**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 S ection 114. Please confirm that the final letter/agreement will indicate that this effort i s being done cooperatively rather than under a S ection 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, cop y 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 c ollection of this information.  Inresponding to Enclosures 1 and 2, will EPA agree that some parts of the data will be submitted by

m ember companies and other data will be submitted by NAIMA?  On all forms, EPA seeks degrees, minutes, and seconds on latitude/longitude data . C an 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 . D oes 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 p articulate matter for PM 2.5 different than that in the NAAQS?**March 11, 2010**

2  The definition of “process line” includes material delivery through waste management . A s 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 c larif

y what is meant by “process line . ”  Why i s a plot plan necessary? They likely do not exist and would take considerable resources to create. What information do es 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 ty

pe.” S ome burners are proprietary

company design and do not necessarily conform to a “burner typ e.”  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.” Als o, 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**

3  Please clarify

the ventilati on system form. I s it only f or 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. P lease 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**

4 **Enclosure 2**  InT able 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 process es and controls operate the same during startup and shutdown. F or those facilities, the response simp ly 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 s imilar 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 PM 2.5 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 PM 2.5 plus the PM fraction greater than PM2.5 ?  Is it even possible to accurately test the inlet? D oes 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 PM 2.5 testing requested just for the furnace and not for the collection, curing, and cooling?**March 11, 2010**

5  For the collection, curing, and cooling emission points, the draft IC R requests PM 2.5 . However, the permits require Method 5E for PM and Method 5/202 for PM 10 at some facilities. There is also limited data for PM 10 using Method 5/OTM 28 and CTM039 to eliminate ammonium sulfate artifact. C ould any o f this data be provided in lieu of the PM 2.5 data requested? P M 10 data available is for run lengths of 2 hours, not 4 hours.  Inthe 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%O 2 ”? From where does the “@7%O 2 ” originate?