**FORM A -1** 

**PA RENT COMPA**  **NY INFORMA TION** 
**I. Parent Company / Legal Corporate Owner Information**
1. Legal Parent Company/ Legal Corporate Name Johns Manville

2. Address 717 17th Street 3. City Denver 4. State Colorado 5. Zip Code 80202 6. County Denver 7. Size of Company (approximate number of employ ees including all subsidiaries, branches, and related establishments owned): 6,491 (end of 2009)

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM A -2** 

**FA CILITY INFORMA** 

**TION**
**II. Facility Information**
Facility Name Johns Manville-Penbry n, NJ Facility Facility Address Street 437 N. Grove St City Berlin State New Jersey Zip Code 08009 County Camden Facility Coordinates Latitude (decimal degrees, six decimal places) 39.757078 Longitude (decimal degrees, six decimal places) 74.939037 Specific location represented (e.g., front door of main building, centroid of property , etc.) Front Door

Number of employees attached to the wool fiberglass
ma nufacturing facility : See CBI Subm ittal

Design capacity

of the plant (tons/y r) See CBI Subm ittal
Ty pe(s) of process(es) (rotary spin, flame attenuation) at this plant Rotary Spin

Operation schedule hrs/day Currenty-0, 2008-24 days/y r Currently-0, 2008-7
Identify what state and local air pollution rules and regulations, including permit requirements, your plant is subject to. (Please provide copies of permit(s) and permit IDs) N.J.A.C.; 7:27-6, 7:27-8, 7:27-16. See Attachment "A" for copies of permit limitations and application forms.

**III. Technical Contact**

Name Mark Uscinowicz Technical Contact Title Manager of Process and Quality Telephone 356 768-7036 Facsimile (Fax) 356 768-7061

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsEmail 

### Mark.Uscinowicz@jm.com

**IV. Other**
Is the facility

a major source of HAP? No

If No, did the facility take a limit of its potential HAP
em issions to avoid classification as a major source: No, true minor
Does the facility

manufacture other products in addition to wool fiberglass? No

If Yes, list the other products manufactured at the facility

. NA

Are there any

HAP em issions associated with anycolocated facilities? List unit operations, e.g., boiler, and pollutant/em issions. No

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM B-1**

**PLA NT OPERA** 

**TIONS**
**I. Overview of Plant Operations**
Number of process lines. Include lines that are currently operational or that are temporarilyshutdown. (Do not include lines permanentlyshutdown). 1

For each process line: Process Line 1 Process Line 2 Process Line 3 Process line identification names or numbers Line 58 Ty pe of process line (e.g., rotaryspin, flame attenuation) Rotary Spin Maximum annual production rate (tons/y r) See CBI Submittal Age of process equipment (y rs) 25 Remaining economic life of process line (y rs) Indefinite (due to rebuild capabilities) List of products produced and most recent annual production (tons/y r; specify year) for each product See CBI Submittal
Please attach detailed schematics of each process line. See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM B-2**

**PLA NT OPERA** 

**TIONS**
**II. Process - Raw materials Handling and Storage**
Molten glass preparation Raw materials and proportions bywt (%) See CBI Submittal Method(s) of convey ing each raw material to furnace/pots Pneum atic Convey ance Binder and Additives List each raw material, including premixed materials, in the binder formulation and its proportion bywt (%) See CBI Submittal List steps in preparing binder, including storage temperature ( ° F) and holding time (hrs) See CBI Submittal Total y early

consumption of binder (gal/y r) See CBI Submittal Cost of binder ($/gal) for most recent y ear (specify year) See CBI Submittal Are binder storage and mixing tanks vented to outside/inside? Inside
Method of treating vent air from storage and mix tanks None Emission control during liquid raw material transfer from vehicles to storage tanks. Resin has a filter The binder for all plant products was converted to a non- Describe future source reduction plans and schedules to reformulate binders; List each constituent, proportions wt (%), cost ($/gal) for reformulation HAP binder in 2002 that significantlyreduces or elim inates HAP emissions from the manufacturing

process.

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM B-3**

**PLA NT OPERA** 

**TIONS**

**III. Process - Glass Melting Furnace (Electric Melters)**
For each Glass Melting Furnace: Electric Melters Furnace 2 Furnace 3 Process unit identification name/number Module 1, 2 & 3 E17, E18 & E19 Process line(s) served (identification name/number) Line 58 Latitude (decimal degrees, six decimal places) 39.758930 Longitude (decimal degrees, six decimal places) -74.439917 Stack or vent height (units) 115 ft Stack or vent diameter (units) 38 in Manufacturer and model JM Proprietary Date of original installation 1985
Estimate of remaining lifetime (y rs) Indefinite (due to continued
ma intenance) Major rebuilds:

W hat constitutes a major rebuild JM is not familiar with the term "major rebuild." JM conducts periodic routine
ma intenace. Frequency

of a major rebuild N/A Cost of ty pical major rebuild N/A Date of last major rebuild N/A Purpose of last major rebuild N/A Increase or decrease in emissions N/A Fuel ty pe: electric, gas, or oil Electric Fuel consumption rate (KW /ton of glass or Btu/ton of glass) See CBI Subm ittal
List HAPs that are in refractory material Chromium Compounds Design production rate (tons/day ) See CBI Subm ittal Actual glass pull rate (tons/day ) See CBI Subm ittal Vent gas flow rate (acfm @ ° F) 397,452 acfm @ 119 O F

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsTemperature ( ° F) of molten glass in furnace and

forehearth (if applicable) See CBI Subm ittal Nature and frequency of routine/preventive maintenance procedures See CBI Subm ittal Describe process modification(s) since 1999 that reduce
em issions None
Describe future source reduction plans and schedules See CBI Subm ittal

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM B-4**

**PLA NT OPERA** 

**TIONS**
**IV. Process - Forming -- Rotary Spin / Flame A ttenuation** 
For each Forming Operation -- Rotary Spin/Flame Attenuation Forming Operation 1 Forming Operation 2 Forming Operation 3 Process unit identification name/number Module 1 E1 Module 2 E2 Module 3 E3 Process line(s) served (identification name/number) Line 58 Line 58 Line 58 Latitude (decimal degrees, six decimal places) 37.758703 37.758780 37.758861 Longitude (decimal degrees, six decimal places) -74.939634 -74.939699 -74.9397764 Stack or vent height (units) 68 in 68 in 68 in Stack or vent diameter (units) 69 ft 69 ft 69 ft Number of fiber forming devices (spinners) per line. See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Method of attenuating fiber (e.g., air, flame, or air and flame). Indicate ty pe of burner used (if flame). Air Air Air Is there a forehearth between the furnace and the forming section? No No No Major rebuilds:

W hat constitues a major rebuild JM is not familiar with the term "major rebuild." JM conducts periodic routine
ma intenace. JM is not familiar with the

term "major rebuild." JM conducts periodic routine
ma intenace. JM is not familiar with the

term "major rebuild." JM conducts periodic routine
ma intenace. Frequency

of a major rebuild N/A N/A N/A Cost of ty pical major rebuild N/A N/A N/A Date of last major rebuild N/A N/A N/A Purpose of last major rebuild N/A N/A N/A Increase or decrease in emissions N/A N/A N/A If modular, number of modules and plenums Each module listed separately Each module listed separately Each module listed separately Presence of water overspray and application rate (gpm) See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Binder applied and application rate (gpm) See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Other material applied and application rate (gpm) See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Temperature of glass fiber when binder is applied (°F) See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Temperature of binder when applied to fibers (°F) See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Method of evenly

distributing fibers onto forming conveyor See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Formed mat thickness (in.) See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Forming air flow rate (acfm @ °F) 50,000 acfm @ 125 o F 50,000 acfm @ 125 o F 50,000 acfm @ 125 o F Percent of forming air recirculated and percent exhausted 100% Exhausted 100% Exhausted 100% Exhausted

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsNature and frequency of routine/preventive maintenance procedures See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal

Describe process modification(s) since 1999 that reduce
em issions The binder for all plant products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP em issions from the
ma nufacturing process. The binder for all plant products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP em issions from the
ma nufacturing process. The binder for all plant products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP em issions from the
ma nufacturing process. Describe future source reduction plans and schedules See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM B-5**

**PLA NT OPERA** 

**TIONS**
**V. Process - Curing**

For each Curing Oven: Curing Oven 1 Curing Oven 2 Curing Oven 3

Process unit identification name/number Line 58 Curing Oven N. HEAF E4 Line 58 Curing Oven S. HEAF E4 Process line(s) served (identification name/number) Line 58 Line 58 Latitude (decimal degrees, six decimal places) 39.758361 39.758281 Longitude (decimal degrees, six decimal places) -74.939400 -74.939325 Stack or vent height (units) 36 in 36 in Stack or vent diameter (units) 72 ft 72 ft Method of curing Hot Air Recirculation Hot Air Recirculation

Manufacturer and model Originally installed by

MidWe st conveyor Co. Modified by K.C. Industrial 1974,
mo dified and enlarged in

1985 Originally installed by

MidWe st conveyor Co. Modified by K.C. Industrial 1974,
mo dified and enlarged in

1985 Date of original installation 1974 1974 Major rebuilds:

W hat constitutes a major rebuild JM is not familiar with the term "major rebuild." JM conducts periodic routine
ma intenace. JM is not familiar with the term "major rebuild." JM conducts periodic routine
ma intenace. Frequency

of a major rebuild N/A N/A Cost of ty pical major rebuild N/A N/A Date of last major rebuild N/A N/A Purpose of last major rebuild N/A N/A Increase or decrease in emissions N/A N/A Fuel ty pe: electric, gas, or oil Natural Gas Natural Gas Fuel consumption rate (KW /hr or BTU/hr) See CBI Subm ittal See CBI Subm ittal Moisture content wt (%) of formed mat: inlet See CBI Subm ittal See CBI Subm ittal outlet 0 0 Air flow rate (acfm @ ° F) from curing 39,000 @ 120 o F 39,000 @ 120 o F Exhaust air temperature ( ° F) 240 o F 240 o F Residence time of product (mins) See CBI Subm ittal See CBI Subm ittal Binder content of cured product (LOI) 6% 6%

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsNature and frequency of routine/preventive
ma intenance procedures See CBI Subm ittal See CBI Subm ittal

Describe process modification(s) since 1999 that reduce emissions The binder for all plant products was converted to a non-HAP binder in 2002 that significantly

reduces or elim inates HAP emissions from the manufacturing process. The binder for all plant

products was converted to a non-HAP binder in 2002 that significantly

reduces or elim inates HAP emissions from the manufacturing process. Describe future source reduction plans and schedules See CBI Subm ittal See CBI Subm ittal

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM B-6**

**PLA NT OPERA** 

**TIONS**

**VI. Process - Cooling**

For each Cooling Operation: Cooling Operation 1 Cooling Operation 2 Cooling Operation 3 Process unit identification name/number Line 58 Cooling E5 Process line(s) served (identification name/number) Line 58 Latitude (decimal degrees, six decimal places) 39.758194 Longitude (decimal degrees, six decimal places) -74.939261 Stack or vent height (units) 72 ft Stack or vent diameter (units) 30 in. Cooling air flow rate (acfm @ ° F) 14,500 @ 120 o F Percentage of cooling air recirculated (if any ) None Cooling air temperature (°F) Am bient Nature and frequency of routine/preventive
ma intenance procedures See CBI Subm ittal

Describe process modification(s) since 1999 that reduce emissions The binder for all plant products was converted to a formaldehyde free binder in 2002. That significantly reduces or eliminates HAP
em issions from the
ma nufacturing process.
Describe future source reduction plans and schedules See CBI Subm ittal

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM B-7**

**PLA NT OPERA** 

**TIONS**

**VII. Process - Use of Solvents**

Use of Solvents

Volatile solvents used at y our facility (where and how used) By agreement this question was limited to HAP containing solvents. W e interpret this question to applyto wool fiberglass lines, from melting through cooling. None List each solvent used and quantity(gal/y r) N/A Emission control device(s) used to control emissions from solvent usage/storage? N/A

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM B-8**

**PROCESS OPERA TIONS** 

VIII. Pollution Prevention

Please describe any

work practices, pollution prevention techniques, and control strategies evaluated and/or implemented at each process unit at your facility

(e.g., binder reformulation, alternative fuels usage, etc.) to reduce emissions of PM and HAPs y ou identified in Form E. You m ust specify

the y ear in which the facility im plem ented the practice/technique and identifythe emission reductions (if measured) from these practices/techniques. JM objects to this question in that it is unbounded in time. We interpret this question, like similar questions in the ICR, to seek data since 1999. W ith that interpretation, JM responds that the binder was reformulated to a formaldehy de free resin in 2002.

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM C-1**

**AI R POLLUTION CONTROL** 
**I. Electrostatic Precipitator (ESP)**

For each ESP: ESP 1 ESP 2 ESP 3 Process line(s) (identification name/number) There is no ESP at this facility

. Equipm ent/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Manufacturer and model Date of original installation Number of collection plates and configuration Gas flow rate to ESP (acfm @ ° F) Inlet gas temperature ( ° F) Outlet gas temperature ( ° F) Inlet grain loading (gr/dscf) Outlet grain loading (gr/dscf) Average stack opacity (%) Pressure drop across ESP (in. H 2 O gauge) Plate area (ft 2 ) Vendor guarantee on ESP efficency (attach copy ) Method of plate cleaning and frequency Flow rate of plate washwater to ESP (gpm), if applicable Temperature of plate washwater to ESP ( ° F), if applicable Source of plate washwater used for cleaning, if applicable Concentration (mg/l) of dissolved and suspended solids in plate washwater, if applicable Conditioning agents used and amounts (in gpm or lbs/hr), if applicable Amount of wastewater generated (gpd), if applicable Amount of wastewater recycled (gpd), if applicable Amount of wastewater disposed of (gpd), if applicable Method of wastewater disposal, if applicalbe Quantity

of solid waste collected (lbs/y r) Quantitiy

of solid waste recycled (lbs/y r)

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsQuantity of solid waste disposed of (lbs/y r) Method of solid waste disposal Nature and frequency of routine/preventive maintenance procedures Problems experienced with control device within the last five ye ars; how were problems solved? Continuous monitoring method(s) used to monitor ESP performance, including parameters monitored Describe any

plans to replace or upgrade ESP

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM C-2**

**AI R POLLUTION CONTROL** 

**II. Scrubber**

For each Scrubber: Scrubber 1 Scrubber 2 Scrubber 3
Process line(s) (identification name/number) There is no Scrubber at this facility

. Equipm ent/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Manufacturer and model Date of original installation Ty pe (e.g., venturi, orifice) Gas flow rate to scrubber (acfm @ ° F) Inlet gas temperature ( ° F) Outlet gas temperature ( ° F) Inlet grain loading (gr/dscf) Outlet grain loading (gr/dscf) Average stack opacity (%) W ater flow rate to scrubber (gpm) Percent of scrubber water from recy cled wastewater
Source of scrubbing water and ty pe of pretreatment. Substance(s) added as part of pretreatment and amount used (gpm or lbs/hr) HAP composition of wastewater (mg/L) Concentration (mg/L) of dissolved and suspended solids in scrubbing water Scrubbing water temperature ( ° F) Liquid/gas ratio (gal/10 3 acfm) Pressure drop across scrubber (in. H 2 O gauge) Amount of wastewater generated (gpd) Amount of wastewater recycled (gpd)

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsAmount of wastewater disposed of (gpd)

Method of wastewater disposal Quantity

of solid waste collected (lbs/y r) Quantity

of solid waste recycled (lbs/y r) Quantity

of solid waste disposed of (lbs/y r) Method of solid waste disposal Vendor guarantee on scrubber efficiency (attach copy ) Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five years; how were problem s solved? Continuous monitoring method(s) used to monitor scrubber performance, including parameters monitored Plans to replace or upgrade scrubber

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM C-3**

**AI R POLLUTION CONTROL** 

**III. Mechanical Collector**

For each Mechanical Collector: Mechanical Collector 1 Mechanical Collector 2 Mechanical Collector 3
Process line(s) (identification name/number) There is no Mechanical Collector at this facility

. Equipm ent/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Manufacturer and model Date of original installation Ty pe of mechanical collector Gas flow rate to collector (acfm @ ° F) Inlet gas temperature ( ° F) Outlet gas temperature ( ° F) Inlet grain loading (gr/dscf) Outlet grain loading (gr/dscf) Average stack opacity (%) Overall pressure drop (in. H 2 O gauge) Vendor guarantee on mechanical collector efficiency (attach copy ) Quantity

of solid waste collected (lbs/y r) Quantity

of solid waste recycled (lbs/y r) Quantity

of solid waste disposed of (lbs/y r) Method of solid waste disposal
Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five ye ars; how were problems solved? Continuous monitoring method(s) used to monitor performance, including parameters monitored

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsPlans to replace or upgrade mechanical collector

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM C-4**

**AI R POLLUTION CONTROL** 

**IV. Fabric Filter**

For each Fabric Filter: Fabric Filter 1 Fabric Filter 2 Fabric Filter 3 Process line(s) (identification name/number) Line 58 Melter Dust Collector Equipm ent/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Controls dust/particulate from three glass melters E17-E19 Latitude (decimal degrees, six decimal places) 39.758930 Longitude (decimal degrees, six decimal places) -74.439917 Stack or vent height (units) 115 ft Stack or vent diameter (units) 32 in Manufacturer and model Ecolaire (2) 625-8 Date of original installation December 1984 Number of compartments 4 Number of bags per compartment 160 Filter material and coatings applied Poly propy lene needle felted with singed finish Fabric weight (oz/yd 2 ) 16 Filter surface area (ft 2 ) 7500 Gas flow rate to filter (acfm @ ° F) 36,000 @ 125 o F Inlet gas temperature ( ° F) Am bient Outlet gas temperature ( ° F) Am bient Inlet grain loading (gr/dscf) Unknown Outlet grain loading (gr/dscf) 0.0016 Average stack opacity (%) 0 Overall pressure drop (in. H 2 O gauge) 3.5

Method and frequency of bag cleaning 1st hour compartment No. 1 shakes for 8 minutes, 2nd hour compartment No. 2 shakes for 8 minute, etc. Vendor guarantee on fabric filter efficiency (attach copy ) Wr itten guarantee is not available, about 99% Quantity

of solid waste collected (lbs/y r) 949,870

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsQuantity of solid waste recycled (lbs/y r) Dust 100% recy cled (930,750 lb/y r) Quantity

of solid waste disposed of (lbs/y r) 19,120 lb/year waste filter bags Method of solid waste disposal Landfill
Nature and frequency of preventive maintenance procedures Every 3 months following dust collector Preventative Maintenance in Attachment C Problems experienced with control device within the last five years; how were problems solved? Nothing specific, general wear and maintenance items Continuous monitoring method(s) used to monitor performance, including parameters monitored None Plans to replace or upgrade fabric filter See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM C-5**

**AI R POLLUTION CONTROL** 

**V. Thermal Incinerator**

For each Thermal Incinerator: Thermal Incinerator 1 Thermal Incinerator 2 Thermal Incinerator 3
Process line(s) (identification name/number) There is no Thermal Incinerator at this facility

. Equipm ent/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Manufacturer and model Date of original installation Fuel ty pe: gas or oil Fuel consumption rate (BTU/hr) Inlet gas flow rate (acfm @ ° F) Inlet gas temperature ( ° F) Combustion chamber gas temperature ( ° F) Outlet gas temperature ( ° F) Inlet grain loading (gr/dscf) Outlet grain loading (gr/dscf) Average stack opacity (%) Excess air (%) Residence time (sec) at temperature ( ° F) Percent heat recovery Vendor guarantee on incinerator efficiency (attach copy ) Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five years; how were problems solved?

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsContinuous monitoring method(s) used to monitor

incinerator performance, including parameters monitored Plans to replace or upgrade thermal incinerator

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM C-6**

**AI R POLLUTION CONTROL** 

**VI. High Velocity A ir Filter (HVA**  **F)**

For each HVAF: HEAF 1 HEAF 2 HVAF 3 Line 58 North HEAF Line 58 South HEAF Equipm ent/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Line 58 Curing Oven E4 Line 58 Curing Oven E4
Latitude (decimal degrees, six decimal places) 39.758361 39.758281 Longitude (decimal degrees, six decimal places) -74.939400 -74.939325 Stack or vent height (units) 72 ft 72 ft Stack or vent diameter (units) 36 inches 36 inches Manufacturer and model Johns Manville Design and fabrication Johns Manville Design and fabrication Date of original installation 1973 1988 Inlet gas flow rate (acfm @ ° F) 28,000 @ 125o F 35,000 @ 125o F Inlet gas temperature ( ° F) 130 130 Outlet gas temperature ( ° F) 120 120 Inlet grain loading (gr/dscf) Unknown Unknown Outlet grain loading (gr/dscf) 0.004 g/dscf 0.004 g/dscf Average stack opacity (%) Less than 10 % Less than 10 % W ater spray

pressure (sdig), if applicable 28 psi 28 psi W ater spray

rate (gpm), if applicable 56 gpm 56 gpm Filter face velocity

(acfm/ft 2 ) Not Available Not Available Maximum pressure drop across mat (in. H 2 O gauge) 1.75 1.75
Vendor guarantee on HVAF efficiency (attach copy ) Not Available Not Available

Method and frequency of filter mad advancement Autom atic advancement based upon time average: every 13 minutes Autom atic advancement

based upon time average: every 13 minutes Amount of wastewater generated (gpd) 4,320 4,320 Amount of wastewater recycled (gpd) 100% (4,320 gpd) 100% (4,320 gpd) Amount of wastewater disposed of (gpd) 0 0

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsMethod of wastewater disposal Not Applicable Not Applicable

Quantity

of solid waste collected (lbs/y r) 26690 for both HEAFs 26690 for both HEAFs Quantity

of solid waste recycled (lbs/y r) 0 0 Quantity

of solid waste disposed of (lbs/y r) 26690 for both HEAFs 26690 for both HEAFs Method of solid waste disposal Landfill Nature and frequency of preventive maintenance procedures Every two weeks preventative
ma intenance electrical and
me chanical Every two weeks preventative
ma intenance electrical and
me chanical

Problems experienced with control device within the last five years; how were problems solved? Problem s are related to cogging of the chain and drum due to sticky

build-up. This problem has not been solved, but our means of addressing it is to have more frequent cleaning. Problem s are related to

cogging of the chain and drum due to sticky

build-up. This problem has not been solved, but our means of addressing it is to have more frequent cleaning. Continuous monitoring method(s) used to monitor HVAF performance, including parameters monitored Pressure drop across the unit. Pressure drop across the unit.
Plans to replace or upgrade HVAF See CBI submittal See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM C-7**

**AI R POLLUTION CONTROL** 

**VII. Mist Eliminator**

For each Mist Eliminator: Mist Eliminator 1 Mist Eliminator 2 Mist Eliminator 3
Process line(s) (identification name/number) There is no Mist Eliminator at this facility

. Equipm ent/process(es) controlled. Include emission point designations (e.g., E3, E4 plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Manufacturer and model Date of original installation Ty pe of mist eliminator Gas flow rate to mist eliminator (acfm @ ° F) Inlet gas temperature ( ° F) Outlet gas temperature ( ° F) Inlet grain loading (gr/dscf) Outlet grain loading (gr/dscf) Average stack opacity (%) Velocity

in m ist elim inator (ft/sec) Pressure drop (in. H 2 O gauge) For chevron blade mist eliminators: Spacing between blades (in.) W ashing frequency of blades For mesh pad mist eliminators: Number of pads or elements Thickness of pad (in.) or element dimensions Density

of pad, (lb/ft 3 ) W ashing frequency of pad
Vendor guarantee on mist eliminator efficiency (attach copy )

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsAmount of wastewater generated (gpd)

Amount of wastewater recycled (gpd) Amount of wastewater disposed of (gpd) Method of wastewater disposal Quantity

of solid waste collected (lbs/y r) Quantity

of solid waste recycled (lbs/y r) Quantity

of solid waste disposed of (lbs/y r) Method of solid waste disposal
Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five ye ars; how were problems solved? Continuous monitoring method(s) used to monitor mist eliminator performance, including parameters monitored Plans to replace or upgrade mist eliminator

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM C-8**

**AI R POLLUTION CONTROL** 
**VIII. Ventilation System** N/A
For each Ventilation System: Ventilation System 1 Ventilation System 2 Ventilation System 3 Process line(s) (identification name/number) Equipm ent/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) For general or building ventilation: Ventilation system used Airflow control system used Number of air changes per hour For unit or local ventilation: Enclosure or hood design used Volume of enclosure or hood Capture velocity (ft/sec) Distance between hood and emission source (ft)

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM C-9**

**AI R POLLUTION CONTROL** 

**IX. Other**

For each Other Air Pollution Control Device (APCD): Other APCD 1 Other APCD 2 Other APCD 3 Process line(s) (identification name/number) Line 58
Equipm ent/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) No other air pollution control devices at this facility

. Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Description

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM D**

**PROCESS LINE STA RTUP A**  **ND SHUTDOWN**
1. For each startup and shutdown (SS) that occurred during the last five years, please provide the following information requested in A. through J.

A. Using the definitions provided above, indicate whether the event was a startup or shutdown; No excess emission events during periods of startup and shutdown. B. A description of the event, including identification of the
em issions source or sources associated with the startup or shutdown; N/A

C. W hether any

permit condition was exceeded and, if so, what permit condition was exceeded; N/A

D. W hether the event was covered by any contingency

plan for controlling emissions during startup and shutdown events and, if so, whether the plan was followed; if the plan was not followed, why not; N/A

E. The duration of the event; N/A F. The actions taken to minimize emissions during the event, including the use of any backup control systems; N/A G. Estimates or measurements, if any , of emissions during the event; if you did not have the ability to quantify

emissions during the event, please explain why ; N/A

H. W hether the emission profile of each unit was different during startup and shutdown than during normal operating conditions and, if so, how emissions were different and why ; please provide any supporting information; N/A

I. All performance test data collected during each period of SS; the test method used for each event; when the testing was conducted and why ; the test conditions at the time of testing; and whether the tests were associated with a routine startup or shutdown; and No data available

J. All monitoring data, including control system parameter
mo nitoring, collected during each period of SS. All required Title V monitoring data would be collected. Startup: the setting in operation of an affected source or portion of an affected source for any purpose. Shutdown: the cessation of operation of an affected source or portion of an affected source for any purpose.

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsIf this information is contained in periodic and immediate SS reports

(either stand-alone or contained within the periodic excess emissions report) submitted to your permitting authority , you may submit copies of those reports instead.
2. Are there any

ty pes of startup or shutdown events that you have been able to elim inate? If so, please describe the ty pe of event and explain how these events were elim inated. N/A
3. Please submit a copy of your SS plan if you are required to develop one. No plan required 4. Please provide all performance test data collected during periods of SS over the last 5 years. Indicate the test method used for each event. No data available
5. Please provide all m onitoring data, including control system parameter monitoring, collected during periods of SS over the last 5 ye ars. N/A
6. Optional: Do you wish to recommend a standard that would apply during startup or shutdown? If so, please describe the event to which the standard would apply ; the recommended standard (this could be an emission limitation, work practice, or operational standard) that would apply during the period; the basis for the recommended standard; why and how the standard would m inim ize
em issions during the event; and how would compliance be determined and/or monitored. No

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM E**

**PRESENCE OF A IR POLLUTA**  **NTS IN EMISSION POINTS a** 

Please provide any

existing emissions information and data covering hazardous air pollutants (HAP) and particulate matter (PM) for each listed process. Identify the appropriate box for which you are providing specific process information and/or pollutant em issions data.

**Me lting Furnace**  **Forming Curing**  **Cooling**

Particulate Matter (PM, PM 2.5, PM Condensable)

Chromium Compounds and Hexavalent Chromium (including any Cr speciation data) Other metal HAP (As, Be, Cd, Co, Hg, Mn, Ni, Pb, Sb, Se) Hydrogen Fluoride (HF) Hydrogen Chloride (HCl) The existing data requested here has been provided to EPA by the industry ’s trade association, the North American Insulation Manufacturers Association (“NAIMA”). The existing data provided by NAIMA was set forth in NAIMA’s May 5, 2010 letter to EPA. The representative existing emissions data provided from fiber glass companies included test results for the following pollutants: formaldehyde, methanol, phenol, particulate
ma tter, hydrogen fluoride, metals (antimony , arsenic, bery llium , cadmium, chromium, cobalt, lead, manganese, nickel, and selenium), mercury , and hexavalent chromium. The representative existing emissions data provided from mineral wool companies included test results for the following pollutants: formaldehyde, methanol, phenol, particulate matter, carbon monoxide, carbony l sulfide, hydrogen fluoride, metals (antimony , arsenic, bery llium , cadmium, chromium, cobalt, lead, manganese, nickel, and selenium ), mercury , and hexavalent chromium. The scope of the existing data provided was the result of consensus reached by EPA, NAIMA, and industry representatives. In addition to the existing data submitted to EPA, extensive new emissions data is being collected from virtually all companies through the “BTEC, Inc. Quality Assurance Project Plan for the Mineral W ool and W ool Fiberglass Emissions Test Program.” This Test Program will collect and submit to EPA, through EPA’s Electronic Reporting Tool, representative emissions data for the following pollutants: formaldehyde, methanol, phenol, particulate matter, carbon monoxide, carbony l sulfide, hydrogen fluoride,
me tals (antimony , arsenic, bery llium , cadmium, chromium, cobalt, lead, manganese, nickel, and selenium), mercury , and hexavalent chromium.

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsFormaldehyde

Phenol Methanol Other organic HAP

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM F-1**

**COST**
**I. Process Unit (e.g., cupola, curing oven, etc.):**

For each Process Unit: Process Unit 1 Process Unit 2 Process Unit 3 Process Unit ID All Units Process Line ID Line 58
**II. Capital Costs**

Base year JM objects to this request in its entirety

because it seeks information that is not relevant to the EPA Adm inistrator’s review obligations pursuant to Clean Air Act Section 112(d)(6) and 112(f)(2). Total capital cost, including costs for individual pieces, if available. See Above **III. A nnual Operating Costs**  Base year (most recent fiscal year) See Above Total annual operating costs See Above
Maintenance materials and replacement parts (specify costs by item ) See Above Raw m aterials costs See Above Labor ($/y r) for each labor class See Above (hr/hr) for each labor class See Above Utilities (breakdown for each utility ) See Above W aste treatment and/or disposal See Above Costs associated with any work practices and pollution prevention techniques that are employed at your facility See Above Savings associated with heat recovery and wastewater and/or solid waste returned to process from APCD (or sold to another user) See Above Indirect costs See Above Other (specify ) See Above

EPA-HQ-OAR-2010-1042-DRAFT-0006.xlsPlease provide the annual report to shareholders or equivalent for the most

recent fiscal year. If reports are not available, provide annual sales and profits (or profit margin) for the most recent fiscal year. If company is publicly owned, please provide a web link to this information. See Above

Identify the market range (regional, national, international) of your products. National

Can your product(s) be substituted by another product(s)? If so, please list yo ur product(s) and substituted product(s). Wo ol fiberglass is used as insulation, as are cellulose (scrap newspaper) treated to resist fires, spray

foam, foam boards, cotton treated to resist fires, and sheep wool treated to resist fires. W ool fiberglass insulation is preferred over these alternative insulation
ma terials because it is easily , economically , and safety installed in various building settings, has superior fire performance capabilities, and a 70- ye ar history

of proven performance and durability

.

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls**FORM F-2**

**COST**

**I. A ir Pollution Control Device (A**  **PCD)** See form F-1

For each APCD: APCD 1 APCD ID Process Unit ID
**II. Capital Costs**

Base year JM objects to this request in its entirety because it seeks information that is not relevant to the EPA Adm inistrator’s review obligations pursuant to Clean Air Act Section 112(d)(6) and 112(f)(2). APCD equipm ent purchase cost and what was included See above List the cost for each piece of auxiliary equipm ent for each APCD not included above See above
Installation cost See above Land purchase cost See above Total capital cost See above Method of financining APCD See above Retrofit installation See above Field erected or modular See above

**III. A nnual Operating Costs**  Base year (most recent fiscal year) See above Maintenance materials and replacement parts (specify costs by item ) See above
Raw m aterials costs See above Labor

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls($/y r) for each labor class See above (hr/hr) for each labor class See above Utilites (breackdown for each utility ) See above W aste treatment and/or disposal See above

Indirect costs See above Other (specify ) See above Total annual operating cost (most recent fiscal year) See above
Attach annual report to shareholders or equivalent for the most recent fiscal year. Alternatively , if company is publicly

owned, you can provide your company 's web link to this information. See above

EPA-HQ-OAR-2010-1042-DRAFT-0006.xls