### DATE: August 11 , 2011

SUBJECT: Section 112(d)(6) Technology Review for Mineral Wool NESHAP EPA Contract No. EP

- D

- 06

- 118; EPA Work Assignment No. 4

- 10 RTI Project No. 0210426.004.010

FROM: Cindy Hancy Dave Reeves

TO: Susan Fairchild , EPA/OA QPS/SPPD/MMG

The purpose of this memorandum is to present the results of a review on developments in practices, processes, and control technologies that apply to mineral wool production , and specifically to sources subject to the national emission standar ds for hazardous air pollutants (NESHAP) for Mineral Wool Production (40 CFR 63, subpart DDD )

. This analysis is part of the U.S. Environmental Protection Agency’s ( EPA’s ) review efforts in accordance with section 112(d)(6) of the Clean Air Act (CAA)

. Sec tion I of this memorandum provides background information on the requirements of section 112(d)(6) of the CAA , the mineral wool source category, and the requirements of the Mineral Wool MACT

. Section II discusses the review of information on developments in practices, processes, and control technologies that have occurred since the original development of this MACT

.

I. Background/Purpose

A. Requirements of Section 112(d)(6) of the CAA

Section 112 of the CAA require s EPA to establish technology

- based s tandards for

source s of hazardous air pollutants (HAP) . These technology

- based standards are often referred to as maximum achievable control technology ( MACT ) standards. Section 112 also contains provisions requiring EPA to revisit these standards. Speci fically, paragraph (d)(6) of section 112 states:

(6) REVIEW AND REVISION.

– The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emission standards promulgated under this section no less often than every 8 years.

### 2

For the purpose of this technology review , a “development” was considered to be any of the following :

• A dd

- on control technology or other equipment that was not identified and considered during the developm ent of the MACT ;

• I mprovements in add

- on control technology or other equipment that w ere not identified and considered during MACT development that could result in significan t additional HAP emissions reductions;

• W ork practice or operational procedure that was not identified and considered during MACT development ; and

• P rocess change or pollution prevention alternative that could be broadly applied that was not identified and considered during the development of the MACT

.

B. Description of Source Category and MACT Requirements 1



### Most mineral wool produced in the United States is produced from slag or a mixture of slag and rock. Most of the slag used by the industry is generated by integrated iron and steel plants as a blast furnace waste product. Other sour ces of slag include the copper, lead
, and phosphate industries. The mineral wool production process has three primary component s: m elting of minerals in the cupola, fiber formation and collection, and curing operations . The first step in the process involv es melting the mineral feed. The raw materials (slag, rock, etc) are loaded into a cupola in alternating layers with coke. As the coke is ignited and burned, the mineral charge is heated to a molten state . Combustion air is supplied through tuyeres (ports) located near the bottom of the furnace. Process modifications at some plants include oxygen enrichment and the use of natural gas auxiliary burners to reduce coke consumption.

The molten mineral charge exits the bottom of the cupola and falls onto a fib erization device. Most of the mineral wool produced in the United States is made by variations of two fiberization methods. One process uses groups of rotors revolving at a high rate of speed to form the fibers. Molten material is distributed in a thin fil m on the surfaces of the rotors and then is thrown off by centrifugal force. As the material lea ves the surface, small globules develop and form long, fibrous tails as they travel horizontally. A ir or steam may be blown around the rotors to assist in fiber izing the material. A second fiberization method uses a spinning concave rotor with air or steam attenuation. Molten material is distributed over the surface of the rotor, from which it flows up an d over the edge and is captured b y a high

- velocity air stre am

. Mineral wool is manufactured as either a “bonded” product that incorporates a binder to increase structural rigidity or a less rigid “nonbonded” product. The production of bonded mineral woo l involves the application of a phenol

- formaldehyde based bin der to the fiber. Binder may be applied in two ways: it may be sprayed onto the fibers during formation at the spinning rotors, or it may be sprayed onto the collected fibers after they have been formed into a mat.

After formation the fibers are collect ed either in a chamber or by air flow and vacuums onto a moving conveyor. Binder may applied at this step if the product is bonded . Fibers are drawn down on a conveyor by a vacuum drawn on the reverse side of the conveyor

. If the product is bonded, the m i neral wool mat with applied bo nding agent is carried by conveyor to a curing

### 3

oven for thermosetting. A cooling section follows the oven, where blowers force air at ambient temperatures through the wool. Nonbonded product does n ot undergo curing. A summary of emission units from mineral wool facilities is included in Table 1.

Table 1. Summary of Mineral Wool Production Emission Units

Emission Unit Description HAP Emitted Cupola Vessel in which the mineral charge is melted; COS, metals , HF, HCl Collectio n/ Forming B low chamber or area in which air and in some cases a binder is sprayed over the fibers, forming them into

a screen F ormaldehyde, methanol , and phenol (bonded products only) Curing Oven O ven that bonds and thermosets the fibers (for bonded prod ucts)

The current Mineral Wool Production MACT was promulgated on June 1, 1999 and applies to existing, new, and reconstructed cupolas and curing ovens at mineral wool production facilities that are major sources of HAP emissions. The 1999 Mineral Wool Production MACT sets particulate matter (PM) emission limits for new and existing cupolas and carbon monoxide (CO) limits for new cupolas. The MACT also established emission limits for formaldehyde from new and existing curing ovens. Based on the 1999 MAC T , these regulated pollutants currently serve as surrogates for other HAPs as follows: PM serves as a surrogate for HAP metals, CO for carbonyl sulfide (COS), and formaldehyde for phenol and methanol. The proposed rule is expected to amend the 1999 MACT t o remove all surrogacy except PM surrogacy for HAP metals. The mineral wool production source category currently consists of 7 facilities in the US; combined, these 7 facilities operate 11 cupolas and 3 curing ovens. The three facilities that operate curin g ovens produce bonded mineral wool products and include collection operations. There were no MACT emission limits established for collection operations in the 1999 Mineral Wool MACT

.

II. Practices, Processes, and Control Technologies for Min e r al Wool Pr oduction

A. Control Technologies Considered for MACT

For the purpose of this exercise, a “development” was considered to be:

• Any add

- on control technology or other equipment (e.g., floating roofs for storage tanks) that was not identified and considere d during MACT development,

• Any improvements in add

- on control technology or other equipment (that was identified and considered during MACT development) that could result in significant additional emission reduction,

• Any work practice or operational proced ure that was not identified and considered during MACT development, and

• Any process change or pollution prevention alternative that could be broadly applied that was not identified and considered during MACT development.

### 4

Table 2 summarizes the practices, processes, and control technologies considered during the development of the MACT standard. This is followed by descriptions of the searches for developments since that time. The specific information sources that were consulted in this effort included EPA regulatory efforts conducted subsequent to these rulemakings ( S ection II.B ), direct correspondence with the industry ( S ection II.C), and EPA’s RACT/BACT/LAER Clearinghouse ( S ection II. D).

Table 2 . Summary of Practices, Processes, and Control Technologies Identified and Considered During Mineral Wool Production MACT Development

Emission Source Practices, Processes, and Control Technologies Cupolas Fabric filters, cyclones, regenerative thermal oxidizer s Curing Ovens Thermal oxidizer Fiber Collection Thermal oxidizer

B. Technology Developments Since Promulgation of MACT

Since the MACT was promulgated in 199 9 , no developments in the methods for controlling emissions from cupolas, curing ovens , or collection operations were identified

. Current add

- on control technologies being utilized are summarized in Table 3

. Table 3. Summary of Practices, Processes, and Control Technologies Currently Used in Mineral Wool Production F acilities.

Emission Source Practices, Processes, and Control Technologies C upolas Fabr ic filter , thermal oxidizer , scrubber Curing Ovens Thermal oxidizer
, fabric filter
, coke

- carbon scrubber Forming/Collection Ther mal oxidizer , fabric filter , scrubber

The coke carbon scrubber was installed in 1997 and uses activated carbon s imilar to a carbon adsorber. The scrubber on the collection system was installed in 1970 and is a cascading water scrubber. Both of these scrubbers are located at the same facility and are intended to control emissions of binder HAP (formaldehyde, phenol, and methanol)

. The use of low sulfur raw materials may be a low cost adjustment to raw material inputs that result in reduction of sulfur compounds (SO2 and COS) emitted from the stack. EPA has identified one facility that has lowered COS emissions from cupolas by using low sulfur rock instead of slag as their raw material. L ow sulfur rock has been used to make mineral wool before the development of the MACT . However, this rock, composed mostly of limestone, is not frequent ly used as a raw material for mi neral wool production because it costs approximately 50% more than slag

. Low sulfur slag and coke may also be available for mineral wool plants to reduce their levels of COS. One facility uses oxygen (O 2 

### ) injection at the cupola to reduce COS emissions bef ore emitting to the ambient air. Both RTOs and O 2 

### injection force the conversion of COS to SO 2 

### ; an RTO drives the reaction at the control device and O 2 

### injection forces the reaction to occur at the cupola.

### 5

C

. C orrespondence with I ndustry

In an attempt to identify new emission control technologies in use, a voluntary information request was sent to all 7 mineral wool facilities. To identify new technologies
, facilities were asked to identify any controls that did not fall under the following categories: electrostatic precipitator ( ESP ), s crubber, mechanical collector, fabric filter, thermal oxidizer
, high velocity air filter (HVAF) , mist eliminator, or ventilation system. One facility identified a caustic injection system was being operated at one of the facility’s cupola. The caustic injection

was installed on a cupola exhaust in 2003 (after a thermal oxidizer ) for control of SO 2 

### emissions

. No other control device s w ere identified.

D

. Search for Other Applicable Technology Developments

In addition t o the information discussed above, searches of the RACT/BACT/LAER Clearinghouse an d the Internet w ere conducted to identify other technologies or developments that could be applied to mineral wool production

. The results of these searches are described in the following paragraphs.

RACT/BACT/LAER Clearinghouse 2



### Under EPA ’ s New Source Review (NSR) program, if a company is planning to build a new plant or modify an existing plant such that air pollution emissions will increase by a large amount, the comp any must obtain an NSR permit. The NSR permit is a construction permit which requires the company to minimize air pollution emissions by changing the process to prevent air pollution and/or installing air pollution control equipment.

The terms “ RACT, ” “ BACT, ” and “ LAER ” are acronyms for different program requirements under the NSR program. RACT, or Reasonably Available Control Technology, is required on sources in areas that are not meeting national ambient air quality standards (i.e., non

attainment ar eas). BACT, or Best Available Control Technology, is required on major new or modified sources in attainment areas. LAER, or Lowest Achievable Emission Rate, is required on major new or modified sources in non

- attainment areas.

BACT and LAER (and some times RACT) are determined on a case

- by

- case basis, usually by State or local permitting agencies. EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to provide a central database of air pollution technology information (including past BACT and LA ER decisions contained in NSR permits) to promote the sharing of information among permitting agencies and to aid in future case

- by

- case determinations. However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER requirements. Not eworthy prevention and control technology decisions and information are included even if they are not related to past R ACT, BACT, or LAER decisions.

The RBLC contains over 5,000 air pollution control permit determinations that can help identify appropria te technologies to mitigate most air pollutant emission streams. It was designed to help permit applicants and reviewers make pollution prevention and control

### 6

technology decisions for stationary air pollution sources, and includes data submitted by severa l U.S. territories and all 50 States on over 200 different air pollutants and 1,000 industrial processes.
To identify technologies appropriate for mineral wool production , searches of the RBLC were made using the Process Type Codes : 99.0 22

- Mineral Woo l. All records from 199 9 to 201 1 were searched. In all cases, the control devices and methods identified through the RBLC search do not represent new technologies. Attachment 1 show s the results of the RBLC search for mineral wool.

Internet Search

A general search of the Internet was conducted for information on control technologies for mineral wool cupolas, curing ovens, and collection operations . The i nternet search did not identif y any new practices, processes, or technologies that have not alrea dy been considered in this review.

III. References

1

. Emission Factor Documentation For AP

- 42 Section11.18 (Formerly 8.16) Mineral Wool Manufacturing. http://www.epa.gov/ttnchie1/ap42/ch11/bgdocs/b11s18.pdf

2. Technology Transfer Network, C lean Air Technology Center

- RACT/BACT/LAER Clearinghouse. http://cfpub.epa.gov/rblc/index.cfm?action=Search.BasicSearch&lang=en

.

### Attachment 1

[Insert RBLC search results

– see separate pdf (26 pages)

- to be combined after review ]

## COMPREHENSIVE REPORT Report Date:08/08/2011 

## Facility Information

RBLC ID: 

## OH-0324 (final) Date Determination Last Updated: 10/26/2009 Corporate/Company Name: JOHNS MANVILLE INTERNATIONAL INC. Permit Number: 03-17389 Facility Name: JOHNS MANVILLE INTERNATIONAL INC., PLANT 8 Permit Date: 05/22/2008 (actual) Facility Contact: G. R. BONIN 4197847916 FRS Number: 110000383549 Facility Description: MINERAL WOOL MANUFACTURING SIC Code: 3296 Permit Type: C: Modify process at existing facility NAICS Code: 327993
Permit URL: EPA Region: 5 COUNTRY: USA Facility County: DEFIANCE Facility State: OH Facility ZIP Code: 43512 Permit Issued By: OHIO ENVIRONMENTAL PROTECTION AGENCY (Agency Name) MS. CHERYL SUTTMAN(Agency Contact) (614)644-3617 CHERYL.SUTTMAN@EPA.STATE.OH.US Permit Notes: THREE GLASS MELTING POTS, FORMING AND COLLECTION GLASS FIBER LINES. RE-INSTALLATION OF ONE AND MODIFICATION OF 2 EXISTING LINES TO PRODUCE A FINE FIBERGLASS PRODUCT. FIRST MODIFICATION WAS ISSUED FINAL 4/22/08 AND REISSUED 5/22/08 FOR AN ADMINISTRATIVE CHANGE; AND MODIFIED AGAIN ON 1/9/09 FOR INCREASE TO VOC LIMIT IN ONE UNIT IN PTI P0103686. THE FACILITY NETTED OUT OF PSD FOR PM10, AND WAS PSD FOR CARBON MONOXIDE ONLY, ORIGINAL NETTING RESULTS SHOWN BELOW.



## Process/Pollutant Information

PROCESS NAME: FORMING AND COLLECTION, LINES #84, 85, AND 87 (3)

Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: NATURAL GAS Throughput:

Process Notes: FIBER GLASS FORMING AND COLLECTION LINES; INCLUDES MELTING POTS, BINDER AND COOLING WATER APPLICATION

SYSTEMS, AND AIR HANDLING COLLECTION BOX. GLASS PULL RATE HAS BEEN SUBMITTED AS CONFIDENTIAL.

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 9.9900 LB/H Emission Limit 2: 43.7600 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes: THE EMISSION FACTOR USED TO CALCULATE THE EMISSION LIMITS ABOVE, DERIVED FROM A STACK TEST ON A SIMILAR UNIT, WAS NOT INCLUDED IN THE PERMIT.

POLLUTANT NAME: Carbon Monoxide

CAS Number: 630-08-0 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 60.0000 LB/H Emission Limit 2: 262.8000 T/YR PER ROLLING 12-MONTH PERIOD Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: BACT-PSD Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes: IT WAS DETERMINED THAT NO CONTROL TECHNOLOGIES FOR CO WERE COST EFFECTIVE. THE EMISSION FACTOR USED TO CALCULATE THE EMISSION LIMITS ABOVE, DERIVED FROM A STACK TEST ON A SIMILAR UNIT, WAS NOT INCLUDED IN THE PERMIT.

POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOCTest Method: Unspecified

Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 7.5100 LB/H FOR UNIT #87 Emission Limit 2: 32.8900 T/YR FOR UNIT #87 Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes: TWO OF THE THREE UNITS, #84 AND #85, HAVE THE FOLLOWING EMISSION LIMITS FOR EACH UNIT: 3.2 LB VOC/H AND 14.02 T/Y. IN THE THIRD UNIT #87 THE VOC EMISSION LIMIT HAS BEEN INCREASE IN PTI#P0103686 ISSUED 1/9/09 AND LIMITS ARE SHOWN ABOVE.

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE Test Method: Unspecified Pollutant Group(s): Emission Limit 1: 20.0000 % OPACITY OPACITY AS 6 MIN AVG EXCEPT BY RULE Emission Limit 2: Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: U Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes: EXCEPT AS PROVIDED BY OHIO RULE: MAY EXCEED 20% OPACITY, AS A 6-MINUTE AVERAGE, FOR NOT MORE THAN 6 CONSECUTIVE MINUTES IN ANY 60 MINUTES, BUT SHALL NOT EXCEED 60% OPACITY AS A 6-MINUTE AVERAGE AT ANY TIME.



## Facility InformationRBLC ID: 

## OH-0261 (final) Date Determination Last Updated: 12/05/2003 Corporate/Company Name: JOHNS MANVILLE INTERNATIONAL, INC. Permit Number: 03-13522

Facility Name: JOHNS MANVILLE INTERNATIONAL, INC. Permit Date: 04/03/2001 (actual) Facility Contact: NED EWERS 419-784-7962 FRS Number: 110006195777 Facility Description: MANUFACTURER OF INSULATION AND BUILDING PRODUCTS. MODIFICATION TO INCREASE PIPE INSULATION CAPACITY, CAUSING A SIGNIFICANT INCREASE IN PM10. ADDING 2 NEW LINES AND MODIFICATION TO A FEW OTHERS. SIC Code: 3296

Permit Type: A: New/Greenfield Facility NAICS Code: 327993
Permit URL: EPA Region: 5 COUNTRY: USA Facility County: DEFIANCE Facility State: OH Facility ZIP Code: 43512 Permit Issued By: OHIO ENVIRONMENTAL PROTECTION AGENCY (Agency Name) MS. CHERYL SUTTMAN(Agency Contact) (614)644-3617 CHERYL.SUTTMAN@EPA.STATE.OH.US Other Agency Contact Info: CHERYL E. SUTTMAN 122 S. FRONT ST. COLUMBUS, OH 43215 614-644-3617 Permit Notes: Manufacturer of wool fiber glass insulation and building products. Modification to increase pipe insulation capacity, causing a significant increase in PM10. Two new lines and increased production on other lines.



## Process/Pollutant Information

PROCESS NAME: PRODUCT CURING UNIT #30 Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: NATURAL GAS Throughput: 381.00 LB/H

Process Notes: Using emission factors derived from similar sources at this facility. Wool glass production rate range from 381 lb/h to 880 lb/h.

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VETest Method: Unspecified

Pollutant Group(s): Emission Limit 1: 20.0000 % OPACITY 6 minute average Emission Limit 2: Standard Emission: 20.0000 % OPACITY 6 minute average Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 0.5300 LB/H Emission Limit 2: 2.3000 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes: Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT), it has been determined that no control technologies were cost effective.

POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOC
Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 0.6700 LB/HEmission Limit 2: 2.9200 T/YR

Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) Emission Limit 1: 0.2500 LB/H Emission Limit 2: 1.1000 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Carbon Monoxide

CAS Number: 630-08-0 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 1.0600 LB/H Emission Limit 2: 4.6600 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/AOther Applicable Requirements: SIP

Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:



## Process/Pollutant Information

PROCESS NAME: FORMING AND COLLECTION, #31 Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: Throughput: 880.00 LB/H

Process Notes: Using emission factors derived from similar sources at this facility. Wool glass production rate range from 381 lbs/hr to 880 lbs/hr.

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE Test Method: Unspecified Pollutant Group(s): Emission Limit 1: 20.0000 % OPACITY 6 minute average Emission Limit 2: Standard Emission: 20.0000 % OPACITY 6 minute average Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 7.9400 LB/HEmission Limit 2: 34.7600 T/YR

Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes: Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT), it has been determined that no control technologies were cost effective.

POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOC
Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 2.4000 LB/H Emission Limit 2: 10.5300 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) Emission Limit 1: 0.8800 LB/H Emission Limit 2: 3.8300 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: UnknownDid factors, other then air pollution technology considerations influence the BACT decisions: Unknown

Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Carbon Monoxide

CAS Number: 630-08-0 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 2.1100 LB/H Emission Limit 2: 9.2600 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Sulfur Dioxide (SO2)

CAS Number: 7446-09-5 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Sulfur (SOx) ) Emission Limit 1: 0.9900 LB/H Emission Limit 2: 4.3500 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N)Est. % Efficiency:

Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Fluorides, Total

CAS Number: 16984-48-8 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 0.3900 LB/H Emission Limit 2: 1.7100 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:



## Process/Pollutant Information

PROCESS NAME: PRODUCT FINISHING, #30, #37 Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: Throughput: 880.00 LB/H

Process Notes: Using emission factors derived from similar sources at this facility. Wool glass production rate range from 381 lb/h to 880 lb/h.

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE Test Method: Unspecified Pollutant Group(s): Emission Limit 1: 20.0000 % OPACITY 6 minute average Emission Limit 2: Standard Emission: 20.0000 % OPACITY 6 minute averageDid factors, other then air pollution technology considerations influence the BACT decisions: Unknown

Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (A) BAGHOUSE AND CYCLONE CONNECTED IN SERIES Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 0.8600 LB/H Emission Limit 2: 3.7700 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (A) BAGHOUSES AND CYCLONE CONNECTED IN SERIES Est. % Efficiency: 99.000 Compliance Verified: Yes Pollutant/Compliance Notes:



## Process/Pollutant Information

PROCESS NAME: HANDWRAP PRODUCT CURING UNIT, (2)

Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: NATURAL GAS Throughput: 553.00 LB/H

Process Notes: Using emission factors derived from similar sources at this facility. Wool glass production rate range from 381 lb/h to 880 lb/h. Units #36 and #38.

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VETest Method: Unspecified

Pollutant Group(s): Emission Limit 1: 20.0000 % OPACITY 6 minute avg Emission Limit 2: Standard Emission: 20.0000 % OPACITY 6 minute avg Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes: Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT), it has been determined that no control technologies were cost effective.

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) Emission Limit 1: 0.4100 LB/H Emission Limit 2: 1.8100 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 0.8400 LB/HEmission Limit 2: 3.6800 T/YR

Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes: Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT), it has been determined that no control technologies were cost effective.

POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOC
Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 0.9800 LB/H Emission Limit 2: 4.3100 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Carbon Monoxide

CAS Number: 630-08-0 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 0.4100 LB/H Emission Limit 2: 1.7900 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: UnknownDid factors, other then air pollution technology considerations influence the BACT decisions: Unknown

Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:



## Process/Pollutant Information

PROCESS NAME: PRODUCT CURING UNIT, #37 Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: NATURAL GAS Throughput: 381.00 LB/H

Process Notes: Using emission factors derived from similar sources at this facility. Wool glass production rate range from 381 lb/h to 880 lb/h.

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 0.7900 LB/H Emission Limit 2: 3.4600 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes: Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT), it has been determined that no control technologies were cost effective.

POLLUTANT NAME: Volatile Organic Compounds (VOC)CAS Number: VOC

Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 1.0200 LB/H Emission Limit 2: 4.4700 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE Test Method: Unspecified Pollutant Group(s): Emission Limit 1: 20.0000 % OPACITY 6 min avg Emission Limit 2: Standard Emission: 20.0000 % OPACITY 6 min avg Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) Emission Limit 1: 1.6700 LB/HEmission Limit 2: 7.3200 T/YR

Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Carbon Monoxide

CAS Number: 630-08-0 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 2.2200 LB/H Emission Limit 2: 9.7200 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:



## Process/Pollutant Information

PROCESS NAME: PRODUCT CURING UNIT, #38 Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: NATURAL GAS Throughput: 880.00 LB/H

Process Notes: Using emission factors derived from similar sources at this facility. Wool glas production rate range from 381 lb/h to 880 lb/h.

POLLUTANT NAME: Visible Emissions (VE)CAS Number: VE

Test Method: Unspecified Pollutant Group(s): Emission Limit 1: 20.0000 % OPACITY 6 min avg Emission Limit 2: Standard Emission: 20.0000 % OPACITY 6 min avg Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 2.0200 LB/H Emission Limit 2: 8.8400 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes: Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT), it has been determined that no control technologies were cost effective.

POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOC
Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) )Pollutant Group(s): ( Volatile Organic Compounds (VOC) )

Emission Limit 1: 2.5600 LB/H Emission Limit 2: 11.2100 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) Emission Limit 1: 0.9700 LB/H Emission Limit 2: 4.2500 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Carbon Monoxide

CAS Number: 630-08-0 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 4.0900 LB/H Emission Limit 2: 17.9200 T/YR Standard Emission:Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown

Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Sulfur Dioxide (SO2)

CAS Number: 7446-09-5 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Sulfur (SOx) ) Emission Limit 1: 0.3400 LB/H Emission Limit 2: 1.5100 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:



## Process/Pollutant Information

PROCESS NAME: FORMING AND COLLECTION, #37 Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: Throughput: 381.00 LB/H

Process Notes: Using emission factors derived from similar sources at this facility. Wool glass production rate range from 381 lb/h to 880 lb/h.

POLLUTANT NAME: Sulfur Dioxide (SO2)

CAS Number: 7446-09-5 Test Method: UnspecifiedPollutant Group(s): ( InOrganic Compounds , Oxides of Sulfur (SOx) )

Emission Limit 1: 1.2200 LB/H Emission Limit 2: 5.3400 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Fluorides, Total

CAS Number: 16984-48-8 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 0.4800 LB/H Emission Limit 2: 2.1000 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Nitrogen Oxides (NOx)

CAS Number: 10102 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds , Oxides of Nitrogen (NOx) , Particulate Matter (PM) ) Emission Limit 1: 2.8500 LB/H Emission Limit 2: 12.4800 T/YR Standard Emission:Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown

Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Carbon Monoxide

CAS Number: 630-08-0 Test Method: Unspecified Pollutant Group(s): ( InOrganic Compounds ) Emission Limit 1: 2.2200 LB/H Emission Limit 2: 9.7200 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE Test Method: Unspecified Pollutant Group(s): Emission Limit 1: 20.0000 % OPACITY 6 min avg Emission Limit 2: Standard Emission: 20.0000 % OPACITY 6 min avg Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N)Est. % Efficiency:

Compliance Verified: Yes Pollutant/Compliance Notes: Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT), it has been determined that no control technologies were cost effective.

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 5.8300 LB/H Emission Limit 2: 25.5400 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (N) Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes: Based on the "Prevention of Significant Deterioration" (PSD) analysis conducted to ensure the application of "Best Available Control Technology" (BACT), it has been determined that no control technologies were cost effective.

POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOC
Test Method: Unspecified Pollutant Group(s): ( Volatile Organic Compounds (VOC) ) Emission Limit 1: 1.8100 LB/H Emission Limit 2: 7.9300 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (N) Est. % Efficiency:Compliance Verified: Yes

Pollutant/Compliance Notes:



## Process/Pollutant Information

PROCESS NAME: HANDWRAP PRODUCT FINISHING Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: Throughput: 553.00 LB/H

Process Notes: Using emission factors derived from similar sources at this facility. Wool glass production rate range from 381 lb/h to 880 lb/h.

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 0.4300 LB/H Emission Limit 2: 1.8800 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (A) BAGHOUSE AND CYCLONE CONNECTED IN SERIES Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE Test Method: Unspecified Pollutant Group(s): Emission Limit 1: 20.0000 % OPACITY 6 minute average Emission Limit 2: Standard Emission: 20.0000 % OPACITY 6 minute average Did factors, other then air pollution technology considerations influence the BACT decisions: UnknownCase-by-Case Basis: N/A

Other Applicable Requirements: SIP Control Method: (A) BAGHOUSE AND CYCLONE CONNECTED IN SERIES Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:



## Process/Pollutant Information

PROCESS NAME: PRODUCT FINISHING, #31, #32, #33, #34 Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: Throughput: 880.00 LB/H

Process Notes: Using emission factors derived from similar sources at this facility. Wool glass production rate range from 381 lb/h to 880 lb/h.

POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 1.1000 LB/H Emission Limit 2: 4.8200 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (A) BAGHOUSE AND CYCLONE CONNECTED IN SERIES Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE Test Method: Unspecified Pollutant Group(s):Emission Limit 1: 20.0000 % OPACITY 6 min avg

Emission Limit 2: Standard Emission: 20.0000 % OPACITY 6 min avg Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (A) BAGHOUSE AND CYCLONE CONNECTED IN SERIES Est. % Efficiency: Compliance Verified: Unknown Pollutant/Compliance Notes:



## Process/Pollutant Information

PROCESS NAME: PRODUCT FINISHING, #35, #38 Process Type: 90.022 (Mineral Wool Manufacturing) Primary Fuel: Throughput: 880.00 LB/H

Process Notes: Using emission factors derived from similar sources at this facility. Wool glass production rate range from 381 lb/h to 880 lb/h.

POLLUTANT NAME: Visible Emissions (VE)

CAS Number: VE Test Method: Unspecified Pollutant Group(s): Emission Limit 1: 20.0000 % OPACITY 6 minute average Emission Limit 2: Standard Emission: 20.0000 % OPACITY 6 minute average Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: N/A Other Applicable Requirements: SIP Control Method: (A) BAGHOUSE AND CYCLONE CONNECTED IN SERIES Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes:POLLUTANT NAME: Particulate matter, filterable < 10 μ (FPM10)

CAS Number: PM Test Method: Unspecified Pollutant Group(s): ( Particulate Matter (PM) ) Emission Limit 1: 1.2000 LB/H Emission Limit 2: 5.2600 T/YR Standard Emission: Did factors, other then air pollution technology considerations influence the BACT decisions: Unknown Case-by-Case Basis: BACT-PSD Other Applicable Requirements: Control Method: (A) BAGHOUSE AND CYCLONE CONNECTED IN SERIES Est. % Efficiency: Compliance Verified: Yes Pollutant/Compliance Notes: