NR 465.28(6)
(6) How do I determine the emission capture system efficiency?. You shall use the following procedures and test methods to determine capture efficiency as part of the performance test required by
sub. (1):
NR 465.28(6)(a)
(a) You may assume the capture system efficiency is 100% if both of the following conditions are met:
NR 465.28(6)(a)1.
1. The capture system meets the criteria of Method 204 in
40 CFR part 51, Appendix M, incorporated by reference in
s. NR 484.04 (9), for a PTE and directs all the exhaust gases from the enclosure to an add-on control device.
NR 465.28(6)(a)2.
2. All coatings, thinners and cleaning materials used in the coating operation are applied within the capture system; coating solvent flash-off and coating, curing and drying occurs within the capture system; and the removal or evaporation of cleaning materials from the surfaces they are applied to occurs within the capture system. For example, this criterion is not met if parts enter the open shop environment when being moved between a spray booth and a curing oven.
NR 465.28(6)(b)
(b) If the capture system does not meet both of the criteria in
par. (a), use one of the 3 protocols described in
subds. 1. to
3. to measure capture efficiency. The capture efficiency measurements use TVH capture efficiency as a surrogate for organic HAP capture efficiency. For the protocols in
subds. 1. and
2., the capture efficiency measurement shall consist of 3 test runs. Each test run shall be at least 3 hours duration or the length of a production run, whichever is longer, up to 8 hours. For the purposes of this test, a production run means the time required for a single part to go from the beginning to the end of production which includes surface preparation activities and drying or curing time. The protocols are as follows:
NR 465.28(6)(b)1.
1. `Liquid-to-uncaptured-gas protocol using a temporary total enclosure or building enclosure.' The liquid-to-uncaptured-gas protocol compares the mass of liquid TVH in materials used in the coating operation to the mass of TVH emissions not captured by the emission capture system. You shall use the following procedures to measure emission capture system efficiency using the liquid-to-uncaptured-gas protocol:
NR 465.28(6)(b)1.a.
a. Either use a building enclosure or construct an enclosure around the coating operation where coatings, thinners and cleaning materials are applied, and all areas where emissions from these applied coatings and materials subsequently occur, such as flash-off, curing and drying areas. The areas of the coating operation where capture devices collect emissions for routing to an add-on control device, such as the entrance and exit areas of an oven or spray booth, shall also be inside the enclosure. The enclosure shall meet the applicable definition of a temporary total enclosure or building enclosure in Method 204 in
40 CFR part 51, Appendix M, incorporated by reference in
s. NR 484.04 (9).
NR 465.28(6)(b)1.b.
b. Use Method 204A or 204F in
40 CFR part 51, Appendix M, incorporated by reference in
s. NR 484.04 (9), to determine the mass fraction of TVH liquid input from each coating, thinner and cleaning material used in the coating operation during each capture efficiency test run. To make the determination, substitute TVH for each occurrence of the term VOC in the methods.
NR 465.28(6)(b)1.c.
c. Use the following equation to calculate the total mass of TVH liquid input from all the coatings, thinners and cleaning materials used in the coating operation during each capture efficiency test run:
(Equation 5)
where:
TVHused is the total mass of TVH liquid input from all coatings, thinners and cleaning materials used in the coating operation during the capture efficiency test run, kg
TVHi is the mass fraction of TVH in coating, thinner or cleaning material, i, that is used in the coating operation during the capture efficiency test run, kg TVH per kg material
Voli is the total volume of coating, thinner or cleaning material, i, used in the coating operation during the capture efficiency test run, liters
Di is the density of coating, thinner or cleaning material, i, kg material per liter material
n is the number of different coatings, thinners and cleaning materials used in the coating operation during the capture efficiency test run
NR 465.28(6)(b)1.d.
d. Use Method 204D or 204E in
40 CFR part 51, Appendix M, incorporated by reference in
s. NR 484.04 (9), to measure the total mass, kg, of TVH emissions that are not captured by the emission capture system; they are measured as they exit the temporary total enclosure or building enclosure during each capture efficiency test run. To make the measurement substitute TVH for each occurrence of the term VOC in the methods. Use Method 204D if the enclosure is a temporary total enclosure. Use Method 204E if the enclosure is a building enclosure. During the capture efficiency measurement, all organic compound emitting operations inside a building enclosure, other than the coating operation for which capture efficiency is being determined, shall be shut down, but all fans and blowers shall be operating normally.
NR 465.28(6)(b)1.e.
e. For each capture efficiency test run, determine the percent capture efficiency of the emission capture system, using the following equation:
(Equation 6)
where:
CE is the capture efficiency of the emission capture system vented to the add-on control device, percent
TVHused is the total mass of TVH liquid input used in the coating operation during the capture efficiency test run, kg
TVHuncaptured is the total mass of TVH that is not captured by the emission capture system and that exits from the temporary total enclosure or building enclosure during the capture efficiency test run, kg
NR 465.28(6)(b)1.f.
f. Determine the capture efficiency of the emission capture system as the average of the capture efficiencies measured in the 3 test runs.
NR 465.28(6)(b)2.
2. `Gas-to-gas protocol using a temporary total enclosure or a building enclosure.' The gas-to-gas protocol compares the mass of TVH emissions captured by the emission capture system to the mass of TVH emissions not captured. You shall use the following procedures to measure emission capture system efficiency using the gas-to-gas protocol.
NR 465.28(6)(b)2.a.
a. Either use a building enclosure or construct an enclosure around the coating operation where coatings, thinners and cleaning materials are applied and all areas where emissions from these applied coatings and materials subsequently occur such as flash-off, curing and drying areas. The areas of the coating operation where capture devices collect emissions generated by the coating operation for routing to an add-on control device, such as the entrance and exit areas of an oven or a spray booth, shall also be inside the enclosure. The enclosure shall meet the applicable definition of a temporary total enclosure or building enclosure in Method 204 in
40 CFR part 51, Appendix M, incorporated by reference in
s. NR 484.04 (9).
NR 465.28(6)(b)2.b.
b. Use Method 204B or 204C in
40 CFR part 51, Appendix M, incorporated by reference in
s. NR 484.04 (9), to measure the total mass, kg, of TVH emissions captured by the emission capture system during each capture efficiency test run as measured at the inlet to the add-on control device. To make the measurement, substitute TVH for each occurrence of the term VOC in the methods. The sampling points for the Method 204B or 204C measurement shall be upstream from the add-on control device and shall represent total emissions routed from the capture system and entering the add-on control device. If multiple emission streams from the capture system enter the add-on control device without a single common duct, the emissions entering the add-on control device shall be simultaneously measured in each duct, and the total emissions entering the add-on control device shall be determined.
NR 465.28(6)(b)2.c.
c. Use Method 204D or 204E in
40 CFR part 51, Appendix M, incorporated by reference in
s. NR 484.04 (9), to measure the total mass, kg, of TVH emissions that are not captured by the emission capture system; they are measured as they exit the temporary total enclosure or building enclosure during each capture efficiency test run. To make the measurement, substitute TVH for each occurrence of the term VOC in the methods. Use Method 204D if the enclosure is a temporary total enclosure. Use Method 204E if the enclosure is a building enclosure. During the capture efficiency measurement, all organic compound emitting operations inside the building enclosure other than the coating operation for which capture efficiency is being determined shall be shut down, but all fans and blowers shall be operating normally.
NR 465.28(6)(b)2.d.
d. For each capture efficiency test run, determine the percent capture efficiency of the emission capture system, using the following equation:
(Equation 7)
where:
CE is the capture efficiency of the emission capture system vented to the add-on control device, percent
TVHcaptured is the total mass of TVH captured by the emission capture system as measured at the inlet to the add-on control device during the emission capture efficiency test run, kg
TVHuncaptured is the total mass of TVH that is not captured by the emission capture system and that exits from the temporary total enclosure or building enclosure during the capture efficiency test run, kg
NR 465.28(6)(b)2.e.
e. Determine the capture efficiency of the emission capture system as the average of the capture efficiencies measured in the 3 test runs.
NR 465.28(6)(b)3.
3. `Alternative capture efficiency protocol.' As an alternative to the procedures specified in
subds. 1. and
2., you may determine capture efficiency using any other capture efficiency protocol and test methods that satisfy the criteria of either the DQO or LCL approach as described in
40 CFR part 63, Subpart KK, Appendix A, incorporated by reference in
s. NR 484.04 (24).
NR 465.28(7)
(7) How do I determine the add-on control device emission destruction or removal efficiency?. NR 465.28(7)(a)(a) For all types of add-on control devices, use the following test methods:
NR 465.28(7)(a)3.
3. Method 3, 3A or 3B in
40 CFR part 60, Appendix A, incorporated by reference in
s. NR 484.04 (13), as appropriate, for gas analysis to determine dry molecular weight. You may also use, as an alternative to Method 3B, the manual method for measuring the oxygen, carbon dioxide and carbon monoxide content of exhaust gas in ANSI/ASME, PTC 19.10-1981, “Flue and Exhaust Gas Analyses", incorporated by reference in
s. NR 484.11 (6).
NR 465.28(7)(a)5.
5. Methods for determining gas volumetric flow rate, dry molecular weight, and stack gas moisture shall be performed, as applicable, during each test run.
NR 465.28(7)(b)
(b) Measure total gaseous organic mass emissions as carbon at the inlet and outlet of the add-on control device simultaneously, using either Method 25 or 25A in
40 CFR part 60, Appendix A, incorporated by reference in
s. NR 484.04 (13), and using the same method for both the inlet and outlet measurements according to the following criteria:
NR 465.28(7)(b)1.
1. Use Method 25 if the add-on control device is an oxidizer and you expect the total gaseous organic concentration as carbon to be more than 50 parts per million (ppm) at the control device outlet.
NR 465.28(7)(b)2.
2. Use Method 25A if the add-on control device is an oxidizer and you expect the total gaseous organic concentration as carbon to be 50 ppm or less at the control device outlet.
NR 465.28(7)(c)
(c) If 2 or more add-on control devices are used for the same emission stream, you shall measure emissions at the outlet of each device.
NR 465.28 Note
Note: For example, if one add-on control device is a concentrator with an outlet for the high-volume, dilute stream that has been treated by the concentrator, and a second add-on control device is an oxidizer with an outlet for the low-volume, concentrated stream that is treated with the oxidizer, you shall measure emissions at the outlet of the oxidizer and the high-volume dilute stream outlet of the concentrator.
NR 465.28(7)(d)
(d) For each test run, determine the total gaseous organic emissions mass flow rates for the inlet and the outlet of the add-on control device, using Equation 8 in this paragraph. If there is more than one inlet or outlet to the add-on control device, you shall calculate the total gaseous organic mass flow rate using Equation 8 in this paragraph for each inlet and each outlet and then total all of the inlet emissions and total all of the outlet emissions.
(Equation 8)
where:
Mf is the total gaseous organic emissions mass flow rate, kg/per hour (h)
Cc is the concentration of organic compounds as carbon in the vent gas, as determined by Method 25 or Method 25A, parts per million by volume (ppmv), dry basis
Qsd is the volumetric flow rate of gases entering or exiting the add-on control device, as determined by Method 2, 2A, 2C, 2D, 2F or 2G, dry standard cubic meters/hour (dscm/h)
0.0416 = conversion factor for molar volume, kg-moles per cubic meter (mol/m3) (at 293 Kelvin (K) and 760 millimeters of mercury (mm Hg))
NR 465.28(7)(e)
(e) For each test run, determine the add-on control device organic emissions destruction or removal efficiency, using the following equation:
(Equation 9)
where:
DRE is the add-on control device organic emissions destruction or removal efficiency, percent
Mfi is the total gaseous organic emissions mass flow rate at the inlet or inlets to the add-on control device, using Equation 8 in par. (d), kg/h
Mfo is the total gaseous organic emissions mass flow rate at the outlet or outlets of the add-on control device, using Equation 8 in par. (d), kg/h
NR 465.28(7)(f)
(f) Determine the emission destruction or removal efficiency of the add-on control device as the average of the efficiencies determined in the 3 test runs and calculated in Equation 9 in
par. (e).
NR 465.28(8)
(8) How do I establish the emission capture system and add-on control device operating limits during the performance test?. During the performance test required by
sub. (1) and described in
subs. (5) to
(7), you shall establish the operating limits required by
s. NR 465.23 (3) according to the following requirements, as applicable, unless you have received approval for alternative monitoring and operating limits under
s. NR 460.07 (6) as specified in
s. NR 465.23 (3):
NR 465.28(8)(a)
(a)
Thermal oxidizers. If your add-on control device is a thermal oxidizer, according to both of the following:
NR 465.28(8)(a)1.
1. During the performance test, you shall monitor and record the combustion temperature at least once every 15 minutes during each of the 3 test runs. You shall monitor the temperature in the firebox of the thermal oxidizer or immediately downstream of the firebox before any substantial heat exchange occurs.
NR 465.28(8)(a)2.
2. Use the data collected during the performance test to calculate and record the average combustion temperature maintained during the performance test. This average combustion temperature is the minimum operating limit for your thermal oxidizer.
NR 465.28(8)(b)1.1. If your add-on control device is a catalytic oxidizer, according to either of the following:
NR 465.28(8)(b)1.a.
a. During the performance test, monitor and record the temperature just before the catalyst bed and the temperature difference across the catalyst bed at least once every 15 minutes during each of the 3 test runs. Use the data collected during the performance test to calculate and record the average temperature just before the catalyst bed and the average temperature difference across the catalyst bed maintained during the performance test. These are the minimum operating limits for your catalytic oxidizer.
NR 465.28(8)(b)1.b.
b. Monitor the temperature just before the catalyst bed and implement a site-specific inspection and maintenance plan for your catalytic oxidizer as specified in
subd. 2. During the performance test, you shall monitor and record the temperature just before the catalyst bed at least once every 15 minutes during each of the 3 test runs. Use the data collected during the performance test to calculate and record the average temperature just before the catalyst bed during the performance test. This is the minimum operating limit for your catalytic oxidizer.
NR 465.28(8)(b)2.
2. You shall develop and implement an inspection and maintenance plan for any catalytic oxidizer or oxidizers for which you elect to monitor according to
subd. 1. b. The plan shall address, at a minimum, the following elements:
NR 465.28(8)(b)2.a.
a. Annual sampling and analysis of the catalyst activity (i.e., conversion efficiency) following the manufacturer's or catalyst supplier's recommended procedures.
NR 465.28(8)(b)2.b.
b. Monthly inspection of the oxidizer system including the burner assembly and fuel supply lines for problems and, as necessary, adjusting the equipment to assure proper air-to-fuel mixtures.
NR 465.28(8)(b)2.c.
c. Annual internal and monthly external visual inspection of the catalyst bed to check for channeling, abrasion and settling. If problems are found, you shall take corrective action consistent with the manufacturer's recommendations and conduct a new performance test to determine destruction efficiency according to
sub. (7).
NR 465.28(8)(c)
(c)
Carbon adsorbers. If your add-on control device is a carbon absorber, according to both of the following:
NR 465.28(8)(c)1.
1. Monitor and record the total regeneration desorbing gas (e.g., steam or nitrogen) mass flow for each regeneration cycle and the carbon bed temperature after each carbon bed regeneration and cooling cycle for the regeneration cycle either immediately preceding or immediately following the performance test.
NR 465.28(8)(c)2.
2. The operating limits for your carbon absorber are the minimum total desorbing gas mass flow recorded during the regeneration cycle and the maximum carbon bed temperature recorded after the cooling cycle.
NR 465.28(8)(d)
(d)
Condensers. If your add-on control device is a condenser, according to both of the following:
NR 465.28(8)(d)1.
1. During the performance test, monitor and record the condenser outlet (product side) gas temperature at least once every 15 minutes during each of the 3 test runs.
NR 465.28(8)(d)2.
2. Use the data collected during the performance test to calculate and record the average condenser outlet (product side) gas temperature maintained during the performance test. This average condenser outlet gas temperature is the maximum operating limit for your condenser.
NR 465.28(8)(e)
(e)
Concentrators. If your add-on control device includes a concentrator, according to all of the following:
NR 465.28(8)(e)1.
1. During the performance test, monitor and record the desorption concentrate stream gas temperature at least once every 15 minutes during each of the 3 runs of the performance test.
NR 465.28(8)(e)2.
2. Use the data collected during the performance test to calculate and record the average temperature. This is the minimum operating limit for the desorption concentrate gas stream temperature.
