March 11, 2010

NAIMA’S PRELIMINARY QUESTIONS FOR EPA ON DRAFT ICR

(RESIDUAL RISK FOR WOOL FIBER GLASS AND

MINERAL WOOL MACT STANDARDS)

General

 EPA’s opening letter references Section 114. Please confirm that the final 

letter/agreement will indicate that this effort is being done cooperatively rather 

than under a Section 114 order.

 The documents provide no “de minimus” levels or thresholds. Does EPA expect

information on insignificant sources (e.g., small batch dust collectors, inkjet

printers, copy machines, etc.)?

 NAIMA wishes to address the requests for cost data and confidential business

information in a separate phone call. NAIMA and its companies will provide 

background information and details on concerns surrounding the collection of this 

information.

 In responding to Enclosures 1 and 2, will EPA agree that some parts of the data 

will be submitted by member companies and other data will be submitted by 

NAIMA?

 On all forms, EPA seeks degrees, minutes, and seconds on latitude/longitude data. 

Can NAIMA rely on Google Earth or similar resources to get the data to six 

decimal places?

 What is meant by “source reduction plans?”

 There will be more questions as we proceed with completing this ICR.

Enclosure 1

Form A-2

 Title V permits include all applicable requirements. Does EPA need us to supply

copies of the permits and then list in Form A-2 all of the applicable requirements

again? Would just a copy of the permit suffice?

 What is meant by a “co-located facility?”

Form B

 Why is the definition of particulate matter for PM2.5 different than that in the

NAAQS?
March 11, 2010

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 The definition of “process line” includes material delivery through waste

management. As it is used later in the forms, it sets up lists of details unrelated to 

air toxics and could be read to include each and every piece of equipment in the

plant. Please clarify what is meant by “process line.”

 Why is a plot plan necessary? They likely do not exist and would take 

considerable resources to create. What information does EPA need and can it be 

provided in an alternative fashion?

Form B-1

 On Form B-1, how detailed does EPA want a list of products?

 On Form B-1, would a sufficiently detailed block flow diagram that indicates all 

equipment and emission points be acceptable?

Form B-4

 On Form B-4, please clarify what is meant by “burner type.” Some burners are 

proprietary company design and do not necessarily conform to a “burner type.”

 On Form B-4, please clarify whether the rebuild information requested pertains to 

forehearths.

 On Form B-4, please define “modules” and “plenums.”

Form B-5

 On Form B-5, please define “oven rebuild.”

Form B-7

 On Form B-7, please clarify the conflict between the form which uses the term 

“volatile solvents” and the instructions which uses the term “HAP solvents.” 

Also, please clarify that this refers to solvents used on affected facilities as 

defined in 40 C.F.R. 63, Subpart NNN.

Form C

 On Forms C-1, C-2, C-3, C-4, C-5, C-6, and C-7, what is meant by “problems” 

with the control device?
March 11, 2010

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 Please clarify the ventilation system form. Is it only for ventilation in the area of 

NNN-affected sources? Is the local ventilation question intended to include 

ventilation that goes through a control device that would be answered in a prior 

portion of the C forms?

Forms C-2, C-7

 Wastewater is apparently water exiting the scrubber. Please define “scrubbing 

water.” Is scrubbing water also the water exiting the scrubber?

Form C-3

 Please define “mechanical collector.”

Form C-4

 Please define “average stack opacity.”

Form C-6

 Please define “High Velocity Air Filter.”

 Does “High Velocity Air Filter” refer to a “High Efficiency Air Filter (HEAF)” 

control device? If not, what form should be used for a HEAF control device?

Form C-8

 Please define “Ventilation system.”

Form D

 With respect to startup and shutdown information, is EPA referring to just the

melters?

Form E

 Is it EPA’s intention to report the data twice?

 On Form E, please clarify the timeframe for which the data is being requested.

Form F-1

 On the last question of Form F-1, please clarify if the substitution mentioned is 

substitution available to the producer or substitution available to the consumer.
March 11, 2010

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Enclosure 2

 In Table 1.1, collection chamber test data on formaldehyde, phenol, and methanol 

is mandated. Are the collection chambers for unbonded lines exempt from having 

any test data on formaldehyde, phenol, and methanol?

 Many operations indicate that processes and controls operate the same during 

startup and shutdown. For those facilities, the response simply would be “not 

applicable.”

 If a company is considered part of the representative subset, can that 

representative data be used for future reporting requirements? This is similar to

how companies use AP-42 tables.

 NAIMA is requesting a separate call to focus exclusively on test methods. See

our “Timeline and Schedule for Preparation of NAIMA Plan and Schedule for 

Completing Both Wool Fiber Glass and Mineral Wool Information Collection 

Requests.”

 Some sources have forming, curing, and cooling combined into one stack. It is 

not possible to sample each process separately and meet test method requirements. 

NAIMA would want to use representative data for these scenarios.

 The listed EPA Method 5 for PM2.5 references a filter temperature of 320°F 

 25°F. This filter temperature does not comply with Method 5 (250  25) or 

Modified Method 5 (350  25). Where does the 320°F come from?

 Why has EPA doubled the minimum time and sample volumes? This will add 

days to the sampling events at the facilities and should be considered in 

calculating the time needed to complete the ICR.

 Is PM filterable the sum of PM2.5 plus the PM fraction greater than PM2.5?

 Is it even possible to accurately test the inlet? Does EPA expect the inlet and 

outlet testing to all be done simultaneously?

 Please define “inlet” and “outlet.”

 Please clarify the purpose for deviating from standard run times/number of runs.

 Is the additional PM2.5 testing requested just for the furnace and not for the 

collection, curing, and cooling?
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 For the collection, curing, and cooling emission points, the draft ICR requests 

PM2.5. However, the permits require Method 5E for PM and Method 5/202 for 

PM10 at some facilities. There is also limited data for PM10 using Method 5/OTM 

28 and CTM039 to eliminate ammonium sulfate artifact. Could any of this data 

be provided in lieu of the PM2.5 data requested? PM10 data available is for run 

lengths of 2 hours, not 4 hours.

 In the case that filterable and not condensable data is available for all furnaces, 

can condensable data be estimated?

 In Table 1.2, what is the purpose of reporting “ppmvd@7%O2”? From where 

does the “@7%O2” originate?