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Title V Air Permit Renewal Application 

Facility No. 211-0013 

IIG Mineral Wool LLC 

Phenix City, AL 

March 2008 

www.erm.com 
IIG Mineral Wool LLC 

908 John Bussey Drive 

Phenix City, Alabama 36869

TITLE V AIR PERMIT 

RENEWAL APPLICATION 

FACILITY NO. 211-0013 

March 2008 

ERM Project No. 0078842 

Environmental Resources Management 

300 Chastain Center Blvd., Suite 375 

Kennesaw, GA 30144 

(770) 590-8383 

PERMIT APPLICATION
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TABLE OF CONTENTS 

TABLE OF CONTENTS i 

LIST OF APPENDICES iii 

CERTIFICATIONS iv 

1.0 INTRODUCTION 1-1 

 1.1 PROJECT DESCRIPTION 1-1 

 1.2 PERMIT SHIELD REQUEST 1-4 

 1.3 FACILITY DESCRIPTION 1-6 

 1.4 PERMIT CHANGES SINCE INITIAL TITLE V PERMIT ISSUANCE 1-10 

2.0 REGULATORY REVIEW 2-1 

 2.1 PERMIT CONDITIONS LIST 2-1 

 2.2 STATE REGULATORY REVIEW 2-27 

 2.3 FEDERAL REGULATORY REVIEW 2-36 

 2.4 NON-APPLICABLE REGULATIONS 2-39 

3.0 APPLICATION FORMS 3-1 

4.0 PROGRAM COMPLIANCE 4-1 

 4.1 PERMIT REQUIRED PERIODIC MONITORING 4-1 

 4.2 COMPLIANCE ASSURANCE MONITORING 4-1 

 4.3 MINERAL WOOL NESHAP APPLICABILITY 4-2 

 4.3.1 Applicability 4-2 

 4.3.2 Standards 4-2 

 4.3.3 Compliance 4-3 
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 4.3.4 Monitoring Requirements 4-3 

 4.4 NOTIFICATION, RECORDKEEPING & REPORTING 4-3 

 4.5 COMPLIANCE CERTIFICATION 4-3 
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LIST OF APPENDICIES 

A Emission Calculations for Significant Activities 

 

B Emission Inventory Summary 

C Emission Calculations for Insignificant Activities 
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CERTIFICATIONS 

Certification of Truth, Accuracy and Completeness 

I certify under penalty of law that, based on information and belief formed 

after reasonable inquiry, the statements and information contained in this 

application are true, accurate and complete. 

Certification of Compliance 

I also certify that the source will continue to comply with applicable 

requirements for which it is compliance, and that the source will, in a 

timely manner, meet all applicable requirements that will become effective 

during the permit term and submit a detailed schedule, if needed, for 

meeting the requirements. 

Name of Official 

Jim Lovell 

Title 

VP - Manufacturing 

Signature 

Date 
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1.0 INTRODUCTION 

IIG Mineral Wools LLC’s (IIG MinWool) Phenix City, AL facility is 

currently operating under a Major Source Operating Permit (also known 

as a Title V permit) issued by Alabama Department of Environmental 

Management (ADEM). This facility is subject to Title V permit 

requirements (established by the 1990 amendments to the Clean Air Act) 

as it is a major source. In the Phenix City area, a major source is defined 

as a source that emits greater than 100 tons per year (tpy) of criteria 

pollutants, or 10 tpy of a single hazardous air pollutant (HAP) or 25 tpy of 

all HAPs combined. IIG MinWool is a major source by these criteria. 

IIG MinWool’s Title V permit expires on September 24, 2008 and must be 

renewed. In accordance with Title V and ADEM Rule 335-3-16-.04, IIG 

MinWool is submitting an application for renewal of the Title V operating 

permit for this facility. A Site Plan for this facility is included as Figure 1-

1. 

1.1 PROJECT DESCRIPTION 

This report contains a Title V Air Permit Application and supplemental 

information for air emission sources at the IIG MinWool facility. The 

Application is made in accordance with ADEM Administrative Code R. 

335-3-16-.04 “Permit Application Requirements” for major sources of air 

pollutants. 

The report section of this Application contains a process description, an 

air emission summary, a regulatory review, compliance plans, and 

compliance certifications. Supplemental information, including all 

figures, tables, and ADEM forms, is included in the text and appendices to 

the report. A brief description of the contents within each section and 

appendix are provided below. 

Section 2 - Regulatory Review 

This section provides a listing of the facility’s current permit 

requirements, Alabama requirements, and Federal requirements. The lists 

are separated according to the subsection titles as 2.1, 2.2, and 2.3, 

respectively. Section 2.4 contains the air regulations that were determined 

to be not applicable to the facility. 
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Section 3 - Application Forms 

This section contains the permit application forms for the facility. One 

copy of each form is included. Those forms that are deemed not 

applicable are noted. 

Appendix A - Emission Calculations for Significant Activities 

This appendix contains the emission calculations for each significant 

activity. 

Appendix B - Emission Inventory Summary 

This appendix provides a spreadsheet of emission points, the emission 

source type, and the source significance. 

Appendix C - Emission Calculations for Insignificant Activities 

This appendix contains the emission calculations for each emission unit 

that was deemed insignificant by emission rate (e.g., < 5 tons/yr.). 

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1.2 PERMIT SHIELD REQUEST 

Permit Application Shield 

This is a formal request for a permit application shield. Section 503(d) of 

the Clean Air Act, as amended in 1990 ("CAAA"), and ADEM Rule 335-3-

16-.04 (6), stipulate that once a timely and complete application for an 

operating permit has been filed, the applicant will be shielded from 

enforcement action for operating without a permit until the permit has 

been issued or other action has been taken on the application. 

In submitting this application, IIG MinWool affirms its understanding that 

once the ADEM determines that a complete and timely application has 

been filed, the IIG MinWool’s Phenix City, AL facility will not be subject 

to any related enforcement actions for operating without a permit during 

the period in which the permit application is under review. 

Permit Shield 

This is a formal request for a permit shield. Both the federal and the 

ADEM Title V permit regulations include provisions for major sources 

covered under the program to request and obtain a permit shield. Section 

504(f) of the CAA defines the permit shield provision, whereby the 

permitting authority is empowered to provide that an applicant's 

compliance with a federal operating permit constitutes compliance with 

all applicable provisions of the Clean Air Act ("CAA") as long as: 

(1) the applicable requirements of these provisions have been identified in 

the permit; or 

(2) the permitting authority determines in the course of acting on the 

permit that other provisions of the act are not applicable. The permit 

must include a list or summary of these provisions.

40 C.F.R. 74.6(f) provides that operating permits may include a statement 

indicating that a source which is in compliance with permit conditions 

shall be considered to be in compliance with any applicable requirements, 

provided that these requirements are included and specifically identified 

in the permit, or that other specific requirements are identified as not 

applicable. The operating permit must explicitly state the existence of the 

permit shield. 
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Similarly, the ADEM permit shield provision found at ADEM Rule 335-3-

16-.10, states as follows: 

 335-3-16-.10 Permit Shield.

(1) Except as provided in this rule, the Department may expressly include 

in an Operating Permit a provision stating that compliance with the 

conditions of the permit shall be deemed compliance with any 

applicable requirements as of the date of permit issuance, provided 

that: 

(a) Such applicable requirements are included and are specifically 

identified in the permit; or 

(b) The Department, in acting on the permit application or revision, 

determines in writing that other requirements specifically 

identified are not applicable to the source, and the permit includes 

the determination or a concise summary thereof. 

(2) An Operating Permit that does not expressly state that a permit shield 

exists shall be presumed not to provide such a shield. 

(3) Nothing in this rule or in any Operating Permit shall alter or affect the 

following: 

(a) The provisions of Section 303 of the Act (emergency orders), 

including the authority of the Administrator under that section; 

(b) The liability of an owner or operator of a source for any violation of 

applicable requirements prior to or at the time of permit issuance; 

(c) The applicable requirements of the acid rain program, consistent 

with Section 408(a) of the Act; or 

(d) The ability of EPA to obtain information from a source pursuant to 

Section 114 of the Act. 

IIG MinWool hereby requests that a permit shield be included in the Title 

V permit issued for their Phenix facility (facility number 211-0013). The 

shield should clearly identify as federally enforceable only those 

requirements identified in this application document as being federally 

enforceable requirements. 

Section 2 includes the regulatory requirements and an assessment of 

whether the requirements are applicable to the 211-0013 facility. In 
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submitting this application, IIG MinWool requests that the Title V 

operating permit for the 211-0013 facility include an explicit statement 

indicating that compliance with the permit shall be deemed to represent 

compliance with all applicable requirements including, but not limited to, 

those requirements specified in Section 2. 

IIG MinWool hereby requests a permit shield for three categories of 

regulatory requirements. First, IIG MinWool requests a permit shield for 

all federally enforceable applicable requirements, which IIG MinWool has 

identified in its Title V permit application and which have been 

specifically incorporated as permit conditions into the Title V permit. 

Second, IIG MinWool requests a permit shield for all non-federallyenforceable requirements that IIG MinWool has identified in its Title V 

permit application and which have been incorporated into the permit 

either as general obligations or as facility-specific, ADEM-only 

requirements. 

Lastly, IIG MinWool requests a permit shield from all regulatory 

requirements listed in the permit application that ultimately are not 

included in the Title V permit because the ADEM has determined that 

they do not apply to the 211-0013 facility. 

1.3 FACILITY DESCRIPTION 

IIG MinWool is a medium size manufacturing facility that produces a 

variety of mineral wool insulation products from raw materials. The 

facility is located in Phenix City, Alabama in an industrial area. 

Operations at the facility began in October 1990 and are currently 

permitted under ADEM Facility Number 211-0013. The facility produces 

mineral (rock) wool insulation products as shown on Figure 1-2. A facility 

location map is provided in Figure 1-3. The first process, molten mineral, 

is where the raw materials are melted in cupola No.1 by heat generated 

during the combustion of coke. The cupola is sized for approximately 8.8 

tons per hour of batch, consisting primarily of basalt, and approximately 

1.25 tons per hour of coke. The emissions from Cupola No. 1 are sent to 

an incinerator/baghouse combination before going to Stack No. 1. 


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The facility has a second incinerator/baghouse control unit that IIG 

MinWool uses as a backup unit. Historically this unit was used to control 

emission from cupola No. 2. Cupola No. 2 is no longer in use. 

In the second process, the molten material is spun into fibers. The fibers 

are collected in the drum collection area after an optional binding agent 

has been sprayed on the fibers. The collected fibers can then be either 

baled and stored for later processing or routed to the mineral (rock) wool 

processing area. Emissions from the spinning/collection drum areas are 

routed to the filterhouse. 

The third process, the mineral (rock) wool process actually consists of two 

production lines: pipe insulation line and board line. These lines are 

operated independently of each other and are operated dependent upon 

the need for a particular final product. The pipe insulation line can be fed 

by either stored feedstock or directly from the cupolas. Both lines could 

be operating at the same time in any given hour and are described in 

greater detail in the following paragraphs. 

In the pipe insulation line, the feedstock is unrolled, sized, and wrapped 

on a pipe mandrel to the desired thickness. The mandrel provides the 

form/shape of the pipe insulation logs (final product). After the feedstock 

is wrapped on the mandrel, heat is applied to set the binding agent, which 

provides the rigidity of the final product. After the binder has set/cured, 

the log is initially cooled on the pipe machine. The log is then removed 

from the pipe machine and sent to a storage area until it is shipped. The 

current production of the pipe insulation line is approximately 1 tons per 

hour (tph). The emission from the pipe insulation line is routed to 

Filterhouse No. 2 and then to Stack No. 2. 

The board line uses the feedstock directly from the fiber formation and 

collection process. After the desired thickness is obtained, the board 

insulation is passed through a curing oven where the binder agent is 

set/cured to provide the rigidity required by the final product (flexible 

mats to rigid boards). The board insulation is then cooled and sized 

before it is sent to storage. The process heater pulls air from the top of the 

oven and supplies heated air for the curing of the binder to the bottom of 

the oven. 

Emissions from the curing oven are controlled by an afterburner located in 

a recirculation loop that pulls fumes from the top of the oven and 

reintroduces the air back into the oven at the inlet vestibule. Exhaust from 

the oven is pulled from the discharge vestibule and vented to Filterhouse 

No. 3. 
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1.4 PERMIT CHANGES SINCE INITIAL TITLE V PERMIT ISSSUANCE 

There have been two permit amendments since initial Title V Permit 

Issuance on September 25, 2003: 

March 2004 – Permit Reopened by ADEM to Add Mineral Wool MACT 

Requirements 

March 25, 2005 – Permit Amended to Allow Slag as Raw Material 
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2.0 REGULATORY REVIEW

Section 2.0 provides a listing of the facility’s permit requirements and the 

Alabama and Federal Air Regulations. The lists are separated according 

to the subsection titles. Permit conditions and regulations, both applicable 

and non applicable to IIG MinWool, are included. 

2.1 PERMIT CONDITIONS LIST 

All permit conditions contained in the current Title V permit are listed in 

this section. 
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

1. Transfer

This permit is not transferable, whether by operation of law 

or otherwise, either from one location to another, from one 

piece of equipment to another, or from one person to another, 

except as provided in Rule 335-3-16-.13(1)(a)5. 

Rule 335-3-16-.02(6) 

2. Renewals

An application for permit renewal shall be submitted at least 

six (6) months, but not more than eighteen (18) months, 

before the date of expiration of this permit. 

The source for which this permit is issued shall lose its right 

to operate upon the expiration of this permit unless a timely 

and complete renewal application has been submitted within 

the time constraints listed in the previous paragraph. 

Rule 335-3-16-.12(2) 

3. Severability Clause

The provisions of this permit are declared to be severable and 

if any section, paragraph, subparagraph, subdivision, clause, 

or phrase of this permit shall be adjudged to be invalid or 

unconstitutional by any court of competent jurisdiction, the 

judgment shall not affect, impair, or invalidate the remainder 

of this permit, but shall be confined in its operation to the 

section, paragraph, subparagraph, subdivision, clause, or 

phrase of this permit that shall be directly involved in the 

controversy in which such judgment shall have been 

rendered. 

Rule 335-3-16-.05(e) 

4. Compliance

(a) The permittee shall comply with all conditions of 

ADEM Admin. Code 335-3. Noncompliance with this 

permit will constitute a violation of the Clean Air Act 

of 1990 and ADEM Admin. Code 335-3 and may result 

in an enforcement action; including but not limited to, 

permit termination, revocation and reissuance, or 

modification; or denial of a permit renewal application 

by the permittee. 

Rule 335-3-16-.05(f) 

(b) The permittee shall not use as a defense in an 

enforcement action that maintaining compliance with

conditions of this permit would have required halting 

or reducing the permitted activity. 

Rule 335-3-16-.05(g) 
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

5. Termination for Cause

This permit may be modified, revoked, reopened, and

reissued, or terminated for cause. The filing of a request by 

the permittee for a permit modification, revocation and 

reissuance, or termination, or of a notification of planned 

changes or anticipated noncompliance will not stay any 

permit condition. 

Rule 335-3-16-.05(h) 

6. Property Rights

The issuance of this permit does not convey any property 

rights of any sort, or any exclusive privilege. 

Rule 335-3-16-.05(i) 

7. Submission of Information

The permittee must submit to the Department, within 30 

days or for such other reasonable time as the Department 

may set, any information that the Department may request in 

writing to determine whether cause exists for modifying, 

revoking and reissuing, or terminating this permit or to 

determine compliance with this permit. Upon receiving a 

specific request, the permittee shall also furnish to the 

Department copies of records required to be kept by this 

permit. 

Rule 335-3-16-.05(j) 

8. Economic Incentives, Marketable Permits, and Emissions 

Trading

No permit revision shall be required, under any approved 

economic incentives, marketable permits, emissions trading 

and other similar programs or processes for changes that are 

provided for in this permit. 

Rule 335-3-16-.05(k) 

9. Certification of Truth, Accuracy, and Completeness: 

Any application form, report, test data, monitoring data, or 

compliance certification submitted pursuant to this permit 

shall contain certification by a responsible official of truth, 

accuracy, and completeness. This certification shall state 

that, based on information and belief formed after reasonable 

inquiry, the statements and information in the document are 

true, accurate and complete. 

Rule 335-3-16-.07(a) 

10. Inspection and Entry

Upon presentation of credentials and other documents as 

may be required by law, the permittee shall allow authorized 

representatives of the Alabama Department of 

Environmental Management and EPA to conduct the 

following: 

Rule 335-3-16-.07(b) 
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

(a) Enter upon the permittee’s premises where a source is 

located or emissions-related activity is conducted, or 

where records must be kept pursuant to the conditions 

of this permit; 

(b) Review and/or copy, at reasonable times, any records 

that must be kept pursuant to the conditions of this 

permit; 

(c) Inspect, at reasonable times, this facility’s equipment 

(including monitoring equipment and air pollution 

control equipment), practices, or operations regulated 

or required pursuant to this permit; 

(d) Sample or monitor, at reasonable times, substances or 

parameters for the purpose of assuring compliance 

with this permit or other applicable requirements. 

11. Compliance Provisions

(a) The permittee shall continue to comply with the

applicable requirements with which the company has 

certified that it is already in compliance. 

Rule 335-3-16-.07(c) 

(b) The permittee shall comply in a timely manner with 

applicable requirements that become effective during 

the term of this permit. 

12. Compliance Certification

A compliance certification shall be submitted annually within 

60 days of the anniversary date of issuance of this permit. 

Rule 335-3-16-.07(e) 

(a) The compliance certification shall include the 

following: 

(1) The identification of each term or condition of

this permit that is the basis of the certification;

(2) The compliance status; 

(3) The method(s) used for determining the 

compliance status of the source, currently and 

over the reporting period consistent with Rule 

335-3-16-.05(c) (Monitoring and Recordkeeping 

Requirements); 

(4) Whether compliance has been continuous or 

intermittent; 

(5) Such other facts as the Department may require 

to determine the compliance status of the 

source; 

(b) The compliance certification shall be submitted to: 
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

Alabama Department of Environmental Management 

Air Division 

P.O. Box 301463 

Montgomery, AL 36130-1463 

and to: 

Air and EPCRA Enforcement Branch 

EPA Region IV 

61 Forsyth Street, SW

Atlanta, GA 30303 

13. Reopening for Cause

Under any of the following circumstances, this permit will be 

reopened prior to the expiration of the permit: 

Rule 335-3-16-.13(5) 

(a) Additional applicable requirements under the Clean 

Air Act of 1990 become applicable to the permittee 

with a remaining permit term of three (3) or more 

years. Such a reopening shall be completed not later 

than eighteen (18) months after promulgation of the

applicable requirement. No such reopening is 

required if the effective date of the requirement is later 

than the date on which this permit is due to expire. 

(b) Additional requirements (including excess emissions 

requirements) become applicable to an affected source 

under the acid rain program. Upon approval by the 

Administrator, excess emissions offset plans shall be 

deemed to be incorporated into this permit. 

(c) The Department or EPA determines that this permit 

contains a material mistake or that inaccurate 

statements were made in establishing the emissions 

standards or other terms or conditions of this permit. 

(d) The Administrator or the Department determines that 

this permit must be revised or revoked to assure 

compliance with the applicable requirements. 

14. Additional Rules and Regulations

This permit is issued on the basis of Rules and Regulations 

existing on the date of issuance. In the event additional Rules 

and Regulations are adopted, it shall be the permit holder’s 

responsibility to comply with such rules. 

§22-28-16(d), Code of 

Alabama 1975, as 

amended 
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

15. Equipment Maintenance or Breakdown

(a) In the case of shutdown of air pollution control 

equipment (which operates pursuant to any permit 

issued by the Director) for necessary scheduled 

maintenance, the intent to shut down such equipment

shall be reported to the Director at least twenty-four 

(24) hours prior to the planned shutdown, unless such 

shutdown is accompanied by the shutdown of the 

source which such equipment is intended to control. 

Such prior notice shall include, but is not limited to the 

following: 

Rule 335-3-1-.07(1), (2) 

(1) Identification of the specific facility to be taken 

out of service as well as its location and permit 

number; 

(2) The expected length of time that the air 

pollution control equipment will be out of 

service; 

(3) The nature and quantity of emissions of air 

contaminants likely to occur during the 

shutdown period; 

(4) Measures such as the use of off-shift labor and

equipment that will be taken to minimize the 

length of the shutdown period; 

(5) The reasons that it would be impossible or 

impractical to shut down the source operation 

during the maintenance period. 
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

(b) In the event that there is a breakdown of equipment or 

upset of process in such a manner as to cause, or is 

expected to cause, increased emissions of air 

contaminants which are above an applicable standard, 

the person responsible for such equipment shall notify 

the Director within 24 hours or the next working day 

and provide a statement giving all pertinent facts,

including the estimated duration of the breakdown. 

The Director shall be notified when the breakdown has 

been corrected. 

16. Operation of Capture and Control Devices

All air pollution control devices and capture systems for 

which this permit is issued shall be maintained and operated 

at all times in a manner so as to minimize the emissions of air 

contaminants. Procedures for ensuring that the above 

equipment is properly operated and maintained so as to 

minimize the emission of air contaminants shall be 

established. 

§22-28-16(d), Code of 

Alabama 1975, as 

amended 

17. Obnoxious Odors

This permit is issued with the condition that, should 

obnoxious odors arising from the plant operations be verified 

by Air Division inspectors, measures to abate the odorous 

emissions shall be taken upon a determination by the 

Alabama Department of Environmental Management that

these measures are technically and economically feasible. 

Rule 335-3-1-.08 

18. Fugitive Dust

(a) Precautions shall be taken to prevent fugitive dust 

emanating from plant roads, grounds, stockpiles, 

screens, dryers, hoppers, ductwork, etc. 

Rule 335-3-4-.02 

(b) Plant or haul roads and grounds will be maintained in 

the following manner so that dust will not become 

airborne. A minimum of one, or a combination, of the 

following methods shall be utilized to minimize 

airborne dust from plant or haul roads and grounds:

(1) By the application of water any time the surface 

of the road is sufficiently dry to allow the 

creation of dust emissions by the act of wind or 

vehicular traffic; 
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

(2) By reducing the speed of vehicular traffic to a

point below that at which dust emissions are 

created; 

(3) By paving; 

(4) By the application of binders to the road surface 

at any time the road surface is found to allow 

the creation of dust emissions; 

Should one, or a combination, of the above methods fail to 

adequately reduce airborne dust from plant or haul roads 

and grounds, alternative methods shall be employed, either 

exclusively or in combination with one or all of the above 

control techniques, so that dust will not become airborne. 

Alternative methods shall be approved by the Department 

prior to utilization. 

19. Additions and Revisions

Any modifications to this source shall comply with the 

modification procedures in Rules 335-3-16-.13 or 335-3-16-.14.

Rule 335-3-16-.13 and 

.14 

20. Recordkeeping Requirements

(a) Records of required monitoring information of the 

source shall include the following: 

Rule 335-3-16-.05(c)2. 

(1) The date, place, and time of all sampling or 

measurements; 

(2) The date analyses were performed; 

(3) The company or entity that performed the 

analyses; 

(4) The analytical techniques or methods used; 

(5) The results of all analyses; and 

(6) The operating conditions that existed at the 

time of sampling or measurement. 

(b) Retention of records of all required monitoring data 

and support information of the source for a period of 

at least 5 years from the date of the monitoring 

sample, measurement, report, or application. Support 

information includes all calibration and maintenance 

records and all original strip-chart recordings for

continuous monitoring instrumentation and copies of

all reports required by the permit. 
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

21. Reporting Requirements

(a) Reports to the Department of any required monitoring 

shall be submitted at least every 6 months. All 

instances of deviations from permit requirements 

must be clearly identified in said reports. All required 

reports must be certified by a responsible official

consistent with Rule 335-3-16-.04(9). 

Rule 335-3-16-.05(c)3. 

(b) Deviations from permit requirements shall be reported 

within 48 hours or 2 working day of such deviations, 

including those attributable to upset conditions as

defined in the permit. The report will include the 

probable cause of said deviations, and any corrective 

actions or preventive measures that were taken. 

22. Emission Testing Requirements

Each point of emission which requires testing will be 

provided with sampling ports, ladders, platforms, and other 

safety equipment to facilitate testing performed in

accordance with procedures established by Part 60 of Title 40 

of the Code of Federal Regulations, as the same may be 

amended or revised. 

Rule 335-3-1-.05(3) and 

Rule 335-3-1-.04(1) 

The Air Division must be notified in writing at least 10 days 

in advance of all emission tests to be conducted and 

submitted as proof of compliance with the Department’s air 

pollution control rules and regulations. 

To avoid problems concerning testing methods and 

procedures, the following shall be included with the 

notification letter: 

(1) The date the test crew is expected to arrive, the date 

and time anticipated of the start of the first run, how 

many and which sources are to be tested, and the 

names of the persons and/or testing company that 

will conduct the tests. 

Rule 335-3-1-.04 

(2) A complete description of each sampling train to be 

used, including type of media used in determining gas 

stream components, type of probe lining, type of filter 

media, and probe cleaning method and solvent to be 

used (if test procedures require probe cleaning). 

(3) A description of the process(es) to be tested including 

the feed rate, any operating parameters used to control 

or influence the operations, and the rated capacity. 
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

(4) A sketch or sketches showing sampling point locations 

and their relative positions to the nearest upstream 

and downstream gas flow disturbances. 

A pretest meeting may be held at the request of the source 

owner or the Air Division. The necessity for such a meeting 

and the required attendees will be determined on a case-bycase basis. 

All test reports must be submitted to the Air Division within 

30 days of the actual completion of the test unless an 

extension of time is specifically approved by the Air 

Division. 

Rule 335-3-1-.04 

23. Payment of Emission Fees

Annual emission fees shall be remitted each year according 

to the fee schedule in ADEM Admin. Code R. 335-1-7-.04. 

Rule 335-1-7-.04 

24. Other Reporting and Testing Requirements

Submission of other reports regarding monitoring records, 

fuel analyses, operating rates, and equipment malfunctions 

may be required as authorized in the Department's air 

pollution control rules and regulations. The Department 

may require emission testing at any time. 

Rule 335-3-1-.04(1) 

25. Title VI Requirements (Refrigerants) 

Any facility having appliances or refrigeration equipment, 

including air conditioning equipment, which use Class I or 

Class II ozone-depleting substances as listed in 40 CFR Part 

82, Subpart A, Appendices A and B, shall service, repair, and 

maintain such equipment according to the work practices, 

personnel certification requirements, and certified recycling 

and recovery equipment specified in 40 CFR Part 82, Subpart 

F. 

No person shall knowingly vent or otherwise release any 

Class I or Class II substance into the environment during the 

repair, servicing, maintenance, or disposal of any device 

except as provided in 40 CFR Part 82, Subpart F. 

The responsible official shall comply with all reporting and 

recordkeeping requirements of 40 CFR 82.166. Reports shall 

be submitted to the US EPA and the Department as required. 

335-3-16-.05(a) 

26. Chemical Accidental Prevention Provisions
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

If a chemical listed in Table 1 of 40 CFR Part 68.130 is present 

in a process in quantities greater than the threshold quantity 

listed in Table 1, then: 

(a) The owner or operator shall comply with the 

provisions in 40 CFR Part 68. 

(b) The owner or operator shall submit one of the 

following: 

(1) A compliance schedule for meeting the 

requirements of 40 CFR Part 68 by the date 

provided in 40 CFR Part 68 § 68.10(a) or, 

(2) A certification statement that the source is in

compliance with all requirements of 40 CFR 

Part 68, including the registration and 

submission of the Risk Management Plan. 

40 CFR Part 68 

27. Display of Permit

This permit shall be kept under file or on display at all times 

at the site where the facility for which the permit is issued is 

located and will be made readily available for inspection by 

any or all persons who may request to see it. 

Rule 335-3-14-.01(1)(d) 

28. Circumvention

No person shall cause or permit the installation or use of any 

device or any means which, without resulting in reduction 

in the total amount of air contaminant emitted, conceals or 

dilutes any emission of air contaminant which would

otherwise violate the Division 3 rules and regulations. 

Rule 335-3-1-.10 

29. Visible Emissions

Unless otherwise specified in the Unit Specific provisos of 

this permit, any source of particulate emissions shall not 

discharge more than one 6-minute average opacity greater 

than 20% in any 60-minute period. At no time shall any 

source discharge a 6-minute average opacity of particulate 

emissions greater than 40%. Opacity will be determined by 

40 CFR Part 60, Appendix A, Method 9, unless otherwise 

specified in the Unit Specific provisos of this permit. 

Rule 335-3-4-.01(1) 
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General Permit Provisos 

Federally Enforceable Provisos Regulations 

30. Fuel-Burning Equipment

(a) Unless otherwise specified in the Unit Specific

provisos of this permit, no fuel-burning equipment 

may discharge particulate emissions in excess of the 

emissions specified in Part 335-3-4-.03. 

(b) Unless otherwise specified in the Unit Specific

provisos of this permit, no fuel-burning equipment 

may discharge sulfur dioxide emissions in excess of

the emissions specified in Part 335-3-5-.01. 

Rule 335-3-4-.03 

Rule 335-3-5-.01 

31. Process Industries – General

Unless otherwise specified in the Unit Specific provisos of 

this permit, no process may discharge particulate emissions 

in excess of the emissions specified in Part 335-3-4-.04. 

Rule 335-3-4-.04 

32. Averaging Time for Emission Limits

Unless otherwise specified in the permit, the averaging time 

for the emission limits listed in this permit shall be the 

nominal time required by the specific test method. 

Rule 335-3-1-.05 
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Summary Page for #1 Cupola 

Permitted Operating Schedule: 24 Hrs/day x 7 Days/week x 52 Weeks/yr = 8760 Hrs/yr 

Emission limitations: 

Emission Point # Description Pollutant Emission limit Regulation 

Stack #1 Cupola & Filterhouse #1 PM 117 lb/hr BACT 

Stack #1 Cupola & Filterhouse #1 CO 17.0 lb/hr Anti-PSD 

Stack #1 Cupola & Filterhouse #1 NOx 15.0 lb/hr BACT 

Stack #1 Cupola & Filterhouse #1 H2S 1.0 lb/hr BACT

Stack #2 Filterhouses #2 & #3 PM 117 lb/hr BACT 
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Provisos for Mineral Wool Cupola #1 

Federally Enforceable Provisos Regulations 

Applicability

1. This mineral wool cupola is subject to the PSD regulations. Rule 335-3-14-.04 

2. This mineral wool production unit is subject to the MACT for 

Mineral Wool Production, Subpart DDD in 40 CFR Part 63. 

Rule 335-3-11-.06(55) 

40 CFR Part 63, Subpart 

DDD 

3. This mineral wool production unit is subject to the General 

Provisions in 40 CFR Part 63, Subpart A, as listed in Table 1 in 

Subpart DDD in 40 CFR Part 63. 

Rule 335-3-11-.06(55) 

40 CFR Part 63, Subpart 

DDD 

Emission Standards

1. The cupola shall be vented to a baghouse and an incinerator in 

series. 

Rule 335-3-14-.04(9) 

2. The baghouse and incinerator shall not be bypassed during 

startup or for more than 4 hours during shutdown periods. 

Rule 335-3-14-.04(9) 

3. The temperature in the firebox of the thermal oxidizer on the 

cupola shall not be less than 1320°F while the cupola is 

operating. 

Rule 335-3-14-.04(9) 

4. The temperature in the firebox of the afterburner on the curing 

oven shall not be less than 1200°F while the curing oven is 

operating. 

Rule 335-3-14-.04(9) 

5. Sulfur dioxide emissions from the #1 cupola shall not exceed 

88.5 pounds per hour. 

Rule 335-3-14-.04(9) 

6. Carbon monoxide emissions from the #1 cupola shall not exceed 

17.0 pounds per hour. 

Rule 335-3-14-.04(9) 

7. Nitrogen oxides emissions from the #1 cupola shall not exceed 

15.0 pounds per hour. 

Rule 335-3-14-.04(9) 

8. Hydrogen sulfide emissions from the #1 cupola shall not exceed 

1.0 pounds per hour. 

Rule 335-3-14-.04(9) 

9. The combined particulate emissions from both stacks shall not 

exceed 117.0 pounds per hour. 

Rule 335-3-14-.04(9) 

10. Only coke derived from coal shall be used as fuel. Such coke 

shall not contain sulfur which exceeds 0.7% by weight. 

Rule 335-3-14-.04(9) 

11. (none) 
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Federally Enforceable Provisos Regulations 

MACT Provisions

12. Particulate matter (PM) from the existing cupola shall not exceed 

0.05 kilograms (kg) of PM per megagram (MG) (0.10 pound [lb] 

of PM per ton) of melt. 

Rule 335-3-11-.06(55) 

40 CFR Part 

63.1178(a)(1) 

13. The following operating limits for each cupola must be met: 

(a) Begin within one hour after the alarm on a bag leak detection 

system sounds, and complete in a timely manner, corrective 

actions as specified in your operations, maintenance, and 

monitoring plan required by Sec. 63.1187 of this subpart. 

(b When the alarm on a bag leak detection system sounds for 

more than five percent of the total operating time in a sixmonth reporting period, develop and implement a written 

quality improvement plan (QIP) consistent with the 

compliance assurance monitoring requirements of Sec. 

64.8(b)-(d) of 40 CFR part 64. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1178(b) 

14. Formaldehyde emissions from the curing oven be limited to 

either of the following: 

a. 0.03 kg of formaldehyde per MG (0.06 lb of formaldehyde 

per ton) of melt or less. 

b. A reduction of uncontrolled formaldehyde emissions by at 

least 80 percent. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1179(a) 

15. The curing oven shall be operated so that the following criteria 

are met: 

a. Maintain the free-formaldehyde content of each resin lot and 

the formaldehyde content of each binder formulation at or 

below the specification ranges of the resin and binder used 

during the performance test. 

b. Maintain the operating temperature of each incinerator so 

that the average operating temperature for each three-hour 

block period never falls below the average temperature 

established during the performance test. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1179(b) 

16. These standards must be met at all times except during periods 

of startup, shutdown, or malfunction. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1180(d) 

Compliance and Performance Test Methods and Procedures

1. If testing is required, the NOx emissions shall be determined by 

Methods 7, 7a, 7b or 7e in 40 CFR Part 60, Appendix A. 

Rule 335-3-1-.05 

2. The CO emissions shall as determined by Methods 10 or 10b in 

40 CFR Part 60, Appendix A. 

Rule 335-3-1-.05 

3. Particulate emissions shall be determined by Method 5e in 40 

CFR Part 60, Appendix A. 

Rule 335-3-1-.05 
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Federally Enforceable Provisos Regulations 

4. If testing is required, the hydrogen sulfide emissions shall be 

determined by Method 11 in 40 CFR Part 60, Appendix A. 

Rule 335-3-1-.05 

5. Sulfur dioxide emissions shall be determined by Methods 6 or 

6c in 40 CFR, Part Appendix A 

Rule 335-3-1-.05 

MACT Provisions

6. The performance tests conducted to demonstrate compliance 

with the emissions limits in 63. 1178 shall conform to the test 

methods and procedures in §63.1189. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1188-

63.1189 

7. To comply with the PM standards for the cupola, the following 

must be met: 

(a) Install, adjust, maintain, and continuously operate a bag leak 

detection system for each fabric filter. 

(b) Do a performance test as specified in Sec. 63.1188 of this 

subpart and show compliance with the PM emission limits 

while the bag leak detection system is installed, operational, 

and properly adjusted. 

(c) Begin corrective actions specified in your operations, 

maintenance, and monitoring plan required by Sec. 63.1187 of 

this subpart within one hour after the alarm on a bag leak 

detection system sounds. Complete the corrective actions in a 

timely manner. 

(d) Develop and implement a written QIP consistent with 

compliance assurance monitoring requirements of 40 CFR 

64.8(b) through (d) when the alarm on a bag leak detection 

system sounds for more than five percent of the total 

operating time in a six-month reporting period. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1181 

8. To comply with the formaldehyde standards, the following must 

met: 

(a) Install, calibrate, maintain, and operate a device that 

continuously measures the operating temperature in the 

firebox of each thermal incinerator. 

(b) Do a performance test as specified in Sec. 63.1188 of this 

subpart while manufacturing the product that requires a 

binder formulation made with the resin containing the 

highest free- formaldehyde content specification range. Show 

compliance with the formaldehyde emission limits while the 

device for measuring incinerator operating temperature is 

installed, operational, and properly calibrated. Establish the 

average operating temperature as specified in Sec. 63.1185(a) 

of this subpart. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1183 
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Federally Enforceable Provisos Regulations 

(c) During the performance test that uses the binder formulation 

made with the resin containing the highest freeformaldehyde content specification range, record the freeformaldehyde content specification range of the resin used, 

and the formulation of the binder used, including the 

formaldehyde content and binder specification. 

(d) Following the performance test, monitor and record the freeformaldehyde content of each resin lot and the formulation of 

each batch of binder used, including the formaldehyde 

content. 

(e) Maintain the free-formaldehyde content of each resin lot and 

the formaldehyde content of each binder formulation at or 

below the specification ranges established during the 

performance test. 

(f) Following the performance test, measure and record the 

average operating temperature of the incinerator as specified 

in Sec. 63.1185(b) of this subpart. 

(g) Maintain the operating temperature of the incinerator so that 

the average operating temperature for each three-hour block 

period never falls below the average temperature established 

during the performance test. 

(h) Operate and maintain the incinerator as specified in your 

operations, maintenance, and monitoring plan required by 

Sec. 63.1187 of this subpart. 

(i) With prior approval from the Administrator, you may do 

short- term experimental production runs using resin where 

the free- formaldehyde content, or binder formulations where 

the formaldehyde content, is higher than the specification 

ranges of the resin and binder used during previous

performance tests, or using experimental pollution 

prevention process modifications without first doing 

additional performance tests. Notification of intent to 

perform a short-term experimental production run must 

include the following information: 
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(1) The purpose of the experimental run. 

(2) The affected production process. 

(3) How the resin free-formaldehyde content or binder 

formulation will deviate from previously approved 

levels or what the experimental pollution prevention 

process modifications are. 

(4) The duration of the experimental run. 

(5) The date and time of the experimental run. 

(6) A description of any emissions testing to be done during 

the experimental run. 

9. Compliance with the MACT limits shall use the following 

equations: 

(a) Using the results of the performance tests, you must use the 

following equation to determine compliance with the PM 

emission limit: 

E = [C x O x K1]/P 

where: 

E = Emission rate of PM, kg/Mg (lb/ton) of melt. 

C = Concentration of PM, g/dscm (gr/dscf). 

Q = Volumetric flow rate of exhaust gases, dscm/hr

(dscf/hr). 

K1 =Conversion factor, 1 kg/1,000 g (1 lb/7,000 gr). 

P = Average melt rate, Mg/hr (ton/hr). 

(b) Using the results of the performance tests, you must use the 

following equation to determine compliance with the CO and 

formaldehyde numerical emission limits: 

E = [C x MW x O x K1 x K2]/[K3 x P x 106] 

where: 

E = Emission rate of measured pollutant, kg/Mg 

(lb/ton) of melt. 

C = Measured volume fraction of pollutant, ppm. 

MW =Molecular weight of measured pollutant, g/g-mole: 

CO =.01, Formaldehyde = 30.03. 

Q = Volumetric flow rate of exhaust gases, dscm/hr

(dscf/hr). 

K1 = Conversion factor, 1 kg/1,000 g (1 lb/453.6 g). 

K2 =onversion factor, 1,000 L/m<SUP>3</SUP> (28.3

L/ ft3). 

K3 =onversion factor, 24.45 L/g-mole. 

P = Average melt rate, Mg/hr (ton/hr). 

(c) Using the results of the performance tests, you must use the 

following equation to determine compliance with the CO and 

Rule 335-3-11-.06(55) 

40 CFR Part 63.11790 
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Federally Enforceable Provisos Regulations 

formaldehyde percent reduction performance standards: 

%R =[(L – Lo)/Li] x 100 

where: 

%R = Percent reduction, or collection efficiency of the 

control device. 

Li = Inlet loading of pollutant, kg/Mg (lb/ton). 

Lo = Outlet loading of pollutant, kg/Mg (lb/ton). 

Emission Monitoring

1. A monitoring device that continuously measures and records the 

firebox temperature of the afterburner on the curing oven shall 

be installed, calibrated, maintained, and operated.

Rule 335-3-14-.04(9) 

2. A monitoring device that continuously measures and records the 

firebox temperature of the incinerator on the cupola shall be 

installed, calibrated, maintained, and operated. 

Rule 335-3-1-.04 

4. Instruments which measure the pressure drop across the 

filterhouses shall be maintained and operated. 

Rule 335-3-1-.04 

5. During the annual compliance tests, minimum pressure drops 

shall be determined for filterhouses. 

Rule 335-3-1-.04 

6. Each day, the pressure drop across each filterhouse shall be 

recorded, except when the source of pollution to the filterhouse 

is not being operated. 

Rule 335-3-1-.04 

7. Emissions tests are to be conducted for the following pollutants 

at intervals not to exceed one year following the date of initial 

compliance testing. All test reports must be submitted to the 

Department within 15 days of completion of testing.

Particulate  Carbon Monoxide 

Sulfur Dioxide 

Rule 335-3-1-.04 

MACT Provisions

8. A bag leak detection system must meet the following 

requirements: 

(a) The bag leak detection system must be certified by the 

manufacturer to be capable of detecting PM emissions at 

concentrations of 10 milligrams per actual cubic meter (0.0044 

grains per actual cubic foot) or less. 

(b) The sensor on the bag leak detection system must provide 

output of relative PM emissions. 

(c) The bag leak detection system must have an alarm that will 

sound automatically when it detects an increase in relative 

PM emissions greater than a preset level. 

(d) The alarm must be located in an area where appropriate 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1184 
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Federally Enforceable Provisos Regulations 

plant personnel will be able to hear it. 

(e) For a positive-pressure fabric filter, each compartment or cell 

must have a bag leak detector. For a negative-pressure or 

induced-air fabric filter, the bag leak detector must be 

installed downstream of the fabric filter. If multiple bag leak 

detectors are required (for either type of fabric filter), 

detectors may share the system instrumentation and alarm. 

(f) Each triboelectric bag leak detection system must be installed, 

operated, adjusted, and maintained so that it follows EPA's 

``Fabric Filter Bag Leak Detection Guidance'' (EPA-454/R-98-

015, September 1997). Other bag leak detection systems must 

be installed, operated, adjusted, and maintained so that they 

follow the manufacturer's written specifications and 

recommendations. 

(g) At a minimum, initial adjustment of the system must consist 

of establishing the baseline output in both of the following 

ways: 

(1) Adjust the range and the averaging period of the device. 

(2) Establish the alarm set points and the alarm delay time. 

(h) After initial adjustment, the range, averaging period, alarm 

set points, or alarm delay time may not be adjusted except as 

specified in the operations, maintenance, and monitoring 

plan required by Sec. 63.1187 of this subpart. In no event may 

the range be increased by more than 100 percent or decreased 

by more than 50 percent over a 365 day period unless a 

responsible official as defined in Sec. 63.2 of the general 

provisions in subpart A of this part certifies in writing to the 

Administrator that the fabric filter has been inspected and 

found to be in good operating condition. 
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Federally Enforceable Provisos Regulations 

9. The following procedures must be done to establish the average 

operating temperature of the curing oven incinerator: 

(a) During the performance test, you must establish the average 

operating temperature of an incinerator as follows:

(1) Continuously measure the operating temperature of the 

incinerator. 

(2) Determine and record the average temperatures in 

consecutive 15-minute blocks. 

(3) Determine and record the arithmetic average of the 

recorded average temperatures measured in consecutive 

15-minute blocks for each of the one-hour performance 

test runs. 

(4) Determine and record the arithmetic average of the three 

one- hour average temperatures during the performance 

test runs. The average of the three one-hour performance 

test runs establishes the temperature level to use to 

monitor compliance. 

(b) To comply with the requirements for maintaining the 

operating temperature of an incinerator after the 

performance test, you must measure and record the average 

operating temperature of the incinerator as required by Secs. 

63.1182 and 63.1183 of this subpart. This average operating 

temperature of the incinerator is based on the arithmetic 

average of the one-hour average temperatures for each 

consecutive three-hour period and is determined in the same 

manner described in paragraphs (a)(1) through (a)(4) of this 

section. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1185 

11. Control device and process operating parameter levels 

established during performance tests and used to monitor 

compliance may be changed if the following procedures are met: 

(a) You must notify the Administrator of your desire to expand 

the range of a control device or process operating parameter 

level. 

(b) Upon approval from the Administrator, you must conduct 

additional performance tests at the proposed new control 

device or process operating parameter levels. Before 

operating at these levels, the performance test results must 

verify that, at the new levels, you comply with the emission 

limits in Secs. 63.1178 and 63.1179 of this subpart. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1186 

12. The operations, maintenance, and monitoring plan must include 

the following: 

(a) Process and control device parameters you will monitor to 

determine compliance, along with established operating 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1187 
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Federally Enforceable Provisos Regulations 

levels or ranges for each process or control device. 

(b) A monitoring schedule. 

(c) Procedures for properly operating and maintaining control 

devices used to meet the standards in Secs. 63.1178 and 

63.1179 of this subpart. These procedures must include an 

inspection of each incinerator at least once per year. At a 

minimum, you must do the following as part of an 

incinerator inspection: 

(1) Inspect all burners, pilot assemblies, and pilot sensing 

devices for proper operation. Clean pilot sensor if

necessary. 

(2) Ensure proper adjustment of combustion air, and adjust if 

necessary. 

(3) Inspect, when possible, all internal structures (such as 

baffles) to ensure structural integrity per the design 

specifications. 

(4) Inspect dampers, fans, and blowers for proper operation. 

(5) Inspect motors for proper operation. 

(6) Inspect, when possible, combustion chamber refractory 

lining. Clean, and repair or replace lining if necessary. 

(7) Inspect incinerator shell for proper sealing, corrosion, 

and/ or hot spots. 

(8) For the burn cycle that follows the inspection, document 

that the incinerator is operating properly and make any 

necessary adjustments. 

(9) Generally observe whether the equipment is maintained 

in good operating condition. 

(10 )Complete all necessary repairs as soon as practicable. 

(d) Procedures for keeping records to document compliance. 

(e) Corrective actions you will take if process or control device 

parameters vary from the levels established during 

performance testing. For bag leak detection system alarms, 

example corrective actions that may be included in the 

operations, maintenance, and monitoring plan include: 

(1) Inspecting the fabric filter for air leaks, torn or broken 

bags or filter media, or any other condition that may cause 

an increase in emissions. 

(2) Sealing off defective bags or filter media. 

(3) Replacing defective bags or filter media, or otherwise 

repairing the control device. 

(4) Sealing off a defective fabric filter compartment. 

(5) Cleaning the bag leak detection system probe, or 

otherwise repairing the bag leak detection system. 
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Federally Enforceable Provisos Regulations 

(6) Shutting down the process producing the particulate 

emissions. 

Recordkeeping and Reporting Requirements

1. This source shall comply with the notification, recordkeeping 

and reporting requirements in §63.1191 through §63.1193. 

Rule 335-3-11-.06(55) 

2. Records shall be maintained of the sulfur content of the basalt 

used in the cupola. 

Rule 335-3-1-.04 

3. A report shall be submitted semi-annually which contains the 

following: 

Rule 335-3-16-.05(c) 

a. The periods when firebox temperate in the incinerator on the 

cupola was below 1320°F and the corrective action taken. 

b. The periods when the temperature of the afterburner on the 

curing oven was below 1200 °F and the corrective action take. 

c. The periods when the pressure drops across the filterhouses 

were below the minimum pressure determined during the 

4. All record shall be maintained for a minimum of 5 years. Rule 335-3-16-.05(c)2.(ii)

MACT Provisions

5. The following notifications are required: 

(a) Notification of intention to construct a new major source or 

reconstruct a major source where the initial startup of the 

new or reconstructed source occurs after the effective date of 

the standard and an application for approval of construction 

or reconstruction under Sec. 63.5(d) of the general provisions 

in subpart A of this part is required. 

(b) Notification of special compliance obligations for a new 

source that is subject to special compliance requirements in 

Sec. 63.6(b)(3) and (4) of the general provisions in subpart A 

of this part. 

(c) Notification of a performance test at least 60 calendar days 

before the performance test is scheduled to begin. 

(e) Notification of compliance status. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1191 
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6. The following recordkeeping provisions must be met: 

(a) Maintain files of all information required by Sec. 63.10(b) of 

the general provisions in subpart A of this part, including all 

notifications and reports. 

(b) Maintain records of the following information also: 

(1) Cupola production (melt) rate (Mg/hr (tons/hr) of melt). 

(2) All bag leak detection system alarms. Include the date and 

time of the alarm, when corrective actions were initiated, 

the cause of the alarm, an explanation of the corrective 

actions taken, and when the cause of the alarm was 

corrected. 

(3) The free-formaldehyde content of each resin lot and the 

binder formulation, including formaldehyde content, of 

each binder batch used in the manufacture of bonded

products. 

(4) Incinerator operating temperature and results of 

incinerator inspections. For all periods when the average 

temperature in any three- hour block period fell below the 

average temperature established during the performance 

test, and all periods when the inspection identified 

incinerator components in need of repair or maintenance, 

include the date and time of the problem, when corrective 

actions were initiated, the cause of the problem, an 

explanation of the corrective actions taken, and when the 

cause of the problem was corrected. 

(c) Retain each record for at least five years following the date of 

each occurrence, measurement, corrective action, 

maintenance, record, or report. The most recent two years of 

records must be retained at the facility. The remaining three 

years of records may be retained off site. 

(d) Retain records on microfilm, on a computer, on computer 

disks, on magnetic tape disks, or on microfiche. 

(e) Report the required information on paper or on a labeled 

computer disk using commonly available and compatible 

computer software. 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1192 

7. The following reports must be submitted: 

(a) A performance test report, as required by Sec. 63.10(d)(2) of 

the general provisions in subpart A of this part, that 

documents the process and control equipment operating 

parameters during the test period, the test methods and 

Rule 335-3-11-.06(55) 

40 CFR Part 63.1193 
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procedures, the analytical procedures, all calculations, and 

the results of the performance tests. 

(b) A startup, shutdown, and malfunction plan, as described in 

Sec. 63.6(e)(3) of the general provisions in subpart A of this 

part, that contains specific procedures for operating and 

maintaining the source during periods of startup, shutdown, 

and malfunction and a program of corrective action for 

malfunctioning process and control systems used to comply 

with the emission standards. In addition to the information 

required by Sec. 63.6(e)(3), your plan must include the 

following: 

(1) Procedures to determine and record what caused the 

malfunction and when it began and ended. 

(2) Corrective actions you will take if a process or control 

device malfunctions, including procedures for recording 

the actions taken to correct the malfunction or minimize 

emissions. 

(3) An inspection and maintenance schedule for each process 

and control device that is consistent with the 

manufacturer's instructions and recommendations for

routine and long-term maintenance. 

(c) A report of each event as required by Sec. 63.10(b) of the 

general provisions in subpart A of this part, including a 

report if an action taken during a startup, shutdown, or 

malfunction is inconsistent with the procedures in the plan as 

described in Sec. 63.6(e)(3) of the general provisions in 

subpart A of this part. 

(d) An operations, maintenance, and monitoring plan as 

specified in Sec. 63.1187 of this subpart. 

(e) A semiannual report as required by Sec. 63.10(e)(3) of the 

general provisions in subpart A of this part if measured 

emissions exceed the applicable standard or a monitored 

parameter varies from the level established during 

performance testing. The report must contain the information 

specified in Sec. 63.10(c) of the general provisions, as well as 

the relevant records required by Sec. 63.1192(b) of this 

subpart. 
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Federally Enforceable Provisos Regulations 

(f) A semiannual report stating that no excess emissions or 

deviations of monitored parameters occurred during the 

reporting period as required by Sec. 63.10(e)(3)(v) of the 

general provisions in subpart A of this part if no deviations 

have occurred. 
ERM 2-27 IIG MinWool Title V App Renewal - 0078842 

2.2 STATE REGULATORY REVIEW

A detailed regulatory review of all applicable Alabama regulations for the 

facility was performed. This review is based upon the knowledge of the 

site, processes, raw materials, and the fact that Russell is a Class I county 

according to ADEM Admin. Code R. 335-3 Appendix A. 

This section provides a table that lists the ADEM air regulations 

applicable to this facility. 
ERM 2-28 IIG MinWool Title V App Renewal - 0078842 

Applicable Alabama Regulations 

IIG MinWool LLC

Citation Requirements/Standards Applicability Emission 

Unit ID 

Comment/Rationale 

335-1-7 Permit fees. Y All Applicable to all major 

sources as defined by 335-

1-7-.02 with exemptions 

335-1-7-.01 Applicable to any person who operates a stationary source, 

except as provided in 335-7-.03. 

Y All Applicable to all major 

sources as defined by 335-

1-7-.02 

335-1-7-.02 Definitions (a-h). Y All Applicable to all major 

sources as defined by 335-

1-7-.02 

335-1-7-.04 Fee schedule applies to major sources and requires 

payment of fees by 1 May for the preceding year for actual 

emissions (except CO) at $25/ton plus CPI adjustment. Fee 

cap at 4000 ton/year per pollutant. 

Y All Applicable to all major 

sources as defined by 335-

1-7-.02 

335-1-7-.04(3) Beginning 1995 & each subsequent year thereafter, fees 

due May 1 for every major source ($25 + diff. in CPI 1989) 

for each regulated pollutant, except CO, during that previous 

year. 

Y All Applicable to all major 

sources as defined by 335-

1-7-.02 

335-1-7-.04(5) Emissions of a regulated air pollutant shall not be counted 

more than once in determining fees. 

Y All Applicable to all major 

sources as defined by 335-

1-7-.02 

335-1-7-.04(6) Facilities having paid fees prior to 1995, shall be given credit 

on the amount owed in the following 5 years (see rule). 

Y All Fees were paid prior to 

1995. 

335-1-7-.04(7) If at the end of any fiscal year, operating fees ($) carried 

over in the budget > than Air Div budget for that year, the 

operating fees shall be reduced the following year.

Y All Applicable to all major 

sources as defined by 335-

1-7-.02 

335-1-7-.05 Fees due 5/1 each yr beginning 1992; Fail to pay result in 

permit revocation; Fail to pay w/in 30 days of 5/1 result in 

3%/month penalty; Fees non-refundable; Fees paid to

ADEM; ADEM w/in 60 days will accept $; Fees support Air 

program 

Y All Applicable to all major 

sources as defined by 335-

1-7-.02 

335-3-1 General provisions. Y All Applicable to all sources 

335-3-1-.01 Purpose to protect and enhance public welfare. Y All Applicable to all sources 

335-3-1-.02 Definitions (a-gggg). Y All Applicable to all sources 

335-3-1-.04 Monitoring, record keeping, and reporting. Y All Applicable to all sources 

335-3-1-.04(1) Director may require sources to keep records, maintain 

monitoring equip., sample emissions & provide reports as 

required. 

Y All Applicable to all sources 

335-3-1-.04(2) Emissions of PM, SO2, and NOx, VEs, and sulfur content of 

fuels burned except nat. gas, shall be expressed 

summarized/recorded and submitted as required (see rule). 

Y All Applicable to all sources 

335-3-1-.05 Sampling testing methods. Y All Applicable to all sources 

335-3-1-.05(1) All required sampling & testing associated calculations shall 

be performed using approved methods. 

Y All Applicable to all sources 

335-3-1-.05(2) The Director shall approve test methods and procedures in 

40 CFR 60. 

Y All Applicable to all sources 

335-3-1-.05(3) The Div. may conduct test & take samples of materials 

which may affect air emissions and provide a receipt for any 

samples taken. Source must provide necessary facilities for 

measurement. 

Y All Applicable to all sources 

335-3-1-.05(4) If requested, the owner or operator shall receive a report 

setting forth all facts found relating to compliance status. 

Y All Applicable to all sources 

335-3-1-.06 New source comply w/ 335-3-3 et seq within 60 days of max 

production but not <120 day after initial start. Existing source 

not in compliance w/ 335-3-3 attain compliance w/in 6 

months or submit schedule (not>3yrs.). Doesn't exempt from 

335-3-1 &2 

Y All Applicable to all sources 

335-3-1-.07 Maintenance and malfunctioning of equipment; reporting. Y All Applicable to all sources 

335-3-1-.07(1) In case of shut down of control equipment for maintenance 

(which operates pursuant to any permit) proper notification 

shall be given at least 24 hr prior to shut down. (see rule for 

content of notification). 

Y All Applicable to all sources 
ERM 2-29 IIG MinWool Title V App Renewal - 0078842 

335-3-1-.07(2) Should an emission source, control equip. or other equip fail 

and cause violations of regs, ADEM to be notified w/in 24 hr 

of failure. ADEM is to be notified when problem is corrected. 

Y All Applicable to all sources 

335-3-1-.08 Prohibition of air pollution: No person shall permit or cause 

air pollution (defined 335-3-1-.02(e)) by the discharge of any 

air contaminant for which no air quality standards have been 

set under 335-3-1-.03(1). 

Y All Applicable to all sources 

335-3-1-.09 Variances. Y All Applicable to all sources 

335-3-1-.9(1) Persons subject to any rule, reg, requirement or order may 

petition the commission for a variance from the application 

thereof as prescribed by the Act. (see rule for petition 

requirements). 

Y All Applicable to all sources 

335-3-1-.9(2) The Director shall not accept any petition which does not 

meet the requirements in 335-3-1-.09(1). Additional info may 

be required. 

Y All Applicable to all sources 

335-3-1-.9(3) A person may file a written objection to the grant of a 

variance w/in 21 days from initial advertised notice & thus 

ensure a public hearing. (see rule for objection 

requirements). 

Y All Applicable to all sources 

335-3-1-.10 Circumvention: No person may conceal or dilute any 

emission of air contaminant which would otherwise violate 

these rules and regulations unless the result is reduction in 

total amount of air contaminant emitted. 

Y All Applicable to all sources 

335-3-1-

.11,.12,.13 

Severability, Bubble Provisions, and Credible Evidence are 

applicable to this facility 

Y All Applicable to all sources 

335-3-2-.01 Air pollution emergency. Y All Applicable to all sources 

335-3-2-.02 Air pollution episodes: ADEM will declare when air pollution 

conditions exist with the potential to threaten the public wellbeing. ADEM may require an owner to plan for reducing 

emissions when notified of an air pollution episode. (see 

rule). 

Y All Applicable to all sources 

335-3-2-.03 Special episode criteria: The Director may declare episodic 

conditions when the concentration of a single contaminant 

or that of a specific locality within the state show elevated 

concentrations. 

Y All Applicable to all sources 

335-3-2-.04 Emission reduction plans: Upon declaring an Episode 

Watch, Alert or Warning, the Director shall order responsible 

persons contributing to the episode to take the general 

measures in the Emergency Episode Plan for the state of 

AL. 

Y All Applicable to all sources 

335-3-2-.05 Two containment episode: The Director shall declare the 

appropriate Alert, Warning or Emergency status when

concentrations of two contaminants simultaneously 

reach/exceed their respective Episode criteria. 

Y All Applicable to all sources 

335-3-2-.06 General episode: The Director shall declare a general Alert, 

Warning or Emergency status when concentrations of 3 or 

more contaminants simultaneously reach their Episodic 

criteria. 

Y All Applicable to all sources 

335-3-2-.07 Local episode: The Director shall specify the area of a Local 

Alert, Warning, or Emergency status. Responsible persons 

shall take corrective measures. 

Y All Applicable to all sources 

335-3-2-.08 Other sources may be required to prepare standby plans for 

reducing emissions during alerts. 

Y All Applicable to all sources 

335-3-2-.09 The provisions of this chapter shall not affect authority of the 

Governor, Chairman or Director relating to Emergency 

Procedures in section 11 of the Act. 

Y All Applicable to all sources 

335-3-3 Control of open burning and incineration. Y 009, 010, 

013 

Have incinerators onsite 

335-3-3-.02 Particulate emissions from incinerator. Y 009, 010, 

013 

Have incinerators onsite 

335-3-4 Control of particulate emissions. Y All Applicable to all sources 

335-3-4-.01 Visible emissions from stationary sources <20 % opacity 

except one 6 min period of 40 % per 60-minute period. 

Director under 335-3-14 may provide relief for short period 

&/or upon meeting PM limit compliance by method 9. 

Y 002, 003, 

004, 005, 

008, 009, 

010, 011, 

013, 015, 

017, 019, 

022 

Applicable to all point 

sources 

335-3-4-.02 Fugitive dust and fugitive emissions shall be controlled using 

reasonable methods to prevent matter from becoming 

Y All Applicable to all sources 
ERM 2-30 IIG MinWool Title V App Renewal - 0078842 

airborne. (see rule). 

335-3-4-.04 Process industries - general. Y 002, 003, 

004, 005, 

013, 015, 

017, 019 

Applicable to all processes 

335-3-4-.04(1) Class 1 Counties: Industrial process based on process 

weight 

 PM = 3.590.62 (P<30tph) 

 PM = 17.310.16 (P<30tph). 

Y 002, 003, 

004, 005, 

013, 015, 

017, 019 

Applicable to processes 

located in Class 1 county 

335-3-4-.04(3) If more than one interpretation of 335-3-4-.04 is possible 

based on the nature of the process operation or the

equipment design, use the interpretation resulting in the 

minimum allowable PM emission. 

Y 002, 003, 

004, 005, 

013, 015, 

017, 019 

Subject to 335-3-4-.04 

335-3-4-.04(4) The total process weight rate from all similar process units 

onsite should be used to determine the maximum allowable 

PM emissions through a stack 

Y 002, 003, 

004, 005, 

013, 015, 

017, 019 

Operates a process 

335-3-5 Control of sulfur compound emissions. Y 002, 003, 

009, 011, 

013 

Has sulfur compound 

emissions. 

335-3-5-.05 Sulfur compound emissions from facilities not covered in 

335-3-5-.01 through 0.04. Requires NSPS, BACT and 

compliance with NAAQS for new facilities. 

Y 002, 003, 

009, 011, 

013 

Has sulfur compound 

emissions not covered in 

335-3-5-.01 to .04 

335-3-6 Control of organic emissions. Y All Applies to sources with 

potential emissions >100 

tpy, even though none of 

it's sections are applicable 

to this facility. 

335-3-9 Motor vehicles will be operated in a manner that prevents 

them from being a public nuisance. 

Y None Applicable to all motor 

vehicles 

335-3-14 Air permits. Y All Applicable to all sources 

335-3-14-

.01(1)(a) 

Facilities must obtain an air permit from ADEM 10 days prior 

to any construction modification or replacement that will 

cause the emission of air pollutants. 

Y All Applicable to all sources 

335-3-14-

.01(1)(b) 

Facilities must obtain an air permit from ADEM prior to 

operating any device that will emit air pollutants.

Y All Applicable to all sources 

335-3-14-

.01(1)(c) 

No article emitting air pollutants may continue to operate 

without obtaining an air permit. 

Y All Applicable to all sources 

335-3-14-

.01(1)(d) 

The permit will be kept onsite and available for inspection. Y All Applicable to all sources 

335-3-14-

.01(1)(e) 

ADEM will decide whether or not a source is subject to this 

rule. 

Y All Applicable to all sources 

335-3-14-

.01(1)(f) 

ADEM may authorize initial operation prior to inspection 

under actual operating conditions upon a submittal from the 

owner that the construction was completed in accordance to 

specifications. 

Y All Applicable to all sources 

335-3-14-

.01(1)(g) 

ADEM may issue an air permit subject to specific conditions. Y All Applicable to all sources 

335-3-14-

.01(1)(k) 

Facilities holding a Synthetic Minor Operating permit or 

operating permit may be exempt from this chapter with 

exceptions. (see rule). 

Y All Applicable to all sources 

335-3-14-

.01(1)(2) 

Sampling and testing will be provided as prescribed in the 

permit. 

Y All Applicable to all sources 

having an air permit 

335-3-14-

.01(1)(3) 

Conditions set forth in an air permit will be met in addition to 

applicable rules and regulations. 

Y All Applicable to all sources 

having an air permit 

335-3-14-

.01(1)(4) 

An air permit is not transferable from one person to another 

or from one facility to another. 

Y All Applicable to all sources 

having an air permit 

335-3-14-

.01(1)(5) 

ADEM may specify a source exempt from needing an air 

permit. 

Y All Applicable to all sources 

335-3-14-

.01(1)(7) 

Public participation. (see rule). Y All Applicable to all sources 

applying for an air permit 
ERM 2-31 IIG MinWool Title V App Renewal - 0078842 

335-3-14-.02(1) Permit applications will be filed as prescribed by ADEM and 

give all information needed to make a full evaluation. (see 

rule). 

Y All Applicable to all sources 

applying for an air permit 

335-3-14-.02(2) ADEM will review application in a timely manner and notify 

applicant of its decision. 

Y All Applicable to all sources 

applying for an air permit 

335-3-14-.02(3) ADEM will notify applicant of denial and reason of such. Y All Applicable to all sources 

applying for an air permit 

335-3-14-.02(4) Revocation of permit may occur if fail to: (a) comply w/ 

conditions of permit, (b) notify ADEM in advance of

operation, (c) maintain monitoring equip./records, (d) comply 

w/ ADEM Admin. Order, (e) allow ADEM staff access to 

info., (f) comply w/ regs or (g) ADEM judgment. 

Y All Applicable to all sources 

having an air permit 

335-3-14-.02(5) Air permits shall expire following the issuance of final denial 

or failure to apply for a Synthetic Minor Operating Permit 

(335-3-15) or Major Source Operating Permit (335-3-16) as 

required by ADEM. 

Y All Applicable to all sources 

having an air permit 

335-3-14-

.03(1)(a) 

Permit denial if source emits air pollutants in violation of 

ADEM rules 

Y All Applicable to all sources 

applying for an air permit 

335-3-14-

.03(1)(b) 

Permit denial if failure to submit an Air Pollution Episode 

Plan, if required. 

Y All Applicable to all sources 

applying for an air permit 

335-3-14-

.03(1)(c) 

Before granting Air Permit, ADEM may require sampling and 

testing equipment. 

Y All Applicable to all sources 

applying for an air permit 

335-3-14-

.03(1)(d) 

Before granting Air Permit, ADEM may require monitoring 

equipment. 

Y All Applicable to all sources 

applying for an air permit 

335-3-14-

.03(1)(e) 

Before granting Air Permit, ADEM may require additional 

equipment. 

Y All Applicable to all sources 

applying for an air permit 

335-3-14-

.03(1)(f) 

Construction not in accordance with an Air Permit must be 

corrected or demonstrate no increase in emissions. 

Y All Applicable to all sources 

having an air permit 

335-3-14-

.03(1)(g) 

Air Permit will be denied if the source exceeds significance 

standards set forth in 335-3-1-.03(1) (NAAQS). (ug/m

3

) 

SO2=1 annual, 5 24hr, 25 3 hr PM10=1 annual, 5 24hr, NO2 

= 1 annual, CO=0.5 8hr, 2 1hr (CO=mg/m3

) 

Y All Applicable to all sources 

applying for an air permit 

335-3-14-

.03(1)(h) 

ADEM may exempt certain emission limits violations, with 

limitations, such as startup shutdown, load changes or 

during emergencies. 

Y All Applicable to all sources 

having an air permit 

335-3-14-.03(2) Stack heights and associated modeling will be based on 

good engineering practices. Refer to 335-3-14-.03(2)(a) 

through (g); however, the stack height will not be limited by 

the requirements of this section. 

Y All Applicable to all sources 

having an air permit 

335-3-14-.04 Air Permits authorizing construction in clean air areas 

(PSD). 

Y All Applicable to all sources in 

attainment areas 

335-3-14-.04(1) Air permits for PSD effective upon EPA approval. Y All Applicable to all sources 

335-3-14-.04(2) Definitions (a-ee). Y All Applicable to all sources 

335-3-14-.04(3) Class I, II, or III areas pollutant concentration increases over 

the baseline may not exceed the standards designated in 

this section. 

Y All Applicable to all sources 

335-3-14-.04(4) Pollutant concentrations may not exceed the National 

Primary or Secondary Ambient Air Quality Standard, 

whichever is lowest. 

Y All Applicable to all sources 

335-3-14-.04(5) The Sipsey Wilderness Area is a Class I area and may not 

be redesignated. All other areas are Class II. 

Y All Applicable to all sources 

335-3-14-.04(6) Certain increases in pollutant concentration may be 

excluded for up to 5 years. (see rule). 

Y All Applicable to all sources 

335-3-14-.04(8) Prior to major stationary source construction or modification, 

requirements must be met for: 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(a) 

Major stationary source can not commence actual 

construction/modification until 335-3-14-.04(9) - (17) have 

been met at a minimum. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(b) 

Requirements of 335-3-14-.04(9) - (17) shall apply to each 

pollutant from a major stationary source/modification subject 

to regulation under the CAA except as otherwise allowed. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 
ERM 2-32 IIG MinWool Title V App Renewal - 0078842 

335-3-14-

.04(8)(c) 

Requirements of 335-3-14-.04(9) - (17) shall apply only to 

major stationary sources/modification constructing in an 

area designated as Attainment or unclassified under section 

107(d)(1)(D) or (E) of the CAA. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(d) 

Requirements of 335-3-14-.04(9) - (17) shall not apply to 

major stationary sources/modification if nonprofit,

health/education facility, solely due to fugitive unless one of 

28 sources, or previously permitted portable source

(restrictions). 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(f) 

Requirements of 335-3-14-(10), (12), (14) shall not apply to 

major stationary sources/modifications if no impact to class I 

area & no area where increment is violated & would be 

temporary. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(g) 

Requirements of 335-3-14-(10), (12), (14) for max increase 

shall not apply to major stationary sources/modifications pre 

3/1/78 if net increase after BACT < 50 TPY 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(h) 

Director may exempt a stationary source/modification from 

335-3-14-.04(12) remonitoring under certain circumstances. 

(see rule). 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(h)1 

Air quality impacts are below specified levels. (see rule). Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(h)2 

Current concentrations of the pollutant in the area are below 

specified levels. (see rule). 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(h)3 

The owner/operator submits a complete application by 

6/1/88 (excluding PM req.). If submittal after 6/1/88 but by 

12/1/88, PM10 data to be gathered from 2/1/88 to submittal 

unless otherwise specified by Director. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(k) 

Exemptions to requirements for air quality monitoring of 

PM10 in 335-3-14-.04(12)(a) through 4. (see rule). 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(8)(l) 

The requirements for PM10 monitoring in 335-3-14-

.04(12)(a)2. & 4. & (12)(c) shall apply if application submittal 

after 6/1/88 but by 12/1/88. Data shall be gathered from 

2/1/88 to submittal date. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-.04(9) A BACT review will be done for each pollutant regulated 

under the CAA at a major stationary source construction or 

modification site. The major source/modification shall meet 

applicable limits under SIP and 40 CFR 60 & 61. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(10) 

Emission increases must not violate NAAQS or exceed

allowable increases over baseline concentrations. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(11) 

Estimates of ambient concentrations are to be based on air 

quality models as specified in "Guidelines on Air Quality 

Models," USEPA. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(12) 

Analysis of each pollutant that will be emitted and/or whose 

increased emission will be significant is required pre- and 

post-construction or modification. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(12)(a) 

Preconstruction analysis to contain ambient air quality 

analysis of affected area to be done over 4 month-1yr of 

data. Where no NAAQS exist, ADEM will determine data 

required. Special requirements apply for PM10. (see rule). 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(12)(b) 

Post-construction monitoring may be conducted to 

determine the impact of source/modification on air quality. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 
ERM 2-33 IIG MinWool Title V App Renewal - 0078842 

335-3-14-

.04(12)(c) 

Federal monitoring quality assurance requirements must be 

met. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(12)(d) 

ADEM may require visibility monitoring in Federal Class I 

area near facility. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(13) 

Additional info to be submitted to ADEM as needed to 

include, but not limited to: nature; location; design capacity; 

operating schedule; schedule for construction/modification; 

emission estimates; and meteorological and drawings. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(14) 

Additional impact analysis required: Visibility; Soils; 

Vegetation. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(15) 

Federal Class I Areas: ADEM will notify EPA and Federal 

Land Managers of permit applications from which emissions 

would affect a Class I area(s). 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(15) 

ADEM will consider Federal Land Managers' 

recommendations in determining permit issuance or denial 

Gubernatorial or Presidential variances may be issued. 

Refer to 335-3-14-.04(15)(f)-(h). 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(16) 

W/in 1 yr of receiving application, ADEM to make final 

determination for issue or denial. Determination to be made 

after public notice, hearing, & comment period. Applicant to 

be notified of decision by mail which is to be made available 

to public. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(17) 

If construction does not begin within 24 months of receipt of 

approval or construction ceases for 24 months, the air 

permit will become invalid. Authorization to construct does 

not relieve applicant of compliance with SIP, state, federal, 

or local law. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(18) 

Applicant may ask for approval to use innovative control 

technology no later than the close of public comment period. 

Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-14-.04 

335-3-14-

.04(19) 

The holder of an Air Permit may request that the permit be 

rescinded in part or whole. If ADEM rescinds permit, the 

public shall be given notice of such. 

Y All Applicable to all sources 

having an air permit 

335-3-16 Major Source Operating Permits. Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.01 Definitions. Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.02(1) A major source operating without a permit, Operating 

Permit, or SMOP must obtain an Operating Permit or SMOP 

before a date set by ADEM. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.02(2) An Operating Permit must be kept at the source for which it 

was issued and must be made available for inspection. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.02(3) ADEM will determine applicability of or exemption from this 

rule for any source or equipment. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.02(4) ADEM may issue an Operating Permit subject to conditions 

that will bring the source within standards of this rule. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.02(5) Sampling and testing facilities may be specified in an 

Operating Permit and must be maintained. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 
ERM 2-34 IIG MinWool Title V App Renewal - 0078842 

335-3-16-.02(6) Operating Permits are not transferable from one location, 

source, or person to another. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.02(8)(a) 

An Operating Permit will not be issued unless every piece of 

equipment at a facility operates in compliance with this 

Administrative Code. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.02(8)(b) 

An Operating Permit will not be issued unless the applicant 

provides a plan of action for Air Episode Periods when 

required. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.02(8)(c) & (d) 

ADEM may require sampling and testing for a facility and 

additional information. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.02(8)(e) 

An Operating Permit will be revoked if any equipment is not 

in compliance with the permit. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.02(9) An Operating Permit may be revoked for failure to: comply 

with conditions of permit; install monitoring equipment; 

maintain records; comply with an ADEM administrative 

order; allow ADEM staff access to: site, records, equipment, 

samples. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.02(10) 

Stack heights and associated modeling will be based on 

good engineering practices. Refer to 335-3-16-.02(10)(a) 

through (f). However, the stack height will not be limited by 

the requirements of this section. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.03 Any major source defined as such by ADEM is subject to the 

requirements of this Chapter. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.04(1)-(F) 

A source must submit an application for an Operating Permit 

within 12 months of becoming subject to this rule unless 

otherwise notified by ADEM. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.04(2) A source may operate without a permit between the date an 

application is completed and the date of final permit 

issuance provided requested information is submitted in a 

timely manner. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.04(8) Application for an Operating Permit will be made using 

ADEM Standard Forms. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.04(9) Forms, reports, or compliance certification submitted as part 

of an Operating Permit application will be certified, by a 

responsible official, as to its' truth, accuracy, and 

completeness. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.05 Permit Content; Standard permit requirements (see rule). Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.06 ADEM can designate any terms of an Operating Permit that 

are not regulated by the CAA as being not federally

enforceable. If such designation is made, the terms will be 

considered state enforceable. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.07 Compliance requirements. Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.08 Genera permits. Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.10 ADEM may stipulate that a source that is in compliance with 

the conditions of an Operation Permit shall be deemed to 

be in compliance with any applicable requirements as of the 

permit issuance. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 
ERM 2-35 IIG MinWool Title V App Renewal - 0078842 

335-3-16-.11 ADEM may exempt emission limits exceedances which are 

unavoidable. In the case where exemptions are made on the 

basis of an emergency ADEM will determine what 

constitutes an emergency. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.12(1) Operating Permits issued within 3 years of EPA's approval 

of ADEM's program. At least 1/3 must be issued each of 

those years unless interim approval is granted, then 20% 

per year. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.12(2)(a) 

The same procedural requirements exist for permits being 

renewed that exist for initial Operating Permits 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.12(2)(b) 

Expiration of an Operating Permit ends the source's right to 

operate unless a renewal application has been submitted 6 

to 18 months before such expiration. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.12(2)(c) 

If a complete renewal application has been submitted and 

the previous Operating Permit expires, the previous permit 

will continue to exist until a decision has been made by 

ADEM on the renewal. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.13(1)(a) 

Administrative Permit Amendments correct typo errors, 

change in name and address, more frequent monitoring, 

incorporate general permits and preconstruction permits. 

(see rule). 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-

.13(1)(c) 

ADEM must respond to a request within 60 days after

submission, submit a copy to the EPA administrator, and 

changes may be made upon request. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.13(2) Modifications which are not modifications under Title I of the 

CAA that contravene an existing permit condition, but do not 

exceed emissions allowable under the Operating Permit, 

can be done if 7 day notice is given. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.13(3) Minor permit modification procedures. (see rule). Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.13(4) Significant permit modification procedures. (see rule). Y All Applicable to all major

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.13(5) Reopening for cause. (see rule). Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.14 Changes made that are not addressed in the federally 

enforceable terms or conditions of the permit will be 

considered as off-permit changes. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.15(1) ADEM must supply EPA with a copy of each proposed and 

final permit. The applicant may be required to submit a copy 

directly to EPA. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.15(2) ADEM must provide notice regarding the draft permit to 

each affected state on or before notice is given to the public 

& state in writing its reasons for not accepting comments. 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.15(3) ADEM will not issue a permit if, within 45 days of receipt of a 

proposed permit or prior to issuance of a final permit EPA 

submits a written objection. (see rule). 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 

335-3-16-.15(4) Public participation requirements shall be met except for 

modifications qualifying for administrative or minor permit 

modification procedures. (see rule). 

 Y All Applicable to all major 

sources and major 

modifications as defined 

by 335-3-16-.01 
ERM 2-36 IIG MinWool Title V App Renewal - 0078842 

2.3 FEDERAL REGULATORY REVIEW

Based upon the same information cited in section 2.2, a detailed review of 

all applicable federal regulations conducted. This section provides a table 

that lists the federal air regulations applicable to IIG MinWool. 

As part of the regulatory review, IIG MinWool certifies that it will comply 

with any and all future state and federal regulations at such time as those 

regulations become applicable. This includes any future MACT standards 

that may be adopted for the processes performed at the Facility. 
ERM 2-37 IIG MinWool Title V App Renewal - 0078842 

Applicable Federal Regulations 

IIG MinWool LLC 

Citation Requirements/Standards Applicability Comments/Rationale 

40CFR 52 Approval and Promulgation of 

Implementation Plans. 

Y Facility subject to part of Part 

52 

40CFR 52 Subpart A (52.21) Prevention of significant 

deterioration of air quality. 

Y Applicable to PSD sources 

40CFR 52 Subpart A (52.23) Violation and enforcement. Y Applicable to PSD sources 

40CFR 52 Subpart B Alabama. Y Applicable to sources in 

Alabama 

40CFR 52 Subpart B (52.60) Significant deterioration of air 

quality. 

Y Applicable to sources in 

Alabama 

40CFR 52 Subpart Kb NSPS for volatile organic liquid 

storage vessels. 

Y Facility operates two tanks that 

meet the Kb requirements 

40CFR 63 National Emission Standards for 

Hazardous Air Pollutants for 

Source Categories. 

Y Affected source pursuant to 

112 

40CFR 63 Subpart A General Provisions. Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.1) Applicability. 

 Applicable if source emits or 

has potential to emit any 

pollutant listed in section 112(b) 

of the Act. 

Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.2) Definitions. Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.3) Units and abbreviations. Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.4) Prohibited activities and

circumvention. 

Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.5) Construction and 

reconstruction. 

Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.6) Compliance with standards and 

maintenance requirements. 

Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.7) Performance testing 

requirements. 

Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.8) Monitoring requirements. Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.9) Notification requirements. Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.10) Recordkeeping and reporting 

requirements. 

Y Affected source pursuant to 

112 

40CFR 63 Subpart A (63.11) Control device requirements. Y Affected source pursuant to 

112 

40CFR 63 Subpart DDD Maximum Available Control 

Technology (MACT) Standards 

Y Mineral Wool MACT 

40CFR 70 State Operating Permit Program Y Applicable to major sources 

40CFR 70 (70.1) Program overview. Y Applicable to major sources 

40CFR 70 (70.2) Definitions. Y Applicable to major sources 

40CFR 70 (70.3) Applicability. Y Applicable to major sources 

40CFR 70 (70.4) State program submittals and 

transition. 

Y Applicable to major sources 

40CFR 70 (70.5) Permit applications. Y Applicable to major sources 

40CFR 70 (70.6) Permit content. Y Applicable to major sources 

40CFR 70 (70.7) Permit issuance, renewal, 

reopenings, and revisions. 

Y Applicable to major sources 

40CFR 70 (70.8) Permit review by the EPA and 

affected States. 

Y Applicable to major sources 
ERM 2-38 IIG MinWool Title V App Renewal - 0078842 

40CFR 70 (70.9) Fee determination and 

certifications. 

Y Applicable to major sources 

40CFR 70 (70.10) Federal oversight and 

sanctions. 

Y Applicable to major sources 

40CFR 70 (70.11) Requirements for enforcement 

authority 

Y Applicable to major sources 

40CFR 82 Subpart F 

(82.150) 

Purpose and scope. Y Applies to maintenance 

activities 

40CFR 82 Subpart F 

(82.152) 

Definitions. Y Applies to maintenance 

activities 

40CFR 82 Subpart F 

(82.154) 

Prohibitions. Y Applies to maintenance 

activities 

40CFR 82 Subpart F 

(82.156) 

Required practices. Y Applies to maintenance 

activities 

40CFR 82 Subpart F 

(82.166) 

Reporting and recordkeeping 

requirements. 

Y Applies to maintenance 

activities 

40CFR 64 Compliance Assurance 

Monitoring (CAM) 

Y The facility will comply with 

applicable CAM rules. 
ERM 2-39 IIG MinWool Title V App Renewal - 0078842 

2.4 NON-APPLICABLE REGULATIONS 

This section provides a table that lists the ADEM and Federal Air 

Regulations that are not applicable to IIG MinWool. The basis for the non 

applicability assignment are provided in a written summary under the 

comment/rationale heading. 
ERM 2-40 IIG MinWool Title V App Renewal - 0078842 

Non-Applicable Alabama Regulations 

IIG MinWool LLC 

Citation Requirements/Standards Applicability Emission 

Unit ID 

Comment/Rationale 

335-3-10-.02(29) NSPS - Glass manufacturing 

plants. See 40 CFR 60 Subpart 

CC. 

N None 

Not a glass manufacturing plant 

335-3-10-.02(68) NSPS - Wool fiberglass insulation 

manufacturing plants. See 40 

CFR 60 Subpart PPP. 

N None 

Not a wool fiberglass 

manufacturing plant 

335-3-3-.02(3) Particular Limit our of incinerators N 9,010,013 The incinerator at this site does 

not receive solid type material 

335-3-11-.02(13) NESHAP - Inorganic arsenic 

emissions from glass 

manufacturing. See 40 CFR 61 

Subpart N. 

N None 

No glass manufacturing onsite 
ERM 2-41 IIG MinWool Title V App Renewal - 0078842 

Non-Applicable Federal Regulations 

IIG MinWool LLC 

Citation Requirements/Standards Applicability Comment/Rationale 

40CFR 60 

Subpart CC 

(60.290-.296) 

Standards of Performance for Glass Manufacturing 

Plants. 

N Not a glass manufacturing 

plant 

40CFR 60 

Subpart PPP 

(60.680-.685) 

Standards of Performance for Wool Fiberglass 

Insulation Manufacturing Plants. 

N Not a wool fiberglass facility 

40CFR 60 

Subpart DDD 

Mineral Wool MACT Standard (for pipe machines) N Not applicable to the pipe 

machines 

40CFR 61 

Subpart N 

(61.160-.165) 

National Emission Standards for Inorganic Arsenic 

Emissions from Glass Manufacturing Plants. 

N Not a glass manufacturing 

plant 

40CFR 63 

Subpart NNN 

National Emission Standards for Hazardous Air 

Emissions from Wool Fiberglass Manufacturing 

Plants. 

N Not a wool fiberglass facility 

40CFR 63 

Subpart WWWW 

National Emission Standards for Hazardous Air 

Emissions from Reinforced Plastic Composites 

Production. 

N Not a reinforced plastics 

production facility 
ERM 3-1 IIG MinWool Title V App Renewal - 0078842 

3.0 APPLICATION FORMS 

Section 3.0 presents the Alabama Department of Environmental 

Management application forms for the facility. One copy of each form is 

included for completeness. Those forms that have been determined to be 

not applicable are noted. 
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ADEM Form 108 01/08 m1 

If additional entries are needed, make additional copies of this form and attach to the application. Make sure to identify the additional sheets su

TABLE 108.1-PROPOSED STORAGE TANK(S)/LOADING RACK(S) AT FACILITY

TANK ID 

TANK CAPACITY 

(gallons) 

TANK TYPE (a)

(HFRT, VFRT, EFLRT, 

DEFLRT, or IFLRT) FILL METHOD (d)

DATE 

MANUFACTURED 

DATE 

INSTALLED OR 

CONSTRUCTION 

COMMENCED 

DATE 

RECONSTRUCTED, 

AS APPLICABLE 

DATE 

MODIFIED, 

AS APPLICABLE 

W

R

S

T01 10,968 VFRT Bottom 1989 1989 N/A N/A T02 10,968 VFRT Bottom 1989 1989 N/A N/A 

Note: These binder/resin storage tanks constitute Trivial Activities per Section 1, T(3) of the Trivial & Insignificant Activities List 

RACK ID 

RACK TYPE 

(Marine, Truck, Rail, etc.) 

PROPOSED PRODUCTS 

TO BE LOADED (c)

TYPE OF 

LOADING (d)

IF SUBMERGED, 

WHAT % IS FILL 

PIPE 

SUBMERGED? 

EQUIPPED WITH VAPOR RECOVERY 

SYSTEM (b)

(Y or N) 

PROVIDE EFFICIENCY O

VAPOR COLLECTION 

SYSTEM 

No ID Truck Unloading to Tanks A Bottom N/A N N/A 

(a) HFRT-horizontal fixed roof tank; VFRT-vertical fixed roof tank; EFLRT-external floating roof tank; DEFLRT-domed external floating roof tank; IFLRT-internal floating roof 

(b) Please attach ADEM Form 110 for the vapor recovery system. (c) Use Product ID from Table 108.2 or list “ALL” if rack may transfer all of the products listed in Table 108.2. (d) Type of Filling/Loading-submerged fill, splash filling, top filling, bottom filling, etc 
ADEM Form 108 01/08 m1 

TABLE 108.2-PROPOSED PRODUCT(S) STORED AND LOADED OUT AT FACILITY

Loadout (b) 

Mark all that ap

PRODUCT CODE PRODUCT NAME & CAS NO., IF APPLICABLE LIQUID MOLECULAR WEIGHT (lb/lb-mole) VAPOR MOLECULAR WEIGHT (lb/lb-mole) AVERAGE TRUE VAPOR PRESSURE (psia) LIQUID DENSITY (a) (lb/gal) TEMP. STORED AT (oF) TOTAL PRODUCT THROUGHPUT (gal/year) 

Marine 

Vessel

Truck 

Rail Car 

A Formaldehyde resin 24.3 24.3 0.35 8.3 ambient 1,000,000 NA NA NA NB 

C Note: The binder/resin storage tanks constitute Trivial Activities per Section 1, T(3) of the Trivial & Insignificant Activities ListD 

E 

F 

G 

H 

I 

J 

K 

L 

M 

N 

O 

P 

Q 

R 

S 

T 

U 

V 

W 

X Y 

(a) Applicable for products stored in tanks with floating roofs. (b) Loadout is product transferred from tank through rack to marine vessel, truck or rail car, or container. 
ADEM Form 108 01/08 m1 Page 4 of 8 

If applying for the construction/modification/reconstruction of more than six tanks, make additional copies of this form as 

needed and attach to the application. Make sure to identify the additional sheets such as 4a of 8 or 4.1 of 8. 

TABLE 108.3- FIXED ROOF STORAGE TANK (HORIZONTAL) 

TANK ID  NONE 

SHELL LENGTH 

(ft-in) 

SHELL DIAMETER 

(ft-in)

HEATED? 

(Y or N)

PRESSURIZED? 

(Y or N)

UNDERGROUND? 

(Y or N)

SHELL COLOR/SHADE (a)

SHELL CONDITION (b)

PROPOSED 

PRODUCTS TO BE STORED (c)

PRODUCT TRANSFER FROM TANK TO: 

gallons per day (GPD) (d) GPD GPD GPD GPD GPD GPD 

TABLE 108.4-FIXED ROOF STORAGE TANK (VERTICAL)

TANK ID  T01 T02 

SHELL HEIGHT 

(ft-in) 18 ft 18 ft 

SHELL DIAMETER 

(ft-in) 10 ft 10 ft 

MAX LIQUID HEIGHT 

(ft-in) 16 ft 16 ft 

AVG LIQUID HEIGHT 

(ft-in) 8 ft 8 ft 

HEATED? 

(Y or N) N N 

PRESSURIZED? 

(Y or N) N N 

SHELL 

COLOR/SHADE (a) A/D A/D 

SHELL 

CHARACTERISTICS SHELL 

CONDITION (b) Good Good 

ROOF 

COLOR/SHADE (a) A/D A/D 

ROOF 

CONDITION (b) Good Good ROOF 

CHARACTERISTICS

CONE/DOME 

HEIGHT 

 (ft-in)

0.69 ft 0.69 ft 

PROPOSED PRODUCTS TO BE 

STORED (c) A A 

process process PRODUCT TRANSFER FROM TANK TO: 

gallons per day (GPD) (d) 2740 GPD 2740 GPD GPD GPD GPD GPD 

(a) Select from: White/White (W/W); Aluminum/Specular (A/S); Aluminum/Diffuse (A/D); Gray/Light (G/L); Gray/Medium (G/M); Red/Primer (R/P) 

 If tank color unknown, list “default” 

(b) Select from: Good or Poor. If tank condition unknown, list “default” 

(c) Use Product ID from Table 108.2 or list “ALL” if tank may store all of the products listed in Table 108.2. 

(d) Should be completed if product in tank is being transferred to a specific piece of equipment or process which is not a loading rack (e.g. boiler).
ADEM Form 108 01/08 m1 Page 5 of 8 

If applying for the construction/modification/reconstruction of more than six tanks, make additional copies of this form as 

needed and attach to the application. Make sure to identify the additional sheets such as 5a of 8 or 5.1 of 8. 

TABLE 108.5-EXTERNAL FLOATING ROOF STORAGE TANK N/A- NONE

TANK ID  NONE 

SHELL DIAMETER 

(ft-in) 

DOMED? 

(Y or N)

INTERNAL SHELL CONDITION (a)

PAINT COLOR/SHADE (b)

PAINT CONDITION (c)

LIST ONE 

PONTOON OR 

ROOF DOUBLE DECK

CHARACTERISTICS ROOF FITTING 

CATEGORY (d) 

TANK 

CONSTRUCTION

LIST ONE 

WELDED OR 

RIVETED

 

PRIMARY (e)

SEAL TYPE

SECONDARY (f) 

PROPOSED PRODUCTS TO BE 

STORED (g) 

PRODUCT TRANSFER FROM TANK TO: 

gallons per day (GPD) (h) GPD GPD GPD GPD GPD GPD 

(a) Select from: Light Rust; Dense Rust; GuniteTM Lining. If internal shell condition unknown, list “default” 

(b) Select from: White/White (W/W); Aluminum/Specular (A/S); Aluminum/Diffuse (A/D); Gray/Light (G/L); Gray/Medium (G/M); Red/Primer (R/P) 

 If paint color unknown, list “default” 

(c) Select From: Good or Poor. If tank condition unknown, list “default” 

(d) Typical or Detail. If detail, list fittings and quantities for each tank on Table 108.7 

(e) Select from: Mechanical Shoe (MS); Liquid Mounted (LM); or Vapor Mounted (VM) 

(f) Select from: None, Shoe Mounted (SM), Rim Mounted (RM) or Weather Shield (WS) 

(g) Use Product ID from Table 108.2 or list “ALL” if tank may store all of the products listed in Table 108.2. 

(h) Should be completed if product in tank is being transferred to a specific piece of equipment or process which is not a loading rack (e.g. boiler). 
ADEM Form 108 01/08 m1 Page 6 of 8 

If applying for the construction/modification/reconstruction of more than six tanks, make additional copies of this form as 

needed and attach to the application. Make sure to identify the additional sheets such as 6a of 8 or 6.1 of 8. 

TABLE 108.6-INTERNAL FLOATING ROOF STORAGE TANK N/A- NONE

TANK ID  NONE 

SHELL DIAMETER 

(ft-in) 

SELF SUPPORT. ROOF? 

(Y or N)

NUMBER OF COLUMNS 

EFFECTIVE COLUMN DIAMETER (a)

INTERNAL SHELL CONDITION (b)

PAINT 

COLOR/SHADE (c) 

EXTERNAL SHELL

PAINT 

CONDITION (d) 

PAINT 

COLOR/SHADE (c) 

ROOF 

CHARACTERISTICS PAINT 

CONDITION (d) 

DECK CHARAC.

LIST ONE 

BOLTED OR 

WELDED (e)

 

PRIMARY (f)

SEAL TYPE

SECONDARY (g) 

PROPOSED PRODUCTS TO BE 

STORED (h) 

PRODUCT TRANSFER FROM TANK TO: 

gallons per day (GPD) (i) GPD GPD GPD GPD GPD GPD 

(a) Select from: 9” by 7” Built-Up Column, 8” Diameter Pipe, or Unknown 

(b) Select from: Light Rust; Dense Rust; GuniteTM Lining. If internal shell condition unknown, list “default” 

(c) Select from: White/White (W/W); Aluminum/Specular (A/S); Aluminum/Diffuse (A/D); Gray/Light (G/L); Gray/Medium (G/M); Red/Primer (R/P) 

 If paint color unknown, list “default” 

(d) Select From: Good or Poor. If tank condition unknown, list “default” 

(e) Typical or Detail. If detail, list fittings and quantities for each tank on Table 108.7 

(f) Select from: Mechanical Shoe (MS); Liquid Mounted (LM); or Vapor Mounted (VM) 

(g) Select from: None, Shoe Mounted (SM), or Rim Mounted (RM) 

(h) Use Product ID from Table 108.2 or list “ALL” if tank may store all of the products listed in Table 108.2. 

(i) Should be completed if product in tank is being transferred to a specific piece of equipment or process which is not a loading rack (e.g. boiler). 
ADEM Form 108 01/08 m1 Page 7 of 8 

TABLE 108.7-FLOATING ROOF FITTINGS-DETAIL 

(DECK OR ROOF CHARACTERISTICS) 

N/A- NONE

TANK ID. TANK CONSTRUCTION: IFRT or EFRT 

(fill out separate page for each IFRT or EFRT) 

 $,/ 6$%,<=;,2/)%// 12,$ $%$#$))%'

N/A- NONE

A. Access Hatch Qty:__________ 

1) Bolted cover, gasketed 

2) Unbolted cover, gasketed 

3) Unbolted cover, ungasketed 

B. Automatic, Gauge Float Well Qty:__________ 

1) Bolted cover, gasketed 

2) Unbolted cover, gasketed 

3) Unbolted cover, ungasketed 

C. Column Well Qty:__________ 

1) Built-up column-sliding cover, gasketed 

2) Built-up column-sliding cover, ungasketed 

3) Pipe column-flexible fabric sleeve seal 

4) Pipe column-sliding cover, gasketed 

5) Pipe column-sliding cover, ungasketed 

D. Gauge-Hatch/Sample Well, 8 inch diameter Qty:__________ 

1) Weighted mechanical actuation, gasketed 

2) Weighted mechanical actuation, ungasketed 

E. Ladder Well Qty:__________ 

1) Sliding cover, gasketed 

2) Sliding cover, ungasketed 

F. Rim Vent, 6 inch diameter Qty:__________ 

1) Weighted mechanical actuation, gasketed 

2) Weighted mechanical actuation, ungasketed 

G. Roof Drain, 3 inch diameter Qty:__________ 

1) Open 

2) 90% Closed 

H. Roof Leg, 3 inch diameter Qty:__________ 

1) Adjustable, Pontoon Area, ungasketed 

2) Adjustable, Center Area, ungasketed 

3) Adjustable, Double Deck Roofs 

4) Fixed 

5) Adjustable, Pontoon Area, gasketed 

6) Adjustable, Pontoon Area, socks 

7) Adjustable, Center Area, gasketed 

8) Adjustable, Center Area, socks 

I. Roof Leg or Hanger Well Qty:__________ 

1) Adjustable 

2) Fixed 

J. Sample pipe or well Qty:__________ 

1) Slotted pipe sliding cover, gasketed 

2) Slotted pipe sliding cover, ungasketed 

3) Slit fabric seal, 10% open area 

K. Slotted Guide-Pole/Sample Well Qty:__________ 

1) Ungasketed sliding cover without float 

2) Ungasketed sliding cover with float 

3) Gasketed sliding cover without float 

4) Gasketed sliding cover with float 

5) Gasketed sliding cover with pole wiper 

6) Gasketed sliding cover with pole sleeve 

7) Gasketed sliding cover with float, wiper 

8) Gasketed sliding cover with float, sleeve, wiper

9) Gasketed sliding cover with pole sleeve, wiper 

L. Stub drain, 1 inch diameter [ Yes or No] 

M. Unslotted Guide-Pole Well Qty:__________ 

1) Ungasketed sliding cover 

2) Gasketed sliding cover 

3) Ungasketed sliding cover with sleeve 

4) Gasketed sliding cover with sleeve 

5) Gasketed sliding cover with wiper 

N. Vacuum breaker Qty:__________ 

1) Weighted mechanical actuation, gasketed 

2) Weighted mechanical actuation, ungasketed 



	
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ERM 4-1 IIG MinWool Title V App Renewal - 0078842 

4.0 PROGRAM COMPLIANCE 

4.1 PERMIT REQUIRED PERIODIC MONITORING 

The facility proposes to continue to perform the following periodic 

monitoring in accordance with the existing permit: 

• Annual testing for CO, SO2, and particulate matter (PM) from the No. 1 

and No. 2 cupola stack. 

• The pressure drop (∆P) across the baghouses in the No. 1 and No. 2 

Envirotech units will be monitored daily (except when the sources of 

emissions to the baghouses are not being operated) and maintained 

within an approved range in accordance with the facility operation, 

maintenance, and monitoring protocol. 

• Records will be maintained of the sulfur content of the coke used to 

charge the cupolas. 

• Records will be maintained for the operating temperatures of both the 

thermal oxidizer serving the cupola and the afterburner serving the 

curing oven. 

• The baghouses in the No. 1 and No. 2 Envirotech units are equipped 

with monitors which continuously sample and determine if there is a 

leak in any bag. An alarm will sound if a leak is detected. 

Additionally, each permitted unit will be operated within the parameters 

of the initial start-up compliance testing. All equipment, including air 

pollution control equipment will be well maintained and regularly 

inspected. 

4.2 COMPLIANCE ASSURANCE MONITORING 

The facility implements Compliance Assurance Monitoring (“CAM”), 

codified in 40 CFR Part 64, through the requirements of 40 CFR Part 63, 

Subpart DDD “National Emission Standards for Hazardous Air Pollutants 

for Mineral Wool Production”. Because Subpart DDD was adopted after 

November 15, 1990, the monitoring requirements contained with the 

subpart have been deemed to satisfy CAM requirements and separate 

monitoring requirements under Part 64 are not required (40 CFR 64.2). 

It is noted that the facility has a non-Subpart DDD emission limit for PM 

of 117 lb/hr, the only other pollutant outside of Subpart DDD for which 

CAM potentially applies. However, the PM emission limit is much higher 

than the Subpart DDD limit. Source testing performed in May of 2002 for 

initial MACT compliance resulted in PM emissions of less than 1.0 lb/hr 
ERM 4-2 IIG MinWool Title V App Renewal - 0078842 

while meeting the MACT limit of 0.1 lb PM/ton melt with actual 

emissions of 0.667 lb PM/ton of melt. This is two orders of magnitude 

less than the non-Subpart DDD limit of 117 lb/hr. Because CAM for PM 

for the most stringent limitation is being implemented through the 

requirements of Subpart DDD, additional monitoring for the less stringent 

limit is not required. 

4.3 MINERAL WOOL NESHAP APPLICABILITY 

The Mineral Wool NESHAP finalized on June 1, 1999 and codified in 40 

CFR Part 63, Subpart DDD (“the MACT”) applies to this facility. This rule 

has not changed since adoption. A summary of the impact of MACT 

standard on the facility follows. 

4.3.1 Applicability 

The MACT sets two tiers of emission limits for the affected sources. The 

first tier is for existing sources. The second tier is for new and 

reconstructed sources. The first tier emission limits apply to this Facility 

and are listed: 

• Cupola – 0.10 lbs PM per ton of melt product. 

• Curing Ovens – 0.06 lbs formaldehyde per ton of melt production or

80% formaldehyde removal from the emission gases. 

4.3.2 Standards 

In addition to the emission limits the units must comply with operating 

standards established by the MACT. For the cupola these are: 

1. Baghouses must have a bag leak detection system and alarm system. 

Within one hour of the alarm sounding, The Facility must begin and 

complete within a timely manner, corrective action specified in the 

operations, maintenance, and monitoring program. 

2. The Facility must have an operations, maintenance, and monitoring 

program for the baghouses. 

3. If the alarm system is activated for more than 5% of the total operating 

time within a six-month reporting period, the facility will develop and 

implement a written quality improvement program consistent with 40 

CFR Part 64. 
ERM 4-3 IIG MinWool Title V App Renewal - 0078842 

4.3.3 Compliance 

Compliance with the MACT must be demonstrated no later than three 

years from the effective date (i.e., June 1, 1999). Initial compliance must be 

demonstrated by a performance test for both the cupola(s) and curing 

oven(s). 

The facility conducted performance tests as required by the MACT in May 

of 2002. These initial tests documented compliance with PM emission rate 

from the cupola and the formaldehyde emission rate from the curing 

ovens. During the test, cupola incinerator and curing oven afterburner 

operating temperatures were established consistent with the MACT. 

4.3.4 Monitoring Requirements 

In accordance with the requirements of this MACT, the facility performs 

the following monitoring: 

• Continuous monitoring of cupola incinerator temperature 

• Continuous monitoring of curing oven afterburner 

• Continuous monitoring of cupola baghouse exhaust (Envirotech 

unit) via a bag leak detection monitor 

4.4 NOTIFICATION, RECORD KEEPING AND REPORTING 

All required notification, record keeping, and reporting required under 

the new MACT will be observed. All compliance records generated as 

part of the Operating Permits Program will be maintained at the Facility 

for a period of five years. All compliance reports will be submitted to 

ADEM in accordance with applicable state or federal regulation that 

requires the report. 

4.5 COMPLIANCE CERTIFICATION 

ADEM Admin. Code R 335-3-16 requires that Major Source Operating 

Permit Applications contain a certification as to the truth, accuracy, and 

completeness of the application, as well as, to the compliance status of the 

source. As required by this rule, the Plant Manager has signed the 

certification on page iv and the certification page in the ADEM Form 103. 
Appendix A 

Emission Calculations 

for Significant Activities 








Appendix B 

Emission Inventory Summary 










Appendix C 

Emission Calculations for 

Insignificant Activities