Question # 603

603. Our facility paints metal cabinets and the paint solvents contain a listed toxic chemical. The system consists of a closed, vacuum vented painting room and a closed oven room vented by an oven stack. Are releases from the vent to the outside of the building over the painting room considered 'releases from building ventilation systems' and therefore reported as fugitive emissions?
No, fugitive releases are emissions that are not in a confined directional air flow. Since your building vent system over the painting room is a confined air stream, it can be combined with the oven stack as a stack or point emissions in Part II Section 5.2 of the Form R.