3M MACT JJJJ Compliance Experiences Using EPA Method 204 Allowed Capture Efficiency Testing Alternative Protocols

摘要

Capture efficiency (CE) test results are required to calculate the fugitive emissions ofvolatile organic compounds (VOC) from surface coating operations. EPA Methods 204,204B, and 204D expanded the approved CE testing options to include gas/gasmethodologies and the use of coating bays (typically large rooms where one or morecoaters are located) as temporary total enclosures (TTE). In January 1995, the EPApublished a guidance document, EMTIC GD-035, on capture efficiency testing whichallowed for the submittal of alternative test protocols. When using alternative protocols,the test results have to meet either a data quality objective or a lower confidence limit testand 8 additional criteria, all of which are described and/or listed in the aforementionedguidance document. The alternative protocols also had to be approved by the US EPAOffice of Air Quality Planning and Standards at Research Triangle Park, when suchapproval was requested by a state regulatory agency.Shortly after their promulgation, 3M discovered the benefits of both building enclosures(BE), i.e., using coating bays as TTE(s) and gas/gas emission testing, i.e., EPA Method204B & D, at one 3M tape coating facility. However, it was only in the past 6 years thatthe gas/gas methodology, the use of coating bays as TTE(s), and the use of alternativeprotocols began to be applied at other 3M facilities. Most of the testing was completed inthe last 3 years to meet the Paper and Other Web Coating MACT compliancecertification requirements. Generally the determined bay capture efficiencies are greaterthan 99%, without the use of permanent total enclosures (PTE). In fact, existing coaterPTE(s) were often opened to the bay and the bay tested as a TTE.3M has found this test method to be both accurate and repeatable. Coating bay CE levelshave been found to be much higher than previously determined by liquid/gas testing forpermit compliance and annual VOC emission reporting. In other words, it correctlymeasured the reductions achieved by the new air pollution control systems being installedby 3M and demonstrated the adequacy of local vapor capture systems evolved over time