FORM A-1

PARENT COMPANY INFORMATION

I. Parent Company / Legal Corporate Owner Information

 1. Legal Parent Company / Legal Corporate Name Guardian Industries Corp.

 2. Address 2300 Harmon Road

 3. City Auburn Hills

 4. State Michigan

 5. Zip Code 48326

 6. County Oakland

 7. Size of Company (approximate number of employees including 

all subsidiaries, branches, and related establishments owned): 18,000
FORM A-2

FACILITY INFORMATION

II. Facility Information

 Facility Name Guardian Fiberglass, Inc Albion

 Facility Address

 Street 1000 E North Street

 City Albion

 State Michigan

 Zip Code 49224

 County Calhoun

 Facility Coordinates

 Latitude (decimal degrees, six decimal places) 42.253925

 Longitude (decimal degrees, six decimal places) 84.739006

 Specific location represented (e.g., front door of main building, centroid 

of property, etc.) front door of main building

 Number of employees attached to the wool fiberglass manufacturing 

facility: CBI

 Design capacity of the plant (tons/yr) CBI

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

 Operation schedule

 hrs/day 24

 days/yr 365

 Identify what state and local air pollution rules and regulations, including 

permit requirements, your plant is subject to. (Please provide copies of 

permit(s) and permit IDs) Please see attached permits.

III. Technical Contact

 Name Grover Thomas

 Technical Contact Title Environmental Manager

 Telephone 517-630-2700

 Facsimile (Fax) 517-630-2009

 Email groverthomas@bp.guardian.com

IV. Other

 Is the facility a major source of HAP? Yes

 

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

classification as a major source:

 Does the facility manufacture other products in addition to wool 

fiberglass? No

 If Yes, list the other products manufactured at the facility.

 Are there any HAP emissions associated with any co-located facilities? 

List unit operations, e.g., boiler, and pollutant/emissions. No
FORM A-2

FACILITY INFORMATION

II. Facility Information

 Facility Name Guardian Fiberglass, Inc Inwood

 Facility Address

 Street 4812 Tabler Station Road

 City Inwood

 State West Virginia

 Zip Code 25428

 County Berkley

 Facility Coordinates

 Latitude (decimal degrees, six decimal places) 39.402947

 Longitude (decimal degrees, six decimal places) 78.023961

 Specific location represented (e.g., front door of main building, centroid 

of property, etc.) front door of main building

 Number of employees attached to the wool fiberglass manufacturing 

facility: CBI

 Design capacity of the plant (tons/yr) CBI

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

 Operation schedule

 hrs/day 24

 days/yr 365

 Identify what state and local air pollution rules and regulations, including 

permit requirements, your plant is subject to. (Please provide copies of 

permit(s) and permit IDs) Please see attached permits.

III. Technical Contact

 Name Grover Thomas

 Technical Contact Title Environmental Manager

 Telephone 517-630-2700

 Facsimile (Fax) 517-630-2009

 Email groverthomas@bp.guardian.com

IV. Other

 Is the facility a major source of HAP? Yes

 

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

classification as a major source:

 Does the facility manufacture other products in addition to wool 

fiberglass? No

 If Yes, list the other products manufactured at the facility.

 Are there any HAP emissions associated with any co-located facilities? 

List unit operations, e.g., boiler, and pollutant/emissions. No
FORM A-2

FACILITY INFORMATION

II. Facility Information

 Facility Name Guardian Fiberglass, Inc Kingman

 Facility Address

 Street 4200 Industrial Blvd

 City Kingman

 State Arizona

 Zip Code 86401

 County Mohave

 Facility Coordinates

 Latitude (decimal degrees, six decimal places) 35.257036

 Longitude (decimal degrees, six decimal places) 113.966261

 Specific location represented (e.g., front door of main building, centroid 

of property, etc.) front door of main building

 Number of employees attached to the wool fiberglass manufacturing 

facility: CBI

 Design capacity of the plant (tons/yr) CBI

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

 Operation schedule

 hrs/day 24

 days/yr 365

 Identify what state and local air pollution rules and regulations, including 

permit requirements, your plant is subject to. (Please provide copies of 

permit(s) and permit IDs) Please see attached permits.

III. Technical Contact

 Name Grover Thomas

 Technical Contact Title Environmental Manager

 Telephone 517-630-2700

 Facsimile (Fax) 517-630-2009

 Email groverthomas@bp.guardian.com

IV. Other

 Is the facility a major source of HAP? No

 

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

classification as a major source: The facility is limited on glass production.

 Does the facility manufacture other products in addition to wool 

fiberglass? No

 If Yes, list the other products manufactured at the facility.

 Are there any HAP emissions associated with any co-located facilities? 

List unit operations, e.g., boiler, and pollutant/emissions. No
FORM A-2

FACILITY INFORMATION

II. Facility Information

 Facility Name Guardian Fiberglass, Inc Mineral Wells

 Facility Address

 Street 7046 State Line Road

 City Olive Branch

 State Mississippi

 Zip Code 38654

 County Desoto

 Facility Coordinates

 Latitude (decimal degrees, six decimal places) 34.993547

 Longitude (decimal degrees, six decimal places) 89.864642

 Specific location represented (e.g., front door of main building, centroid 

of property, etc.) front door of main building

 Number of employees attached to the wool fiberglass manufacturing 

facility: CBI

 Design capacity of the plant (tons/yr) CBI

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

 Operation schedule

 hrs/day 24

 days/yr 365

 Identify what state and local air pollution rules and regulations, including 

permit requirements, your plant is subject to. (Please provide copies of 

permit(s) and permit IDs) Please see attached permits.

III. Technical Contact

 Name Grover Thomas

 Technical Contact Title Environmental Manager

 Telephone 517-630-2700

 Facsimile (Fax) 517-630-2009

 Email groverthomas@bp.guardian.com

IV. Other

 Is the facility a major source of HAP? Yes

 

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

classification as a major source:

 Does the facility manufacture other products in addition to wool 

fiberglass? No

 If Yes, list the other products manufactured at the facility.

 Are there any HAP emissions associated with any co-located facilities? 

List unit operations, e.g., boiler, and pollutant/emissions. No
FORM A-2

FACILITY INFORMATION

II. Facility Information

 Facility Name Guardian Fiberglass, Inc Winnsboro

 Facility Address

 Street 1 Guardian Way

 City Winnsboro

 State South Carolina

 Zip Code 29180

 County Fairfield

 Facility Coordinates

 Latitude (decimal degrees, six decimal places) 34.331453

 Longitude (decimal degrees, six decimal places) 51.054114

 Specific location represented (e.g., front door of main building, centroid 

of property, etc.) front door of main building

 Number of employees attached to the wool fiberglass manufacturing 

facility: CBI

 Design capacity of the plant (tons/yr) CBI

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

 Operation schedule

 hrs/day 24

 days/yr 365

 Identify what state and local air pollution rules and regulations, including 

permit requirements, your plant is subject to. (Please provide copies of 

permit(s) and permit IDs) Please see attached permits.

III. Technical Contact

 Name Grover Thomas

 Technical Contact Title Environmental Manager

 Telephone 517-630-2700

 Facsimile (Fax) 517-630-2009

 Email groverthomas@bp.guardian.com

IV. Other

 Is the facility a major source of HAP? Yes

 

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

classification as a major source:

 Does the facility manufacture other products in addition to wool 

fiberglass? No

 If Yes, list the other products manufactured at the facility.

 Are there any HAP emissions associated with any co-located facilities? 

List unit operations, e.g., boiler, and pollutant/emissions. No
FORM B-1

PLANT OPERATIONS

I. Overview of Plant Operations

Number of process lines. Include lines that are currently 

operational or that are temporarily shutdown. (Do not 

include lines permanently shutdown). 9

For each process line: Process Line 1 Process Line 2 Process Line 3 Process Line 4 Process Line 5 Process Line 6 Process Line 7 Process Line 8 Process Line 9

 Process line identification names or numbers Albion Line 1 Albion Lines 2 and 4Albion Line 3 Inwood Line 1 Inwood Line 2 Kingman Mineral Wells Line 1 Mineral Wells Line 2 Winnsboro

 Type of process line (e.g., rotary spin, flame attenuation) Rotary Spin Rotary Spin Rotary Spin Rotary Spin Rotary Spin Rotary Spin Rotary Spin Rotary Spin Rotary Spin

 Maximum annual production rate (tons/yr) CBI CBI CBI CBI CBI CBI CBI CBI CBI

 Age of process equipment (yrs) 29 11 4 11 6 10 24 4 3

 Remaining economic life of process line (yrs) NA NA NA NA NA NA NA NA NA

 List of products produced and most recent annual 

production (tons/yr; specify year) for each product CBI CBI CBI CBI CBI CBI CBI CBI CBI

Please attach detailed schematics of each process line.
FORM B-2

PLANT OPERATIONS

II. Process - Raw materials Handling and Storage

ALBION MWELLS INWOOD KINGMAN WINNSBORO

 Molten glass preparation

 Raw materials and proportions by wt (%)

Soda Ash 9% Borax 12% 

Cullet 34% Limestone 

9% Sand 31%

Soda Ash 9% Borax 12% 

Cullet 34% Limestone 9% 

Sand 31%

Soda Ash 9% Borax 12% 

Cullet 34% Limestone 9% 

Sand 31%

Soda Ash 9% Borax 12% 

Cullet 34% Limestone 9% 

Sand 31%

Soda Ash 9% Borax 12% 

Cullet 34% Limestone 9% 

Sand 31%

 Method(s) of conveying each raw material to furnace/pots Conveyor Belt

Mix of pneumatic and 

conveyor belt

Mix of pneumatic and 

conveyor belt Conveyor Belt Conveyor Belt

 Binder and Additives

 List each raw material, including premixed materials, in the 

binder formulation and its proportion by wt (%) CBI CBI CBI CBI CBI

 List steps in preparing binder, including storage temperature (°F) 

and holding time (hrs)

 Total yearly consumption of binder (gal/yr) CBI CBI CBI CBI CBI

 Cost of binder ($/gal) for most recent year (2009) CBI CBI CBI CBI CBI

 Are binder storage and mixing tanks vented to outside/inside? Inside Inside Inside Inside Inside

 Method of treating vent air from storage and mix tanks No treatment No treatment No treatment No treatment No treatment 

 Emission control during liquid raw material transfer from vehicles 

to storage tanks.

There are no emission 

controls for unloading

There are no emission 

controls for unloading

There are no emission 

controls for unloading

There are no emission 

controls for unloading

There are no emission 

controls for unloading

Describe future source reduction plans and schedules to reformulate 

A change in wax could be 

coming but at this time it 

is speculation. A vendor 

needs to be chosen 

before costs can be 

obtained. Formaldehyde 

free binder is also being 

considered however a 

A change in wax could be 

coming but at this time it 

is speculation. A vendor 

needs to be chosen 

before costs can be 

obtained. Formaldehyde 

free binder is also being 

considered however a 

A change in wax could be 

coming but at this time it is 

speculation. A vendor 

needs to be chosen before 

costs can be obtained. 

Formaldehyde free binder 

is also being considered 

A change in wax could be 

coming but at this time it is 

speculation. A vendor 

needs to be chosen before 

costs can be obtained. 

Formaldehyde free binder 

is also being considered 

A change in wax could be 

coming but at this time it is 

speculation. A vendor 

needs to be chosen before 

costs can be obtained. 

Formaldehyde free binder 

is also being considered 

The resin is stored at 58-77°F. The ammonia sulfate is mixed with water, then moved to the next tank where the Urea is added. The 

mixture is moved to the pre react tank where resin is added and the prereaction takes place. After pre-reaction is complete Silane, more 

water and Ammonium Hydroxide are added. The temperature of the binder room where mixing takes place is the ambient plant 

temperature which varies by season. Holding time varies based on product need.

Describe future source reduction plans and schedules to reformulate 

binders; List each constituent, proportions wt (%), cost ($/gal) for 

reformulation

considered however a 

vendor has not been 

chosen.

considered however a 

vendor has not been 

chosen.

is also being considered 

however a vendor has not 

been chosen.

is also being considered 

however a vendor has not 

been chosen.

is also being considered 

however a vendor has not 

been chosen.
FORM B-3

PLANT OPERATIONS

III. Process - Glass Melting Furnace

 For each Glass Melting Furnace: Furnace 1 Furnace 2 Furnace 3 Furnace 4 Furnace 5 Furnace 6 Furnace 7 Furnace 8 Furnace 9 Furnace 10

 Process unit identification name/number EU-EM9 EU-EM6 EU-EM7 EU-EM8 Group 002 Group 003 EP2 AB003 AB005 ES1

 Process line(s) served (identification name/number) Albion Line 1 Albion Line 2 Albion Line 4 Albion Line 3 Inwood Line 1 Inwood Line 2 Kingman Mineral Wells Line 1 Mineral Wells Line 2 Winnsboro

 Latitude (decimal degrees, six decimal places) 42.253725 42.253750 42.253750 42.252961 39.402139 39.401586 35.256033 34.993806 34.993806 34.331719

 Longitude (decimal degrees, six decimal places) 84.737864 84.737225 84.737125 84.737136 78.023742 78.022950 113.965628 89.865275 89.865275 51.084525

 Stack or vent height (units) 125 feet 125 feet 125 feet 150 feet 60.31 feet 60.31 feet 100 feet 62 feet high 72 feet 100 feet

 Stack or vent diameter (units) 48 inches 48 inches 48 inches 42 inches 28 inches 28 inches 42 inches 34 inches 30 inches 3.5 feet

 Manufacturer and model GF Proprietary design GF Proprietary design GF Proprietary design GF Proprietary design

GF Proprietary 

design GF Proprietary design

GF Proprietary 

design

GF Proprietary 

design

GF Proprietary 

design

GF Proprietary 

design

 Date of original installation 1980 1999 2006 2005 1998 2004 1999 1986 2005 2006

 Estimate of remaining lifetime (yrs)

Not Applicable as 

melters can last 

indefinitely with 

routine maintenance

Not Applicable as 

melters can last 

indefinitely with 

routine maintenance

Not Applicable as 

melters can last 

indefinitely with 

routine maintenance

Not Applicable as 

melters can last 

indefinitely with 

routine maintenance

Not Applicable as 

melters can last 

indefinitely with 

routine maintenance

Not Applicable as 

melters can last 

indefinitely with 

routine maintenance

Not Applicable as 

melters can last 

indefinitely with 

routine maintenance

Not Applicable as 

melters can last 

indefinitely with 

routine maintenance

Not Applicable as 

melters can last 

indefinitely with 

routine maintenance

Not Applicable as 

melters can last 

indefinitely with 

routine maintenance

 Major rebuilds:

 What constitutes a major rebuild

 Frequency of a major rebuild NA NA NA NA NA NA NA NA NA NA

 Cost of typical major rebuild NA NA NA NA NA NA NA NA NA NA

 Date of last major rebuild NA NA NA NA NA NA NA NA NA NA

 Purpose of last major rebuild NA NA NA NA NA NA NA NA NA NA

 Increase or decrease in emissions NA NA NA NA NA NA NA NA NA NA

 Fuel type: electric, gas, or oil Electric Electric Electric Electric Electric Electric Electric Electric Electric Electric Fuel consumption rate (KW/ton of glass or Btu/ton of 

glass) CBI CBI CBI CBI CBI CBI CBI CBI CBI CBI

 List HAPs that are in refractory material Chromium, Lead Chromium, Lead Chromium, Lead Chromium, Lead Chromium, Lead Chromium, Lead Chromium, Lead Chromium, Lead Chromium, Lead Chromium, Lead

 Design production rate (tons/day) CBI CBI CBI CBI CBI CBI CBI CBI CBI CBI

 Actual glass pull rate (tons/day) CBI CBI CBI CBI CBI CBI CBI CBI CBI CBI

The company undertakes routine refractory repair and replacement projects every few years. These projects do not impact the furnace emissions, and therefore are not considered major rebuilds for the purpose of this ICR. The 

company undertakes routine repair and replacement projects that coincide with the furnace repairs. As with the furnace, these projects are normally "as-is" maintenance projects that do not impact the oven emissions. Therefore, 

the company does not consider these to be major rebuilds for the purpose of this ICR.

 Actual glass pull rate (tons/day) CBI CBI CBI CBI CBI CBI CBI CBI CBI CBI

 Vent gas flow rate (acfm @ °F) 15,000 cfm @ 200°F 15,000 cfm @ 200°F 15,000 cfm @ 200°F 15,000 cfm @ 200°F 15,000 cfm @ 200°F 15,000 cfm @ 200°F 15,000 cfm @ 200°F 15,000 cfm @ 150°F 15,000 cfm @ 150°F 15,000 cfm @ 200°F

 Temperature (°F) of molten glass in furnace and 

forehearth (if applicable) Up to 3000°F Up to 3000°F Up to 3000°F Up to 3000°F Up to 3000°F Up to 3000°F Up to 3000°F Up to 3000°F Up to 3000°F Up to 3000°F

 Nature and frequency of routine/preventive 

maintenance procedures

A profile of the melter 

is completed monthly 

and additional 

refractory is added to 

weak spots if needed.

A profile of the melter 

is completed monthly 

and additional 

refractory is added to 

weak spots if needed.

A profile of the melter 

is completed monthly 

and additional 

refractory is added to 

weak spots if needed.

A profile of the melter 

is completed monthly 

and additional 

refractory is added to 

weak spots if needed.

A profile of the melter 

is completed monthly 

and additional 

refractory is added to 

weak spots if 

needed.

A profile of the melter 

is completed monthly 

and additional 

refractory is added to 

weak spots if needed.

A profile of the 

melter is completed 

monthly and 

additional refractory 

is added to weak 

spots if needed.

A profile of the melter 

is completed monthly 

and additional 

refractory is added to 

weak spots if 

needed.

A profile of the melter 

is completed monthly 

and additional 

refractory is added to 

weak spots if needed.

A profile of the 

melter is completed 

monthly and 

additional refractory 

is added to weak 

spots if needed.

 Describe process modification(s) since 1999 that 

reduce emissions none none none none none none none none none none

 Describe future source reduction plans and schedules none none none none none none none none none none
FORM B-4

PLANT OPERATIONS

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

 For each Forming Operation -- Rotary Spin/Flame Attenuation Forming Operation 1 Forming Operation 2 Forming Operation 3 Forming Operation 4 Forming Operation 5 Forming Operation 6 Forming Operation 7

 Process unit identification name/number EU-RESFORMCOL EU-RFC2 Group 004 Group 005 EP1 AC002 ES3

 Process line(s) served (identification name/number) Albion Line 1 Albion Line 3 Inwood Line 1 Inwood Line 2 Kingman Mineral Wells Line 1 Winnsboro

 Latitude (decimal degrees, six decimal places) 42.253694 42.252956 39.402164 39.401628 35.256147 34.993881 34.331597

 Longitude (decimal degrees, six decimal places) 84.738019 84.737217 78.023933 78.022964 113.965800 89.865247 51.084467

 Stack or vent height (units) 168 feet 168 feet 120 feet 120 feet 135 feet 90 feet 100 feet

 Stack or vent diameter (units) 86 inches 90 inches 78 inches 86 inches 78 inches 66 inches 6.67 feet

 Number of fiber forming devices (spinners) per line. 9 9 8 8 7 8 8

 Method of attenuating fiber (e.g., air, flame, or air and flame). 

Indicate type of burner used (if flame). air air air air air air air

 Is there a forehearth between the furnace and the forming 

section? yes yes yes yes yes yes yes

 Major rebuilds:

 What constitutes a major rebuild Please see cover letter Please see cover letter Please see cover letter Please see cover letter Please see cover letter Please see cover letter Please see cover letter 

 Frequency of a major rebuild NA NA NA NA NA NA NA

 Cost of typical major rebuild NA NA NA NA NA NA NA

 Date of last major rebuild NA NA NA NA NA NA NA

 Purpose of last major rebuild NA NA NA NA NA NA NA

 Increase or decrease in emissions NA NA NA NA NA NA NA

 If modular, number of modules and plenums plenums plenums plenums plenums plenums 3 modules and 3 plenums plenums

 Presence of water overspray and application rate (gpm) 3.5-6 up to 6.5 5-6 Shut down 4-6.5 4 - 8 3.3-5

 Binder applied and application rate (gpm) 3.5-5.5 up to 5.6 5-7 Shut down 4.2-6.1 4.5-7.5 3.5-4.5

 Other material applied and application rate (gpm) NA NA NA NA NA NA NA

 Temperature of glass fiber when binder is applied (°F) 200 250 200 150-200 225 200

 Temperature of binder when applied to fibers (°F) 75-80 86 75 73-80 80 75-85

Dampers and suction Dampers and suction Dampers and suction Dampers and suction Dampers and suction Dampers and suction fans Dampers and suction 

 Method of evenly distributing fibers onto forming conveyor

Dampers and suction 

fans are used to 

distribute fibers evenly

Dampers and suction 

fans are used to 

distribute fibers evenly

Dampers and suction 

fans are used to 

distribute fibers evenly

Dampers and suction 

fans are used to 

distribute fibers evenly

Dampers and suction 

fans are used to 

distribute fibers evenly

Dampers and suction fans 

are used to distribute 

fibers evenly

Dampers and suction 

fans are used to 

distribute fibers evenly

 Formed mat thickness (in.) Up to 14 in Up to 18 in Up to 14 in Up to 14 in Up to 14 in Up to 14 in Up to 14 in

 Forming air flow rate (acfm @ °F) 80,000 cfm @ 115°F 140,000 cfm @ 170°F 80,000 cfm @ 110°F 100,000 cfm @ 110°F 100,000 cfm @ 120°F 80,000 cfm @ 140°F 130,000 cfm @ 110°F

 Percent of forming air recirculated and percent exhausted exhausted exhausted exhausted exhausted exhausted exhausted exhausted

 Nature and frequency of routine/preventive maintenance 

procedures

inspected daily and 

cleaned weekly. Every 6 

to 8 weeks extensive 

cleaning is done.

inspected daily and 

cleaned weekly. Every 6 

to 8 weeks extensive 

cleaning is done.

inspected daily and 

cleaned weekly. Every 6 

to 8 weeks extensive 

cleaning is done.

inspected daily and 

cleaned weekly. Every 6 

to 8 weeks extensive 

cleaning is done.

inspected daily and 

cleaned weekly. Every 6 

to 8 weeks extensive 

cleaning is done.

inspected daily and 

cleaned weekly. Every 6 

to 8 weeks extensive 

cleaning is done.

inspected daily and 

cleaned weekly. Every 6 

to 8 weeks extensive 

cleaning is done.

 Describe process modification(s) since 1999 that reduce 

emissions

No process modifications 

have been done that 

reduce emissions

No process modifications 

have been done that 

reduce emissions

No process modifications 

have been done that 

reduce emissions

No process 

modifications have been 

done that reduce 

emissions

No process 

modifications have been 

done that reduce 

emissions

No process modifications 

have been done that 

reduce emissions

No process 

modifications have been 

done that reduce 

emissions

 Describe future source reduction plans and schedules

There are no plans at 

this time.

There are no plans at 

this time.

There are no plans at 

this time.

There are no plans at 

this time.

There are no plans at 

this time.

There are no plans at this 

time.

There are no plans at 

this time.
FORM B-5

PLANT OPERATIONS

V. Process - Curing 

 For each Curing Oven: Curing Oven 1 Curing Oven 2 Curing Oven 3 Curing Oven 4 Curing Oven 5 Curing Oven 6 Curing Oven 7

 Process unit identification name/number EU-RESCURE EU-RC2 Group 006 Group 007 EP3 AC001 ES4

 Process line(s) served (identification name/number) Albion Line 1 Albion Line 3 Inwood Line 1 Inwood Line 2 Kingman Mineral Wells Line 1 Winnsboro

 Latitude (decimal degrees, six decimal places) 42.253700 42.252961 39.402417 39.402022 35.256347 34.993653 34.331464

 Longitude (decimal degrees, six decimal places) 84.738322 84.737350 78.023169 78.022714 113.965783 89.865033 51.084442

 Stack or vent height (units) 168 feet 168 feet 120 feet 120 feet 135 feet 90 feet 100 feet

 Stack or vent diameter (units) 86 inches 90 inches 78 inches 57 inches 78 inches 66 inches 6.67 feet

 Method of curing gas fired oven gas fired oven gas fired oven gas fired oven gas fired oven gas fired oven gas fired oven

 Manufacturer and model Midwest GF Proprietary design GF Proprietary design GF Proprietary design GF Proprietary design Midwest GF Proprietary design

 Date of original installation 1980 2006 1998 2004 1999 1986 2006

 Major rebuilds:

 What constitutes a major rebuild Please see cover letter Please see cover letter Please see cover letter Please see cover letter Please see cover letter Please see cover letter Please see cover letter 

 Frequency of a major rebuild NA NA NA NA NA NA NA

 Cost of typical major rebuild NA NA NA NA NA NA NA

 Date of last major rebuild NA NA NA NA NA NA NA

 Purpose of last major rebuild NA NA NA NA NA NA NA

 Increase or decrease in emissions NA NA NA NA NA NA NA

 Fuel type: electric, gas, or oil gas gas gas gas gas gas gas 

 Fuel consumption rate (KW/hr or BTU/hr) CBI CBI CBI CBI CBI CBI CBI

 Moisture content wt (%) of formed mat: 

 inlet 2% 2% 2% 2% 2% 2% 2%

 outlet 0% 0% 0% 0% 0% 0% 0%

 Air flow rate (acfm @ °F) from curing 34,000 cfm @ 125°F 140,000 cfm @ 170°F 34,000 cfm @ 235°F 34,000 cfm @ 228°F 34,000 cfm @ 275°F 34,000 cfm @ 140°F 34,000 cfm @ 230°F

 Exhaust air temperature (°F) 200-250°F 200-250°F 200-250°F 200-250°F 200-250°F 200-250°F 200-250°F

 Residence time of product (mins)

Up to 5 minutes depending 

on product

Up to 5 minutes depending 

on product

Up to 5 minutes depending 

on product

Up to 5 minutes 

depending on product

Up to 5 minutes 

depending on product

Up to 5 minutes depending 

on product

Up to 5 minutes 

depending on product

 Binder content of cured product (LOI) Up to 8.4 Up to 7.2 Up to 8.3 Up to 6.6 Up to 8.1 Up to 8.4 Up to 8.9

 Nature and frequency of routine/preventive 

maintenance procedures

Every 6 to 8 weeks extensive 

cleaning is done and any 

needed repairs are done at 

that time

Every 6 to 8 weeks extensive 

cleaning is done and any 

needed repairs are done at 

that time

Every 6 to 8 weeks extensive 

cleaning is done and any 

needed repairs are done at 

that time

Every 6 to 8 weeks 

extensive cleaning is 

done and any needed 

repairs are done at that 

time

Every 6 to 8 weeks 

extensive cleaning is 

done and any needed 

repairs are done at that 

time

Every 6 to 8 weeks 

extensive cleaning is done 

and any needed repairs are 

done at that time

Every 6 to 8 weeks 

extensive cleaning is 

done and any needed 

repairs are done at that 

time

 Describe process modification(s) since 1999 that 

reduce emissions None None None None None None

Low NOx burners were 

included during 

construction

 Describe future source reduction plans and 

schedules None at this time None at this time None at this time None at this time None at this time None at this time None at this time
FORM B-6

PLANT OPERATIONS

VI. Process - Cooling

 For each Cooling Operation: Cooling Operation 1 Cooling Operation 2 Cooling Operation 3 Cooling Operation 4 Cooling Operation 5 Cooling Operation 6 Cooling Operation 7

 Process unit identification name/number EU-RESCURE EU-RC2 Group 006 Group 007 EP3 AC001 ES4

 Process line(s) served (identification name/number) Albion Line 1 Albion Line 3 Inwood Line 1 Inwood Line 2 Kingman Mineral Wells Line 1 Winnsboro

 Latitude (decimal degrees, six decimal places) 42.253694 42.252956 39.402486 39.402033 35.256639 34.993594 34.331386

 Longitude (decimal degrees, six decimal places) 84.738600 84.737556 78.023561 78.022692 113.965811 89.864961 51.084397

 Stack or vent height (units) 168 feet 168 feet 120 feet 120 feet 135 feet 90 feet 100 feet

 Stack or vent diameter (units) 86 inches 90 inches 78 inches 57 inches 78 inches 66 inches 6.67 feet

 Cooling air flow rate (acfm @ °F) 16,000 cfm @ 125°F 140,000 cfm @ 170°F 16,000 cfm @ 235°F 16,000 cfm @ 228°F 16,000 cfm @ 275°F 16,000 cfm @ 140°F 16,000 cfm @ 230°F

 Percentage of cooling air recirculated (if any) None None None None None None None

 Cooling air temperature (°F)

room temperature, varies 

by season

room temperature, varies 

by season

room temperature, 

varies by season

room temperature, 

varies by season

room temperature, varies 

by season

room temperature, varies 

by season

room temperature, 

varies by season

 Nature and frequency of routine/preventive 

maintenance procedures

Every 6 to 8 weeks 

extensive cleaning is 

Every 6 to 8 weeks 

extensive cleaning is 

Every 6 to 8 weeks 

extensive cleaning is 

Every 6 to 8 weeks 

extensive cleaning is 

Every 6 to 8 weeks 

extensive cleaning is 

Every 6 to 8 weeks 

extensive cleaning is 

Every 6 to 8 weeks 

extensive cleaning is 

 Describe process modification(s) since 1999 that 

reduce emissions None None None None None None None

 Describe future source reduction plans and 

schedules None None None None None None None
FORM B-7

PLANT OPERATIONS

VII. Process - Use of Solvents

 Use of Solvents

 Volatile solvents used at your facility (where and how used) There are no solvents used in the process

 List each solvent used and quantity (gal/yr)

 Emission control device(s) used to control emissions from solvent 

usage/storage?
FORM B-8

PROCESS OPERATIONS

VIII. Pollution Prevention

Please describe any work practices, pollution prevention techniques, 

and control strategies evaluated and/or implemented at each process 

unit at your facility (e.g., binder reformulation, alternative fuels usage, 

etc.) to reduce emissions of PM and HAPs you identified in Form E. 

You must specify the year in which the facility implemented the 

practice/technique and identify the emission reductions (if measured) 

from these practices/techniques.

A stringent maintenance routine is in place for the control 

devices to help them work at the optimal level which has 

an effect of PM and HAP emissions. Please see Form C 

for more information on maintenance.
FORM C-2

AIR POLLUTION CONTROL

II. Scrubber

 For each Scrubber: Scrubber 1 Scrubber 2 Scrubber 3 Scrubber 4 Scrubber 5 Scrubber 6 Scrubber 7 Scrubber 8 Scrubber 9

 Process line(s) (identification name/number) Albion Line 1 Albion Line 1 Albion Line 3 Albion Line 3 Inwood Line 2 Inwood Line 2 Mineral Wells Winnsboro Winnsboro

 Equipment/process(es) controlled. Include emission point 

designations (e.g., E3, E4 from plot plan) EU-RESFORMCOL

Combined stack with the 

HEAF

EU-RFC2 Combined stack 

with EU-RC2

EU-RC2 Combined stack 

with EU-RFC2 Group 005

Group 007 Combined 

stack with the RTO AC002 ES3 

ES4 Combined with RTO 

stack

 Latitude (decimal degrees, six decimal places) 42.253653 42.253572 42.252986 42.252858 39.401572 39.401878 34.993889 34.331472 34.331386

 Longitude (decimal degrees, six decimal places) 84.738019 84.738567 84.737231 84.737419 78.022964 78.022300 89.865347 51.084575 51.084492

 Stack or vent height (units) 168 feet 150 feet 168 feet 168 feet 120 feet 120 feet 90 feet 100 feet 100 feet

 Stack or vent diameter (units) 86 inches 60 inches 90 inches 90 inches 86 inches 57 inches 66 inches 6.67 feet 5 feet

 Manufacturer and model

3- Fisher Klosterman 

MS850 Fisher Klosterman MS650

Fisher Klosterman MS850 

Fisher Klosterman 

MS1100 

3-Fisher Klosterman 

MS650

2-Fisher Klosterman 

MS850 Fisher 

Klosterman MS650 Fisher Klosterman MS650

2- Fisher Klosterman 

MS850

3- Fisher Klosterman 

MS850 Fisher Klosterman MS650

 Date of original installation

2-850: 2005 1-850: 

2008 2006 2006 2006 2004 2004 2001 2006 2006

 Type (e.g., venturi, orifice) venturi venturi venturi venturi venturi venturi venturi venturi venturi

 Gas flow rate to scrubber (acfm @ °F) 102,159 acfm @ 102.8°F 55,575 acfm @ 136.5°F 124,362 acfm @ 106°F 124,362 acfm @ 106°F 71,372 acfm @ 107°F 29,284 acfm @ 258°F 65,610 acfm @ 117°F 125,776 acfm @ 101.7°F 32,151 acfm @ 211.7°F

 Inlet gas temperature (°F) Not tested Not tested Not tested Not tested Not tested Not tested Not tested Not tested Not tested

 Outlet gas temperature (°F) 102.8°F 136.5°F 106°F 106°F 107°F 258°F 117°F 101.7°F 211.7°F

 Inlet grain loading (gr/dscf) Not tested Not tested Not tested Not tested Not tested Not tested Not tested Not tested Not tested

 Outlet grain loading (gr/dscf) 0.0059 0.02035 0.00875 0.00875 0.0085 0.0025 0.01455 0.0053 0.0016

 Average stack opacity (%) <5% <5% <5% <5% <5% <5% <5% <5% <5%

 Water flow rate to scrubber (gpm)

Parameters set from stack 

test 171-271

Parameters set from stack 

test 145-198

Parameters set from stack 

test MS850 158-195 

MS1100 163-204 

Parameters set from stack 

test 130-169

Parameters set from stack 

test 189-392

Parameters set from stack 

test 94-219

Parameters set from stack 

test 170-328

Parameters set from stack 

test 148-256

Parameters set from stack 

test 101-161

 Percent of scrubber water from recycled wastewater 0 0 0 0 0 0 0 0 0

 Source of scrubbing water and type of pretreatment. Substance(s) 

added as part of pretreatment and amount used (gpm or lbs/hr)

closed loop system with 

city water added only due 

to evaporation. No 

treatment chemicals are 

used

closed loop system with 

city water added only due 

to evaporation. No 

treatment chemicals are 

used

closed loop system with 

city water added only due 

to evaporation. No 

treatment chemicals are 

used

closed loop system with 

city water added only due 

to evaporation. No 

treatment chemicals are 

used

closed loop system with 

city water added only due 

to evaporation. No 

treatment chemicals are 

used

closed loop system with 

city water added only due 

to evaporation. No 

treatment chemicals are 

used

closed loop system with 

city water added only due 

to evaporation. No 

treatment chemicals are 

used

closed loop system with 

city water added only due 

to evaporation. No 

treatment chemicals are 

used

closed loop system with 

city water added only due 

to evaporation. No 

treatment chemicals are 

used

 HAP composition of wastewater (mg/L) NA NA NA NA NA NA NA NA NA

 Concentration (mg/L) of dissolved and suspended solids in 

scrubbing water Usually range from 1-6% Usually range from 1-6% Usually range from 1-6% Usually range from 1-6% Usually range from 1-6% Usually range from 1-6% Usually range from 1-6% Usually range from 1-6% Usually range from 1-6%

 Scrubbing water temperature (°F)

Varies by season but 

generally slightly warmer 

than ambient temperature

Varies by season but 

generally slightly warmer 

than ambient temperature

Varies by season but 

generally slightly warmer 

than ambient temperature

Varies by season but 

generally slightly warmer 

than ambient temperature

Varies by season but 

generally slightly warmer 

than ambient temperature

Varies by season but 

generally slightly warmer 

than ambient temperature

Varies by season but 

generally slightly warmer 

than ambient temperature

Varies by season but 

generally slightly warmer 

than ambient temperature

Varies by season but 

generally slightly warmer 

than ambient temperature

 Liquid/gas ratio (gal/103 acfm) 8 gal/ 1,000 ACFM 8 gal/ 1,000 ACFM 8 gal/ 1,000 ACFM 8 gal/ 1,000 ACFM 4 gal/ 1,000 ACFM 4 gal/ 1,000 ACFM 8 gal/ 1,000 ACFM max 15 gal/ 1,000 ACFM max 20 gal/ 1,000 ACFM

 Pressure drop across scrubber (in. H2O gauge)

Parameters set from stack 

test 4.6-10

Parameters set from stack 

test 6.4-10

Parameters set from stack 

test MS850 4.4-10.1 

MS1100 4-10.1 

Parameters set from stack 

test 5.9-9.9

Parameters set from stack 

test 6.9-14

Parameters set from stack 

test 6.9-15

Parameters set from stack 

test 4.55-7.79

Parameters set from stack 

test 4-12.2

Parameters set from stack 

test 4.1-11.2

 Amount of wastewater generated (gpd)

The scrubber water is a 

closed loop system with 

water loss only due to 

evaporation. 

The scrubber water is a 

closed loop system with 

water loss only due to 

evaporation. 

The scrubber water is a 

closed loop system with 

water loss only due to 

evaporation. 

The scrubber water is a 

closed loop system with 

water loss only due to 

evaporation. 

The scrubber water is a 

closed loop system with 

water loss only due to 

evaporation. 

The scrubber water is a 

closed loop system with 

water loss only due to 

evaporation. 

The scrubber water is a 

closed loop system with 

water loss only due to 

evaporation. 

The scrubber water is a 

closed loop system with 

water loss only due to 

evaporation. 

The scrubber water is a 

closed loop system with 

water loss only due to 

evaporation. 

 Amount of wastewater recycled (gpd) 0 0 0 0 0 0 0 0 0

 Amount of wastewater disposed of (gpd) 0 0 0 0 0 0 0 0 0

 Method of wastewater disposal NA NA NA NA NA NA NA NA NA

 Quantity of solid waste collected (lbs/yr) 0 0 0 0 0 0 20,080 0 0

 Quantity of solid waste recycled (lbs/yr) 0 0 0 0 0 0 0 0 0

 Quantity of solid waste disposed of (lbs/yr) 0 0 0 0 0 0 20,080 0 0

 Method of solid waste disposal 0 0 0 0 0 0 Landfill 0 0

 Vendor guarantee on scrubber efficiency (attach copy) Vendor guarantee on scrubber efficiency (attach copy) See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached 

 Nature and frequency of preventive maintenance procedures

Weekly maintenance is 

done on the fan and motor 

and every 6 to 8 weeks 

extensive cleaning is done 

Weekly maintenance is 

done on the fan and motor 

and every 6 to 8 weeks 

extensive cleaning is done 

Weekly maintenance is 

done on the fan and motor 

and every 6 to 8 weeks 

extensive cleaning is done 

Weekly maintenance is 

done on the fan and motor 

and every 6 to 8 weeks 

extensive cleaning is done 

Weekly maintenance is 

done on the fan and motor 

and every 6 to 8 weeks 

extensive cleaning is done 

Weekly maintenance is 

done on the fan and motor 

and every 6 to 8 weeks 

extensive cleaning is done 

Weekly maintenance is 

done on the fan and motor 

and every 6 to 8 weeks 

extensive cleaning is 

done 

Weekly maintenance is 

done on the fan and motor 

and every 6 to 8 weeks 

extensive cleaning is done 

Weekly maintenance is 

done on the fan and motor 

and every 6 to 8 weeks 

extensive cleaning is done 

 Problems experienced with control device within the last five years; 

how were problems solved?

problems with the 

scrubbers

problems with the 

scrubbers

problems with the 

scrubbers

problems with the 

scrubbers

problems with the 

scrubbers

problems with the 

scrubbers

problems with the 

scrubbers

problems with the 

scrubbers

problems with the 

scrubbers

 Continuous monitoring method(s) used to monitor scrubber 

performance, including parameters monitored

Water flow and differential 

pressure are recorded 

every 15 minutes

Water flow and differential 

pressure are recorded 

every 15 minutes

Water flow and differential 

pressure are recorded 

every 15 minutes

Water flow and differential 

pressure are recorded 

every 15 minutes

Water flow and differential 

pressure are recorded 

every 15 minutes

Water flow and differential 

pressure are recorded 

every 15 minutes

Water flow and differential 

pressure are recorded 

every 15 minutes

Water flow and differential 

pressure are recorded 

every 15 minutes

Water flow and differential 

pressure are recorded 

every 15 minutes

 Plans to replace or upgrade scrubber None at this time None at this time None at this time None at this time None at this time None at this time None at this time None at this time None at this time
FORM C-4

AIR POLLUTION CONTROL

IV. Fabric Filter 

 For each Fabric Filter: Fabric Filter 1 Fabric Filter 2 Fabric Filter 3 Fabric Filter 4 Fabric Filter 5 Fabric Filter 6 Fabric Filter 7 Fabric Filter 8

 Process line(s) (identification name/number) Albion Line 1, 2 and 4 Albion Line 3 Inwood Line 1 Inwood Line 2 Kingman Mineral Wells Line 1 Mineral Wells Line 2 Winnsboro

 Equipment/process(es) controlled. Include emission 

point designations (e.g., E3, E4 from plot plan) EU-EM6,7&9 EU-EM8 Group 002 Group 003

EP2 combined stack with a 

drop out box AB003 AB005 ES1

 Latitude (decimal degrees, six decimal places) 42.253592 42.253008 39.402108 39.401572 35.255958 34.993911 34.993411 34.331772

 Longitude (decimal degrees, six decimal places) 84.737608 84.737231 78.023967 78.022864 113.965628 89.865383 89.865339 51.084456

 Stack or vent height (units) 125 feet 150 feet 60.31 feet 60.31 feet 100 feet 62 feet high 72 feet 100 feet

 Stack or vent diameter (units) 48 inches 42 inches 28 inches 28 inches 42 inches 34 inches 30 inches 3.5 feet

 Manufacturer and model

Any combination of 2 (2)- 

Rayjets and (1)-Mactiflo 

4MTF128

MAC Equipment 78-LSTC144, Style IIIMAC 4- MTF96 Mactiflo and 

Mactiflo 4MTF32 backup MAC 4- MTF96 Mactiflo MAC 4- MTF96 Mactiflo MAC 4- MTF96 Mactiflo

BACT Cartridge dust 

collector

MAC Equipment 78-LSTC144, Style III

 Date of original installation

Rayjets- 1980 Mactiflo1999 2005 1998 2004 1999 1986 2006 2006

 Number of compartments 1 1 1 1 1 1 2 1

 Number of bags per compartment Rayjets- 150 Mactiflo- 128 144 filters

96 filters MTF96 and 32 

filters MTF32 96 filters 96 filters 96 filters 70 filters 144 filters

 Filter material and coatings applied Polyester Cartridge Polyester Cartridge Polyester Cartridge Polyester Cartridge Polyester Cartridge Polyester Cartridge Polyester Cartridge Polyester Cartridge

 Fabric weight (oz/yd2) Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable Not applicable

 Filter surface area (ft2)

Rayjets- 8,530 

Mactiflo- 14,080 8,200

10,560 MTF96 and 3,530 

MTF32 10,560 10,560 10,560 7,040 8,200

 Gas flow rate to filter (acfm @ °F) 44,024 cfm @ 117°F 17,553 cfm @ 116°F 15,000 cfm @ 200°F 15,000 cfm @ 200°F 15,000 cfm @ 200°F 15,000 cfm @ 150°F 15,000 cfm @ 150°F 13,622 cfm @ 131.4°F

 Inlet gas temperature (°F) Not tested Not tested Not tested Not tested Not tested Not tested Not tested Not tested

 Outlet gas temperature (°F) 117°F 116°F 159.2°F 149.2°F 161°F 116°F 151.8°F 131.4

 Inlet grain loading (gr/dscf) Not tested Not tested Not tested Not tested Not tested Not tested Not tested Not tested

 Outlet grain loading (gr/dscf) 0.0018 0.0012 0.0012 0.001 0.00137 0.0005 0.00132 0.0004

 Average stack opacity (%) 0% 0% 0% 0% 0% 0% 0% 0%

 Overall pressure drop (in. H2O gauge) Less than 6 Less than 6 Less than 6 Less than 6 Less than 6 Less than 6 Less than 6 Less than 6

 Method and frequency of bag cleaning

Pulse cleaning whenever the 

differential pressure is above 

the setpoint

Pulse cleaning whenever the 

differential pressure is above 

the setpoint

Pulse cleaning whenever the 

differential pressure is above 

the setpoint

Pulse cleaning whenever the 

differential pressure is above 

the setpoint

Pulse cleaning whenever the 

differential pressure is above 

the setpoint

Pulse cleaning whenever the 

differential pressure is above 

the setpoint

Pulse cleaning whenever the 

differential pressure is above 

the setpoint

Pulse cleaning whenever the 

differential pressure is above 

the setpoint

 Vendor guarantee on fabric filter efficiency (attach 

copy) See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached 

 Quantity of solid waste collected (lbs/yr) 196,292 Line not in operation currently 414,600 631,467 Line was not in operation 533,941

 Quantity of solid waste recycled (lbs/yr) 195,980 Line not in operation currently 413,400 631,217 Line was not in operation 533,941

 Quantity of solid waste disposed of (lbs/yr) 312 Line not in operation currently 1,200 250 Line was not in operation 0

 Method of solid waste disposal Landfill Landfill Landfill Landfill Landfill Landfill

 Nature and frequency of preventive maintenance 

procedures

The BLDS is calibrated every 

month and bags are 

replaced as needed

The BLDS is calibrated every 

month and bags are 

replaced as needed

The BLDS is calibrated every 

month and bags are 

replaced as needed

The BLDS is calibrated every 

month and bags are 

replaced as needed

The BLDS is calibrated every 

month and bags are replaced 

as needed

The BLDS is calibrated every 

month and bags are replaced 

as needed

The BLDS is calibrated 

every month and bags are 

replaced as needed

The BLDS is calibrated 

every month and bags are 

replaced as needed

There have been no There have been no There have been no There have been no There have been no problems There have been no problems 

There have been no 

problems with the 

There have been no 

problems with the 

1,270,813 lbs of dust collected

1,268,613 lbs of recycled dust is total collected

2,200 lbs of dust is disposed of combined

Landfill

 Problems experienced with control device within the 

last five years; how were problems solved?

problems with the baghouses 

in the last five years.

problems with the baghouses 

in the last five years.

problems with the baghouses 

in the last five years.

problems with the baghouses 

in the last five years.

with the baghouses in the last 

five years.

with the baghouses in the last 

five years.

baghouses in the last five 

years.

baghouses in the last five 

years.

 Continuous monitoring method(s) used to monitor 

performance, including parameters monitored

A BLDS is installed as 

required

A BLDS is installed as 

required

A BLDS is installed as 

required

A BLDS is installed as 

required

A BLDS is installed as 

required

A BLDS is installed as 

required

A BLDS is installed as 

required

A BLDS is installed as 

required

 Plans to replace or upgrade fabric filter Not at this time Not at this time Not at this time Not at this time Not at this time Not at this time Not at this time Not at this time
FORM C-5

AIR POLLUTION CONTROL

V. Thermal Incinerator

 For each Thermal Incinerator: Thermal Incinerator 1 Thermal Incinerator 2 Thermal Incinerator 3 Thermal Incinerator 4

 Process line(s) (identification name/number) Inwood Line 1 Inwood Line 2 Kingman Winnsboro

 Equipment/process(es) controlled. Include emission 

point designations (e.g., E3, E4 from plot plan) Group 006 Group 007 EP3 EP4

 Latitude (decimal degrees, six decimal places) 39.402225 39.401822 35.256508 34.331475

 Longitude (decimal degrees, six decimal places) 78.024003 78.022331 113.966111 51.084569

 Stack or vent height (units) 120 feet 120 feet 135 feet 100 feet

 Stack or vent diameter (units) 78 inches 86 inches 78 inches 6.67 feet

 Manufacturer and model United McGill Model 2-151 United McGill Model MCT30.0 United McGill Model 2-151 United McGill Model 2-170

 Date of original installation 1998 2004 1999 2006

 Fuel type: gas or oil gas gas gas gas

 Fuel consumption rate (BTU/hr) 2.628 MMft3/hr 1.785 MMft3/hr 2.628 MMft3/hr 4.56 mmBTU/hr

 Inlet gas flow rate (acfm @ °F)

design of 50,418 acfm @ 

150°F

design of 40,997 acfm @ 

250°F

design of 50,418 acfm @ 

150°F

design of 67,919 acfm @ 

250°F

 Inlet gas temperature (°F) Not tested Not tested Not tested Not tested

 Combustion chamber gas temperature (°F) minimum 1525°F minimum 1556°F minimum 1550°F minimum 1507°F

 Outlet gas temperature (°F) 256°F 258°F 260 211.7

 Inlet grain loading (gr/dscf) Not tested Not tested Not tested Not tested

 Outlet grain loading (gr/dscf) 0.0007 0.0025 0.00165 0.0016

 Average stack opacity (%) <5% <5% <5% <5%

 Excess air (%) maximum of 15% maximum of 15% maximum of 15% maximum of 15%

 Residence time (sec) at temperature (°F) 0.9 seconds at 1500°F 1.0 seconds at 1500°F 0.9 seconds at 1500°F 0.9 seconds at 1500°F

 Percent heat recovery 94.18% 93.87% 94.18% 92.91%

 Vendor guarantee on incinerator efficiency (attach 

copy) Please see attached letter Please see attached letter Please see attached letter Please see attached letter

 Nature and frequency of preventive maintenance 

procedures

Bake outs are done as 

needed and a thorough 

inspection is done annually

Bake outs are done as 

needed and a thorough 

inspection is done annually

Bake outs are done as 

needed and a thorough 

inspection is done annually

Bake outs are done as 

needed and a thorough 

inspection is done annually

 Problems experienced with control device within the 

last five years; how were problems solved?

The bed kept plugging and 

shutting the RTO down. As 

Bake outs were not working 

the refractory was replaced. None

A bypass valve warped due to 

a fire, the unit was taken off 

line and the valve replaced.

The shaft that controls the 

poppet valves fractured. The 

manufacturer stated it was a 

factory defect and a new 

shaft was installed.

 Continuous monitoring method(s) used to monitor 

incinerator performance, including parameters 

monitored

Chamber temperature is 

monitored continuously

Chamber temperature is 

monitored continuously

Chamber temperature is 

monitored continuously

Chamber temperature is 

monitored continuously

 Plans to replace or upgrade thermal incinerator None at this time None at this time None at this time None at this time
FORM C-6

AIR POLLUTION CONTROL

VI. High Velocity Air Filter (HVAF)

 For each HVAF: HVAF 1 HVAF 2

 Process line(s) (identification name/number) Albion Line 1 Mineral Wells

 Equipment/process(es) controlled. Include emission 

point designations (e.g., E3, E4 from plot plan) EU-RESCURE AC001

 Latitude (decimal degrees, six decimal places) 42.253578 34.993594

 Longitude (decimal degrees, six decimal places) 84.738503 89.865075

 Stack or vent height (units) 168 feet 90 feet 

 Stack or vent diameter (units) 86 inches 66 inches

 Manufacturer and model Anderson 2000, Inc Model DF-44-IV Anderson 2000, Inc Model DF-44-IV

 Date of original installation 1980 1986

 Inlet gas flow rate (acfm @ °F) Not tested Not tested

 Inlet gas temperature (°F) Not tested Not tested

 Outlet gas temperature (°F) 136.5°F 111.5°F

 Inlet grain loading (gr/dscf) Not tested Not tested

 Outlet grain loading (gr/dscf) 0.02035 0.01275

 Average stack opacity (%) <5% 5.50%

 Water spray pressure (sdig), if applicable Not applicable Not applicable

 Water spray rate (gpm), if applicable Not applicable Not applicable

 Filter face velocity (acfm/ft2) per manual 13,000-18,000 ft/min per manual 13,000-18,000 ft/min

 Maximum pressure drop across mat (in. H2O gauge) 24 45

 Vendor guarantee on HVAF efficiency (attach copy)

Original documents could not be 

located

Original documents could not be 

located

The filter media automatically 

advances when the differential 

The filter media automatically 

advances when the differential 

 Method and frequency of filter mat advancement pressure reaches the setpoint. pressure reaches the setpoint.

 Amount of wastewater generated (gpd) 0 0

 Amount of wastewater recycled (gpd) 0 0

 Amount of wastewater disposed of (gpd) 0 0

 Method of wastewater disposal 0 0

 Quantity of solid waste collected (lbs/yr) 0 12,080

 Quantity of solid waste recycled (lbs/yr) 0 0

 Quantity of solid waste disposed of (lbs/yr) 0 12,080

 Method of solid waste disposal NA Landfill

 Nature and frequency of preventive maintenance 

procedures

The HEAF is inspected and lubed 

weekly and extensive cleaning and 

maintenance is done every 6 to 8 

weeks

The HEAF is inspected and lubed 

weekly and extensive cleaning and 

maintenance is done every 6 to 8 

weeks

 Problems experienced with control device within the 

last five years; how were problems solved? No problems in the last five years No problems in the last five years

 Continuous monitoring method(s) used to monitor 

HVAF performance, including parameters monitored

system, however the temperature, 

fan amps and filter paper dp are 

recorded every 4 hours per 40CFR60 

Subpart PPP

system, however the temperature, fan 

amps and filter paper dp are recorded 

every 4 hours per 40CFR60 Subpart 

PPP

 Plans to replace or upgrade HVAF Not at this time

The HEAF will be removed and 

replaced with 3 scrubbers in 2010
FORM C-9

AIR POLLUTION CONTROL

IX. Other 

 For each Other Air Pollution Control Device (APCD): Other APCD 1 Other APCD 2 Other APCD 3

 Process line(s) (identification name/number) Inwood Line 1 Kingman Kingman

 Equipment/process(es) controlled. Include emission point 

designations (e.g., E3, E4 from plot plan) Group 004 EP1 EP2

 Latitude (decimal degrees, six decimal places) 39.402114 35.255961 35.256561

 Longitude (decimal degrees, six decimal places) 78.022950 113.965847 113.965981

 Stack or vent height (units) 120 feet 135 feet 100 feet

 Stack or vent diameter (units) 78 inches 78 inches 42 inches

 Description

defined in 40 CFR 60 

Subpart PPP

defined in 40 CFR 60 

Subpart PPP

defined in 40 CFR 60 

Subpart PPP
FORM D

PROCESS LINE STARTUP AND SHUTDOWN

1. For each startup and shutdown (SS) that occurred during the last 

five years, please provide the following information requested in A. 

through J. 

Guardian has not had any uncontrolled startup or shutdown malfunctions of 

the melters in the last five years.

 A. Using the definitions provided above, indicate whether the 

event was a startup or shutdown;

 B. A description of the event, including identification of the 

emissions source or sources associated with the startup or 

shutdown;

 C. Whether any permit condition was exceeded and, if so, what 

permit condition was exceeded;

 D. Whether the event was covered by any contingency plan for 

controlling emissions during startup and shutdown events and, if so, 

whether the plan was followed; if the plan was not followed, why not;

 E. The duration of the event;

 F. The actions taken to minimize emissions during the event, 

including the use of any backup control systems;

 G. Estimates or measurements, if any, of emissions during the 

event; if you did not have the ability to quantify emissions during the 

event, please explain why;

 H. Whether the emission profile of each unit was different during 

startup and shutdown than during normal operating conditions and, if 

so, how emissions were different and why; please provide any 

supporting information;

 I. All performance test data collected during each period of SS; 

the test method used for each event; when the testing was 

conducted and why; the test conditions at the time of testing; and 

whether the tests were associated with a routine startup or 

shutdown; and

 J. All monitoring data, including control system parameter 

monitoring, collected during each period of SS.

If this information is contained in periodic and immediate SS reports 

(either stand-alone or contained within the periodic excess 

emissions report) submitted to your permitting authority, you may 

submit copies of those reports instead.

2. Are there any types of startup or shutdown events that you have 

been able to eliminate? If so, please describe the type of event and 

explain how these events were eliminated.

3. Please submit a copy of your SS plan if you are required to 

develop one.

4. Please provide all performance test data collected during periods 

of SS over the last 5 years. Indicate the test method used for each 

event.

5. Please provide all monitoring data, including control system 

parameter monitoring, collected during periods of SS over the last 5 

years. 

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

Shutdown: the cessation of operation of an affected source or portion of an affected source for any purpose.
6. Optional: Do you wish to recommend a standard that would 

apply during startup or shutdown? If so, please describe the event 

to which the standard would apply; the recommended standard (this 

could be an emission limitation, work practice, or operational 

standard) that would apply during the period; the basis for the 

recommended standard; why and how the standard would minimize 

emissions during the event; and how would compliance be 

determined and/or monitored. 
FORM E

PRESENCE OF AIR POLLUTANTS IN EMISSION POINTSa

Please provide any existing emissions information and data 

covering hazardous air pollutants (HAP) and particulate 

matter (PM) for each listed process. Identify the 

appropriate box for which you are providing specific 

process information and/or pollutant emissions data.

Submitted to EPA by 

NAIMA

Melting Furnace Forming Curing Cooling

Particulate Matter (PM, PM 2.5, PM Condensable) 

Chromium Compounds and Hexavalent Chromium 

(including any Cr speciation data)

Other metal HAP (As, Be, Cd, Co, Hg, Mn, Ni, Pb, Sb, Se)

Hydrogen Fluoride (HF)

Hydrogen Chloride (HCl)

Formaldehyde

Phenol

Methanol

Other organic HAP
FORM F-1 

COST

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

 For each Process Unit: Process Unit 1

 Process Unit ID

 Process Line ID

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

Can your product(s) be substituted by another product(s)? If so, please list 

your product(s) and substituted product(s).

Wool fiberglass insulation comprises approximat

used in the United States. The remaining perc

(scrap newspaper) treated to resist fires, spray 

fires, and sheep wool treated to resist fires. Woo

alternative insulation materials because it is ea

various building settings, has superior fire perfor

The company objects to this request because it 

EPA Administrator’s review obligations pursua
Process Unit 2 Process Unit 3 Process Unit 4

International International International

glass insulation comprises approximately 80% of the residential insulation material 

the United States. The remaining percentage of the market consists of cellulose 

ewspaper) treated to resist fires, spray foam, foam boards, cotton treated to resist 

sheep wool treated to resist fires. Wool fiberglass insulation is preferred over these 

ive insulation materials because it is easily, economically, and safety installed in 

uilding settings, has superior fire performance capabilities, and a 70-year history of 

proven performance and durability.

pany objects to this request because it seeks information that is not relevant to the 

dministrator’s review obligations pursuant to Clean Air Act Section 112(d)(6) and 
FORM F-2

COST

I. Air Pollution Control Device (APCD)

 For each APCD: APCD 1

 APCD ID

 Process Unit ID

The company objects to this request because it seeks i

EPA Administrator’s review obligations pursuant to C
APCD 3 APCD 4 APCD 5

pany objects to this request because it seeks information that is not relevant to the 

dministrator’s review obligations pursuant to Clean Air Act Section 112(d)(6) and