# FORM A**-1**

**PA RENT COMPA** **NY INFORMA TION** 

**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 reformulateA 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**

**PLA NT** **OPERA**

**TIONS**

**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 designGF Proprietary designGF Proprietary designGF Proprietary designGF Proprietary design GF Proprietary designGF 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 fansDampers 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 eachCuring 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 eachCooling 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

**PLA NT OPERA** 

**TIONS**

**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 OPERA TIONS** 

VIII. Pollution Prevention

Please describe any

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

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

the year in which the facility implemented the practice/technique and identifythe 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/103acfm) 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. H 2O 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) See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached See Attached 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

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 doneWeekly maintenance is done on the fan and motor and every 6 to 8 weeks extensive cleaning is doneWeekly maintenance is done on the fan and motor and every 6 to 8 weeks extensive cleaning is doneWeekly 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 doneWeekly maintenance is done on the fan and motor and every 6 to 8 weeks extensive cleaning is doneWeekly 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 doneWeekly 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 III MAC 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 (ft 2) 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 currently414,600 631,467 Line was not in operation 533,941

Quantity of solid waste recycled (lbs/yr) 195,980 Line not in operation currently413,400 631,217 Line was not in operation 533,941

Quantity of solid waste disposed of (lbs/yr) 312 Line not in operation currently1,200 250 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 problemsThere have been no problemsThere 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

**AI R 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 MCT30.0United 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-IVAnderson 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. H2

### O 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 STA RTUP A** **ND SHUTDOWN**

1. For each startup and shutdown (SS) that occurred during the last five years, please provide the following information requested in A. through J. 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 POINTS a** 



### Please provide any existing emissions information and data covering hazardous air pollutants (HAP) and particulate matter (PM) for each listed process. Identify the appropriate box for which you are providing specific process information and/or pollutant 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 approximately 80% of the residential insulation material used in the United States. The remaining percentage of the market consists of cellulose (scrap newspaper) treated to resist fires, spray foam, foam boards, cotton treated to resist fires, and sheep wool treated to resist fires. Wool fiberglass insulation is preferred over these alternative insulation materials because it is easily, economically, and safety installed in various building settings, has superior fire performance capabilities, and a 70-year history of The company

objects to this request because it seeks information that is not relevant to the EPA Administrator’s review obligations pursuant to Clean Air Act Section 112(d)(6) and

# Process Unit 2 Process Unit 3 Process Unit 4

International International International

Wool fiberglass insulation comprises approximately 80% of the residential insulation material used in the United States. The remaining percentage of the market consists of cellulose (scrap newspaper) treated to resist fires, spray foam, foam boards, cotton treated to resist fires, and sheep wool treated to resist fires. Wool fiberglass insulation is preferred over these alternative insulation materials because it is easily, economically, and safety installed in various building settings, has superior fire performance capabilities, and a 70-year history of proven performance and durability

. The company

objects to this request because it seeks information that is not relevant to the EPA Administrator’s review obligations pursuant to Clean Air Act Section 112(d)(6) and

# FORM F-2

**COST**

**I. A ir Pollution Control Device (A** **PCD)**

For each APCD: APCD 1 **A PCD ID**  Process Unit ID The company objects to this request because it seeks information that is not relevant to the EPA Administrator’s review obligations pursuant to Clean Air Act Section 112(d)(6) and

# APCD 3 APCD 4 APCD 5 The company

objects to this request because it seeks information that is not relevant to the EPA Administrator’s review obligations pursuant to Clean Air Act Section 112(d)(6) and