**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 employees including all subsidiaries, branches, and related establishments owned): 6,491 (end of 2009)



### EPA-HQ-OAR-2010-1042-DRAFT-0008.xls

### FORM A-2

**FACILITY INFORMATION**

**II. Facility**

**Information**

Facility Name Johns Manville-Cleburne Plant Facility Address Street 200 W est Industrial Boulevard City Cleburne State Texas Zip Code 76031 County Johnson Facility Coordinates Latitude (decimal degrees, six decimal places) N32.38691 Longitude (decimal degrees, six decimal places) W9 7.39483 Specific location represented (e.g., front door of main building, centroid of property, etc.) Front Door - Center Curb Line

Number of employees attached to the wool fiberglass manufacturing facility: See CBI submittal

Design capacity of the plant (tons/yr) See CBI submittal

Type(s) of process(es) (rotary spin, flame attenuation) at this plant Rotary Spin and Flame Attenuation

Operation schedule hrs/day 24 days/yr 365

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) Federal Title V Permit #01677 TCEQ Title V Permit #946A PSDTX #1025M1 (See Attachment A)

**III. Technical Contact**

Name Ricardo A. Santos Technical Contact Title Environmental Specialist Telephone 817-556-6659 Facsimile (Fax) 817-556-7559 Email 

## santosr@jm.com

**IV. Other**

Is the facility a major source of HAP? Yes



## EPA-HQ-OAR-2010-1042-DRAFT-0008.xls

### If No, did the facility take a limit of its potential HAP emissions to avoid

classification as a major source: Not Applicable

Does the facility manufacture other products in addition to wool fiberglass? Yes

If Yes, list the other products manufactured at the facility. Chopped Fibers and Reinforcements

Are there any HAP emissions associated with any co-located facilities? List unit operations, e.g., boiler, and pollutant/emissions. Weinterpret this to seek information on sources of HAPs other than wool fiber glass at the facility rather than co-located facilities. Yes. A solvent is used to clean the ink jet printer cartridges. Ink jet printers are used for print information on the product. This solvent is used at L91 and two mat coating process lines (L90 and L97). Methyl Alcohol compose about 5% of product. Gallons per year of this solvent used: 35.17 gallons.1901 forming MeOH: Fug. Emissions 17,088 lbs/Yr (8.54 TPY), HCHO emissions from binder tanks, combustion, and maintenance: Fug emissions 2,661 lbs/Yr (1.33 TPY).



## EPA-HQ-OAR-2010-1042-DRAFT-0008.xls

### FORM B-1

**PLA NT OPERATIONS** 

**I. Overview of Plant Operations**

Number of process lines. Include lines that are currently operational or that are temporarily shutdown. (Do not include lines permanently shutdown). 3

For each process line: Process Line 1 Process Line 2 Process Line 3 Process line identification names or numbers Line 91 Line 92 Line 93

Type of process line (e.g., rotary spin, flame attenuation) Rotary Spin Flame Attenuation Flame Attenuation Maximum annual production rate (tons/yr) See CBI submittal See CBI submittal See CBI submittal Age of process equipment (yrs) 20 46 45

Remaining economic life of process line (yrs) Indefinite (due to rebuild capabilities) Indefinite (due to rebuild capabilities) Indefinite (due to rebuild capabilities)
List of products produced and most recent annual production (tons/yr; specify year) for each product See CBI submittal See CBI submittal See CBI submittal

Please attach detailed schematics of each process line. See Attachment B See Attachment B See Attachment B



### EPA-HQ-OAR-2010-1042-DRAFT-0008.xls**FORM B-2**

**PLANT OPERATIONS**

**II. Process - Raw materials Handling and Storage Process Line 1 - Line 91**  **Process Line 2 - Line 92 Process Line 3 - Line 93** 

Molten glass preparation

Raw materials and proportions by w t (%) See CBI submittal Glass Marbles Glass Marbles Method(s) of conveying each raw material to furnace/pots Mechanical conveyance and gravity feed Bucket hopper and gravity Bucket hopper and gravity Binder and Additives

List each raw

material, including premixed materials, in the binder formulation and its proportion by w t (%) See CBI submittal See CBI submittal See CBI submittal

List steps in preparing binder, including storage temperature (° F) and holding time (hrs) See CBI submittal See CBI submittal See CBI submittal

Total yearly consumption of binder (gal/yr) See CBI submittal See CBI submittal See CBI submittal Cost of binder ($/gal) for most recent year (specify year) See CBI submittal See CBI submittal See CBI submittal Are binder storage and mixing tanks vented to

outside/inside? Inside Inside Inside Method of treating vent air from storage and mix tanks No Treatment No Treatment No Treatment

Emission control during liquid raw material transfer from vehicles to storage tanks. There are no emission controls on anything except the aqua ammonia transfer. W hen ammonia is unloaded, the holding tank is vented back into the truck. There are no emission controls on anything except the aqua ammonia transfer. W hen ammonia is unloaded, the holding tank is vented back into the truck. There are no emission controls on anything except the aqua ammonia transfer. W hen ammonia is unloaded, the holding tank is vented back into the truck.

Describe future source reduction plans and schedules to reformulate binders; List each constituent, proportions w t (%), cost ($/gal) for reformulation See CBI submittal See CBI submittal See CBI submittal



### EPA-HQ-OAR-2010-1042-DRAFT-0008.xls

### FORM B-3

**PLANT OPERATIONS**

**III. Process - Glass Melting Furnace**

For each Glass Melting Furnace: Line 91- Melters 1902 Furnace 3 Process unit identification name/number L 91 F1902 Process line(s) served (identification name/number) Unit 94, Unit 97 None Latitude (decimal degrees, six decimal places) N32.38827 N32.387693 Longitude (decimal degrees, six decimal places) W9 7.39715 W9 7.393087 Stack or vent height (units) 43 feet 78 feet Stack or vent diameter (units) 51 7/8" 65" Manufacturer and model JMProprietary JMProprietary Date of original installation 1990 1974

Estimate of remaining lifetime (yrs) Indefinite (due to continued maintenance) Indefinite (due to continued maintenance) Major rebuilds:

W hat constitues a major rebuild See CBI Submittal See CBI Submittal Frequency of a major rebuild N/A N/A Cost of typical 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 type: electric, gas, or oil Electric Gas Fuel consumption rate (KW /ton of glass or Btu/ton of glass) See CBI Submittal See CBI Submittal List HAPs that are in refractory material Chromium Compounds Chromium Compounds Design production rate (tons/day) See CBI Submittal See CBI Submittal Actual glass pull rate (tons/day) See CBI Submittal See CBI Submittal Vent gas flow rate (acfm @ ° F) 40,318 @ 145 °F 33,296 @ 322 °F Temperature (° F) of molten glass in furnace and forehearth (if applicable) See CBI Submittal See CBI Submittal

Nature and frequency of routine/preventive maintenance procedures CBI See CBI Submittal See CBI Submittal Describe process modification(s) since 1999 that reduce emissions None None

Describe future source reduction plans and schedules See CBI Submittal See CBI Submittal



## EPA-HQ-OAR-2010-1042-DRAFT-0008.xls**FORM B-4**

**PLANT OPERATIONS**

**IV. Process - Forming -- Rotary Spin / Flame Attenuation** 

For each Forming Operation -- Rotary Spin/Flame Attenuation Forming Operation 1 Forming Operation 2 Forming Operation 3 Process unit identification name/number Line 91 Line 92 Line 93 Process line(s) served (identification name/number) None None None

Latitude (decimal degrees, six decimal places) Module 1: N32.38801 Module 2: N32.38801 Module 3: N32.38802 Module 4: N32.38802 N32.38754 N32.3876

Longitude (decimal degrees, six decimal places) Module 1: W 97.39708 Module 2: W 97.39712 Module 3: W 97.39713 Module 4: W 97.39716 W9 7.39465 W9 7.39462

Stack or vent height (units) Refer to C-2 for stack information EPN 1 53.5 ft EPN 2 53.5 ft EPN 4 53.708 ft EPN 5 53.729 ft

Stack or vent diameter (units) Refer to C-2 for stack information EPN 1 63.625x63.5 in EPN 2 63.5x63.5625 in EPN 4 63.5x64 in EPN 5 63.5x64 in Number of fiber forming devices (spinners) per line. See CBI Submittal See CBI Submittal See CBI Submittal Method of attenuating fiber (e.g., air, flame, or air and flame). Indicate type of burner used (if flame). Air flame attenuation, gas burner flame attenuation, gas burner Is there a forehearth between the furnace and the forming section? Yes No No Major rebuilds:

W hat constitues a major rebuild JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. Frequency of a major rebuild N/A N/A N/A Cost of typical 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 4 Non modular Non modular Presence of water overspray and application rate (gpm) See CBI Submittal See CBI Submittal See CBI Submittal Binder applied and application rate (gpm) See CBI Submittal See CBI Submittal See CBI Submittal Other material applied and application rate (gpm) See CBI Submittal See CBI Submittal See CBI Submittal Temperature of glass fiber when binder is applied (°F) See CBI Submittal See CBI Submittal See CBI Submittal Temperature of binder when applied to fibers (°F) See CBI Submittal See CBI Submittal See CBI Submittal Method of evenly distributing fibers onto forming converyor See CBI Submittal See CBI Submittal See CBI Submittal Formed mat thickness (in.) See CBI Submittal See CBI Submittal See CBI Submittal

Forming air flow rate (acfm @ °F) Module 1: 21,582 @ 102 °F Module 2: 22,687 @ 103 °F Module 3: 22,085 @ 99 °F Module 4: 23,496 @ 102 °F 2 fans @ 65000 CFM @160F 2 fans @ 65000 CFM @160F

Percent of forming air recirculated and percent exhausted 100% Exhausted 100% Exhausted 100% Exhausted

Nature and frequency of routine/preventive maintenance procedures See CBI Submittal See CBI Submittal See CBI Submittal Describe process modification(s) since 1999 that reduce emissions Reducing HAPs in binder formulations Reducing HAPs in binder formulations Reducing HAPs in binder formulations Describe future source reduction plans and schedules See CBI Submittal See CBI Submittal See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0008.xls

### FORM B-5

**PLANT OPERATIONS**

**V. Process - Curing**

For each Curing Oven: Curing Oven 1 Curing Oven 2 Curing Oven 3 Process unit identification name/number Line 91 Curing Oven Line 92 Curing Oven Line 93 Curing Oven

Process line(s) served (identification name/number) Line 91 Line 92 Line 93 Latitude (decimal degrees, six decimal places) N32.38791 N32.38757 N32.38763 Longitude (decimal degrees, six decimal places) W97.39664 W97.39479 W97.39474

Stack or vent height (units) Refer to C-2 (EPN 20) for stack info Refer to C-6 (EPN 3) for stack info Refer to C-6 (EPN 3) for stack info

Stack or vent diameter (units) Refer to C-2 (EPN 20) for stack info Refer to C-6 (EPN 3) for stack info Refer to C-6 (EPN 3) for stack info Method of curing Gas Oven Gas Oven Gas Oven

Manufacturer and model Continental Steel & Conveyors The R.C.MAHON Company The R.C.MAHON Company Date of original installation 1990 1964 1964 Major rebuilds:

W hat constitues a major rebuild JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. Frequency of a major rebuild NA NA NA Cost of typical major rebuild NA NA NA Date of last major rebuild NA NA NA Purpose of last major rebuild NA NA NA Increase or decrease in emissions NA NA NA Fuel type: electric, gas, or oil Gas Gas Gas Fuel consumption rate (KW/hr or BTU/hr) See CBI Submittal See CBI Submittal See CBI Submittal Moisture content wt (%) of formed mat: inlet See CBI Submittal See CBI Submittal See CBI Submittal outlet 0 0 0 Air flow rate (acfm @ ° F) from curing 52,452 24,183.50 24,183.50 Exhaust air temperature (° F) Up to 450 degrees Up to 500 degress Up to 500 degress Residence time of product (mins) See CBI Submittal See CBI Submittal See CBI Submittal Binder content of cured product (LOI) 5% to 18% 5% to 16% 5% to 16% Nature and frequency of routine/preventive maintenance procedures See CBI Submittal See CBI Submittal See CBI Submittal Describe process modification(s) since 1999 that reduce emissions Reducing HAPs in binder formulations Reducing HAPs in binder formulations Reducing HAPs in binder formulations

Describe future source reduction plans and schedules See CBI Submittal See CBI Submittal See CBI Submittal



### EPA-HQ-OAR-2010-1042-DRAFT-0008.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 91 Cooling Line 92 Cooling Line 93 Cooling

Process line(s) served (identification name/number) Line 91 Line 92 Line 93 Latitude (decimal degrees, six decimal places) N32.38791 N32.3875 N32.38763 Longitude (decimal degrees, six decimal places) W9 7.3965 W9 7.395 W9 7.395 Stack or vent height (units) Routed to curing control N/A N/A Stack or vent diameter (units) N/A N/A N/A Cooling air flow rate (acfm @ ° F) N/A N/A N/A Percentage of cooling air recirculated (if any) None None None Cooling air temperature (°F) Ambient Ambient Ambient Nature and frequency of routine/preventive maintenance procedures See CBI submittal See CBI submittal See CBI submittal Describe process modification(s) since 1999 that reduce emissions Reducing HAPs in binder formulations Reducing HAPs in binder formulations Reducing HAPs in binder formulations Describe future source reduction plans and schedules See CBI submittal See CBI submittal See CBI submittal



### EPA-HQ-OAR-2010-1042-DRAFT-0008.xls**FORM B-7**

**PLANT OPERATIONS**

**VII. Process - Use of Solvents**

Use of Solvents

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



### EPA-HQ-OAR-2010-1042-DRAFT-0008.xls**FORM B-8**

**PROCESS OPERATIONS**

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 you identified in Form E. You must specify the year in which the facility implemented the practice/technique and identify the emission reductions (if measured) from these practices/techniques. See CBI Submittal



### EPA-HQ-OAR-2010-1042-DRAFT-0008.xls

### FORM C-1

**AIR POLLUTION CONTROL**

**I. Electrostatic Precipitator (ESP)**

For each ESP: ESP 1 Process line(s) (identification name/number) N/A Equipment/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 (ft2 

### ) 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/yr) Quantitiy of solid waste recycled (lbs/yr) Quantity of solid waste disposed of (lbs/yr) Method of solid waste disposal Nature and frequency of routine/preventive maintenance procedures Problems experienced with control device within the last five years; 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-0008.xls**FORM C-2**

**AIR POLLUTION CONTROL**

**II. Scrubber**

For each Scrubber: Scrubber 1 Scrubber 2 Scrubber 3 Scrubber 4 Oven Scrubber Process line(s) (identification name/number) Collection Scrubber 1 Collection Scrubber 2 Collection Scrubber 3 Collection Scrubber 4 Oven Scrubber Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Line 91 - EPN 16 Line 91 - EPN 17 Line 91 - EPN 18 Line 91 - EPN 19 Line 91 - EPN 20 Latitude (decimal degrees, six decimal places) N32.38796 N32.38795 N32.38796 N32.38794 N32.38785 Longitude (decimal degrees, six decimal places) W9 7.39723 W9 7.39716 W9 7.39703 W9 7.39706 W9 7.39664 Stack or vent height (units) 125 ft 125 ft 125 ft 125 ft 81.17 ft Stack or vent diameter (units) 59.0625 in 60 in 60.5 in 60.125 in 60 in Manufacturer and model AiPol Inc. Cyclonic C-V AiPol Inc. Cyclonic C-V AiPol Inc. Cyclonic C-V AiPol Inc. Cyclonic C-V AiPol Inc. Cyclonic C-V Date of original installation 1990 1990 1990 1990 1990 Type (e.g., venturi, orifice) Venturi Venturi Venturi Venturi Venturi Gas flow rate to scrubber (acfm @ ° F) 38,806 38,279 34,455 28,913 52,452 Inlet gas temperature (° F) Not Available Not Available Not Available Not Available Not Available Outlet gas temperature (° F) 100 101 96 99 357 Inlet grain loading (gr/dscf) Not Available Not Available Not Available Not Available Not Available Outlet grain loading (gr/dscf) 0.0083 0.0062 0.0075 0.0062 0.0059 Average stack opacity (%) < 10% < 10% < 10% < 10% < 10% W ater flow rate to scrubber (gpm) 600 600 600 600 630 max Percent of scrubber water from recycled wastewater 100% 100% 100% 100% 100%

Source of scrubbing water and type of pretreatment. Substance(s) added as part of pretreatment and amount used (gpm or lbs/hr) City W ater - Defoamer - 1/2 gal as needed City W ater - Defoamer - 1/2 gal as needed City W ater - Defoamer - 1/2 gal as needed City W ater - Defoamer - 1/2 gal as needed City W ater - Defoamer - 1/2 gal as needed

HAP composition of wastewater (mg/L) None Detected None Detected None Detected None Detected None Detected Concentration (mg/L) of dissolved and suspended solids in scrubbing water N/A N/A N/A N/A N/A
Scrubbing water temperature (° F) N/A N/A N/A N/A N/A Liquid/gas ratio (gal/10 3acfm) N/A N/A N/A N/A N/A Pressure drop across scrubber (in. H 2 O gauge) 14 14 14 14 29 max Amount of wastewater generated (gpd) None None None None None Amount of wastewater recycled (gpd) None None None None None Amount of wastewater disposed of (gpd) None None None None None Method of wastewater disposal Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Quantity of solid waste collected (lbs/yr) 203,087 203,087 203,087 203,087 203,087 Quantity of solid waste recycled (lbs/yr) None None None None None Quantity of solid waste disposed of (lbs/yr) 203,087 203,087 203,087 203,087 203,087 Method of solid waste disposal TCEQ Class 1 Landfill TCEQ Class 1 Landfill TCEQ Class 1 Landfill TCEQ Class 1 Landfill TCEQ Class 1 Landfill Vendor guarantee on scrubber efficiency (attach copy) None None None None None

Nature and frequency of preventive maintenance procedures Monthly - Inspect and repair Monthly - Inspect and repair Monthly - Inspect and repair Monthly - Inspect and repair Monthly - Inspect and repair Problems experienced with control device within the last five years; how were problems solved? None None None None None Continuous monitoring method(s) used to monitor scrubber performance, including parameters monitored Pressure Drop and W ater Flow Rate Pressure Drop and W ater Flow Rate Pressure Drop and W ater Flow Rate Pressure Drop and W ater Flow Rate Pressure Drop and W ater Flow Rate Plans to replace or upgrade scrubber See CBI submittal See CBI submittal See CBI submittal See CBI submittal See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0008.xls**FORM C-3**

**AIR POLLUTION CONTROL**

**III. Mechanical Collector**

For each Mechanical Collector: Mechanical Collector 1 Mechanical Collector 2 Mechanical Collector 3 Process line(s) (identification name/number) N/A Equipment/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 Type 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 2O gauge) Vendor guarantee on mechanical collector efficiency (attach copy) Quantity of solid waste collected (lbs/yr) Quantity of solid waste recycled (lbs/yr) Quantity of solid waste disposed of (lbs/yr) Method of solid waste disposal

Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five years; how were problems solved? Continuous monitoring method(s) used to monitor performance, including parameters monitored Plans to replace or upgrade mechanical collector

EPA-HQ-OAR-2010-1042-DRAFT-0008.xls

### FORM C-4

**AIR POLLUTION CONTROL**

**IV. Fabric Filter**

For each Fabric Filter: Fabric Filter 1

Process line(s) (identification name/number) Line 91-Dust Collector - Melters

Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Line 91 - EPN 21

Latitude (decimal degrees, six decimal places) N32.38812 Longitude (decimal degrees, six decimal places) W9 7.39713 Stack or vent height (units) 60 ft Stack or vent diameter (units) 51.875 in Manufacturer and model Mac 144rpt252 Date of original installation 1990 Number of compartments 4 Number of bags per compartment 135 Filter material and coatings applied Polyester Fabric weight (oz/yd 2 

### ) 16 oz Filter surface area (ft2 

### ) 6"x12' = 6 ft2 per bag Gas flow rate to filter (acfm @ ° F) 40,318 Inlet gas temperature (° F) 145 Outlet gas temperature (° F) 145 Inlet grain loading (gr/dscf) Not Available Outlet grain loading (gr/dscf) 0.0022 Average stack opacity (%) < 5% Overall pressure drop (in. H 2 

### O gauge) 16 Method and frequency of bag cleaning Continuous/Automatic Vendor guarantee on fabric filter efficiency (attach copy) None Quantity of solid waste collected (lbs/yr) 346,000 Quantity of solid waste recycled (lbs/yr) None Quantity of solid waste disposed of (lbs/yr) 346,000 Method of solid waste disposal RCRA Landfill

Nature and frequency of preventive maintenance procedures Weekly / monthly - Inspect and repair as needed Problems experienced with control device within the last five years; how were problems solved? None Continuous monitoring method(s) used to monitor performance, including parameters monitored Pressure Drop
Plans to replace or upgrade fabric filter See CBI Submittal



### EPA-HQ-OAR-2010-1042-DRAFT-0008.xls**FORM C-5**

**AIR POLLUTION CONTROL**

**V. Thermal Incinerator**

For each Thermal Incinerator: Thermal Incinerator 1 Thermal Incinerator 2 Thermal Incinerator 3 Process line(s) (identification name/number) N/A

Equipment/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 type: 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?

Continuous monitoring method(s) used to monitor incinerator performance, including parameters monitored Plans to replace or upgrade thermal incinerator



### EPA-HQ-OAR-2010-1042-DRAFT-0008.xls**FORM C-6**

**AIR POLLUTION CONTROL**

**VI. High Velocity**

**Air Filter (HVAF)**

For each HVAF: HVAF 1

Process line(s) (identification name/number) HIGH ENERGY AIR FILTRATION

Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) EPN 3

Latitude (decimal degrees, six decimal places) N32.38759 Longitude (decimal degrees, six decimal places) W9 7.39491 Stack or vent height (units) 52.75ft Stack or vent diameter (units) 59.875x45.875 in

Manufacturer and model Andersen 2000 Inc., Rotary Drum DF-54-VI Date of original installation 1964 Inlet gas flow rate (acfm @ ° F) 48,367 @ 145F Inlet gas temperature (° F) 145 Outlet gas temperature (° F) 145 Inlet grain loading (gr/dscf) Not Available Outlet grain loading (gr/dscf) 0.0058 Average stack opacity (%) < 10% W ater spray pressure (sdig), if applicable Not Applicable W ater spray rate (gpm), if applicable Not Applicable Filter face velocity (acfm/ft2 ) 1,500 - 1,700

Maximum pressure drop across mat (in. H 2O gauge) 28

Vendor guarantee on HVAF efficiency (attach copy) None Method and frequency of filter mad advancement Timer controlled Amount of wastewater generated (gpd) None Amount of wastewater recycled (gpd) None Amount of wastewater disposed of (gpd) None Method of wastewater disposal N/A Quantity of solid waste collected (lbs/yr) 2,000 Quantity of solid waste recycled (lbs/yr) None Quantity of solid waste disposed of (lbs/yr) 2,000 Method of solid waste disposal TCEQ Class II Landfill Nature and frequency of preventive maintenance procedures Monthly - Inspect and clean thermocouples Problems experienced with control device within the last five years; how were problems solved? None Continuous monitoring method(s) used to monitor HVAF performance, including parameters monitored None Plans to replace or upgrade HVAF See CBI Submittal



### EPA-HQ-OAR-2010-1042-DRAFT-0008.xls**FORM C-7**

**AIR POLLUTION CONTROL**

**VII. Mist Eliminator**

For each Mist Eliminator: Mist Eliminator 1 Mist Eliminator 2 Mist Eliminator 3 Process line(s) (identification name/number) N/A Equipment/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 Type 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 mist eliminator (ft/sec) Pressure drop (in. H 2O 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/ft3 ) W ashing frequency of pad

Vendor guarantee on mist eliminator efficiency (attach copy) Amount 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/yr) Quantity of solid waste recycled (lbs/yr) Quantity of solid waste disposed of (lbs/yr) Method of solid waste disposal

Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five years; 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-0008.xls**FORM C-8**

**AIR POLLUTION CONTROL**

**VIII. Ventilation System**

For each Ventilation System: Ventilation System 1 Ventilation System 2 Ventilation System 3 Process line(s) (identification name/number) N/A Equipment/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-0008.xls

### FORM C-9

**AI R POLLUTION CONTROL** 

**IX. Other**

For each Other Air Pollution Control Device (APCD): Other APCD 1 Process line(s) (identification name/number) Line 91 Oven-Ring Burner Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) EPN 20 Latitude (decimal degrees, six decimal places) N32.38785 Longitude (decimal degrees, six decimal places) W9 7.39664 Stack or vent height (units) 59 feet Stack or vent diameter (units) 60 inches

Description Two burners of 5 MM BTU/hr each installed inside of the exhaust stack associated with EPN 20 (L91 oven scrubber) with the purpose of reducing opacity from its source.



## EPA-HQ-OAR-2010-1042-DRAFT-0008.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.

Shutdown: the cessation of operation of an affected source or portion of an affected source for any purpose.

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 emissions 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 monitoring, collected during each period of SS. All required Title V monitoring data would be collected.

If 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. Startup: the setting in operation of an affected source or portion of an affected source for any purpose.



## EPA-HQ-OAR-2010-1042-DRAFT-0008.xls

### 2. Are there any types of startup or shutdown events that you have been able to eliminate? If so, please describe

the type of event and explain how these events were eliminated. N/A 3. Please submit a copy of your SS plan if you are required to develop one. See CBI Submittal 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. N/A 5. Please provide all monitoring data, including control system parameter monitoring, collected during periods of SS over the last 5 years. 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 minimize emissions during the event; and how would compliance be determined and/or monitored. N/A



## EPA-HQ-OAR-2010-1042-DRAFT-0008.xls**FORM E**

**PRESENCE OF AIR POLLUTANTS 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 wh ich you are providing specific process information and/or pollutant emissions data. **Melting Furnace Forming**  **Curing Cooling**  Particulate Matter (PM, PM 2.5, PM Condensable) 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 matter, hydrogen fluoride, metals (antimony, arsenic, beryllium, 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, carbonyl sulfide, hydrogen fluoride, metals (antimony, arsenic, beryllium, 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 newemissions 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 wi ll 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, carbonyl sulfide, hydrogen fluoride, metals (antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel, and selenium), mercury, and hexavalent chromium.

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)
Formaldehyde
Phenol
Methanol Other organic HAP



### EPA-HQ-OAR-2010-1042-DRAFT-0008.xls

## FORM F-1

**COST**

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

For each Process Unit: Process Unit 1 Process Unit ID All Units Process Line 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). 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 ($/yr) 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-0008.xls

## Please 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). Wool 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

materials because it is easily, economically, and safety installed in various building settings, has superior fire performance capabilities, and a 70- year history

of proven performance and durability

.



## EPA-HQ-OAR-2010-1042-DRAFT-0008.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 ($/yr) for each labor class See Above



## EPA-HQ-OAR-2010-1042-DRAFT-0008.xls

## (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



## EPA-HQ-OAR-2010-1042-DRAFT-0008.xls