
Velocity
M1-M4
Traverse before/after each test;
continuously monitor single point
VOC
M25A
1 h continuous
2.
Incinerator inleta
Velocity
Ml-M-1
Traverse before/after each test;
continuously monitor single point
VOC
M25A
1-h continuous
3.
Enclosure venta
Velocity
M1-M4
Traverse before/after each test;
continuously monitor single point
VOC
M25A
1-h continuous
4.
Incinerator exhaust
Velocity
M1-M4
Traverse before/after each test;
continuously monitor single point
VOC
M25A
Monitor before/after each test run
5.
Oven Inlet
Velocity
Anemometer
1-h continuous
6.
Ambient within enclosure
VOC
M25A (OVA-1)
Continuous
7.
Ambient outside enclosure
VOC
M25A (OVA-1)
before/after each test
M25A = flame Ionization analyzer (FIA).
M25 = Total gaseous nonmethane organlcs (TGNMO).
Simultaneous sampling.
Option 1—add H25 at locations 1, 2, and 4
Option 2—replace H25A with M25 at 1, 2, 3, and 4
-------
9
system Is at steady state, and whether significant VOC is drawn into the
TTE through the NDO's, respectively.
An alternative to using M25A (which uses a flame ionization analyzer
[FIAJ) is to use Method 25 (M25), although M25A appears to be more suitable
because a continuous measurement may be made. A continuous readout at the
site would be preferable to having to wait for lab analysis after testing
because it would allow the site crew to modify parameters such as the
fugitive exhaust flow rate before actual test runs began. If the control
device efficiency were being measured, M25 at locations 1, 2, and 4 would
be the more suitable method because M25 is not affected by the presence of
a variable mixture of compounds (Including products of Incomplete
combustion) and, therefore, would yield a more accurate measurement of
control device efficiency. Note, however, that M25 is less sensitive to
low concentrations, which could be encountered at the incinerator exhaust
(test location 4) and the fugitive exhaust (test location 3).
An OVA-I type meter is recommended to monitor the ambient VOC
concentration insiae and outsiae *ne enclosure :ecausa a "asser ^avei jf
accuracy is acceptable for these two measurements. The purpose of the
ambient Inside measurement is to assure that steady state is maintained
within the enclosure. The purpose of the outside ambient measurement is to
evaluate the potential impact of ambient VOC drawn Into the TTE. The OVA-1
measurements could be "calibrated" against the FIA measurements, if
iscassary, to or3v?de a basis of ccmoarison.
It is recommended that the test protocol procedure for processes that
do not generate fugitive emissions at a constant rate be used at this
facility. The facility uses many different coatings, and process runs
typically are too short (average about 5 hours) to allow two complete sets
of three test runs to be conducted during a single process run as required
by the "before/after" procedure for processes that generate fugitives at a
constant rate.
III. Specifications
Drawings of the top and side views of the proposed TTE are presented
in Figures 2 and 3, respectively. A drawing of the proposed fugitive
exhaust system 1s presented In Figure 4.
The materials used to construct the TTE and their costs are listed in
Table 2. The most significant materials, from a cost standpoint, are the
fan and associated ducting. The fan was sized for an exhaust rate of
10,300 ft /m1n, based on the amount of air needed to maintain the concen-
tration of VOC 1n the enclosure at a maximum of 100 ppm. The calculations
and assumptions that provide a basis for this fugitive exhaust rate are
included in the attachment. In addition to the materials necessary for
construction of the temporary total enclosure as specified in Table 2,
Table 3 lists suggested tools and equipment necessary for Installation. It
was assumed for the cost analysis that the facility would have access to
all tools except for the scaffolds and walkboard (these were assumed to be
rented) at no additional cost.
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0 3 6
1 1
Feet
Figure 2. Top view of the TTE over coating line 23 at
American National Can Company.
-------
Side View ol Line 23
0 3 6
L t I
Feet
ft
kc«i 1>ouf
Mult Ou I (
Wiftiit EikIomm* NMdttd
L. *4
C .^ui On
ftSidu
Figure 3. Side view of the IT £ over coatf^j line 23 at American National Can Company.
(Modified to remove material considered confidential by ANC. The entire figure Is
Included 1n the confidential addendum to this report.)
-------
Sliccl Metal Flexible Duct
Figure 4. Proposed fugitive exhaust system at American National Can Company.
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13
TABLE 2. MATERIALS, EQUIPMENT, AND LABOR FOR CONSTRUCTION OF A
TEMPORARY TOTAL ENCLOSURE AT AMERICAN CAN COMPANY,
CHICAGO, ILLINOIS
"otal
Materials
Quantity
Cost, S
Labor
Cost. J
cost, $a
Cable instal lation
I. 3/16 in. fiber core cable
200 ft
50.00
2. 3/4 in. bean claaps
3
40.00
2 FTE'sx4 hours ¦ 8 MH
320
3. 3/16 in. U-bolts
4
28.00
9 140.00/MH
4. 2 in. 1(4 In.xl4 ft lumber brace
12.00
24.00
SUBTOTAL
152.00
320
472.00
Hang plastic
I. 6 mi 1*20 ft plastic
50 ft
35.00
Hang plastic, dip to cable, seal
640
2. 6 mi 1k16 ft plastic
300 ft
55.00
all joints, i.e., wall to wall.
3. Duct tape
3 rolls
10.50
wall to ceilinq, wall to oven.
). Mediue binder clips
I jross
12.60
wall to wall
S. Floor cleaning solvent
1 gal
25.00
2 FTExS hours ¦ 16 MH
5. Scaffold rental
2 9 4 days
80.00
i S40.00/MH
.5' «a1kbaard r
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14
TABLE 3. SUGGESTED TOOL AND EQUIPMENT LIST FOR INSTALLATION
Equipment
Tools .
Cutting knife (utility) T« r0'"n9 '"ffolds4
Cable cutter- Ladders
J . Cable ties
Screw drivers
Rags
Handsaw
Fire extinguishers (2)
Hammer
16 ft walk board*
Pliers
Qver-wai' hcis~
wrencnes
Metal snips
Siiggpsted staging of construction
i. Place blower md d-ctuork
Z. Pldca ;cq piasfic
3. Place side wall plastic
aAssumed to be rented.
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15
IV. Cost Analysis
The estimated cost of a capture efficiency determination at this
facility using the TTE protocol 1s about $24,000, not including the cost of
lost production. This cost Includes costs associated with TTE design,
materials, equipment rental, labor, and testing for the TTE design
specified In Sacticn II!. Tf t^.e tast were conducted during a peak demand
period, it 1s estimated that as much as 11 hours of production cou'
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TABLE 4. SAMPLING COST ESTIMATE
Base cost
Site survey - I person, 2 daysx8 hx$75
2 THC operators - 2x3 daysxlO hx$70
3 velocity oersons - 3x3daysxl0hx$70
Preparation and posttest checks - 40 hx$50
Calibration gases and supplies
Oata reduction and reporting - 40hx$60
Total
Option 1 - add M25 at locations 1, 2, and 4
2 operators - 2x3 daysxlO hx$70
-dasd = -0 '-^SSO
analysis - ixixSI5C
Total
Option 2 - replace M25A with M25 at 1, 2, 3,
"uine- -ra :r«w
Less caiioration
Analysis - 4x3x$150
Total
Assumptions:
1. 3 runs of 1-h each.
2. Method 25 options will use single sampling trains.
3. Base cost requires three heated THC analyzers and one OVA HC monitor
4. Estimates include moderate travel costs.
5. One day of travel/setup, 1 day of testing, and 1 day of teardown/
travel in field.
6. Note that the base cost requires $80K of analyzers. Equipment costs
for Option 2 would save about S60K in equipment but M25A is capable of
0 to 10 ppm range with detectable values to <1 ppm with good AC noise
M25 is not useful except at 10 to 100 times higher concentrations. *
$17,100
$4,200
2. COG
$7,700
md 4
- * j wvJU
* IiSOO
+$ 800
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17
TABLE 5. COST ANALYSIS FOR THE CAPTURE EFFICIENCY TEST
Cost to
Task complete, $
1. Design
a. Examination of facility 160*
b. Design of enclosure 320
2. Materials and equipment rental 4,615
3. Construction labor l,600c
4. Lost production d
5. Testina cocts 17,100
5. Dismantling 480e
TOTAL 24,275f
*Four labor hours at $40/h, including benefits and overhead.
-^!ant ' ibor 'icurn -it i40/h. "'ncludlnq senef't" ana iverneaa.
•;:-crty idocr "cure,it• -40/h, ir.ciucing aenef~ts ana over^eaa.
°The dollars per hour cost of lost production is considerec "y
ANC to be confidential business information (CBI). This
value is contained 1n the confidential addendum to the
report. Lost production 1s estimated to be as much as
11 hours, assuming 8 hours for hanging plastic and suspending
exhaust duct and 3 hours for dismantling plastic and exhaust
duct.
^Twelve labor hours at $40/h.
The total cost of the capture efficiency determination,
including the cost of lost production, is contained in the
confidential addendum to this report.
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13
The next two ^^,eSUsi?0Tr'S! "eftlmaUd at
S!Ss!1,Th?e^SS^l«bor cost estimate totals $1,600 for 40 labor
hours.
The fourth
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19
The cost analysis presented above is specific to line No. 23.
However, because the roll coating lines at this facility appear to be
nearly Identical, the cost of testing any of the lines would be expected
to be similar. A capture efficiency determination for a lithographic
printing line also would be expected to involve similar costs because the
process layout, VOC sources, and emission capture system are similar to
the roll coating lines.
V. Potential Problems
Several potential problems with the measurement of capture
efficiency using the TTE protocol specific to this plant and the chosen
coating line are listed below.
A. Drying Oven
The drying oven apparently does not meet the criteria for a TTE. It
is unlikely, however, that a significant amount of VOC will escape the
:ven is rjgi-:ve .anrissicns, .:S Jisc-ssea 'rj Cacc:cn !I. :
B. Oven Recycle
Because combustion gases are recirculated into the drying oven to
supply heat, any VOC contained on these gases will be measured at the
incinerator Inlet along with solvent vapors dried the coated
ineets. :--ni -3uqn icuiaf.cns irasentsa :n -ne ittacnment.
contribution co VOC concentration at the incinerator iniet r'rom :ne
recirculated combustion gases is 7 percent, based on a 92 percent
incinerator destruction efficiency and flow rates for the streams supplied
by ANC. Testing at the incinerator exhaust has been recommended to allow
the effect of the recycle to be evaluated.
C. Cleaning Solvent Emissions
According to Mr. Gere, the "double-scraper" or continuous cleaning
system that services the coater is not considered part of the affected
facility. It would not be possible to exclude this VOC source from the
TTE. The effect of emissions from the cleaning system on the measured
capture efficiency 1s uncertain. Some VOC from this system would be
measured with the "captured" emissions in the incinerator combustion air
stream, while some would be drawn out through the fugitives exhaust
vent. The direction of the effect upon the measured captive efficiency
value will depend on whether the emissions from the cleaning system are
captured at a higher or lower proportion than are emissions from the
coating. In any case, emissions from this source should be small relative
to the affected emissions and should not have a large effect on the
measured capture efficiency.
-------
20
VI. Conclusions
A TTE could be constructed around coating line 23. The capture
efficiency test using the TTE protocol would be feasible with the above
qua!ifiers.
Attachment
bl806-3/ESD
-------
Attachment
I. Calculation of Necessary Exhaust
Based on information received from Mr. Gere of ANC transmitted by
cover letter dated March 6, 1989, and in followup telephone conversations.
Assumptions:
1. Coating type is specified in the confidential addendum to this
report;
2. Plant achieves 90 percent capture; fugitive emission rate is
10 percent; and
3. 20 ppm solvent background ambient concentration in plant.
Total solvent application rate:
The dry solids application rate2for the coating is 11 mg/4 in.2. A
large sheet size would have 1,345 in. of coating. The coating line
mantes at about 100 sheets/mln. According to the formulation data
.•'srwarsaa sy ANC, :r.e :=at:ng :S sarcant so5 ias -ina :5 :?.ri2r.z .si-
by weight.
r 11 mq sol Ids a r 1,343 1n.*w65 mq solvents * nm
( 4,n>! "-"sKSt—'(TTSgsond?) * 6'859 solvent/sheet
-6,359 m soivent)fICO sneetwoO nnn]( 1 kg |f2.: ib, 9Q - lb
1 sheet n mln jl h n 1Qe mgA kg J ID/n
Application rate by solvent species:
(From formulation data for the coating)
»'««* application rate)
= Solvent species application rate
Xylene—36.7 lb/h
MIBK--38.0 lb/h
n-Butanol—14.9 lb/h
Olacetone alcohol—0.9 lb/h
-------
Volume of fugitive emissions by solvent species:
At 32°F and 1 atm.
(Solvent species application rateU^K^fj^KoaoHgi-jL-)
= Solvent species volumetric emission rate
Xylene (MW = 106)--0.21 f13/min
MIBK (MW = 100)—0.23 ft3/min
n-Butanol (MW = 74)—0.12 ft3/m1n
Dlacetone alcohol (MW = 116)—0.005 ft3/m1n
Volume of ventilation air required to meet OSHA standards:
The OSHA standards are:
100 ppm - Xylene
50 ppm - MIBK, n-Butanol, dlacetone alcohol
~-e ;cu.:.ifrsr! if :acsssary "entv.ir:on iir - icccmoi::neci ;sir:g
the following formulas: "•
E» ¦
-------
The calculation of the speclated background concentration is accomplished
through ratio of their relative vapor pressures as follows:
VP @ 0 °C, Background
Compound mmHq concentration
Xylene 2 9.0
MIBK 1.26 5.6
n-Butanol 1.22 5.4
Dlacetone alcohol -0 0_
20 ppm
Therefore, the volume of ventilation air required to meet OSHA standards
is found as follows:
0.21 ft3/min 0.23 ftVmin 0.12 ftVmin
3 3 3
x ft /min x ft /min x ft /min
—^30-9'/ ;ar- * * ':0- = s :art-
101 parts 10° parts 10° parts
0.005 ftVmin
x ft3/min
~Q~Y, j&rzz
10s parts
(0.21H1Q6), (0.23H106) . (0.12mQ6) (0.0051(10*) _ ,
91 x 44 x 45 x 50 x " 1
i (10,301) = 1
x » 10,301 ft3/min
II. Estimation of Recycle Contribution
See Figure 1 for a schematic of the corresponding stream numbers
V ¦ volumetric flow
V1+V2 = Vu + VR
VR = V^Vj-V* = 681+7,121-1,569 = 6,233 scfm
^R "^makeup s
(vmakeup = volume air entering oven from other sources)
-------
Vm = V2-VR = 7,121-6,233 = 888 scfm
C = concentration
Assume incinerator is 92 percent efficient and that the VOC content
in the combustion air is completely destroyed (between the action of the
burner flame and the incinerator)
Ci» = = 0.08 C2
What contribution to C2 does CR have after it is diluted by makeup
air?
C^' = concentration at point 2 resulting from recycle
CR = CR^Vr+vJ = CR = ^°-08 ^7»121 ^ = 0,07 C2
up to 7 percent of the incinerator inlet concentration could oe
from the recycle stream rather than from VOC evaporated from the substrate
in the oven.
Ill* Evaluation of TTE vs. Criteria
1. Average face velocity through NOO's >200 ft/min.
Air will be drawn from the TTE in three places, the oven sheet
entrance, the incinerator combustion air pickup, and the fugitive
exhaust. An equal volume of ventilation air will.be drawn into the TTE
through the NDO's.
• Volume drawn into oven through sheet entrance:
Average inward velocity -140 ft/min
(140 ft/min)(4.25 ftxl.83 ft) = 1,090 ft3/min
• Volume of incinerator combustion air:
680 ft3/roin (from ANC submittal)
-------
Volume of fugitive exhaust:
10,300 ft3/min (as calculated above in Section I)
Total volume drawn in through NDO's:
1,090 ft3/min
680
10.300
12,070 ft /min
There is one required ND0 where the line penetrates the end wall.
This ND0 was sized to be 6 ft wide x 5 ft high. Since there are about
12,000 ft /min drawn into the TTE, the face velocity across it will be:
12t000 ft /min a 40Q ft/min
30 ft
Distance between V0C sources and NDO's >4 x ND0 equivalent
amenar.
ND0 area is 30 ft2. The equivalent diameter for this area is:
30 ft'
: = 5.2
4x (6.2 ft) = 24.8 ft minimum alstance. From trie proposed TT.
deslgn shown in Figure 2, the distance between the NDO at the end wall and
the coater just meets the minimum distance criterion.
3. Distance between exhaust hoods or ducts and NDO's >4 x exhaust
equivalent diameter.
The four exhaust ducts each have 1-foot diameters. Therefore, the
minimum distance between the ducts and the NDO at the end wall must be
4 feet, which is easily met.
4. Total area of NDO's <5 percent of the enclosure surface area.
The total surface area of the walls, celling, and floor of the total
enclosure 1s:
(2 x 43 ft x 13 ft) + (2 x 16 ft x 13 ft) + (2 x 43 ft x 16 ft)
= 2,910 ft2
-------
The only design NDO in the TTE is 5 ft x 6 ft, or 30 ft2.
30 j ~ or * Percent
2,910 ft
IV. Value of Lost-Production
See discussion in the confidential addendum to this report.
bl806-3A/ESD
-------
WESTVACO CORPORATION
-------
MRII§) REPORT
FINAL COST AND FEASIBILITY STUDY: WESTVACO CORPORATION
EPA Contract No. 68-02-4379
ior^ issianment -5
ESD Project' No. 87/07
MRI Project No. 8952-26
Prepared for:
Karen Catlett
Chemicals and Petroleum Branch
Emission Standards Division
Office of A1r Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
Prepared by:
Stephen W. Edgerton
Midwest Research Institute
401 Harrison Oaks Boulevard, Suite 350
Cary, North Carolina 27513
October 12, 1989
MIDWEST RESEARCH INSTITUTE 425 Volker Boulevard, Kansas City, MO 64110-2299 • (816) 753-7600
-------
FINAL COST AND FEASIBILITY STUDY: WESTVACO CORPORATION
I. Summary of Analysis and Findings
The Westvaco Corporation facility in Richmond, Virginia, prints and
cuts paper to manufacture boxes for packaging. The facility uses
eight-color rotogravure presses. A site visit report, dated May 12, 1989,
contains detailed information on the process and facility layout.
A. Temporary Total Enclosure (TTE) Configuration
The Westvaco facility production lines are located side-by-side in a
large room called the press room. The basic process is very similar on
all the lines. At the suggestion of Mr. John Murphy, Plant Engineer at
the facility, Line No. 13 was selected for in-depth study as the most
difficult of the lines to enclose because it is crowded between lines on
either side. Potential TTE configurations were identified and evaluated
•ronsider-'na the layout of the orocsss. the locations of af^ctad a.rd
r.onaff3C"3-om "he „nwina .-reef: on zz :r.e
jutz^ng ina izacxing ^rea. 3acause -mxing squipment 'z consiaarsc :r
the affected facility at this plant, the HE would Include the press, the
mixing equipment, and the aisle between. Operators would generally remain
within the TTE during testing, and access to the equipment would not be
hindered. It appears that any attempt to span the print stations with a
TTE roof would be difficult because of obstructions; therefore, the TTE is
designed so that its walls reach to the plant roof.
The exhaust duct for the fugitive emissions should run from the
unwind end of the TTE out to a location on the plant floor inside the
press room. The exhaust fan would be located on the plant floor. A
natural draft opening (NDO) would be provided 1n the form of an open door
4 feet (ft) wide by 8 ft high at the cutting and stacking end of the
TTE. Additional detail on the TTE configuration can be found in
Section III.
B. TTE Materials of Construction
The TTE side walls should be constructed out of 6-mil polyethylene
sheets hung from I-beam roof supports that run parallel to the production
line. The plastic sheeting would be fastened using C-clamps and lath
strips. The end walls should be constructed out of 6-m1l polyethylene
sheets hung from the bottom of the celling trussels that run perpendicular
between the beams. These plastic sheets would be fastened using binder
clips and wire ties. The open lattice of the trusses would be closed off
using paperboard from the plant. Duct tape would be used to seal any gaps
1n the plastic sheeting and to connect the walls of the enclosure to the
:"ioor.
-------
2
Specifications have been prepared for the TTE, including drawings of
the TTE structure and a list of materials and equipment necessary to
construct the TTE. The specifications are presented in Section III.
C. Testing
The gas streams, sampling locations, and EPA Methods for measuring
VOC for the capture efficiency determination have been tentatively
identified. (Final identifications will be made in the testing phase of
this project should testing be carried out at this facility.) Volumetric
flow rate and VOC concentration measurements would be conducted on the
duct to the control device, the floor sweep duct, the scrap vent, and the
enclosure vent (fugitive exhiust) using EPA Methods 1 through 4 (velocity)
and Method 25 (VOC concentration). Additional volumetric flow measure-
ments would be made on the forced makeup air and forced-air fire safety
system ducts using Methods 1 through 4. The ambient VOC concentration
inside and outside of the enclosure, along with the VOC concentration in
the forced makeup air and forced-air fire safety system ducts would also
be measured usina Method 25A fusing *n OVA-1 tyoe tieter^.
For each test run, velocity traverse measurements would be taken
before and after each test run and continuously monitored during the run
at a single point. Method 25 measurements would be taken over a 1-hour
period for each run, with the resulting concentration determined as a
1-hour average value. The OVA-1 measurement of VOC concentration within
".ha sncicsure. -ou'c ;e rratie ;-nt:-uouf. iy :ur-ng »acn l-.iour -jn, .
-------
3
B. TTE Configuration
There are few options in the TTE design for Line No. 13. Because
the mixing area which is located on the press room floor across from the
press line is considered part of the affected facility, it has to be
included in the TTE. Because each of the line's eight dryers sits
immediately on top of its respective print station, the dryers also are
included in the TTE. The only options in the TTE design are how far to
extend the sides of the TTE along the cutting and stacking area (one end)
and the unwind station, and how high to build the TTE roof. There also is
some freedom in the placement of the fugitive exhaust system and NDO's. A
discussion of how the recommended options were chosen 1s presented below.
1. Length of TTE sides. The TTE was designed to extend for
120 feet to enclose all of the unwind area, the print stations, the mixing
line, and the cutting and stacking area. A shorter TTE could have been
desiqned to exclude the cutting and stacking area and the unwind area, but
¦"is nsG "ridt ^"i3c~no ~r.s snc'.csurs iround trcc3£~
and other ODStructions present in cnese areas wouia oe more aifficuic wiiir.
enclosing the entire line. Many obstructions such as pipes, ducts,
electrical conduit, and light fixtures would protrude through the end
walls with the shorter design; fewer obstructions would be encountered
with the longer TTE. Also, the separation between the nearest print
:~aticns md the NDO's necessary to allow the orocass Mne ta cass thr~uch
:ne snas :f i ;norr.3r "" *ou!a iqe neet :*e .?auivaient .iiometsr ::-itzr.cz
criterion jet forth in w.ne 77c 'protocol.
2. TTE roof. A large quantity of ductwork, pipe, electrical
conduit, light fixtures, and support structures are located above the
print stations. These obstructions, 1n conjunction with a water sprinkler
system located near the ceiling level, make any attempt to span the line
with a TTE roof very difficult. As a solution, the side and end walls of
the TTE are proposed to be draped from ceiling supports thereby making use
of the press room roof for the TTE roof. Note that draping the plastic
from the ceiling eliminates the need for a TTE frame, which 1s cumbersome
1n the crowded areas between the press lines.
3. Exhaust pickup. Two dampered pickups for the fugitive emissions
exhaust are included in the specifications for the TTE for maximum
flexibility in adjusting air flow patterns. The dampered pickup ducts are
proposed to be located at the unwind end of the TTE extending approximately
15 to 20 ft into the TTE. The pickup ducts would be joined Into a single
exhaust duct which would discharge at floor level Inside the plant. The
NDO, an open door 4 ft by 8 ft,' would be located at the other end of the
TTE near the cutting and stacking area.
Locating the fugitive exhaust duct and NDO 1n this manner would
create a general flow of air along the aisle between the line and the
mixing area from the cutting and stacking area toward the unwind area.
This airflow would tend to sweep the VOC out of the areas where personnel
are working. Secondly, the Inspectors that work at the cutting and
¦stacxmq need to oass in and out of the TTE occasionally;
-------
4
locating the fugitive exhaust system at this end might hinder their work
space or create unsuitable working conditions. Of course, the fugitive
exhaust ducts could also be located above the print line at any distances
meeting the criterion of four equivalent duct diameters from the NDO's.
However, these locations would present the problem of hanging the ducts or
attaching them to existing structures. Also, there is more room available
for the fugitive exhaust system on the plant floor at the unwind end of
the line.
It should be noted that, because the recommended TTE encloses all
the makeup air sources and exhausts that normally operate in the vicinity
of the process line, the addition of a fugitive exhaust system may not be
necessary for adequate ventilation of the area. However, theoretical
calculations provided in the attachment show that additional ventilation
is needed to keep the level of toluene inside the TTE below 100 parts per
million (ppm). Therefore, an exhaust duct is part of the TTE design.
C. Materials of Construction
Plascic ;neer"rg v-i .m is .vas c.-osen ."'.r :;;s ,,d;; ; ;-3
enclosure for a number of reasons. These reasons include its low cost,
manageability, relative transparency, availability, and flexibility.
0. Testing
^'gure ! rr^sants >. :cnemar:c -jf *.ha 't'estvaco. :nt i-'r - ana: •' -is
system. Fdoie - presents :.ie gssi2c neasurgments, .asi: netncas, ip.a
frequencies for each sampling point. Capture efficiency would oe
calculated by dividing the VOC mass flow rate from test location 1 by the
sum of the VOC mass flow rates from test locations 1, 2, 3, and 4.
Measurements of the ambient VOC concentration inside of the enclosure
(location 5) will indicate whether the system is at steady state and
whether the OSHA standards for personnel exposure are being met. Ambient
VOC measurents outside the NDO's (location 6) will indicate to what extent
nonaffected emissions are drawn into the enclosure during the test runs.
The additional measurements of VOC and volumetric flow at points 7
(forced makeup air) and 8 (forced-air fire safety system) would provide an
indication of the amount of forced makeup air flowing into the enclosure
and would indicate whether the background VOC levels outside the TTE where
the respective air intakes are located are low enough not to Interfere
with the capture efficiency test.
The choice of which EPA method to use when measuring VOC
concentration at points 1, 2, 3, and 4 presents a problem because the
dryers operate with direct-fired recirculation. Because direct-fired
dryers frequently have partially combusted VOC, Method 25 is preferred to
Method 25A. However, the fugitive exhaust duct will contain a low
concentration of VOC in it, dictating Method 25A. A comparislon -of the
measured VOC concentrations using two different methods will probably
-------
Scrap to Baling System
10 Units
In Press Room
1 Unitw/ln
Enclosure
.MakeUp Air
-75,000 CFM
Total;
-7.500 CFM
Inside Enclosure
V
I
©
8 Station
Press
7 Presses
Total;
1 Press
w/in
Enclosure
Scrap Duct
—1-2700 CFM
—"Each Press
Floor Sweep ..
Om /Press /
-800 CFM /
To Atmo , nore
SLA lo
Solv Roc
52.000 CFM
Max
1
w
IB-
J i
Exhaust
600-4000 CFM
Each Station
Forced-Air
Fire Salety
(ii «l»c+'»ci4 J,. *«l)
Station UQ
Station #1
^— Enclosure
I
I EjU.,,1
Figure 1. Schematic of the Westvu..,* Plant air ton, iling system.
-------
TABLE 1. SAMPLING PLAN Fl
-------
7
yield a faulty capture efficiency value. Therefore, this approach is not
advised.
Our initial recommendation is to use Method 25 for the VOC
measurements of streams 1, 2, 3, and 4 to account for the effect of the
direct-fired ovens. It should be noted, however, that concentratons below
100 ppm may not be accurately measured using Method 25. An alternative to
using Method 25 at 1, 2, 3, and 4 would be to use Method 25A. This method
has the added advantage of a continuous display of results, allowing
adjustments to be made to the fugitive exhaust system, NDO's, etc., if
necessary during the test. Note that the effect of the direct-fired oven
on the gas stream composition cannot be measured directly because there
are no defined ducts (contrary to Figure 1) where measurements might be
made.
In the event that this facility is selected for testing, further
information can be gathered to facilitate a final cioice between
Msthod: .5 ^nd ?5A. This facility analyzes the recovered solvent bv gas
:nromatsgripn jC, ;at£~rins :na TJant—.y eacn :a iven: "^ccvar^i-.
Small quantities of impurities, such as partial combustion products, are
Ignored. Examination of representative GC charts should allow a
determination to be made with regard to how the direct-fired ovens affect
the gas stream composition. That is, the compostion of the captured
stream can be compared to the expected composition of the fugitive stream,
ma i jetamination can be made regardinq whether an -"D win crcv-'se
:2moaraD:a ~2su.:3 -it '.ha :v;a "ocations.
An OVA-1 type meter is recommended to monitor the ambient VOC
concentration at points 5, 6, 7, and 8 because a lesser level of accuracy
is acceptable for these measurements. The OVA-1 measurements could be
calibrated against FID measurements, if necessary, to provide a basis of
comparision.
III. Specifications
A drawing of the top view of the proposed TTE is presented in
Figure 2. A drawing of the proposed fugitive exhaust system is presented
in Figure 3. The materials used to construct the TTE and tneir costs are
listed in Table 2. The most significant materials, from a cost stand-
point, are the fan and associated ducting. The fan was sized for an
exhaust rate of 10,200 cubic feet per minute (ft /min), based on the
amount of air needed to maintain the concentration of VOC in the enclosure
at a maximum of 100 ppm. The calculations and assumptions that provide a
basis for this fugitive exhaust rate are included in the attachment. The
rate was calculated based on coating usage and formulation data provided
by the facility. In addition to the materials necessary for construction
of the temporary total enclosure as specified in Table 2, Table 3 lists
suggested tools and equipment necessary for installation.
-------
Automatic Damper
Controllers Lino 13
Enclosure
1
Column
Catw^ii
EFT
\
Column
n.n.n.n.r i
8 Print Stations
I I
Elec Conduit
o
Unwind
Supply Ak-R..'l.ii.uular Duct
Catwalk
-Line t, i tuing Drums
j€Z
I tglil Fixtuiu
2
24'
Elec Conduit
a___P=S
»On.1,1OC'Oi" i >o oc
P.| . Duds. —1 Eloctncal _1 Work
C - .i iit, Elc Control Box Table
I Autumiiii ... i.tiollors —
,iv,ur,i J lor Exhuun uampors on
Cabinot Floor
Sweep Column ¦
Exhaust Solvent—' lor fcxtuuni uampers (
Line 12 '
Linos
120-
Right
Cutter End •
10 It
->¦ Unwind End
Lell
2011
Figure 2. Top view of proposed TTE at Westvu>o Corp., Ricltii, nd, Virginia.
-------
Top View
Cutting <-
Printing «-
Doc./
Nt>o
Enclosure 120'x 24 X 2"i' k.^>
Unwind
ti iiuinolef Flex M V
S.H* D^c-f-
Vlifl,
Spi.. Collr...
24" Flox Duel
3=f
£
V
• Fan
Damper
24" Diamolur
Metal Duct
If Long
Figure 3. Proposed fugitive «>< haust systen,
-------
TABLE 2. MATERIALS AND LABOR FOR CONSTRlu HON OF A TEln ORARY TOTAL ENCLOSURE AT
WESTVACO CORPORATION, RICHMOND, VIRGINIA
Mater i a 1s
Cos t, S
i .ibor
Cost, $
Total
cost, J
1. Sidewalls—24xl20'x2
Construction of side walls. Hang from I-beam with lath strips
C-clamps; duel tape to floor
Plastic
Lath bundles
C-clamps
Duel tape
F loor solvent
145.00
59.00
322.00
14.00
25.00
FTEx16 h = 32 MH
cMO.OO/MH
1.280.00
SUBTOTAL
565.00
1,280.00
1,845.00
2. End walls—24,x24'x2
Hang from roof bar joist with binder clips and wire ties, duel
to duct, through-pipe, and floor
Plast ic
Binder ct ips
Wire ties
Duct tape
Scaffold rental (also used in sidewall construction)
14 days x SlO/dayl
¦ >i|ie
35.20
12.60
35.00
10.50
40.00
FTEx8 h = 16 MH
d J40/MH
640.00
SUBTOTAL
133.30
640.00
773.30
3. Exhaust system3
a. Peer 1 ess Mode 1 300J be 11 dr i ve utility b1ower, 3HP,
460V, 3-phase explosion-proof motor and conduit oox
10,340 It /min, 1 in. SP, 877 rpm
b. 24 in. Hypolon" notch lock expansion collar, to blower
c. 24 in. x5 ft flexible duct and damper
d. 24 in. x 15 ft duct, blank one end
e. Two 18 in. dampered spin collars
f. 18 in. flexible ductx60 tt
g. Connecting duct clamps *
2,200.00
o2.00
182.00
190.00
160.00
772.00
34.00
i FTE x 5 h = 5 MH
c J40/MH
200.00
SUBTOTAL
3,600.00
200.00
3,800.00
4. Di sman11i ny
ME x 4 h = 8 MH
i 140/MII
320.00
320.00
TOfAl COS!
4,298.30
2,440.00
6,738.30
FTE = Full time employee.
MH = Man hour.
dAn exhaust system was costed out. However, plant representative., .uted in a foil.- p telephone conversation thai there would be
enough air flow through the proposed enclosure due to the numeral: f >rced air and .raust systems to maintain OSHA standards lor
solvent vapor. However, calculations (Included in the attachment) how that an a«i.ii iional exhaust may be necessary.
-------
11
TABLE 3. SUGGESTED TOOL AND EQUIPMENT LIST FOR INSTALLATION
Tools cost
Equipment
Utility knives
Ladders (2)
Metal snips
Rolling scaffold4
Pliers
100 ft 3/8 in. rope
Screwdrivers
Gloves
Rags
""•ssunsea '3a r-sntad.
-------
12
IV. Cost Analysis
A breakdown of the testing costs is provided in Table 4. Materials,
equipment, and labor are listed specifically in Tables 2 and 3. Table 5
summarizes the costs associated with performing the capture efficiency
test at the facility.
The major cost of the test program is the actual testing cost
($22,600), not the design and construction of the TTE. This testing cost
represents about 76 percent of the total cost, not including the cost of
any lost production.
Production losses are estimated at a maximum of 8 hours for this
facility. The cost associated with lost production is included in the
confidential addendum to this report. The lost production would occur
during the construction of the TTE end walls, since the unwind and cutting
and stacking areas require unencumbered access during production and the
amount of piecing around of obstructions in the end walls is expected to
:rsata "cme *aat"^l vrdnncss.
Costs are presented for conducting the test on one line. The cost
of tests on the other lines is expected to be comparable. It is not clear
whether test results from one line could be reasonably generalized to the
other lines. The process equipment is not identical, but the air handling
systems appear to be very similar. The plant currently demonstrates
:cmo 1 : inca :sinc • :: ihtwms ':"natervil :.iMrc3. ver. :np
. ;ne iuo/jac- , ina• Region ill :i pressing ;cr
compliance test on this line alone.
V. Potential Problems
As stated in Section II, the direct-fired ovens present a problem
that is not unique to the TTE protocol for determining capture effi-
ciency. The problem is that there likely is destruction of solvents in
the ovens that won't be accounted for in the CE determination. Any VOC
that 1s completely destroyed will not be measured. Also, products of
Incomplete combustion may affect the accuracy of Method 25A for comparison
of the captured and fugitive streams.
VI. Conclusions
A TTE can be constructed around line No. 13. The capture efficiency
test using the TTE protocol is feasible with the above qualifiers.
Attachment
bl802-6/ESD
-------
13
TABLE 4. ESTIMATED TESTING COSTS AT WESTVACO CORPORATION,
RICHMOND, VIRGINIA
Base cost
Site survey—1 person, 2 days x 8h x $75/h $1,200
4 M25 operators—4x3 days x lOh x $70/h 8,400
1 OVA operator—1x3 days x 10 h x $70/h 2,100
2 lab persons—2x3 days x lOh x $70/h 4,200
Preparation and posttest checks—40h x $50/h 2,000
Supplies 500
Data reduction and reporting 40h x $60/h 2,400
Analysis—4 locations x 3 runs x $150/sample 1.800
TOTAL $22,600
Option: Replace M25 with M25A
Remove 2 'id arsons
Remove analysis
Add calibration gases
Remove one operator
TOTAL
Assumptions
1. Three runs of 1 h each
2. Method 25 uses single sampling trains
3. Estimates include moderate travel costs
4. One day of travel/set-up; 1 day of testing, and 1 day of
teardown/travel in field
5. The option requires four THC analyzers, gaining sensitivity of 10 to
100 times M25 but requires more THC's than most test contractors would
have available. Combination might be useful.
6. Industrial-style project costing, no test, QA plans, etc.
-i,80G
+1,000
-2,100
-$7 100
-------
14
TABLE 5. COST ANALYSIS FOR THE CAPTURE EFFICIENCY TEST AT
WESTVACO CORPORATION, RICHMOND, VIRGINIA
Cost to
Task complete, $
1. Design
a. Examination of facility 160a
b. Design of enclosure 320*3
2. Materials and equipment rental for 4,300
construction of TTE
3. Labor costs for construction of TTE 2,120
4. Lost production c
5. isscing josis jOG
6. Dismantling 320^
TOTAL 29,820d
aFour 'labor hours at SJO/h, including benefits and overhead.
JE:gnt idcor .*our<: it j40/h, :nc:ua"sng oenefiri ma
overhead.
CEight hours estimated lost production time. The Westvaco
Corporation estimate of cost of lost production, in S/h, is
contained in the confidential addendum to this report.
dNot including lost production costs. The total cost of
performing a capture efficiency test, including lost
production cost, is included in the confidential addendum to
this report.
-------
Attachment
I. Calculation of Necessary Exhaust
Assumptions:
1. 75 lb VOC/h on Line 13.
2. 79 percent capture.
3. Assume all solvent 1s toluene.
4. 25 ppm background concentration.
(75 lb VOC/h) (1-0.79) = 15.75 lb/h
(15.75 lb/h/92 lb/lbmol) (359 ft3/lbmol) = 61.5 ft3/h = 1 ft3/min
100 ppm (fugitive)-25 ppm (background) = —5—VOC (ft /min)
ft /m1n necessary airflow
(61.5 ft3/hHh/60 min) = (100-25)
Ix.O
x = 13,700 ft3/min
Other exhaust sources:
"oor iweeo: 300 r't ,-min
2. Scrap duct: 2,700 ft /min
3,500 ft /min
13,700 ft3/min-3,500 ft3/min = 10,200 ft3/m1n
The exhaust fan should be sized for 10,200 ft3/m1n because there are
two other sources that exhaust 3,500 ft /m1n from the enclosure.
II. Criterion Checklist
See Checklist Table for sunmiary.
A. Minimum Face Velocity of 200 ft/min Through NOO's
Under the most likely test conditions, the press exhaust will be
operating at or near the maximum rate of 12,000 ft /min. The total
exhaust r|te from the TTE 1n this case, therefore, will be about
25,700 f$ /min. However, a forced makeup air system supplies about
7,500 ft /min to the enclosure. Thus, the net quantity of makeup air that
will flow in through the NDO's 1s about 18,200 ft/min.
The2design calls for a doorway measuring approximately 8 ft x 4 ft,
or 32 ft . Therefore, the face, velocity through this N00 is:
18,200 ft /m1n , 57Q ft/min
32 ft
-------
Therefore, the criterion of greater than 200 ft/min through the NDO's
is met.
B. Distance of VOC Emission Sources to NDO's Must Be At Least Fnnr
NDO Equivalent Diameters ~ '—
itr2 = 32 ft2 (area of doorway)
req = 3.2 ft
Deq = 6.4 ft
VOC sources must be >26 feet from this NDO. From the diagrams, this
criterion is met as the end of the TTE at the cutting and stacking end
(which is where the doorway would be located) is at least 30 feet away
from the closest VOC source, which is the last print station.
C. Distance of NDO's to Hoods or Exhaust Ducts Must Be At Least Fnitr
Equivalent Duct Diameters' '
^ • nca *na -00 ~ iz ".'is "r.r.sr ;nd :f ".."is 1 "*~rn
distance of greater cnan 100 ft), the criterion of four equivalent duct
diameters from the NDO is met.
D. Area of NDO's Must Be Less Than 5 Percent of the Total Surfaro
Area of the TTE ~~~ "
Surf-ics ir?a ;f <00: .12 r":'
Surface area of TTE:
(120 ft x 24 ft x 4) + (24 ft x 24 ft x 2) = 12,672 ft2
32/12,672 = 0.003 or 0.3 percent of surface area. Therefore, this
criterion is met.
bl802-6A/CBI
-------
CHECKLIST TABLE
Plant-specific design
Applicable Criterion
Criterion value met
1. Airflow through NDO's >200 ft/min 570 ft/min Yes
i nward
2. Distance of VOC emission >4 NDO equivalent >30 ft Yes
sources to NDO's diameters
(26.5 ft)
3. Distance of NDO's to >4 hood or duct >100 ft Yes
hoods or exhaust ~ equivalent
ducts diameters
(6 ft each)
4. Area of i^DG's percent of u.5 percant res
total surface
area of the
TTE
-------
kenyon INDUSTRIES
-------
MRII§) REPORT
FINAL COST AND FEASIBILITY STUDY: KENYON INDUSTRIES, INC.
EPA Contract No. 68-02-4379
Work Assignment 26
ESD Project No. 87/07
MRI Project No. 8952-26
^•"eparea ;ar:
Karen Catlett
Chemicals and Petroleum Branch
Emission Standards Division
Office of A1r Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
Prepared by:
Stephen W. Edgerton
Midwest Research Institute
401 Harrison Oaks Boulevard, Suite 350
Cary, North Carolina 27513
May 16, 1989
(Finalized May 3, 1990)
MIDWEST RESEARCH INSTITUTE 425 Volker Boulevard, Kansas City, MO 64110-2299 • (816) 753-7600
-------
FINAL COST AND FEASIBILITY ANALYSIS
FOR
KENYON INDUSTRIES, INC.
I. Summary of Analysis and Findings
The Kenyon Industries, Inc. (Kenyon), facility in Kenyon, Rhode
Island, performs fabric finishing, drying, printing, and coating on a
commission basis. The fabric coating lines generate emissions of volatile
organic compounds (VOC) and are the objects of this analysis. A site
visit report, dated May 12, 1989 (finalized April 27, 1990), .contains
detailed information on the process and the facility layout.
A. Temporary Total Enclosure Configuration
Coating line 5 was selected for in-depth analysis based on its large
size, relatively complex temporary total enclosure (TTE) requirements, and
type of add-on control device (thermal incinerator). This coating line
:2ns: tcc :f -'-ur :oati nq stations and ir/ina .ovens 11 tarn at-rr; !-
series. Potential TTE configurations were identified ana avaiuatsa
considering the layout of the process, the locations of affected and
nonaffected VOC emission sources, the locations-of permanent structures
that would aid or obstruct TTE construction, operator access requirements,
material flows, health and safety requirements, and the criteria included
'n the TE orotocol. The proposed enclosure would consist of four TTE's.
*acn snciasina me :f ".he rcatlrrq .stations ma the nornai ..orK iraa ;f :na
station's operator. Zicn zi :ne 'raiviauai 7~E'o wouia iave a rug"", •¦•a
emission exhaust duct. These four ducts would join, and the common duct
would pass through an unused stack to a fan located on the plant roof.
Additional detail on the TTE configuration can be found 1n Section II,
Part B, and in Section III.
B. Materials of Construction
The proposed TTE's would be constructed of 6-mil plastic sheeting.
The support structure would consist of existing structures augmented with
wire and 2x4's as necessary. More detail on construction is presented in
Section III.
C. Testing
The gas streams, sampling locations, and U. S. Environmental
Protection Agency (EPA) Methods for the capture efficiency determination
were tentatively identified. (Final identifications will be made in the
testing phase of this project should testing be carried out at this
facility.) Volumetric flow rate and VOC concentration measurements would
be conducted on the Incinerator inlet duct and the common fugitive
emission exhaust duct using EPA Methods 1 through 4 (M1-M4) for the
volumetric flow rate measurements and EPA Method 25A (M25A) for the VOC
concentration measurements. It appears that a suitable test point for the
volumetric flow rate measurement is present 1n the incinerator inlet
without any duct modifications, provided cyclonic flow is not present.
-------
For each run, simultaneous M25A measurements at the two test
locations would be made continuously over a 1-hour (h) period. Volumetric
flow rate measurement traverses would be conducted at each point before
and after each test run. A single point on the traverse would be
monitored continuously during the 1-h test runs.
The ambient VOC concentration inside the TTE's would be monitored
with an OVA meter during the test runs to ensure that steady-state
conditions exist and that the personnel exposure standards are not
violated. The ambient VOC concentration outside the enclosures would be
monitored with an OVA meter to evaluate the potential for VOC drawn in
through the natural draft openings (NDO's) to affect the capture
efficiency determination significantly.
Additional detail on testing considerations is presented in
Section II, Part 0. Testing costs are presented in Part IV.
D. Specifications
'cscif"!2l*ens uvs ^esn **.he '~,c1udi~c
tne TTE structure ana a Mst of cne materiaii ana equipment .-.ece^ary
construct the TTE. The specifications are presented in Section III.
E. Cost Analysis
The costs associated with performing a caDture efficiency
;2t3HT!inati on i2"'nc ~ha - ^rctccc: '?.va :2sn ^sfimatscj zazzc. :r> *r:a ~
specifications dna sampling .ocaticns ;2iect2a. ill ispectt :t
constructing and dismantling the TTE would total approximately 39,900.
Additional costs of about $15,000 would be incurred for the testing, for a
total of approximately $24,900. Details on costs are presented in
Sections III and IV.
II. Options Considered and Rationale for Selections
A. Production Line to be Evaluated
The facility has six fabric coating, lines. All the coating lines
consist of floating knife coaters followed by infrared drying ovens.
Line 3 has only one coater and drying oven. Lines 1, 2, and 6 each
consist of two coaters and two drying ovens. Lines 4 and 5 each consist
of four coaters and four drying ovens. On the lines with multiple coaters
and ovens, the fabric web is alternately coated and dried as 1t passes
sequentially through a coater, a drying oven, then to the next coater and
drying oven, and so on until it has passed along the entire line.
Line 5 was chosen for detailed analysis because of its large size,
the relatively complicated TTE configuration required, and the add-on
control device (thermal incinerator) used to reduce emissions. Lines 1,
2, and 3 are older, smaller lines located together 1n a small room that
could be augmented with plastic film relatively easily to construct a
common TTE or individual TTE's. Line 4 is similar in size and complexity
2
-------
to line 5, but its emissions are controlled and recovered with a system of
dedicated condensers. For this reason, compliance determinations for
line 4 would be very likely to be conducted using a liquid/liquid material
balance. Line 6 is smaller than line 5 and also is controlled using
dedicated condensers to recover VOC emissions.
B. TTE Configuration
The first decision to be made in considering the TTE configuration is
whether the drying oven can be considered part of the total enclosure or
must itself be enclosed. For the drying oven to be considered part of the
enclosure, VOC emissions must not escape the drying oven as fugitive
emissions. All VOC emissions must be vented through ducts or stacks. As
a means of determining whether this condition is met, the draft TTE
protocol requires that the drying oven meet the general criteria specified
for a total enclosure.
As illustrated 1n Attachment 1, the drying ovens on line 5 meet all
*.^e :r'*3r*.i ;f :r:3 protocol ixcast -..-tat Tsverning :hs ;~ ".*dO • =
distance Detween the NOO's and the sources of VOC. However, ;ms
criterion will never be met at a drying oven entrance slot, and conformity
at the exit slot and any other NDO's is doubtful for any drying oven. Of
course, the drying oven entrance slot at this or any facility will not be
a problem because the entrance slot must be within the TTE for the
enclosure to caDture amissions from the entire flashoff area. rhe same i-s
:ot -acassar' ? -.rye :-r :ne :rynq :ven ax it - .at. ^vRrrna >. ¦
ovens are constructed to contain the VOC emissions generated «;tmn
them. Airflow patterns within the oven generally are engineered rather
than haphazard. The comfort of the employees and OSHA exposure standards
dictate that drying ovens be operated at negative pressure so that VOC
does not escape into the process area. For these reasons, the requirement
that a drying oven meet the criteria for a TTE in order to avoid being
enclosed by the TTE should be reevaluated when revisions to the protocol
are considered.
In the case of the drying ovens on line 5, 1t 1s unlikely that
significant VOC escapes through the exit slot or the row of makeup air
intake holes in the back wall of the oven. As shown in Attachment 1, the
average velocity inward through these openings 1s 1n excess of 200 feet *
per minute (ft/m1n). The orientation of the intake holes relative to the
wet web within the oven is unknown, but 1t 1s clear that the exit slot
(which has a much greater area than the intake holes) is oriented such
that the air entering the slot will flow parallel to the web after it has
already been dried. Thus, the air entering the exit slot will not impinge
directly on the wet web, and little turbulence will be created.
For the reasons discussed above, it would be unnecessary for the
drying ovens at this facility to be within the TTE. The emission points
that would have to be within the TTE are the coater, the coating supply
vessel, and the flashoff area.
3
-------
The smallest enclosure that could contain these sources would
actually consist of four small enclosures, each fitting closely around the
coating equipment (including the coating supply vessel) adjacent to the
drying oven entrance. The operator would remain outside these small
TTE's. This configuration was rejected for several reasons. The TTE's
would hamper operator access to the coating equipment, which is frequently
required during operation. With such small TTE's, it would be difficult
to size and locate the NDO's to meet the criteria of the protocol,
particularly if openings must be provided in specific locations for
operator access. Also, location of the NDO's so close to the emission
points could significantly alter the normal airflow patterns, changing the
rate of evaporation and the performance of the capture system. Finally,
the TTE would have to be largely freestanding; little use could be made of
existing structures for support.
Instead of these small TTE's enclosing the coaters, larger individual
TTE's enclosing the normal work area of each coating station's operator
were selected for this facility. Each of the four TTE's would encompass
the entire area between successive drying ovens and extend outward on
either side of 'the ^'-le to '-c' jda Lha mating :uc3*icntar-sr > -,r.a
left aisie dna cne crying oven control panei in ;ne ngnc aisie. 7he
operators typically would remain inside the enclosures during the test
runs; covered doors would be supplied to allow passage in and out of the
enclosures as necessary. This configuration is illustrated and discussed
in greater detail in Section III where the TTE specifications are
Dresented.
.An evaluation of :ne Tc's in reiif.cn :o ;ne ;rotoco: £ jesij-r
criteria is presented in Attachment 2. As discussed in the attachment,
the TTE's might have difficulty meeting the criteria that establish the
minimum allowable distances between NDO's and VOC sources or exhausts.
These difficulties would result from the relatively small size of the
TTE's. However, as presented in Attachment 2, the TTE's would violate
only the letter of the criteria; the conditions that the criteria were
intended to prevent would not occur in the TTE's. For this reason, this
configuration was not rejected. This situation indicates that the design
criteria in the protocol should be reevaluated when revisions to the
protocol are considered.
A single large TTE consisting of walls running from the plmnt ceiling
to the floor to enclose the entire line was considered for this analysis
and rejected. Such an enclosure could meet all the design criteria of the
protocol but would be much larger than the selected combination of four
TTE's. A single large enclosure would have to contend with numerous
obstructions avoided by the selected configuration. The large enclosure
would have to include the line's nonaffected curing oven, which would
require an additional sampling point, or the builders would have to
contend with placement of the TTE end wall between the final drying oven
and the curing oven. Finally, a large enclosure would not take advantage
of the existing support structures conveniently located above each coating
station.
4
-------
The fugitive emissions from each of the four TTE's of the selected
configuration would be exhausted through a dampered duct connected to a
fan and ductwork suitable for emission testing located on the plant
roof. As an alternative, the fugitive exhaust system could be placed
entirely within the plant and exhausted inside. However, this might
create obstructions to the normal flow of materials and personnel. Also,
an "explosion-proof" fan would be required for fire safety, increasing the
fan cost.
C. Materials of Construction
Plastic sheeting (6 mils thick) was chosen for the walls and roof of
the enclosures because it is lightweight, inexpensive, and offers some
visibility from outside the enclosure. Plastic sheeting is also easy to
work with because it can be cut and resealed and can be moved easily if
necessary. Also, the TTE could be vacated quickly in case of emergency.
Support for the four TTE's would come largely from existing
icmczunss. -govs aach -raatirq station there -'3 1 r-imewcr'<
from cne ceiling trusses :c .upport ;ne iignc fixtures ana iiactr- :z.
conduit that serve the station. This framework would provide much of the
necessary support for each station's individual TTE. Additional support
would be provided by existing ductwork to the left of the line and an
electrical bus to the right of the line. These existing structures would
be augmented as necessary with wire and 2x4's to complete the suDport
TT"!3 "IT* 1 ~ ^
The support system outlined above was selected instead of a
self-supporting wooden frame. A wooden frame would be more costly in
materials and labor to construct and dismantle. Also, the selected
supports would take up less space than a wooden frame in the aisles on
either side of the line.
D. Testing
Figure 1 is a schematic of the proposed sampling points for the
capture effi-ciency test. This figure has been adapted from a schematic
supplied by Kenyon. Table 1 presents the suggested measurements, test
methods, and frequencies for each sampling point. At this facility, short
product runs are the rule. Consequently, use of the TTE protocol option
that allows testing with and without the TTE to determine capture
efficiency is not recommended. Capture efficiency would be calculated by
dividing the VOC mass flow rate from test location 1 (exhaust duct to the
incinerator) by the sum of the VOC mass flow rates from test locations 1
and 2 (fugitives exhaust).
In addition to the measurements at test locations 1 and 2,
measurements at locations 3a through 3d and 4a through 4d have been
included in the tentative test program. The ambient measurements inside
the TTE's (locations 3a through 3d) would Indicate whether the system 1s
at steady state and whether personnel exposure regulations are in danger
of being violated. The ambient measurements outside the TTE's would
5
-------
iMD
O
«-•
fJ^Upl
13,000 SCFM
~
L-©
/
A
/
/
* \\
\ N
MO
t
Vp
—-fev-U
MO
f;
-LcT" ^
Manual
tor By-Pass.'./
^ Water B«_. ^
* ,
MO
Coatings
Dryer 4
r-Lj-
~©"
i
Dryer 3 tT
MO
0
Slack lo Atmos
15,374 ACFM <3> 1080"
600°F ,
Q Fan 6300 ACFM <8>200°F
©
3c L}
}b>
Dryer 2
Ov .,1 Hans (5). 1200 CFM@ 150 200°F Each
..1.
The
i— n
— < „.iting Heads (4) w/Capture Hoods
£L;j
©
Dryer
hK-—i ^ ,
•n.
1 L- -4
©
Cloth Web Let-OH
Enclosure
1500°F
n
HE.
Incin 11
II
U
Gas Burner
No. 5 K-Kote Range PROCESS SCHEMATIC
Kenyon Industries. Inc.
Kenyon. R.I. 02836
Figure 1. Sampling points
-------
TABLE 1. SAMPLING PLAN FOR KENYOIl
Test location Measurement Method
1. Captured Volumetric
flow
VOC
2. Fugitive Volumetric
flow
VOC
3a, b, c, d VOC
Inside ambient
4a, b, c, d VOC
Outside ambient
Alternative—Replace M25A with M25
M1-M4
M25A
M1-M4
M25A
M25A (OVA)
M25A (OVA)
INDUSTRIES, KulYON, RHODE ISLAND
i iequency
traverse befo«,;/after run; continuously monitor
single poini
i h continuous runs
\ i averse befoi^/after run; continuously monitor
single point
i h continuou-.. runs
lUnitor, alternating among locations during test
runs
iiunltor, alternating among locations before and
after test ¦ tins
-------
provide an indication of whether a significant quantity of VOC enters the
TTE's through the NDO's.
Method 25A is recommended for measuring VOC concentrations at test
locations 1 and 2. Method 25A uses a total hydrocarbon analyzer with a
flame ionization detector (FID) and provides a continuous measurement. A
continuous measurement would allow the test crew to monitor emission
levels and adjust parameters such as the fugitive exhaust flow rate before
actual test runs begin. In addition, M25A has a low detection limit, and
relatively low VOC concentrations are expected in the fugitive exhaust.
As an alternative to M25A, EPA Method 25 (M25) could be used at test
locations 1 and 2. Although M25 involves collecting gas samples for
subsequent analysis in the laboratory and has a higher detection limit
than M25A, M25 might be preferable over M25A if there were a significant
difference in the VOC compositions of the gas streams at test locations 1
and 2. However, this condition is not expected at this facility. Because
M25 is used for tests of incinerator destruction efficiency, M25 might be
desirable for the capture efficiency test in cases where the capture
rf-'-riancv -na :rntr^; :av".:3 ~.i~4ancv :3st~ .cnaucraa :rrcur-T- : v
as would be iikeiy for d compliance cast. using M25 for cctn zests .vcuia"
allow a single measurement of the incinerator inlet stream (test
location 1) to be used in both calculations. If M25A were used for
capture efficiency measurements and incinerator destruction efficiency
measurements also were desired, the incinerator inlet stream would have to
be measured us1na both M25A ind M25.
rtn JVA portaDis rlu instrument t racsnnnenasa --;r ssnrccrfirucus
monitoring of the ambient VOC concentrations inside and outside the TTE's
(test locations 3a through d and 4a through d) because a lesser level of
accuracy 1s acceptable for these measurements. When M25A is used at test
locations 1 and 2, the OVA could be "calibrated" against the test FID to
provide a basis of comparison.
III. Specifications
Drawings of three views of the proposed TTE's are presented in
Figures 2, 3, and 4. A drawing of the proposed fugitive exhaust system is
presented in Figure 5.
The materials used to construct the TTE's and their costs are listed
in Table 2. The greatest expense 1s associated with the exhaust system
fan and ducting. The fan was sized based on the quantity of ventilation
air needed to maintain the concentration of VOC in the enclosures at a
maximum of 100 ppm. The required fan size was calculated to be
13,000 cubic feet per minute (ft /min). The assumptions and calculations
that provide the basis for this fugitive exhaust rate are presented 1n
Attachment 3. In addition to the materials necessary for construction of
the TTE's, Table 2 lists the estimated labor hours required to construct
and dismantle the TTE's.
8
-------
Plant Roof
— Vertical Supports
(Dropped from truss to
support horizontal support
framework)
4— Electrical Bus
foffl Eyhwtt —~
Drying Oven
#2
i 1 i
o aft Wl
Figure 2. Side view of third coating u.uion (typical oi all coating stations).
-------
Plant Root
Enclosure
\/\ / \/\7\ /\/ \ / y \/\cei""9 T,"ss
Mam \ I
Horizontal \
btaJLu
• Vertical Support
(from truss to horizontal
support framework)
Electrical
Bus
Lefl-4
~Riglu
Figure 3. Front view of first coating stati.... enclosure (generally typical of all stations).
-------
Figure 4. Top view of first coating station enti.^ure (general 1/ typical of all stations).
-------
Figure 5. Proposed fnyiilve exhausl iystem.
-------
TABLE 2. MATERIALS AND LABOR FDR CONSImil HON OF TEMhiRARY TOTAL ENCLOSURES AT
KENYON INDUSTRIES, Mil* ON, RHODE I ii AND
Mdteriils
FRAMING (1st station)
1. 2 in.*4 in.xl6 ft lunber
2. Tie aire
3. 5 in. C-claops
PLASTIC SHROUDING (1st station)
1. 6-«il plastic (20 ft wide)
2. 6-aiI plastic (12 ft wide)
3. Duct tape
4. Medium bi niter cl ips
5. Floor cleaning solvent
6. Roll trig scaffold rental
7. 16-ft walkboard rental
1st STATION SUBTOTAL
2nd, 3rd, and 4th stations
FRAMING
t, 2 in.x4 in.x!6 ft J umber
2. Tie wire
3. 5 in. C-clamps
Qj^nt j ty
4 lb rolI
10
75 ft
36 ft
3 rolls
I gross
1 gal
2 § 4 days
4 days
3
4 lb rol
15
Cost, 1
6.00
3.10
59.20
56.00
21.00
10.50
12.60
25.00
80.00
40.00
313.40
9.00
3.10
88.80
I ..i
1 .ii.. n.dte support li.n.iing
2 iux2 h = 4 Mil § i-KJ/MH
11 j plastic, clip
;e_.l all joints,
la ceiling, wal I
o uiI to fIoor
i f"ft k4 h = 8 MH i HU/HH
.11 to ceiling plastic,
i.e., wal I to Mai I, wal l
l.j oven and accumulator.
Total
Cost, S cost, S1®
160.00
320.00
480.00 793.40
(ju. icafe support I. jwing
2- fit k6 h = 12 MH k t40/MH
480.00
PLASTIC SHROUDING
1. 6-«iI plastic (16 ft wide)
2. 6-aiI plastic (12 ft wide)
3. Ouct tape
4. Binder ci ips
5. Floor cleaning solvent
6. Rolling scaffold rental
7. 16-ft walkboard rental
200 ft
100 ft
6 rolls
3 gross
2 gal
Included
above
Included
above
2nd, 3rd, AND 4th STATION SUBTOTAL
112.00
42.00
21.00
37.80
50.00
363.70
plastic, clip ,
i jit ic, seal a I i
i i1£*I2 h = 24 MH :
.ills to cell ing
joints as above
140/Mfl
960.00
,440.00 1,803.70
(continued)
-------
TABLE 2.
Materials
Quantity
Cost, S
EXHAUST SYSTEM
1. Uti1ity blower
13,000 ft /*in
1
2,300.00
2. 12 in. flex duct drops
3. 12 in. full blast gate dampers
4. 12 in. connecting duct clamps
5. 24 in. flexible duct with damper
6. 24 in. sheet netal duct
(include 12 in.x24 in.
transition)
7. Roof support clamps
8. 24-in. duct clamps
9. 4 ftxfl ftxl/2 in. plywood for
roof platforms
4
4
16
5 ft
5 1 5 ft
4
4
2
2,080.00
382.80
52.20
182.00
520.00
62.00
36.00
50.00
EXHAUST SYSTEM SUBTOTAL
5,665.00
DISMANTLING
TOTAL
6,342.10
Materials and labor.
FTE = full time employee.
MH - man hour.
(continued)
itjor
Total
Cost, $ cost, ia
.unt blower and instruments on roof plat- ' 640.00
forms. Drop ft* duct and electrical
extension cora iur root power requirements
FTEx8 h = 16 Mil d J40/h
640.00 6,505.00
I TEx6 h = 12 Mi, tf $40/h 480.00 480.00
3,040.00 9,382.10
-------
Table 3 lists the tools and equipment necessary for construction of
the TTE's. It was assumed for the cost analysis that the facility would
have access to all these items at no cost except for the rolling scaffolds
and walkboard. The scaffolds and walkboard rental charges were included
in Table 2.
For each coating station's TTE, the left side wall would be hung from
the bottom of the duct that supplies makeup air to the coating room. The
wall would be located to contain the coating supply vessel (a 450-gallon
"tote" or a 55-gallon drum): Openings in the room makeup air supply duct
within the TTE would be sealed off because the volume of these forced
airstreams would be difficult to determine accurately. The right side
wall of each TTE would be suspended from the electrical bus and would fall
outside the drying oven control panel to include the panel in the TTE. On
the first coating station, the bus would be extended using a 2x4 so that
the recordkeeping stand could be included (see Figure 4).
The end wall of the TTE's toward the rewind end of the line would be
•UDDor*ad with i w1r» -jnnina "-im the nakeuo iir runcly "iuct -ns
overneaa norlzontai support rrame, :nen ay cne rrame itseir over zne
coating station, and finally by the electrical conduit that runs across
the right aisle from the support frame to the electrical bus. These walls
would hang to the floor in the aisles and would be fastened to the sides
and top of the drying oven at that end of the coating station.
~ie sna w
-------
TABLE 3. SUGGESTED TOOL AND EQUIPMENT LIST FOR INSTALLATION
Tools
Equipment
Utility knives
Side cutter pliers
Hand saw
Pliers
Wrenches
Hammers
Gloves
16-ft tape measure
Two narrow rolling scaffolds
16-ft walk board
Two 8-ft ladders
Rags •
Fire extinguishers (4)
Over wall hoist
Suggested staging of construction
1. Place blower and ductwork
2. Place framing
3. Place top plastic
151 -iC2 r:::a : :;isz":c
16
-------
A series of small NDO's would be cut in both end walls that cross the
right aisle. Additional small NDO's would be cut in the roof above the
right aisle and/or in the right wall above the control panel. Together,
the area of the NDO's for each TTE would total more than 8 square feet
(ft ) but less than 23 ft . The size and placement of the NDO's was
chosen to allow the TTE's to achieve the intent of the protocol's design
criteria and, at the same time, operate at a static pressure relative to
the coating room (maximum differential of less than 0.05 inches of water)
that would maintain the integrity of the TTE. This NDO placement also
would tend to establish a general airflow from the NDO's at the right of
the line toward the fugitive exhaust pickup at the left, which would tend
to sweep the VOC from the enclosure. At the same time, the makeup air
entering the NDO's would not impinge directly on the coating equipment,
and significant effects on the normal evaporation rate and capture
efficiency would be avoided.
Each TTE would be exhausted by a dampered duct. The four individual
ducts would be joined to a single duct passing through an unused roof
--xnausr. \z *:he =nd :f line 4. 'In order to use this exhaust, the existing
stacx wouid nave to oe removed., A Horizontal run of ouct on :ne pUn-
roof would afford a suitable test point. The system fan would be located
on the roof either before and after the horizontal test duct according to
the preference of the testing contractor. This system is illustrated in
Figure 5.
V. lost -naivr:"
The total cost of conducting a capture efficiency determination at
this facility using the TTE protocol 1s estimated to be about $24,900.
This total cost includes costs associated with TTE design, materials,
equipment rental, labor, lost production, and testing for the TTE design
specified in Section III.
The specifics of the cost of materials, equipment, and labor are
presented 1n Tables 2 and 3. The details of the proposed test program
were presented earlier in Section II, Part D. Specific costs associated
with the testing are broken down in Table 4.
Except for the testing crew, a wage rate of $40 per hour, including
fringes and overhead, has been used throughout this analysis. This value
is likely to overstate the actual wage rate in many cases, but has been
adopted to be conservative. The wage rate Included for testing personnel
has been adjusted upward to allow for moderate travel costs.
Table 5 summarizes the costs associated with performing the capture
efficiency test at this facility. The first component cost 1n Table 5 is
design of the TTE's. This step is further subdivided Into the onsite
evaluation phase and the actual design phase.
During the onsite evaluation, one individual would examine the
affected facility to be tested, noting the physical and process-related
requirements for the TTE's, taking the necessary measurements, and
17
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TABLE 4 ESTIMATED COSTS FOR SAMPLING AT KENYON INDUSTRIES
KENYON, RHODE ISLAND
Base cost Oollsrs
Site survey—1 person, 2 days x 3 h x $75/h i 200
1 THC operator—1 x 3 days x 10 h x $70/h 2'lOO
2 velocity persons--2 x 3 days x 10 h x $70/h 4*200
1 OVA operator--l x 3 days x 10 h x $70/h 2* 100
Preparation and posttest checks—40 h x $50/h 2'000
Calibration gases and supplies l'ooo
Data reduction and reporting 40 h x $60/h 2*400
total Tstom
Alternative—Replace M25A with M25 at test locations 1 and 2
900
Same size crew
Add analysis—2 locations x 3 runs x $150/sample
\ca 1 '20 tar^cn—j " IQ h x
Less calibration gases -:*5on
ADDED COST "zloiflj
Assumptions
1- T,ir»e -jns -zf \ '1
-------
TABLE 5. COST ANALYSIS FOR THE CAPTURE EFFICIENCY TEST AT
KENYON INDUSTRIES, KENYON, RHODE ISLAND
Cost to
Task complete, $
1. Design
a. Examination of facility 160*
b. Design of enclosure 320°
2. Materials and equipment rental 6,342
3. Construction labor 2,560c
4. Lost production 0
3. "-5Su";-;g :csi3 '.J.-CZ
6. Dismantling labor 480d
TOTAL 24,862
a,rcur ' -aor '^our-- it S40/H, '-icludina *"r"'nqes ind overhead.
^:gnt '.ioor -.ours i40/h. 'nciualng •>:naes ma overnaaa.
^Sixty-four laDor hours at $40/h, including fringes and overhead.
"Twelve labor hours at $40/h, including fringes and overhead.
to
-------
i-• t-ur. ia\/nnf This nrocess would be similar to the site visit
sketching the lay • fa t ld not 5e as extensive. Under normal
COn^iHnns the evaluation would be limited to the single line for which
conditions, the e a include the extensive background
"dfsc slio Si 9P ant personnel on the HE protocol and the process that
^ norp^arv for this study. In addition, the site survey for testing
were necessary o te activity carried out by the testing
SSXicto?0 The cost of this test survey is included in the testing
contractor, me nhase of TTE design is estimated to require
At°riabor?iUtf;? S^hour, this'activlty wou,d cost 5160.
n 4 „ vv,Q artnai dpsian Dhase, the ventilation requirements for the
___| up dgte^m]ned from process information. The proposed TTE
TTE's would be determined rrompo re1at1ve t0 the criteria in the
"Ut^ort^JeHfy that the criteria can be met. Upon corroboration that
protocol to v^yy drawings of the TTE's and materials, equipment,
th5 f^no^ication^ would be prepared. These activities might or
a" hJSnnt he carried out by a single individual, but the total labor
required is estimated at 8 hours. At $40 per hour, the cost of this phase
would total $320.
II neX5 ESlSTStSM for1 TTE construction^re^stlinated it
estimate 52,560 for 64 labor
hours.
-9 ---ur-.s•» -»b!i 5
r"'x\ 'pn -»* .. »6 ¦ -** " —
-iw oiarampnt of the exhaust system ana the ist
^uDDort1f rami ng*cou1d be accomplished during the week prior to testing
support framing cou conducted while the process operates.
S?caus!j ^iustic ceiling and walls, which might require the line
fISbfshJt dom could be accomplished without lost production on the
weekend prior to Jesting because the facility does not operate for more
than half a day on weekends.
tk* costs appear next in Table 5. At $15,000, this component
The nesting costs appear ^ tacol< Th1s cost estimate is based
In the use°of EPA Method IsA for VOC measurements; 1f Method 25 were used,
testing would cost about $2,000 more.
,, Mmrw,nant r0et listed on Table 5 is the cost of dismantling
the TO It 1s estimated that thls activity would take about 12 labor
the TTE. it is esTjinmw *480 Most of the dismantling could be
hours chlltt1na ^own the process; the balance (e.g., roof\
accomplished without shu g weekend. Thus, no production
1 ""expected to be lost as TresSn of dismantling the TTE.
Taken together the
$24,900 for the TTE ^sign p im re anowed to test only one
* «" °ther 5t"10nS- In
:g
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this case, the cost of TTE construction would be cut by about 75 percent,
although actual testing costs would not be reduced. A technical problem
with this approach is the 1-ck of a suitable test point in the drying over
exhaust duct prior to its junction with the main duct to the incinerator.
In any case, it would seem unlikely that such an approach would be
approved because of the variable coating application rates and the
variations in configuration at the various stations of the line.
The cost analysis presented above is specific to line 5. Compliance
tests for lines 4 and 6, which are each served by inert atmosphere conden-
sation systems, would not be expected to involve capture efficiency deter-
minations. Rather, these lines' emissions reductions likely would be
determined using liquid/liquid material balances. Lines 1, 2, and 3 might
be tested using the TTE protocol. These lines are controlled by a thermal
incinerator.
The cost of testing lines 1, 2, and 3 would be expected to be
considerably less than the cost for line 5. These lines are much smaller
;na ire "ccatad *'n i ^maP -com. The caoturs efficiency datari^nafisn
cost wouia oe nr.ninnzea if cne app Meade regulation ai icwea tr.e :nrse
lines to be tested together. In that case, the room containing the lines
could be adapted fairly easily to function as an enclosure for testing.
Even if individual tests were required, the existing room could be
augmented with plastic sheeting to form individual TTE's without great
difr*culty. However, the ductwork to the incinerator that serves these
¦ ""as '<«is lot -jxaminea. -hi Ta 't * Ike]-/ ".hat i suitaoie ; - '3
round for a ccniDinea capture ifficiency determination, :s not «
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Attachment 1
EVALUATION OF DRYING OVENS VS. TTE CRITERIA
1. Average face velocity through natural draft openings >200 ft/min.
Minimum oven exhaust rate is 1,200 ft3/m1n at 150° to 200°F (see
Figure 1). At standard conditions (32°F, 1 atmosphere), this
exhaust rate is a minimum of:
1,200 ft3/min (g° + |ga) . 895 scfm
Natural draft openings:
Entrance slot—4 1n. x 70 1n.
Exit slot—4 1n. x 70 1n.
Intake holes—7 at 3 1n. diameter
Total NDO area
'2 ' - ' . < '0 :ri. -i
144 1n//ft2
- 4.2 ft2
Minimum average face velocity (FV):
"V - i95 ;cfoi/4.Z ft' = .12 "t/min
(Note: Drying oven No. 4, with twice the exhaust rate used above,
would have a face velocity exceeding 400 ft/m1n)
2. Distance between V0C sources and NDO's >4 x NDO equivalent diameter.
This criterion is not met for these drying ovens or any other drying
ovens. See the discussion on this subject in Section II, Part B.
3. Distance between exhaust ducts or hoods and NDO's >4 X exhaust
equivalent diameter unless the enclosure 1s a permanent installation.
This criterion 1s not applicable because the drying ovens are
permanent Installations.
4. Total area of NDO's <5 percent of the enclosure surface area.
The minimum oven dimensions (No. 4 1s larger than the others) are
approximately 9.5 ft wide by 14 ft long by 7 ft high.
Area ¦ ( 2 x 9.5 x 14) + (2 x 9.5 x 7) + (2 x 14 x 7) - 595 ft2
Maximum allowable NDO area:
595 ft2 x 0.05 « 30 ft2
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As calculated above for Criterion No. 1, the NDO area is only 4.2 ft2,
so this criterion is met.
5. The VOC concentration inside the enclosure must not continue to
increase but shall reach a constant level.
This criterion is more applicable to TTE's erected to contain process
fugitive emissions. However, these drying ovens will surely meet
this criterion because they are designed and operated to meet
Factory Mutual requirements for fire safety.
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Attachment 2
EVALUATION OF TTE's vs. CRITERIA
1. Average face velocity through natural draft openings >200 ft/min.
Each coating station's TTE needs ventilation air (i.e., fugitive
exhaust) totaling 3,250 scfm (32°F, 1 atmosphere) to maintain VOC
concentration at 100 ppm at the maximum coating application rate
(see Attachment 3). In addition, the makeup air for the drying
ovens will be drawn through the TTE's because the oven openings will
be within the TTE's. As indicated in figure 1, the first three
drying ovens have exhaust rates of 1,200 acfm at 150° to 200°F
(about 930 scfm), and the fourth oven has double this exhaust rate
(2,400 acfm, or about 1,860 scfm). Assuming that half the makeup
air for each oven enters through the web entrance slot (located in
the oven's front wall) and half enters through the web exit slot and
intake holes (located 1n the back wall), the minimum volume of air
that must be drawn through each enclosure's NDO's at the maximum
~za.tlrsa idd!ication rata is as follows:
Dampered enclosure serving Coater 1:
(Enclosure contains inlet to Drying Oven No. 1)
3,250 scfm + 465 scfm = 3,715 scfm
"dmoersa enclosure ^rv^na Coater Z:
Znciosura contains outiat "'rem Drying Oven ^o. ana- "mat ~.z
No. 2)
3,250 scfm + 465 scfm + 465 scfm » 4,180 scfm
Dampered enclosure serving Coater 3:
(Enclosure contains outlet from Drying Oven No. 2 and inlet to
No. 3)
3,250 scfm + 465 scfm + 465 scfm » 4,180 scfm
Dampered enclosure serving Coater fc4:
(Enclosure contains outlet from Drying Oven No. 3 and Inlet to
No. 4)
3,250 scfm + 465 scfm + 930 scfm = 4,645 scfm
Thus, to maintain average face velocities of at least 200 ft/min under
these conditions, the maximum allowable,NDO area varies from about
18 ft for the first TTE to about 23 ft for the fourth.
Only the first coating station has a process-Imposed NDO, the area
under the operator's catwalk where the web enters the TTE. The
functional area of this opening 1s not.certain because it is
partially blocked by a roller. Based nn the outside dimensions of
the opening (about 9 ft x 1 ft), the maximum area Is 9 ft2. Thus,
this mandatory NDO meets this criterion, and any additional NDO's
-------
added in the first coating station can be sized so that the total
area continues to meet the criterion.
On the other coating stations, no process-imposed NDO's are
.j Thp NDO1s can be placed and sized to meet the
criterion. The tot^l area of the NDO's for these stations will be
between 8 and 23 ft .
Final verification that the TTE's meet this criterion will have to be
21LItthP time of the test because the actual ventilation volume
"ill be JSEn uni" then. The HDD areas can be adjusted as
necessary at that time.
2. Olstance between VOC sources and NDO's >4 X NDO equivalent diameter.
1 4-««+-iai nrnhlpm with meeting this criterion is the opening
underVthe operator's catwalk where the web enters the first coating
Finn's TIE The outside dimensions of the opening are about 9 ft
station S* 'unction*! am of ''DO !s
x" a : i ir -.Qcxs .r.ucn :r :r.e area. «! 'in -
ctraiaht 1 ine~distance to the nearest VOC source (the coating knife)
oTlblJt's ft, the maximum equivalent diameter this opening could
2 moot the letter of this criterion is only 1.2 ft,
have to meet 0Deninq of 9 ft x 1.6 in. If the opening is
considered to function as two seoarata NDO's, one above the roller
consiaereu _ _ :nat *aCR :r -r.a ^oerrr.q:- .ou;s
-^-gc-a^ne-s-ens. 3et2i:ad •neasur^enrs :r -ns ccemng
that could confirm or rule out this interpretation were not made
: 7 „tl! cite visit In any case, other considerations indicate
that the oDening under the catwalk would not cause the problems that
K?C ^iteriSn is intended to prevent. According to the preamble to
S inlnrn this criterion is Intended to keep air entering an NDO
the protoco ,this cr iiari
-------
sources. Also, the entering airstreams would intersect from
different directions, breaking up the directionality of the
individual streams and further preventing direct impingement on the
sources of VOC inside the enclosure.
3. Distance between exhaust hoods or ducts and NDO's >4 X exhaust
equivalent diameter.
Each individual TTE would have a fugitive exhaust duct with a 1-ft
diameter and a slot above the coating knife (1 in. x 70 in.) that
would serve as an enclosure exhaust. (Makeup air enters the drying
oven that follows the coater through the slot.) In addition, all
but the first coating station would have the back wall of the
preceding oven within the TTE. This oven wall has seven 3-in.
intake holes and the exit slot (4 in. x 70 in.), which would all act
as enclosure exhausts as makeup air for the ovens was drawn in
through them.
only ;ne oven exit siots present any prooiem *Tcn crse ietzar or ;r.i5
criterion. The fugitive exhaust duct, located in the left wall of
the TTE, would be more than the required 4 ft from the NDO's. The
slot above the coating knife would be separated from the NDO's by
more than the required 3 ft, and the small intake holes in the back
wall of the oven would be more than the required 1 ft away from the
iOO':. -iawever., :ne .1D0' z 21 acea "he fail mat :rcssas :r.a
disia -rom :ne ana of ;Me preceding oven co che ngnc wail vouic: ;e.
only about half the required 6.3 ft from the nearest end of the oven
exit slot. The other NDO's would be far enough away from the
slot. As discussed above in relation to the second criterion, the
failure to meet the letter of this criterion should not be
significant 1n this case. There is no discussion of the purpose of
this criterion in the protocol preamble, but presumably the
criterion 1s Intended to avoid the channeling of air from an NDO
into an exhaust. Were channeling to occur, the normal capture
achieved by a permanent exhaust could be altered, and the exhausts
might not adequately remove VOC from the TTE, allowing the
concentration to increase to potentially dangerous levels. (This
latter effect is addressed more directly by the following
criterion.) However, such channeling 1s unlikely 1n this case
because the critical exhaust opening (the preceding oven's exit
slot) and the nearest NDO's would be 1n approximately the same
plane. Thus, the alrstream entering the NDO's would not be directed
toward the exit slot and would not be channeled into the slot.
Also, because of the orientation of the NDO's, the airstreams would
be expected to Intersect and lose their directionality before
channeling could occur. This criterion should be reevaluated when
revisions to the protocol are considered.
-------
4. Total area of NDO's <5 percent of the enclosure surface area.
This criterion would be easily met. The surface area of each TEE
(with approximate dimensions of 16 ft x 8 ft x 11 ft high) is:
(2 x 16 x 8) + (2 x 16 x 11) + (2 x 8 x 11) = 784 ft2
Five percent of this area is about 39 ft2. Because the NDO's would be
sized to meet Criterion No. 1, which imposes a maximum total NDO
area of about 23 ft , this criterion would certainly be met also.
5. The VOC concentration inside the enclosure must not continue to
increase but shall reach a constant level.
The fugitive exhaust system at this facility has been designed to meet
this criterion. The exhaust fan has been sized to provide adequate
ventilation volume for the maximum coating application rate on each
of the coaters. Each TTE's exhaust duct would have a damper to
allow the flows from each to be adjusted and balanced. Finally, the
«nau3- juc- iouia :a ocataa icr-rs: :na * " :~.x CC-' -. :-«»
general airflow should sweep the enclosure of VOC.
There is potential for fugitive VOC emissions to increase above the
level at maximum production when equipment is cleaned with solvents
between process runs. Because testing will be suspended at such
times, t.ie .icor*! can ::a "oensd and ".ha ^akaus i1r ••jcc1y "«nt:
:e jnccverna :s -insurs *.nat :ne irnsossner*; :r.a ;
remains safe and healthful.
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Attachment 3
CALCULATION OF NECESSARY EXHAUST, KENYON INDUSTRIES
Assumptions
1. 10 gal/h maximum coating use per station
2. Coating is 50 percent solvent by weight
3. Coating density is 8 lb/gal
4. Fugitives comprise 10 percent of sovlent by weight
5. Solvent 1s toluene
Volume of ventilation air (at background concentration of 20 ppm) needed
to dilute fugitives to 100 ppm:
(ji~pj(0.50) (Q.iQ) = 4 ;b co iuene/h
(4 lb tol/h)+(92 lb/1bmol toluene) » 4.3xl0~z lbmol tol/h
'.t -tandard corditions (32"F, 1 atm)
^Ibmol )(4-3x10"2 ^bmol/h) = 15.6 ft3/h
15.6 ft'/h = (100-20)
x 1x10s
x ¦ 195,000 ft3/h = 3,250 scfm/coater
Total for all four coaters * 13,000 scfm
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ATLANTA FILM CONVERTING COMPANY
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MRI(§J REPORT
FINAL COST AND FEASIBILITY STUDY: ATLANTA FILM CONVERTING
EPA Contract No. 68-02-4379
Work Assignment 26
ESO Project No. 87/07
MRI Project No. 8952-26
Prepared for:
,
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I. INTRODUCTION
The Atlanta Film Converting facility in Atlanta, Georgia, prints
flexible packaging such as plastic film that is used mostly for food
wrapping. At the time of the site visit in September 1988, the facility
operated two six-color flexographic presses (one "stack" press and one
"central impression" [CI] press) and one laminator. A site visit report,
dated February 17, 1989, contains detailed information on the process and
the facility layout at the time of the site visit. Since that time, the
stack press has been replaced by a new CI press, and the bulk of the
facility's production has been shifted to the new press. However, this
facility has been analyzed based on conditions as they existed at the time
of the site visit because no details of the subsequent modifications are
known. This report presents the findings of the cost and feasibility
analysis of constructing a temporary total enclosure (TTE) and conducting
a capture efficiency (CE) test according to the draft procedure at this
facility prior to the recent modifications.
'here '3 cne ixcept".on ;o cne ioove statement; :r,ac :r,e dnasys ;s
based on conditions as they existed during the site visit. At that time,
the facility did not control emissions of volatile organic compounds
(VOC). Each press's overhead dryer and between-color dryers were
exhausted directly to the atmosphere through separate stacks. However, a
determination of CE is useless and would not be conducted in the absence
:r in idd~~n -.cntrsl levies, "her^fore. -.r.is inaiysis -.as :arr-ir?
-------
2
dimensions would be 18 feet (ft) wide by 36 ft long. The TTE roof would
have to be at least 16 ft high to clear the press and ductwork. A
fugitive exhaust would be located in the end wall of the enclosure nearest
the CI cylinder. Additionally, the following three stacks would pierce
the roof of the enclosure: (1) the between-color dryer exhaust staok,
(2) the overhead dryer exhaust stack, and (3) the makeup air intake duct
for the overhead dryer. There would be one door measuring approximately
4 ft x 8 ft located in the side wall of the TTE on the side of the press
where print cylinders and rolls of film are changed out. Natural draft
openings (NDO's) would be located in the end wall of the TTE nearest the
unwind/rewind end of the press, the opposite end from the fugitive
exhaust. As indicated in Attachment 1, this TTE configuration would meet
the criteria in the draft test procedure.
A self-supporting wooden frame covered by 6-mil polyethylene was
chosen over the following two options: (1) dropping polyethylene
enclosure walls from the plant ceiling, thereby using the plant ceiling as
the TTE ceiling; and (2) dropping polyethylene enclosure walls from the
bottom of *he ~ai1 ->q rucccrt trusses, •sav'ia onen ~aacas
funccion is fiOC'sj oetween cne cop or cne -vaiis ana cne p.anz _2i;;ng,
which also would be the TTE ceiling. The latter two options actually'
might prove to be less costly in both materials and labor; however,
because this site visit was made before the cost and feasibility study
plan was formulated, not enough information about the CI press area
(including potential overhead obstructions to the TTE construction) was
Minerva rjr^g iit ~'nr i zrnser ivaiudtinn -f -.nsss
""p.r^rcr^, zhe 'construction or a is if--.upper1::ng ;'-ame -vds -sec
evaluating the cost and feasibility of performing a capture test at this
facility using the CE/TTE protocol. The selection of this construction
option has the added benefit for the overall project of generating cost
figures that could be applicable at other facilities where the other
options would not be feasible.
C. Testing
The gas streams, sampling locations, and EPA methods for measuring
VOC for the CE determination were tentatively identified. Figure 1
presents a schematic of the proposed sampling locations, while Table 1 is
a summary of the sampling plan for the facility. (Final identifications
will be made 1n the testing phase of the project should testing be carried
out at this facility.) Measurements would be conducted on the fugitive
exhaust stream and the capture stream to the control device using EPA
Methods 1 through 4 (M1-M4) for volumetric flow rate and EPA Method 25A
(M25A) for VOC concentration. In addition, a volumetric flow measurement
of the overhead dryer intake air duct would be performed using M1-M4 so
that the average face velocity across the NDO's could be calculated. The
VOC concentration Inside the TTE would be continuously measured during
each run using an OVA meter, while the ambient VOC concentration outside
the enclosure would be measured before and after each run using the same
OVA meter.
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Figure 1. Proposed testing locations fAtlanta Film .onverting, Atlanta, Georgia.
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4
TABLE 1. SAMPLING PLAN FOR ATLANTA FILM CONVERTING
ATLANTA, GEORGIA
Test location
I. Captured'
2. Fugitivea
3. Inside ambient
5. Dryer intake
Measure-
ment Method
VOC
VEL
VOC
VEL
VOC
VEL
M25A
M1-M4
M25A
M1-M4
M1-M4
Frequency
1-h continuous each run
Traverse before/after run;
continuous single point
measurement
1-h continuous each run
Traverse before/after run;
continuous single point
measurement
M25A (OVA) 1-h continuous each run
•ar/
Traverse before/after run;
continuous single point
measurement
M25A * -'cnizatlcn analyzer (?IA),
*25 - :ct.i i ; as ecu s "onmetriane .-HiNMOl.
"Simu i caneous samppng.
Option: Replace M25A with M25 at locations 1 and 2.
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5
The M25A measurements using the OVA meter would verify that steady-
state conditions prevail inside the enclosure and would be used to
evaluate the potential for VOC drawn in through the NOO's to affect the CE
determination significantly. A great degree of accuracy in the
measurements is not necessary; therefore, the use of an OVA meter is
appropriate. For the capture and fugitive stream VOC concentration
measurements, however, flame ionization analyzers with a higher degree of
accuracy would be used. The VOC concentration measurements would be made
continuously during each run, while the volumetric flow determinations
would be made before and after each run with a continuous single point
measurement during each run.
III. Specifications
Tables 2 and 3 present the materials and labor costs for
construction of a TTE and the suggested tools and equipment necessary for
construction. The TTE would consist of a 16-ft-high, self-supporting
wooden frame to which polyethylene would be fastened to form +;he TT^ "a1"1:
ana ;2i 1 ;"!C. "ha i: isi'c zr.aeteng .*ou i a :e .-'sszanaa ~.z :r.a --ama << en
staples initially; the stapled areas subsequently would be reinforced with
wood laths. Duct tape would be used to seal any gaps in the plastic and
to piece around the three exhaust vents. Figure 2 presents a diagram of
the enclosure.
The fuaif.ive exhaust systam would consist if k.wo \~-?t .""ix'b
:":c:juds -n tr? .3--ncrs -n.', nameters jamaa ^mnoeraa ;si 1 ,ir-.
into a singie i5-ft, 24-in.-diameter metal duct to provide a sampling
location. The exhaust fan was sized for about 6,600 cubic feet per minute
as Indicated by the calculations presented in Attachment 2.
IV. Cost Analysis
The costs associated with performing the test according to the draft
protocol have been estimated based on the TTE specifications and sampling
locations selected. The specific material and labor costs of constructing
and dismantling the TTE are presented in Table 2. The details of the
proposed test program were presented in Section II, Part C. A breakdown
of the testing costs is provided in Table 4.
Table 5 summarizes the costs associated with performing the CE test
at the facility. Of the total estimated cost of about $20,000, the major
cost of the test program is the actual testing cost ($15,000).
V. Potential Problems
The destruction of VOC emissions in the direct-fired dryers used at
this facility presents a problem because the destroyed VOC will not be
measured as having been captured. (This would be a problem no matter
which CE determination method was used.) Also, because some partial
combustion products may be present, the use of M25 over M25A might be
preferred for this stream, even though the measurement of the low VOC
concentration in the fugitive exhaust stream dictates the use of M25A.
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6
TABLE 2. MATERIALS AND LABOR FOR CONSTRUCTION OF A TEMPORARY TOTAL
ENCLOSURE AT ATLANTA FILM CONVERTING COMPANY, ATLANTA, GEORGIA
Materials
Quantity
Cost, S
Labor
Cost, S
Total
cost
Enclosure
1. 2 in.x4 in.xl6 ft boards
2. Wood laths
3. 6 ni1*16 ft plastic
4.' Nails, 16 d
5. Nails, 4 d
6. Duct tape and staples
7. Rolling scaffold rental
107
2 bundles
150 ft
25 lb
10 lb
2 9 3 days
321.00
22.00
55.00
17.75
9.80
18.60
60.00
3uild self-supporting frame, attach
plastic with staples and laths
2 FTEx12 h * ?4 HH at S40/MH
360
SUBTOTAL
504.15
960
t,«4.15
Exhaust system
1. 6,600 ftin explosion-proof
fan with motor
2. Flexible 18 in. duct and clamps
3. 18 in, dampered spin collars
4. 24 in. flexible duct and damper
5. 24 In. metal duct
? 8 MH at S40/MH
320
SUBTOTAL
0
320
320.00
;:sl
-..90.-5
. .JW
' 4 -^0. . J
FTE ¦ full tifflt employee.
MH • vanhour,
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7
TABLE 3. SUGGESTED TOOL AND EQUIPMENT LIST
Hammer
Tri square
Staple-gun
Ramset and concrete nails (if wish
to anchor TTE to floor)
Tools
Equipment
Ski 1 saw
Utility knife
Two narrow rolling scaffolds
10 ft step ladder
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Capture
4 NDO's
2' x 2"
Fugitive
Exhaust
Fan
24" Fexible Duct
with Damper
Figure 2.
Proposed TTE for Atlanta Film Convicting, Atlanta, Georgia.
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9
TABLE 4. SAMPLING COST ESTIMATE FOR ATLANTA FILM
CONVERTING, ATLANTA, GEORGIA
Base cost
Site survey--! person, 2 days x 8 h x $75/h $ 1,200
1 THC operator--! x 3 days x 10 h x $70/h 2,100
2 velocity persons--2 x 3 days x 10 h x S70/h 4,200
1 OVA operator--l x 3 days x 10 h x $70/h 2,100
Preparation and posttest checks--40 h x $50/h 2,000
Calibration gases and supplies 1,000
Data reduction and reporting 40 h x $60/h 2,400
TOTAL 515,000
Option: Replace M25A with M25 at 1, 2
Same site crew
Add analysis — 2 ooints x 3 runs x SlSO/samo"= S °00
-oa )ne 'do terser:— •. a * •; .0 < J7Q/h
Less calibration gases -1,000
ADDED COST S 2,000
Assumptions
"hrse "'.ins or 1 i ^ach
J. '
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10
TABLE 5. COST ANALYSIS FOR THE CAPTURE EFFICIENCY TEST
AT ATLANTA FILM CONVERTING, ATLANTA, GEORGIA
Cost
Task to complete, $
1. Design
a. Examination of facility 160a
b. Design of enclosure 320*3
2. Materials and equipment rental 2,990
3. Construction labor l,280c
.Jsz zr'zaucon
5. Testing costs 15,000
6. Dismantling 320^
hlFour labor hours at i40/h, including oenefits ana overneaa.
Eight labor hours at $40/h, including benefits and overhead.
cThirty-two labor hours at $40/h, including benefits and
.overhead.
No production loss expected because TTE can be constructed
and dismantled during weekends when the plant normally does
not operate.
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11
VI. Conclusions
A TTE can be constructed around the CI line. The CE test using the
CE/TTE protocol is feasible.
2 Attachments
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Attachment 1
EVALUATION OF TTE VS. CRITERIA
1. Average face velocity through NDO's >200 ft/min.
Because the entire press would be enclosed, there would be no process-
imposed NDO's. Therefore, the NDO's can readily be sized to meet this
criterion. The net exhaust rate f^om the enclosure associated with
the dryers would be about 1,300 ft /min. At the maximum VOC usage
rate, about 6,600 ft /min of supplemental ventilation air would be
needed to assure a healtnful atmosphere within the TTE (see
Attachment 2, Situation No. 2). ThuSj the total net exhaust rate from
the enclosure would be about 7,900 ft /min. The maximum NDO area
under these conditions would be:
7.900 ft /min _ ™ c
200 ft/min J rz
At lesser VOC usage rates, the ventilation rate could be decreased,
and the allowable MOO would deer*; as a iccsrri^raly. inv :n22.
ZTtz area of iHQO's can oe aCjUStaci ;o ,neet cms criterion.
2. Distance between VOC sources and NDO's >4 x NDO equivalent diameter.
The sources of VOC within the enclosure include the ink supply
buckets, the printing decks, and the printed film (prior to.dry'nqK
These "-ource's *ouiu lil be 'located in :ne •/icimty ar :.~:e :2ntr.i;
impression SZ1) cylinder. The IQO": 'n -he enciosure wou ia zs oca:ao
at the unwind/rewind end of the TTE, away from the CI cylinder and VOC
sources. Because there are no process-related constraints on the
NDO's, they can readily be sized and located to meet this criterion.
A likely configuration would consist of four 2 ft x 2 ft NDO's in the
wall at the opposite end of the TTE from the CI cylinder, each located
near a corner of the end wall. Up to five additional 2 ft x 2 ft
NDO's (depending on the actual net exhaust rate from the TTE) would be
placed near the same end of the enclosure. All the NDO's could easily
be located to exceed the 9-ft separation from VOC sources necessary to
meet this criterion.
3. Distance between exhaust hoods or ducts and NDO's >4 x exhaust
equivalent diameter.
The exhausts from the enclosure would include the intake slots of the
between-color dryers, the web slots of the overhead dryer, and the
fugitive exhaust system pickups. The precise dimensions of the
between-color and overhead dryer slots are not known, but none is
likely to exceed 4 in. x 60 in. As discussed above, there is
considerable freedom in NDO placement in this case; no difficulty is
anticipated in locating the NDO's at least 6 ft away from the dryer
slots in order to meet this criterion. (Based on slots 4 in. x 60 in.,
a separation of just over 5.8 ft would be required.)
-------
Likewise, the fugitive exhaust system pickups could meet this
criterion easily. Two dampered 18-in. flexible ducts have been
included in this analysis as pickups to provide flexibility in the
exhaust system. The duct openings would have to be a minimum of 6 ft
from any NDO. The proposed TTE configuration would have the fugitive
exhaust system located at the end of the enclosure nearest the CI
cylinder; the flexible duct pickups would be placed near this end of
the TTE. With the NDO1s located at the far end of the enclosure, this
criterion would be met.
4. Total area of NDO1s <5 percent of the enclosure surface area.
The proposed TTE dimensions are 18 ft x 36 ft x 16 ft tall. The total
surface area of the walls, ceiling, and floor of the enclosure is
3,024 ft . Five percent of this surface area is about 151 ft . This
criterion is much less restrictive than the criterion governing
minimum face velocity (No. 1 above), which dictates a maxima area of
39.5 ft2. This criterion would be met easily.
i. "he iQC ccncsntrition -ns'aa -snc:asura tucc hoc r.uc ;a
increase but shall reach a constant level.
The fugitive exhaust system at this facility has been designed to meet
this criterion. The exhaust fan has been sized to provide adequate
ventilation volume for the maximum VOC application rate. Dampers have
taen "'icIugsq ,!n t.ta -sxnaus« iys~5.ni to ju iow ~ne ¦ cw -c :a '.ctu-tsci
is necassar'. :;nai 'y. the axnausz iystam "icxups -oui
-------
Attachment 2
Calculation of Necessary Supplemental Exhaust for Atlanta Film Converting
A. Situation No. 1
Assumptions
1. Max VOC usage rate is 90 lb VOC/h
2. Capture efficiency is 70 percent (based on RACT)
3. Solvent is ethanol (TLV = 1,000 ppm)
4. 20 ppm already in ventilation air
(90 lb VOC/h)(0.30) = 27 lb VOC/h
Methanol " 46 Wlbmole
Wtett&t ¦ °"59 "-"'h
(0.59 lbmol/h)(359 ftVlbmol) = 211 ft'/h
1,000 ppm (fugitive)-20 ppm (background) VOC (ft /min) ^
necessary airflow (ft /min)
::i -t3 _ 'i.soo-^
" ixiO *
x = 21,113 ft3/h
x = 352 ft3/min
B. Situation No. 2
Assumptions
1. Max VOC usage rate 1s 90 Ib/h
2. Capture efficiency 1s 45 percent, (as Indicated by facility
personnel)
3. Solvent 1s ethanol (TLV = 1,000 ppm)
4. 20 ppm already In ventilation air
(90 lb VOC/h)(0.55) = 49.5 lb VOC/h
Methanol = 46 lb/lbmo1
S'lb/L.1 ' 1'1 lbmo,/h
(1.1 lbmol/h)(359 ft3/lbmol) = 386 ft3/h
-------
1,000 ppm (fugitive)-20 ppm (background) = VOC (ft /min)
necessary airflow (ft /min)
386 ft3/h _ (1,000-20)
x " lxlO6
x = 6,570 ft3/min
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PRINTPACK,
-------
MRII§I REPORT
FINAL COST AND FEASIBILITY STUDY: PRINTPACK INC.
EPA Contract No. 68-02-4379
Work Assignment 26
sc. No. 37/T7
MRI Project No. 8952-26
Prepared for:
Karen Catlett
Chemicals and Petroleum Branch
Emission Standards Division
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
Prepared by:
Stephen W. Edgerton
Brenda Shine
Midwest Research Institute
401 Harrison^Oaks Boulevard, Suite 350
Cary, North Carolina 27513
October 12, 1989
MIDWEST RESEARCH INSTITUTE 425 Volker Boulevard, Kansas City, MO 64110-2299 • (816) 753-7600
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I. Introduction
The Printpack facility in Atlanta, Georgia, currently operates
several central impression flexographic printing lines to produce flexible
packaging products. The facility has both six-color and eight-color web-
fed presses. A site visit report dated February 17, 1989, contains
detailed infonation on the process and the facility layout. This report
presents the findings of the cost and feasibility analysis of constructing
a temporary total enclosure (TTE) at this facility and conducting a
capture efficiency determination according to the draft procedure.
II. Options Considered and Rationale for Selections
A. Production Line to be Evaluated
One of the eight-color presses (No. 12) was chosen for evaluation
because this press represents the newer, larger presses at the facility.
The newer oresses are nuch loncer =ind wider '¦han the o"Mer ^
' irger "" *ouia oe rsquirea. -ccass -squirsments ir» lor* ;>r
the eight-color presses because more individuals typically need access to
these presses than to the six-color presses. In addition to two operators
assigned to each press, an additional two persons are assigned to the
eight-color presses as a floating changeout team. For all presses, access
is routinely required during operation in order to check the ink level and
'iscasity 'n tse "Vit." «suDp!y'nq aacn "riming :tar:an. -bout •jverv
•b" mnutss, iccsss ".o :he ^nvnna iraa - -sauirsa :a reoiacs .ns csenr co
roll. The floating changeout team replaces the spent web rolls on the
eight-color presses.
B. Temporary Total Enclosure Configuration and Materials of
Construction
It was determined that the TTE should enclose the entire press,
including the unwind and rewind stations. This configuration would allow
the press operators to remain inside the TTE much of the time rather than
frequently passing in and out to monitor the parts of the press Inside and
outside the enclosure. In addition, enclosing the entire press would
avoid the difficult task of piecing an enclosure wall around the overhead
dryer and the ductwork on top of the dryer.
During the site visit, it was estimated that an enclosure
approximately 33 feet (ft) wide by 66 ft long by 30 ft high would be
needed to contain this press. After followup contacts with facility •
representatives, it was determined that the actual enclosure dimensions
necessary to contain the press are 33 ft wide by 72 ft long. The height
of the building over this area, measured from floor to ceiling, is
25 ft. The TTE's fugitive exhaust would be located in the end wall of the
enclosure nearest the printing stations. There would be one covered door
measuring approximately 4 ft by 8 ft located in the side wall of the TTE
on the side of the press where print cylinders and rolls of film are
changed out. Natural draft openings (NDO's) would be located in the end
wall of the TTE at the rewind end of the press, the opposite end from the
-------
2
fugitive exhaust. As indicated in Attachment 1, this TTE configuration
would meet the criteria in the draft test procedure.
The NOO's and fugitive exhaust pickups would be located so as to
minimize effects on the normal fugitive emission rate and capture
efficiency thit prevail in the absence of the TTE. Measures to minimize
disruption of normal conditions would include adhering to the TTE criteria
that govern distances and orienting the NDO's and fugitive exhaust pickups
so that air currents will not impinge directly on sources of volatile
organic compounds (VOC) or on permanent exhausts from the enclosure.
Additional measures, such as the use of baffles, could be used if deemed
necessary.
The following three construction options for the TTE were
tentatively identified in the site visit report:
1. Dropping polyethylene enclosure walls from the plant ceiling,
thereby using the plant ceiling as the TTE ceiling;
I. >cDpina ;a; yetny ¦ ^-ne -inc::;Surr? ..n : --cm :zzz~~ .r v.?
ceiling support beams or trusses. The plant ceiling would function as the
TTE ceiling. The open spaces between the top of the walls and the plant
ceiling would be considered NDO's; and
3. Constructing a wooden frame to which polyethylene would be
fastened ~o -he war" '.nd • tai"!fna "sannina '¦he
Initially, che tnird option was selected for cms analysis as zr,z
most generally applicable configuration across facilities of all types.
This approach was adopted at first because the site visit was made before
the cost and feasibility study plan was formulated, so little specific
information about the press area (including ceiling-level obstructions
that might interfere with the other TTE configurations) was gathered
during the site visit. However, because the minimum height necessary to
clear the press is about 20 ft and the TTE would be too wide to span with
2x4's, a wooden structure would need braces extending out from the walls
in order to be self supporting. There 1,s insufficient clearance around
the presses at this facility to accommodate such braces. As a result, the
construction option finally selected for this cost and feasibility
analysis is the first option described above.
Under this construction option, 6-mi1 plastic sheeting would be
suspended from the bottom of the ceiling bar joists to the floor, and the
area between the bottom of the joists and the ceiling would be filled in
with separate pieces of 6-mil plastic. Considering the reed to piece
around the ceiling joists, this method of extending the walls to the
ceiling is expected to be easier than attempting to fit a single piece of
plastic from floor to ceiling.
-------
3
C. Testing
The gas streams, sampling locations, and EPA methods for measuring
VOC for the capture efficiency determination were tentatively
identified. (Final identifications will be made in the testing phase of
the project should testing be carried out at this facility.) Figure 1
presents a schematic of the proposed sampling locations, while Table 1 is
a summary of the sampling plan for the facility. Measurements would be
conducted on the fugitive exhaust stream and the captured stream to the
control device using EPA Methods 1 through 4 (M1-M4) for volumetric flow
rate and EPA Method 25A (M25A) for VOC concentration. In addition, a
volumetric flow measurement of the makeup air intake duct would be
performed using M1-M4 so that the average face velocity across the NDO's
could be calculated. The VOC concentration inside the TTE would be
continuously measured during each run using an OVA meter, while the
ambient VOC concentration outside the enclosure would be -neasured before
and after each run using the same OVA meter.
"he M25A iiieasuremenis using cne OVA i^eiar .vouio /er:r'y cna; i': a in-
state conditions prevail inside the enclosure and would be used to
evaluate the potential for ''CC drawn ;n through r.he NDO's to affect the
capture efficiency determination significantly. A great degree of
accuracy in the measurements is not necessary; therefore, the use of an .
OVA meter is appropriate. For the captured and fugitive stream VOC
:cnc2ntr.Tc:an .ireasur^nient;. icwever, -'oniration .ina1yi2r«- <*th i
.ngner :sgr«e of iccisracy *ou id :e usaa. "he VOC jsncsntraclon
measurements would be made continuously during each run, while the
volumetric flow determinations would be maae before and after each run
with a continuous single point measurement during each run.
III. Specifications
Tables 2 and 3 present the materials and labor and the suggested
tools and equipment for construction of the proposed TTE. The TTE would
consist of 6-mil plastic sheeting extending from the plant ceiling to the
floor to enclose an area 33 ft wide by 72 ft long. The plastic sheeting
would be suspended from the existing ceijlng bar joists. A diagram of the
enclosure is presented in Figure 2.
The joists run perpendicular to the press. The plastic for each end
wall of the TTE (33 ft long) would be fastened directly to the bcttom of a
single joist. For the side walls (72 ft long), the plastic would be
fastened to lx4's laid across the spaces between the joists. Duct tape
would be used to seal the walls to each other, to the floor, to the
ceiling, and around any obstructions that must be accommodated.
The fugitive exhaust system would consist of two 15-ft flexible duct
pickups with 18-inch (in.) diameters joined with dampered spin collars
into a single 15-ft, 24-1n.-diameter metal duct to provide a sampling
location. 3The exhaust fan was sized for up to 11,400 cubic* feet per
minute (ft /m1n). The basis for this flow rate 1s presented in
Attachment 2.
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Figure 1. Sampling points at f'rintpack in. Atlanta, Georgia.
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5
TABLE 1. SAMPLING PLAN FOR PRINTPACK INC., ATLANTA, GEORGIA
Test location
Measure-
ment
Method
Frequency
1. Captured'
2. Fugitive'
2. -ambient
voc
VEL
VOC
VEL
\'CC
M25A
M1-M4
M25A
M1-M4
M25A 'OVA^
1-h continuous each run
Traverse before/after
run; continuous single
point measurement
1-h continuous each run
Traverse before/after
run; continuous single
point measurement
4. Outside ambient VOC
5. Makeup air VEL
Intake
M25A (OVA) Before/after each run
M1-M4 Traverse before/after
run; continuous single
¦joint "aasur«!nart
M25A = flame ionization analyzer (FIA).
M25 = total gaseous nonmethane organics (TGNMO).
Option: Replace M25A with M25 at locations 1 and 2.
Simultaneous sampling.
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TABLE 2. MATERIALS AND LABOR FOR CONSIkm LION OF TEMl'OKARY TOTAL ENCLOSURE AT
PRINTPACK INC., aYiANTA, GEORGln
Materials
HANG PLASTIC
Quanti ty
Cost, $
L OlA
Cost, $
Total
cost,
1. 6-mi1 plastic (30 ft wide)
300 ft
300.00
IL
2. Ouct tape
3 rolIs
10.50
3. Floor cleaning solvent
1 gal
25.00
2
4. Medium binder clips
1 gross
12.60
5. 2-in. C-clamps
12
16.92
6. 1 in.x4 in.x12 ft lumber
16
48.00
7. 4-ft laths
2 bundles
44.00
8. Boom truck rental
4 days
1,200.00
SUBTOTAL
1,657.02
SEAL BAR JOISTS
1. Plastic 1o root line
Included
above
S,
2. Cleaning solvent for roof
1nc1uded
above
3. Duct tape
Included
above
2
4. 3/8 in. staples
4 boxes
8.00
5. 1J in. coated naiIs
5 pounds
8.00
6. Boom truck rental
1 i)c 1 uded
above
SUBTOTAL
16.00
EXHAUST SYSTEM
I.
2.
3.
4.
5.
6.
Utility blower with explosion-
proof motor and conduit box
11,400 f t /min
18 in. flex duct with duct
cI amps
18 in. dampered spin collars
24 in. metal duct
24 in. flex duct with damper
24 in. duct clamps
2 « 15 ft
2
15 ft
5 ft
2
2,330.00
3&O.00
160.00
190.00
182.00
18.00
plastic to bar
Ports
2 f fl >.a h = 16 MH 6 nu/MH
isi and 1 in.*4 in.
640.00
640.00 2,297.02
640.00
~.. i it I orce
640.00
656.00
li.-iili exhaust sys1.,..on plant floor
1 Fli'hS h = 5 MH § t H) MH
200.00
SUBTOTAL
3,266.00
200.00 3,466.00
con t i nued
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TABLE 2. (cu.unued)
Materials
Quantity
Cost, $
Labo>
Cost, $
Tota 1
cost, $a
in SHANTUNG
T. Dismantle TTE and dispose
of fTE construction materials
150 ft3c
26.00d
Remove plastic sheet in.j ,»d scrap lumber
anj ,.ljce in dumpster
2 FTE. i I. = 8 MH 0 $40, nn
320.00
iilBTOTAL
26.00
320.00
346.00
luTAi.
4,965.02
1,800.00
6,765.02
HE - full tine employee.
MH = man hour.
^'Materials dad labor.
lidded on Printpack's comments on the draft cost and feasibility sli. i, , a rolling scuiiold may not be adequate to hang the plastic
walls on all sides of all presses due to spacial constraints. In II.is situation, a I. o
-------
TABLE 3. SUGGESTED TOOL AND EQUIPMENT LIST FOR INSTALLATION
Tools
Equipment
Utility knives
Staple gun
Hammer
Tape measure
Boom truck or narrow rolling
scaffold3
Two ladders
Rags
100-ft rope
2ss-ga11 on bucket
Gloves
Suggested staging of construction
: iC 2 i
;r*sz licng 3".:a iway
;va
2. Place end walls.
3. Place blower and ductwork.
4. Place wall along side with overhead crane,
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Makeup Bypass lo
-72*-
Flgure 2. Proposed TTE for Pri..
r— 18" Flexible Duel
! 15' Each Section
j— Dampered
' Spin Collars
-24" Metal Duct
15' Long
-Sampling
Location
Fugitive
Exhaust
i£
0
Fan
24" Flexible Duct
with Damper
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10
IV. Cost Analysis
The costs associated with performing the test according to the draft
protocol have been estimated based on the TTE specifications and sampling
locations selected. The specific material and labor costs of constructing
and dismantling the TTE are presented in Table 2. The details of the
proposed test program were presented in Section II, Part C. A breakdown
of the testing costs is provided in Table 4. A summary of all costs
associated with the capture efficiency determination is presented in
Table 5.
A wage rate of $40 per hour, including fringes and overhead, has
been used fcr all labor except testing personnel. Tiis rate is likely to
overstate the labor costs in many cases, but has been used to be
conservative. The wage rate for testing personnel has been adjusted
upward to allow for moderate travel costs.
The total cost is estimated to be approximately $22,000, not
including lost oroduction costs. Of this total, the na.ior ccmoone"1:
:nti ictusi *.2s-c isnrcx:.^ar= !;•
about 67 percent of the total cost.
The cost of lost production is not included in this report because
of confidentiality considerations. The confidential addenum to this
report contains information received from Printpack on the cost of lost
^rncuction.
It is estimated that 7 hours of lost production wouid oe associated
with the construction and dismantling of the TTE side wall on the side of
the line from which the print cylinders and rolls of film are changed
out. It is not expected that production would be lost during construction
or dismantling of the other walls.
It should be noted that the capture efficiency determination may not
require any production to be lost. The facility operates 5, 6, or 7 days
per week, depending on demand. Production would be lost only if the test
were scheduled at a time when the plant „was operating 7 days per week.
Otherwise, construction and dismantling of the TTE could take place when
the line was not operating. However, increased labor costs would be
Incurred to construct the TTE over the weekend. At Printpack, the weekend
labor rate is 150 percent of the weekday rate; the Sunday rate is
200 percent of the weekday rate.
V. Potential Problems
The use of direct-fired dryers at this facility presents a problem
because some VOC will be destroyed and, therefore, will not be measured as
having been captured. (This would be a problem with any of the capture
efficiency determination methods.) Also, because some partial combustion
products may be present, EPA Method 25 might be preferred over M25A even
though the low VOC concentration in the fugitive exhaust stream tends to
indicate the use of M25A.
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11
TABLE 4. ESTIMATED COSTS FOR SAMPLING AT PRINTPACK INC.,
ATLANTA, GEORGIA
Base cost
Site survey--l person, 2 days x 8 h x $75/h $ 1,200
1 THC operator--l x 3 days x 10 h x $70/h 2,100
2 velocity persons—2 x 3 days x 10 h x $70/h 4,200
1 OVA operator—1 x 3 days x 10 h x $70/h 2,100
Preparation and posttest checks—40 h x $50/h 2,000
Calibration gases and supplies 1,000
Data reduction and reporting 40 h x $60/h 2,400
TOTAL $15,000
Alternative—Replace M25A with M25 at test locations 1 and 2
Same size crew
';od maiysis—r locations x 3 r'jns x $150/samo!e S 900
Add i iao person--! x 3 days x .3 < 570/h
Less calibration gases -1,000
ADOED COST $ 2,000
Assumptions
"hrse "'.ins i iacn
i. Hetnoa 25 options jse j-.naie iamo i inq -rams
3. Estimates include moderate travel costs
4. 1 day of travel/set-up; 1 day of testing; and 1 day of teardown/travel
, in field
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TABLE 5. COST ANALYSIS FOR THE CAPTURE EFFICIENCY TEST AT
PRINTPACK INC., ATLANTA, GEORGIA
Cost to
Task complete, $
1. Design
a. Examination of facility 160a
b. Design of enclosure 320b
2. Materials and equipment rental 4,965
3. Construction labor I,480°
4. Lost production ^
5. Testing costs 15,000
6. Dismantling "aocr
TOTAL 22,245e
j*Four labor hours at $40/h, including fringes and overhead.
^¦"'ght labor Hours at $40/h. including fringes and overnead.
* ¦"•I"!rty--even isor 'ourr: it i*. :nciusing -r-'nqas \r.a ;:r"=ac.
^Estimated zzzi I ' mOUTj, .5 ,iours aur:ng c3nstv-jcf.cn ina . ,:cur jurv.'~
dismantling. The hourly cost of lost production is subject to a claim of
confidentiality and is not presented here. The confidential addendum to
this report contains this information.
eThis total does not Include the cost of lost production. The total
estimated cost including lost production is included in the confidential
addendum to this report.
-------
13
VI. Conclusions
1. It is feasible to construct a TTE around a press at this
facility. Construction and dismantling are estimated to cost approxi-
mately $7,200, not including the cost of lost production.
2. A capture efficiency determination can be conducted at this
facility. The testing is estimated to cost approximately $15,000.
2 Attachments
b2606-l/C8I
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Attachment 1
EVALUATION OF TTE VS. CRITERIA
1. Average face velocity through NDO's >200 ft/min.
Because the entire press would be enclosed, there would be no process-
imposed NDO's. Therefore, the NDO's can readily be sized to meet this
criterion. With dryer exhaust recirculation, the net |xhaust from the
enclosure associated with the dryers would be 2,000 ft /mi^ (see
Figure 1). At the maximum VOC usage rate, about 11,400 ft /min of
ventilation air would be needed to assure a healthful atmosphere
within the TTE (see Attachment 2). Thus, the total net exhaust rate
from the enclosure would be 13,400 ft /min. The maximum NCO area
under these conditions would be:
13,400 ft3/m1n _ ^2
200 ft/min = 67 ft
At lesser VOC usage rates, the ventilation rate could be decreased,
ind :!ia 'Jlowable NDO area would decrease accord i rial v. In a.ny -"rase,
cne area of ;ne iNDO! 3 can dajuszea za flieet this cnter-ion.
2. Distance between VOC sources and NDO's >4 x NDO equivalent diameter.
The sources of VOC within the enclosure include the ink supply
buckets, the printing decks, and the printed film (prior to drying),
"'lese sourcas would ill :e located in the vicinity if the cantral
•iapr?ssion \CZ) zy•'ir.oer. The .•iOO's -n :ne snciasure vouia :a '.ocataa
at the unwind/rewind end of the TTE, away from the CI cylinder and VOC
sources. Because there are no process-related constraints on the
NDO's, they can readily be sized and located to meet this criterion.
A likely configuration would consist of nine 2 ft x 2 ft NDO's
(equally spaced 1n three rows of three) in the wall at the opposite
end of the TTE from the CI cylinder. Up to seven additional
2 ft x 2 ft NDO's (depending on the actual net exhaust rate from the
TTE) would be placed near the same end of the enclosure. All the
NOO's could easily be located to exceed the 9-ft separation from VOC
sources necessary to meet this criterion.
3. Distance between exhaust hoods or ducts and NDO's >4 x exhaust
equivalent diameter.
The exhausts from the enclosure would include the intake slots of the
between-color dryers, the web slots of the overhead dryer, and the
fugitive exhaust system pickups. The precise dimensions of the
between-color and overhead dryer slots are not known, but none -is
Hkely to exceed 4 in. x 60 in. As discussed above, there 1s
considerable freedom in NDO placement 1n this case; no difficulty is
anticipated in locating the NDO's at least 6 ft away from the dryer
slots 1n order to meet this criterion. (Based on slots 4 in. x 60 in.,
a separation of just over 5.8 ft would be required.)
-------
Likewise, the fugitive exhaust system pickups could meet this
criterion easily. Two dampered 18-in. flexible ducts have been
included in this analysis as pickups to provide flexibility in the
exhaust system. The duct openings would have to be a minimum of 6 ft
from any NDO. The proposed TTE configuration would have the fugitive
exhaust system located at the end of the enclosure nearest the CI
cylinder; the flexible duct pickups would be placed near this end of
the TTE. With the NDO1s located at the far end of the enclosure, this
criterion would be met.
Total area of NOO's <5 percent of the enclosure surface area.
The proposed TTE dimensions are 33 ft x 72 ft x 25 ft tall. The total
surface area of the walls, ceiling, and floor of the enclosure is
10,002 ft . Five percent of this surface area is about 500 ft2. This
criterion is much less restrictive than the criterion governing
minimum face velocity (No. 1 above), which dictates a maximum area of
67 ft . This criterion would be met easily.
The VOC C3nc2rur.ii::on ;r:s"ice cne enclosure must not cont:r,ue zz
increase but shall reach a constant level.
The fugitive exhaust system at this facility has been designed to meet
this criterion. The exhaust fan has been sized to provide adequate
ventilation volume for the maximum VOC application rate. Dampers have
:?esn 'needed **8 exhaust r/sram zPow -.rse " rw ~~ "a vj.rii-ac
as necassary. --"naily, tna axnausz systani :"f::
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Attachment 2
CALCULATION OF NECESSARY SUPPLEMENTAL EXHAUST FOR PRINTPACK INC.
Based on a 4/4/89 telephone conversation between Mr. Doug Cook,
Printpack inc., and Mr. Stephen Edgerton, MRI, the fugitive emission rate
from a past liquid/gas test was:
9.09 lb carbon/h (Average of three runs)
These test runs were during a process run with coverage of about
150 percent, which is a typical coverage rate. Heavy coverage would be
about 200 percent, so for a heavy coverage job, the fugitive rate would be
about:
(9.09 lb C/h)(200/150) = 12.12 lb carbon/h
Assume the solvent is 100 percent n-pro.Danol (TLV = 200 ODm^ . N-nrocarcl
:s i na^cr lanszituenc of -na 'nks 4sea :;ur->ng cne :3sz ~jns, ir.Q ~.z
combination of a relatively low molecular weight and relatively
restrictive TLV makes this a conservative assumption.
Mol. wt. » 60; 3 carbon atoms per molecule
(12.12 "'b C/h)(1 lb no! C/12 lb CH0.33 "!b mol n-crnoanol-""b to1
¦ 0.33 lb moi n-propanol/h
(0.33 lb mol/h)(359 ft3/lb mol) = 120 ft3/h
Calculating the amount of ventilation air needed to dilute the n-propanol
to 200 ppm, assuming a background concentration of 25 ppm:
(120 ft3/h)(h/60 min) = (200-25)
x 1x10s
x = 11,396 ft3/min
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TECHNICAL REPORT DATA
'Please read Insrrucnons on the reverse oetore comnienmi
1 REPORT Nio. |2. ;3. RECIPIENT'S ACCESSION NO.
EPA-450/3-91-004 ! 1
4. TITLE ANO SUBTITLE
Cost and Feasibility of the Temporary Total Enclosure
Method for Determining Capture Efficiency
5. REPORT DATE
November 1990
6. PERFORMING ORGANIZATION CODE
7. AUTHORIS)
Stephen W. Edgerton
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Midwest Research Institute
401 Harrison Oaks Boulevard', Suite 350
Cary, North Carolina 27513
10. PROGRAM ELEMENT NO.
1 1. CONTRACT GRANT NO.
68-02-4379
12. SPONSORING AGENCY NAME ANO AOORESS
Emission Standards Division
Office of Air Quality Planning and Standards
c. r.*v: rormenta1 °rotect.ion Aqencv
;asaarcn .Yiangia .-arx, ::c
13. TYPE OF REPORT AND PERIOD COVERED
Fi ml
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
EPA Work Assignment Manager
Karen Catlett, ESD/CPB/CAS, Research Triangle Park, N.C.
16. ABSTRACT
"ns joc'jment presencs .-'inaings of a szuay of :ne cast ma -"3as".u". :
of determining VOC capture efficiency using the gas/gas temporary total
enclosure method. For the study, five coating and printing facilities were
visited, and site-specific cost and feasibility analyses were conducted. The
five site visit reports and Individual cost and feasibility analyses are
appended.
17. KEY WORDS ANO DOCUMENT ANALYSIS
a. DESCRIPTORS
b. IOENTIF1ERS/OPEN ENDED TERMS
c. COSATi Field/Croup
Air Pollution
Volatile Organic Compounds
Performance Testing
Capture Efficiency
Temporary Total Enclosure
Determination of V0C
Capture Efficiency
'¦i. . p>*ur. "/N :.Ta rsMEN r
1
:9. SECURITY CLASS > T'r.is iteoom
Jnciassifiea
;oo
i Release unlimited
1
20. SECURITY CLASS (This page)
Unclassified
12. PRICE
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