# IIG MinWool LLC

Phenix City Plant

Startup, Shutdown, Malfunction Plans 

# MACT

Operations, Maintenance, Monitoring PlansMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

Table of Contents

A Applicability

................................ ................................ ................................ ............... 5

B General Information

................................ ................................ ................................ .... 6

B.1 Recordkeeping

................................ ................................ ................................ .... 6

B.2 Modifications to Plan

................................ ................................ .......................... 6

B.3 General Malfunction Procedures

................................ ................................ ........ 6

B.4 Resin Free Formaldehyde Content

................................ ................................ ...... 6

B.5 Cupola

................................ ................................ ................................ ................. 7

B.5.1 Description

................................ ................................ ................................ .. 7

B.5.2 MACT

– Carbon Monoxide

................................ ................................ ........ 7

B.5.3 MACT

– PM as HAP Surrogate

................................ ................................ . 7

B.5.4 Cupola w/ Baghouse

................................ ................................ ................... 8

B.5.4.1 Overview

................................ ................................ ................................ . 8

B.5.4.2 Startup and Shutd own of Cupola

................................ ............................ 8

B.5.4.3 Malfunctions of Cupolas

................................ ................................ ......... 8

B.5.5 Baghouses

................................ ................................ ................................ ... 9

B. 5.5.1 Overview

................................ ................................ ................................ . 9

B.5.5.2 Malfunction

................................ ................................ ............................. 9

B.5.5.3 Monitoring

................................ ................................ .............................. 9

B.5.6 Bag Leak Detection System

................................ ................................ ........ 9

B.5.6.1 Overview

................................ ................................ ................................ . 9

B.5.6.2 Operations & Maintenance

................................ ................................ ... 10

B.5.6.3 Responding to Leak Detector Alarms

................................ ................... 10

B.5.7 Cupola Melt Rate Monitoring

................................ ................................ ... 10

B.5.7.1 Overview

................................ ................................ ............................... 10

B.5.7.2 Melt Rate Measurement

................................ ................................ ........ 11

B.6 Rockwool Curing Oven

................................ ................................ .................... 11

B.6.1 Description

................................ ................................ ................................ 11

B.6.2 MACT

– Formaldehyde as HAP Surrogate

................................ .............. 11

B.6.3 Curing Oven Startup & Shutdown

................................ ............................ 11

B.6.4 Oven Incinerator

................................ ................................ ....................... 12

B.6.4.1 Overview

................................ ................................ ............................... 12

B.6.4.2 Malfunction

................................ ................................ ........................... 12Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

B.6.4.3 Annual Inspections

................................ ................................ ................ 12

B.6.5 Oven Incinerator Temperature Monitoring

................................ ............... 12

B.6.5.1 Overview

................................ ................................ ............................... 12

B.6.5.2 Malfunctions

................................ ................................ ......................... 12

C Resin Free Formaldehyde Monitoring

................................ ................................ ...... 13

C.1 Resin Vendor Certificate of Analysis

................................ ............................... 13

C.2 Monitoring

................................ ................................ ................................ ........ 13

C.3 Corrective Actions

................................ ................................ ............................ 13

C.4 Required R ecords

................................ ................................ .............................. 13

D Cupola and Curing Oven SSM/OMM

................................ ................................ ...... 14

D.1 Cupola

................................ ................................ ................................ ............... 14

D.1.1 Star tup and Shutdown Procedures

................................ ............................ 14

D.1.2 Required Records

................................ ................................ ...................... 14

D.1.3 Baghouse

................................ ................................ ................................ ... 16

D.1.3.1 Operations & Monitoring

................................ ................................ ...... 16

D.1.3.2 Maintenance: Calibration and Inspections

................................ ........... 16

D.1.3.2.1 Calibration

................................ ................................ ...................... 16

D.1.3.2.2 Inspections

................................ ................................ ..................... 16

D.1.3.2.3 Envirotech System Maintenance

................................ .................... 18

D.1.3.2.4 Spare Parts List

................................ ................................ .............. 18

D.1.3.3 Operational Malfunctions

................................ ................................ ..... 18

D.1.3.3.1 Baghouse Inlet High Temperature Alarm

................................ ...... 18

D.1.3.3.2 Other Bypass Events

................................ ................................ ...... 18

D.1.3.4 Responding to Leak Detector Alarm

................................ .................... 19

D.1.4 Bag Leak Detectio n System

................................ ................................ ...... 20

D.1.4.1 Monitoring

................................ ................................ ............................ 20

D.1.4.2 Maintenance & Calibration

................................ ................................ ... 20

D.1.5 Cupola Melt Rate Monitoring

................................ ................................ ... 22

D.1.5.1 Operation

................................ ................................ ............................... 22

D.1.5.2 Monitoring Requirements

................................ ................................ ..... 22

D.1.5.3 Calibration Program

................................ ................................ .............. 22

D.1.5.4 Malfunctions

................................ ................................ ......................... 23

D.1.6 Spare Parts List

................................ ................................ ......................... 23Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

D.2 Curing Oven and Incinerator

................................ ................................ ............ 24

D.2.1 Startup and Shutdown Procedures

................................ ............................ 24

D.2.2 Maintenance

................................ ................................ .............................. 24

D.2.3 Incinerator

................................ ................................ ................................ . 24

D.2.3.1 Annual Incinerator Inspection

................................ ............................... 24

D.2.3.2 Malfunctions

................................ ................................ ......................... 25

D.2.3.2.1 Exhaust Fan Malfunction

................................ ............................... 25

D.2.4 Incinerator Temperature Monitoring

................................ ........................ 25

D.2.4.1 Monitoring Parameter Deviation

................................ .......................... 25

D.2.4.2 Maintenance and Calibration

................................ ................................ 25

D.3 Binder Formulation M onitoring

................................ ................................ ........ 26

D.3.1 Binder Formulation

................................ ................................ ................... 26

D.3.2 Monitoring

................................ ................................ ................................ 27

D.3.3 Mon itoring Parameter Deviation

................................ .............................. 27

E Appendices

................................ ................................ ................................ ................ 28

E.1 Regulations

................................ ................................ ................................ ....... 29

E.1. 1 General Provisions 40CFR63 Subpart A

................................ .................. 29

E.1.2 MACT

– Mineral Wool Production

– 40CFR63 Subpart DDD

............... 29

E.2 Resin Free Formaldehyde

................................ ................................ ................. 30

E.2.1 Resin Specification

– Dynea 367.10

................................ ......................... 30

E.2.2 Resin Certificate of Analysis

................................ ................................ .... 30

E.3 Equipment Documents

................................ ................................ ...................... 31

E.3.1 Cupola

– General Description

................................ ................................ ... 31

E.3.1.1 Cupola and Envirotech P&ID

................................ ............................... 35

E.3.2 Curing Oven

– General Description

................................ ......................... 36

E.3.2.1 Curing Oven Diagram

................................ ................................ ........... 37

E.3.3 Bag house Leak Detector

................................ ................................ ........... 38

E.3.3.1 Manufacturer Certification

................................ ................................ .... 38

E.3.3.2 USEPA Guidance on Baghouse Leak Detectors

................................ .. 38

E.4 Incinerator Inspections

................................ ................................ ...................... 39

E.4.1 Annual Incinerator Inspection SAP Document

................................ ......... 39

E.4.2 Most Recent Report

................................ ................................ .................. 39

E.5 Required Checklists

................................ ................................ .......................... 40Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

E.5.1 Cupola Startup/Shutdown Checklists

................................ ....................... 40

E.5.2 Oven Startup/Shutdown Checklist

................................ ............................ 40

E.5.3 Pressure Transmitter Calibration Checklist

................................ .............. 40

E.5.4 Baghouse Checklists

................................ ................................ ................. 40

E.5.4.1 Monthly Inspection Checklist

................................ ............................... 40

E.5.4.2 BHA Bi

- Annual Inspection Proposal / Checklist

................................ . 40

E.5.4.3 Baghouse High Temperature Alarm

................................ ..................... 40

E.5.4.4 Leak Detector Alarm Checklist

................................ ............................ 40

E.5.4.5 General Baghouse Bypass Checklist

................................ .................... 41

E.5.5 Cupola Flue Gas Treatment Maintenance Checklists

............................... 41

E.5.6 Curing Oven System Maintenance Checklists

................................ .......... 41

E.5.7 Incinerator Checklists

................................ ................................ ............... 41

E.5.7.1 Incinerator Temperature Calibration Procedure

................................ ... 41

E.5.7.2 Incinerator Exhaust Fan Failure Checklist

................................ ............ 41

E.5.7.3 Incinerator Low Temperature Alarm

................................ .................... 41

E.5.8 Malfunction Procedures not Listed: Form

................................ ................ 41

E.6 Historic Documents

................................ ................................ .......................... 42

E.6.1 Notifications

................................ ................................ .............................. 42

E.6.2 Test Protocol

................................ ................................ ............................. 42

E.6.3 Final Compliance Report

................................ ................................ .......... 42

E.7 Applicable Requirements: Summary

................................ ............................... 43

E.8 Version Control Section

................................ ................................ .................... 44Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



## A Applicability

These plans are implemented pursuant to the requirements of 40 CFR 63, Subparts A and DDD. Copies of these regulations can be found in the Appendix, Section E.1. As such, these plans cover only those aspects of the affected facilities that relate to the control of the surrogate species selected by the agency for the covered HAPs, i.e., formaldehyde for curing ovens and parti culate emissions for the cupola.

Additional activities required for the safe and productive operation of the equipment are captured in other, appropriate documents.

This document contains

 Startup and Shutdown plans for the affected sources,

 Malfunction p lans for the sources and control equipment, and

 Operations, Maintenance, and Monitoring plans for the control equipment and monitoring devices.

 A summary of all Applicable Requirements based on Performance Sampling and the MACT Regulations. (See Appendix E.7)

The required documents are identified in the table below.

Required Procedures

Area TypeStartup/ShutdownMalfunctionMonitoring &CorrectiveActionsOperations &Maintenance

Resin Free Formaldehyde Monitoring X

Cupola Source X

Baghouse Control

X Corrective

actions for

leak alarm. X

Baghouse Leak

Detector Monitoring X X

Cupola Melt Rate Monitoring X X

Manufacturing Line Source X

Oven Incinerator Control X Annual Inspection

Incinerator Temp Monitoring 3

- hour block X

Bind er formulation Monitoring Formulation

of each batchMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



## B General Information

B.1 Recordkeeping

Records required by the MACT standard must be retained for five (5) years. The most recent two (2) years of records must be kept on site. Required records are list ed in each

section.



### B.2 Modifications to Plan

Per the requirements of §63.1186, the limits established through the initial performance tests may be changed if additional performance tests are completed to support those changes. Proper notifications and agen cy involvement is required.



### B.3 General Malfunction Procedures

MACT Requirements:

There are regulatory requirements to follow the procedures outlined below for malfunctions occurring that impair the operation of the ESP. When a m alfunction occurs that impacts the operation of the unit, follow the attached checksheets to insure malfunction plans are followed. Checksheets can be found in the Appendix, Section E.2. MALFUNCTIONS LISTED IN PLAN

In cases where a malfunction occurs that is not part of the list included in the Appendix, special instructions must be followed and documented. A responsible individual must: MALFUNCTIONS NOT LISTED IN PLAN

 Record date and time of malfunction.

 Record nature of malfunction and steps taken to correct.

 Record date and time when malfunction is corrected.

 Develop a new checksheet and incorporate into this plan.

 Contact appropriate agency personnel.

A copy of a checklist suitable for documenting information in these cases can be found in the Appendix, Section E.5.8.



### B.4 Resin Free Formaldehyde Content

The free formaldehyde content of the incoming resin used to formulate binder is limited by the standard to the maximum level of the resin specification used during the performance testing.

§63.1183(e) Maintain the free

- formaldehyde con tent of each resin lot and the formaldehyde content of each binder formulation at or below the specification ranges established during the performance test.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

Therefore, the limit is not based upon the maximum free

- formaldehyde used during the performance te sting, but is based upon the maximum in the resin specification. The agency must concur that the resin shipments used during the performance testing are representative of resin specification.

The Phenix City facility uses only one resin under one resin sp ecification. The current resin is purchased from Dynea. A copy of the resin specification and Certificates of Analysis for resin free formaldehyde can be found in the Appendix, Section E.2.



### B.5 Cupola

B.5.1 Description

A cupola is defined in §63.1196:

Cupola mean s a large, water

- cooled metal vessel to which is charged a mixture of fuel, rock and/or slag, and additives. As the fuel is burned, the charged mixture is heated to a molten state for later processing to form mineral

wool.

The cupola at the Phenix City fa cility is heated using a combination of combustion air (preheated from the Envirotech incinerator) and coke. A detailed description of the setup and operation of the cupola along with the Environmental controls can be found in the Appendix, Section E 3.1.



### B.5.2 MACT

– Carbon Monoxide

In §63.1178(a)(2), the MACT standard places a requirement on control of carbon monoxide from new or reconstructed cupolas. Although the Phenix City cupola controls CO using an incinerator, it is not regulated under this standard du e to the definition of “new” or “reconstructed” source. According to the definition found in §63.1196:

New Source means any affected source the construction or reconstruction of which is commenced after May 8, 1997.

The cupola within the Phenix City facil ity was built in 1989 and has not been

“reconstructed” based on USEPA definitions.



### B.5.3 MACT

– PM as HAP Surrogate

For all cupolas, the MACT standard identifies particulate matter (PM) as the surrogate parameter for metal HAPs. The standard [§63.1178(a)(1)] de fines PM by citing the USEPA Method 5 test method, commonly referred to as filterable particulate. This plan details the procedures followed and the precautions taken to control the rate of particulate emissions from the cupola.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### B.5.4 Cupola w/ Baghouse

B.5.4.1 Overvie w Mineral wool fiber is produced by melting several raw materials in a cupola type melter. The rockwool at Phenix City is made from three ores: basalt, dolomite, and limestone. These three materials are melted in a cupola type furnace that uses coke as f uel to produce a melt that is fiberized to produce mineral wool fiber. No slag is melted within this cupola per State permit requirements.

The cupola furnace used to produce the mineral wool material is a vertical shaft type

melter. It consists of vertica l carbon steel cylinder closed at the bottom except for a channel from which to extract melt and provided with a sealing door at the top to charge raw materials. Melt exits toward the bottom of the cupola and flue gasses exit at the top of the cupola.

F lue gas exiting the cupola consists of gasses generated by the combustion of the coke and the calcining of the carbonate containing raw materials. These gases contain significant levels of particulate both from entrained fines from the charge and re

conden sed particulate from the melt. The flue gas cleaning system consists of two major units: an inertial separator (designated as the preheater/cooler separator) and a bag type pulsejet dust collector. The inertial collector is designed to remove large particu late form the stream. Located immediately after the inertial collector, is the bag type dust collector. This unit is designed to remove fine particulate from the cupola exhaust. The unit is equipped with felted Nomex filtration media (bags), which is cove red with a PTFE membrane providing fine particulate separation capability. This collector is equipped with pulse

- jet cleaning which utilizes bursts of compressed air admitted to the clean side of the media to remove collected particulate. The cleaning mode of the collector is initiated by a high

- pressure drop across the unit, the pressure drop being continuously monitored and controlled by the process control system. A triboelectric type bag leak detector is provided at the collector outlet to indicate high particulate levels indicating a bag failure or similar condition. The removed particulate is collected in a hopper located below the bags and removed from the system via a screw conveyor and rotary airlock. The dust is collected in a portable hopper.

A mo re detailed description of the cupola and exhaust cleaning system can be found in the Appendix, Section E.3.1.

B.5.4.2 Startup and Shutdown of Cupola
The cupola in use at the Phenix City facility is shutdown on a frequent basis (every 5 to 14 days) in order to rec harge the coke bed, replace the siphon, and other maintenance items. This unit is incapable of running continuously for periods in excess of 14 days.

During each startup and shutdown episode, procedures will be in place to ensure the

Envirotech control de vice is operated in a manner to reduce emissions from the cupola.

B.5.4.3 Malfunctions of Cupolas
Since the cupola at the Phenix City facility is equipped with a control device, there are no separate malfunction procedures written. The malfunctions that are deeme d critical toMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

emissions will be described as they pertain to the operation of the baghouse. Cupola operational malfunctions that do not interfere with the baghouse will not be dealt with in

this document.



### B.5.5 Baghouses

B.5.5.1 Overview
Baghouses consist of bags made of a filtering material that are installed in parallel. The number of bags for an installation is determined by the desired surface area of cloth that is needed to treat the air stream at a given pressure drop. PM collected on the cloth surface is period ically cleaned by some means

– mechanical, sonic, or pneumatic. A dust collection system is used to collect and transport the PM released from the bags.

Bag leak detection systems are devices placed in the air stream after the bags. These

devices can d etect the concentration of PM in the air stream and will alarm when a predetermined concentration is exceeded.

B.5.5.2 Malfunction
There are two main categories of malfunctions for a baghouse, those that cause the baghouse to be bypassed to protect the baghouse an d those that reduce the collection effectiveness of the baghouse. Known malfunctions in both these categories are

discussed in Section D.1.4.3.

B.5.5.3 Monitoring
Due to the installation of the bag leak detection system, there are no requirements for monitoring the operation of the baghouse itself. However, procedures must be in place to respond to the bag leak detection system alarm. These are listed in Section D.1.4.4.



### B.5.6 Bag Leak Detection System

B.5.6.1 Overview
Bag leak detection systems are devices that are placed in the air stream after the bags.

These devices can detect the concentration of PM in the air stream and will alarm when a predetermined concentration is exceeded. Per 40 CFR 63.1184, the bag leak detection system must meet the following requirements:

 Ce rtified by the manufacturer to be able to sense PM concentrations below 10 milligrams per actual cubic meter (0.0044 grains/scf) (A certification document can be found in the Appendix, Section E.3.3.1.)

 Produce an output of relative PM emissions

 Audibly alarm where it can be heard by the appropriate plant personnel when the preset level is exceeded

 Proper installation, including consistency with referenced USEPA guidance

documents

 Initially adjustedMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

 Not subsequently adjusted unless proper procedures are f ollowed

B.5.6.2 Operations & Maintenance
§63.1184(f) requires that triboelectric bag leak detection system be installed, operated, adjusted, and maintained in a manner consistent with the USEPA guidance, “Fabric Filter Bag Leak Detection Guidance” (EPA

- 454/R

- 98

- 01 5, September 1997). Other systems shall follow manufacturer’s written specifications and recommendations. A copy of this EPA guidance document can be found in the Appendix, Section E.3.3.2.

B.5.6.3 Responding to Leak Detector Alarms
In the event of a baghouse le ak detector alarm, the standard indicates the proper procedures to document the alarm.

§ 63.1192 (b)(2) All bag leak detection system alarms. Include the date and time of the alarm, when corrective actions were initiated, the cause of the alarm, an explana tion of the corrective actions taken, and when the

cause of the alarm was corrected.

The follow examples of corrective actions are given in the regulation for response to the bag leak detector alarm and are incorporated into the malfunction plan.

§ 63.1187 (b)(5)(i) Inspecting the fabric filter for air leaks, torn or broken bags or filter media, or any other condition that may cause an increase in emissions. (ii) Sealing off defective bags or filter media. (iii) Replacing defective bags or filter media, or otherwise repairing the control device. (iv) Sealing off a defective fabric filter compartment. (v) Cleaning the bag leak detection system probe, or otherwise repairing the bag leak detection system. (vi) Shutting down the process producing the pa rticulate

emissions.



### B.5.7 Cupola Melt Rate Monitoring

B.5.7.1 Overview
The production rate of a cupola is known as “melt rate”. In a standard cupola, raw materials and fuel (coke) are charged into the device and are heated with combustion air. Since flow from the cup ola is governed by gravity, the raw materials gradually move downward heating as they move. When a certain temperature is reached within the unit, the raw materials begin to soften and subsequently liquefy. The liquid material, “melt”,

is removed from th e cupola toward the bottom of the unit and is fiberized using a standard rockwool wheel type fiberizing process.

The definition of “melt” and “melt rate” can be found in §63.1196:

Melt means raw materials, excluding coke, that are charged into the cupola, heated to a molten state, and discharged to the fiber forming and collection process.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

Melt Rate means the mass of molten material discharged from a single cupola over a specified period of time.

B.5.7.2 Melt Rate Measurement

Since there is no automatic method of measuring the rate of molten material coming from the cupola, means have been devised to measure the input raw materials on a per “charge” basis. Based on the definition of “melt” shown above, and based on the requirements of §63.1188(g) for determining m elt rate during the performance test, the weight of all raw materials added to the cupola was monitored with the exception of

coke. More details can be found in Section D.1.6.



### B.6 Rockwool Curing Oven

B.6.1 Description

The definition of “curing oven” and “incinerat or” can be found in §63.1196:

Curing oven means a chamber in which heat is used to

thermoset a binder on the mineral wool fiber used to make bonded products.

Incinerator means an enclosed air pollution control device

that uses controlled flame combustion t o convert combustible materials to noncombustible gases.

The curing oven located within the Phenix City facility uses an incinerator (also referred

to as a thermal oxidizer ) to control VOC emissions. A pictorial representation of the oven and correspond ing airflows is located in Section E.3.2.1.



### B.6.2 MACT

– Formaldehyde as HAP Surrogate

The HAPs of concern for this standard are phenol, methanol, and formaldehyde. However, formaldehyde was selected as the surrogate parameter for all of these HAPs.



### B.6.3 Curing Oven Startup & Shutdown

Emissions from the curing oven go to a control device. Prior to the startup of the manufacturing line, the oven control device is put on line and checked to assure that it is operating within the established limits.

If the oven c ontrol device operation falls outside of the MACT limits, then the manufacturing line is shut down. There are no special procedures required for the shutdown of the manufacturing line.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### B.6.4 Oven Incinerator

B.6.4.1 Overview
The curing oven “incinerator” is a system th at collects the fumes from the curing oven and treats those fumes within a thermal oxidizer. A minimum operating temperature, established during the MACT performance testing, is used as an absolute limit. In other words, no rockwool insulation product sh all be run through the oven until the thermal oxidizer firebox temperature is at or above this minimum temperature.

The standard requires that the incinerator be operated to keep the 3

- hour block average of the incinerator temperature above the average e stablished during the performance testing [§63.1179(b)(2)].

IIG MinWool LLC continually monitors the firebox temperature and sets alarms at or above the established minimum average temperature. If the firebox temperature falls below the minimum temperat ure, the curing oven is shut down until the problem is identified and resolved. Because the reaction procedure is based upon real time temperature data, not the three

- hour block average, the three

- hour block temperature

should never fall below the minimum level while the curing oven is in operation.

B.6.4.2 Malfunction
Given the above procedure (line shutdown) and the annual inspection, there are no malfunctions in the manufacturing line or thermal oxidizer that will cause excess formaldehyde emissions. The incin erator portion of the line is coupled closely to the curing oven. As long as the curing oven is operating properly and as long as temperature is maintained in the incinerator, formaldehyde emissions will remain in check.

B.6.4.3 Annual Inspections

The standard re quires an annual inspection of the incinerator system to assure that it is in good working order. [§63.1187(b)(3)]. Documentation of the inspection and any resulting repairs must be filed as part of the MACT records.



### B.6.5 Oven Incinerator Temperature Monito ring

B.6.5.1 Overview
§63.1192(b)(4) requires the monitoring and recording of the temperature of the thermal oxidizer firebox, averaged over a three

- hour block. These average block temperatures must be above the average temperature established during the performa nce testing. The operating schedule of the manufacturing line will need to be included as part of the

MACT record for correlation with these three

- hour block average temperatures.

B.6.5.2 Malfunctions
Operation of the temperature monitoring system is required for the operation of the incinerator. If the temperature monitoring system fails, the curing oven must be shut down until the problem is resolved.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



## C Resin Free Formaldehyde Monitoring

The MACT standard requires that the formaldehyde content for each resin sh ipped to the facility be recorded. The Certificate of Analysis (C of A) from the resin vendor, which includes the free formaldehyde content, will be checked and the free formaldehyde data will be retained for each shipment of resin.

MACT also requires t hat no binder be formulated with a resin that contains a level of free formaldehyde higher than the upper specification that was used during the performance

tests.



### C.1 Resin Vendor Certificate of Analysis

The maximum allowed formaldehyde content is 9.0%, bas ed on the resin specification Dynea 367

- 10 (found in Section E.2.1).

During the performance sampling, the average free formaldehyde content, as measured by Dynea, was 8.86% which is considered to be at the very top of the specification

maximum of 9.0%. Th e C of A’s collected during the performance sampling can be

found in Section E.2.2.



### C.2 Monitoring

Prior to unloading any shipment of resin, the Certificate of Analysis corresponding to that shipment will be reviewed by an IIG MinWool LLC employee. The free f ormaldehyde level will be checked against the maximum limit of 9.0% and the C of A will be signed to confirm the level has been checked. The signed and dated C of A’s will be kept in the Quality Assurance lab.



### C.3 Corrective Actions

If the level of free form aldehyde in any resin shipment (as indicated by the vendor C of A) exceeds 9.0%, the shipment of resin will be rejected and will not be unloaded.

Note that there are no exceptions to this requirement, regardless of the potential impact on the facility.



### C.4 Required Records

The following records must be kept per §63.1192(b)(3):

The free

- formaldehyde content of each resin lot and the binder formulation, including formaldehyde content, of

each binder batch used in the manufacture of bonded products.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



## D Cupola a nd Curing Oven SSM/OMM

D.1 Cupola

A detailed description of the cupola can be found in Section E.3.1 and a P&ID diagram of the operation can be found in Section E.3.1.1. Startup and shutdown checklists can be found in the Appendix, Section E.5.1.



### D.1.1 Startup and Shutdown Procedures

The cupola in operation at the facility goes through a shutdown and startup cycle relatively frequently as discussed elsewhere in this document. The startup sequence can

be described as follows: Cupola Startup

 Start Envirotech system

 C harge cupola with 2100 lbs coke before normal charging

 Inject blast air at 3000 scfm when temperature is 850 °F (minimum) and

incinerator T

- 1 temperature is 1000 °F (minimum)

 Light cupola with oxygen lance

 Add oxygen enrichment to blast air at 7500 cfh

 Send exhaust gases to Envirotech by switching to S

- 3 mode

 Seal tapping hole when melt flow is obtained

 Increase blast air to 3800 scfm when melt flows from siphon

The cupola in operation at the facility goes through a shutdown and startup c ycle relatively frequently as discussed elsewhere in this document. The shutdown sequence

can be described as follows: Cupola Shutdown

 Prepare deck for cupola drop

 Open tapping hole and drain melt

 Set blast air to 2500 scfm

 Drop cupola contents to pit

 Select Envirotech S

- 2 mode (auto switch to S

- 1 stop at timeout)



### D.1.2 Required Records

The following records must be kept per § 63.1193(b)

- (c) :

 A completed startup checklist for each startup of the cupola, including any deviations from the written procedure contained within this pl an.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

 A completed shutdown checklist for each shutdown of the cupola, including any deviations from the written procedure contained within this plan.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### D.1.3 Baghouse

D.1.3.1 Operations & Monitoring
The Bahnson Norblo baghouse in operation at the Phenix City facility is used to control particulate emissions from the cupola. It employs a typical pulse jet cleaning system to remove dust from a series of 312 Nomex felt filter bags with PTFE membranes (39 rows of 8 bags each). The cleaning cycles are operated via a pressure drop; when the pressure across the bags reaches a certain maximum, the cleaning cycle is engaged, a pulse of air enters the clean air side of the bag, and the filter cake is removed thus lowering the pressure. The current set up for the baghouse is to ru n at a DP of about 7” w.c. Once this pressure is reached the cleaning cycle begins using a short pulse of air throughout the entire baghouse, row

- by

- row.

In order to insure adequate removal of particulate and normal operation of the baghouse,

a triboelect ric leak detection system is used. The bag leak detector is described in Section D.1.5. The baghouse is also inspected on at least a monthly basis. Inspections

are described in Section D.1.4.2.2.

D.1.3.2 Maintenance: Calibration and Inspections



### D.1.3.2.1 Calibration

The DP Cell transmitter used for the operation of the pulse jet system will be calibrated on at least an annual basis, or when a problem is suspected. The maintenance checklist for calibrating the DP cell can be found in the Appendix, Section E.5.3.



### D.1.3.2.2 Inspecti ons There will be two frequencies of inspection for the baghouse, monthly and bi

- annual. In each case as problems are found, they will be documented and fixed as soon as is practicable. Note that monthly inspections may be done on a more frequent basis, but will be done no less than monthly. The bi

- annual inspections will take the place of the monthly inspections for those months the inspection is scheduled. Therefore, at a

minimum there will be 2 bi

- annual inspections and 10 monthly inspections per yea r.

Facility personnel will conduct, at a minimum, a monthly inspection of the baghouse. A checklist for the monthly inspection is shown in the Appendix, Section E.5.4.1. The elements of this monthly inspection are shown below: Monthly Inspections

 Inspec t clean

- air plenum for dust. Clean as necessary.

 Inspect inside of bags for dust accumulation.

 If necessary, do Visolite® leak check determination.

 Inspect all seals around doors.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

 Inspect diverter plate for holes or other damage. Repair as necessary.

 Ins pect all air connections to pulse

- jet venturi’s.

 Inspect all air filters on combustion air fans for integrity and cleanliness.

 Inspect and clean baghouse leak detector probe.

The Phenix City Plant will enter into a voluntary contra ct with BHA group to have a

semi

- annual baghouse inspection completed. The proposal from BHA is located in the Appendix, Section E.5.4.2. The elements of this semi

- annual inspection are shown

below: Semi

- annual Inspections

 Lock and tag out main control panel and perform safety orientation prior to commencing internal work.

 Vacuum or sweep minor tubesheet accumulation under 2" into the hopper to ensure proper inspection for leaks and to facilitate proper bag installation.

 Perform Visolite® Leak Detection test or otherwise visuall y inspect for leaks immediately upon completion of the scope of work to ensure a leak free system.

 Inspect bags visually to determine any problems and evaluate overall condition.

 Change up to 5% of the bags as needed. Bags to be provided by customer.

 Insp ect for and repair minor leaks in tubesheet and housing.

 Inspect for hopper problems such as buildup or bridging.

 Inspect for baffle plate wear.

 Inspect for and repair minor door seal leaks 10% with materials supplied by

customer.

 Clean static pressure tap s for Magnehelic® Gauges or manometers.

 Observe and document cleaning cycle information (frequency, duration, etc.)

while collector is on

- line.

 Observe and record differential pressure readings on each compartment (or as appropriate) while collector is on

- line.

 Submit a written report on each collector inspected, identifying current condition, work completed, inventory use and recommendations.

 Inspect all pulse valves and solenoids for proper operation and repair up to 20% with repair parts supplied by cust omer.

 Inspect cages for corrosion and overall condition.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### D.1.3.2.3 Envirotech System Maintenance

The Envirotech unit controls emissions from the cupola and consists of a baghouse and incinerator (for CO emissions). A description of this device and the role it plays can be

found in Section E.3.1.

The documented maintenance schedule for this device can be found in the Appendix,

Section E.5.5.



### D.1.3.2.4 Spare Parts List

As part of the ongoing operation of the baghouse, the Phenix City facility will have the following spare parts , at a minimum, on

- hand:

 15 Bags (Nomex felt bags w/ PTFE membrane)

 10 Cages

 10 Sets of air cleaning solenoids and diaphragms

 1 Spare screw for baghouse dust conveying system

D.1.3.3 Operational Malfunctions



### D.1.3.3.1 Baghouse Inlet High Temperature Alarm

The flue gas from the cupola is cooled via a heat exchanger, as described in Section E.3.1, prior to entering the baghouse. The Nomex bags currently in use cannot be used for extended periods above 450oF. In the event the temperature in the inlet to the baghouse reaches a critical point, the baghouse will be bypassed to prevent destruction of the Nomex filter media. In some instances, the bypass lasts for only several minutes until the temperature can be lowered. If the temperature cannot be reset within 30 minutes, a

m alfunction condition exists and the following steps will be taken to correct the situation:

 Insure cooling to the heat exchanger is maximized.

 Continue to bypass the baghouse to prevent damage to the filter media if temperature reaches critical level.

 Moni tor and respond to cupola as necessary to reduce temperature.

 If none of the above steps correct the temperature problem within 1 hour of bypassing the baghouse, the agency must be contacted per the facilities State Operating Permit.

A checklist can be fou nd in Section E.5.4.3.



### D.1.3.3.2 Other Bypass Events

There are other malfunctions that can lead to a bypass of the baghouse. These malfunctions will be detected via monitoring of the process. As part of troubleshooting any bypass, standard procedures will insure m alfunctions that hamper baghouse performance are examined. In all instances, the bypass will be concluded as soon as is practicable to insure safety of employees and to prevent damage to equipment.

The main response to a bypass without an immediate alarm or known cause is to:Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

 Insure the stack cap is open for a reason (such as a power failure), and troubleshoot problem. If not, or if system has been accidentally tripped, close stack cap.

 If bypass has occurred because of an assignable cause, document time and date of occurrence, cause, and steps taken to fix problem.

A checklist for a bypass event caused by unplanned issues, such as power outages, general equipment failure, operator error, and the like, can be found in the Appendix,

Section E.5.4.5.

D.1.3.4 Respo nding to Leak Detector Alarm
The leak detector alarm has been calibrated by B3 Systems in accordance with recommendations cited within the EPA Baghouse Leak Detector Guidance document. Although ideally a calibrated leak detector will alarm only when there is a leak, there has been evidence that the leak detector in place within the facility can alarm for several minutes at a time during cleaning cycles. In these instances, Visolite® leak checks have shown no noticeable bag leaks. For this reason, it beco mes necessary to define an alarm

as “a continuous alarm that lasts for a minimum of 15 minutes”.

In the event of a continuous alarm, the following procedure will be done:

 The time and date will be documented.

 The most recent 24

- hour detector trend will be examined to determine if the alarm has resulted from a “sudden” jump or a longer

- term rise.

 All systems will be examined to insure there has not been a cupola upset that may be causing problems with the baghouse.

 As soon as is practicable, B3 Systems will be contacted to run a diagnostics on the probe to determine if the system is operating properly.

 As soon as is practicable, the leak detector probe will be removed and will be cleaned in accordance with manufacturer’s recommended practices.

If none of thes e steps solve the problem, and the baghouse remains in alarm, the following steps will be followed:

 If there has been a known problem (over temperature of the baghouse for example) where a catastrophic failure of the system is possible, shut the cupola

dow n as soon as is practicable.

 If there has been no known problems with cupola operation, continue running the cupola until the next scheduled downtime, but no later than 120 hours from the initial alarm. Do not bypass the baghouse.

The current inlet loadin g on the baghouse is >150#/hour. Bypassing the baghouse for even a short amount of time while in a leak detector alarm mode would be allowing an inordinate amount of emissions into the atmosphere. Even with multiple broken bags, the level of dust escapin g from the system has been shown to be minimal (<5#/hour).Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

In order to “take the cupola down”, numerous items have to be in place. A standard downtime lasts for at least 12 hours and takes a large number of Plant personnel to accomplish in a safe manner. Waiting at most

Once the cup ola is down and it is safe to enter the baghouse, the following steps will be

taken to determine the reason for the leak detector alarm: 120 hours from the onset of a leak detector alarm to shut the system down would be consistent with safe operating practices. Once the cupola is down, other safety factors have to be considered such as CO levels in the

system.

 Visually inspect the clean air plenum in the baghouse.

 Visually inspect the insides of all bags.

 Inspect the diverter p late near the inlet of the baghouse.

 Visually inspect the outside of the first several rows of bags.

 Correct any problems found including sealing off or replacing the bag or bags.

 When completed, run a Visolite® leak check on the system to insure all poten tial leaks have been repaired.

 Once all bags have been shown to be intact, go through the standard monthly inspection list.

A checklist to follow can be found in the Appendix, Section E.5.4.4.



### D.1.4 Bag Leak Detection System

D.1.4.1 Monitoring
The calibration and setup of the baghouse leak detection system will be completed through contractual arrangement with B3 Systems. The Phenix City Plant will monitor the output of the leak detector. If the leak detector signal results in an audible alarm, facility personnel will respond as described in Section D.1.3.4.

D.1.4.2 Maintenance & Calibration
Maintenance will be performed on the leak detector probe on a monthly basis as

described in D.1.3.2.2.

IIG MinWool LLC has entered into a contractual arrangement with B3 Systems to

monitor and calibrate the baghouse leak detection system. B3 follows recommendations found within the Leak Detector Guidance document found in the Appendix, Section E.3.3.2. Responsibility of daily monitoring, probe cleaning, and response to audible

alarms is t hat of IIG MinWool LLC

. EPA’s “OAQPS Fabric Filter Bag Leak Detection Guidance” provides information on how to initially setup the baghouse monitors and how to conduct on

- going quality assurance procedures. The guidance is somewhat subjective and allows fo r differing procedures based on facility

- specific issues. The yearly monitor setup procedures and results must be documented and certified by the personnel who conduct them. B3 Systems has developed a procedure whereby they can access the baghouse leak det ectorMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

and conduct the monitor setup procedures remotely. In this procedure, they adjust the sensitivity, zero offset, span multiplier, time constant, alarm level, and alarm delay for

each sensor.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### D.1.5 Cupola Melt Rate Monitoring

D.1.5.1 Operation

The device in use me asures the weight of all raw materials, “the charge”, entering the cupola. The system is referred to as the “ABB Advant with Operate IT”. Raw material weights are continuously added for each “charge” over a period of 12 hours (once per shift) at which ti me the counters are reset. To determine the total amount of any or all raw materials, one simply subtracts the reading at the end of the period in question from the reading at the beginning of the period in question.

The various rock types that make up th e recipe for a “charge” are stored in bins in the

rockhouse . Each bin holds one particular type of rock. However, two separate bins may hold one type of rock. The “charge” is made up of X pounds of each type of rock. The “charge” is called for through an “ on demand” system from the Cupola. The control system then energizes the appropriate bins, constantly registering the weight change until the recipe is satisfied. As the rocks are fed from the bins, a conveyor system then travels the rock to the top of the Cupola. This process is repeated on a cycle of approximately

10

- 12 minutes.

D.1.5.2 Monitoring Requirements
The current system in use to monitor raw material input in to the cupola is described in section D.1.6.1. The raw material input will be determined on a p er shift block basis (shifts vary between 8 and 12 hours) and will be converted to throughput in pounds per

hour. The method is outlined below:

Throughput (#/hr) =

Shift time (8 or 12 hours) (total basalt + total dolomite + total limestone) pounds

Ba sed on the requirements of the standard, coke does not get included as input raw material into this equation. The value will be recorded in the operators logbook every 8

- 12 hours when the unit is operational.

D.1.5.3 Calibration Program
The ABB System must be c alibrated in accordance with manufacturer’s recommendations at a minimum. Calibration will be conducted, at a minimum, on a bi

annual basis. The Phenix City facility will calibrate these scales by performing the following tasks.

The scale calibration c onsists of placing known weights on the scale platform that equals 10% of the scales’ capacity. The scale then is placed into calibration mode, the variables are keyed into the unit, and it runs a self

- calibration routine. A known weight is then reapplied to the scale platform to verify the weight being displayed. After this, the signal from the scale to the control system is calibrated.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

D.1.5.4 Malfunctions
In the event the ABB System malfunctions, the following will be done to insure timely

resolution.

If a scal e malfunction occurs, the system is changed to a bin that a particular rock type is charged from. This allows facility personnel to repair the scale or feeder without any effect to the process. If the problem is related to a bin for which this is not possi ble, charging must be stopped and the cupola must go into a “bank” mode. This mode allows Operations to hold the molten rock in the Cupola until the repairs are completed.

Malfunctions can include scale failures, signal feedback problems, vibrating feeder failures or conveyor belt problems. Since many of these malfunctions cannot be fixed short of device replacement, the facility will keep a number of items within the spare parts inventory, and simply replace them as needed. Note that if a device fails th at prevents the ABB System from working, charging of raw materials to the cupola halts as does production.



### D.1.6 Spare Parts List

Because of the type of malfunctions that occur, the facility will keep the following spare parts in inventory:

 scale controller

 load cell

 vibrator coil and core

 S.C.R. for the vibrator controller

 pneumatic vibratorMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### D.2 Curing Oven and Incinerator

D.2.1 Startup and Shutdown Procedures

The startup and shutdown procedures for the curing oven are shown below. It is imperative to insure that the i ncinerator temperature is at or above setpoint whenever product is introduced into the oven. Checklists for the startup and shutdown can be found

in Section E.5.2.

 Start Filterhouse 3 motor group Curing Oven Startup

 Start oven chain drive (curing warm mod e, 10 f/min)

 Start Integral motor group (includes burner start sequence)

 Allow oven return temperature to reach operational range

 Insure incinerator temperature is at or above 1300oF.

 Begin production

 Empty oven Curing Oven Shutdown

 Incinerator temperatur e can be lowered below 1300oF at this stage

 Shut off oven burners

 Allow oven return temperature to fall to 200 degrees

 Shut off chain drives

 Shut off Integral motor group

 Shut off Filterhouse 3 if rollup is not running



### D.2.2 Maintenance

The oven and incinerator are closely coupled devices. Maintenance of these two systems is integral to the proper operation of the control device. Maintenance task checklists can be found in the Appendix, Section E.5.6.



### D.2.3 Incinerator

D.2.3.1 Annual Incinerator Inspection
The annual inspect ion covers both the internal and external portions of the oxidizers. For the internal evaluations, the oxidizer must be shut down in advance to cool down to ambient temperature for personnel entry.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

The SAP description of both the internal and external ph ases of the annual evaluation that will be performed can be found in Section E.4.1. The most recent incinerator inspection report can be found in the Appendix, Section E.4.2.

D.2.3.2 Malfunctions



### D.2.3.2.1 Exhaust Fan Malfunction

If the exhaust fan malfunctions, the operat or will take the following actions:

 Stop all product on the line.

 Shut off all oven burners.

 Shut off all incinerator burners.

 Call maintenance if fan cannot be restarted.

A checklist for the exhaust fan failure can be found in the Appendix, Section E.5.7. 2.



### D.2.4 Incinerator Temperature Monitoring

D.2.4.1 Monitoring Parameter Deviation
During performance testing a minimum temperature was determined for the curing oven incinerator. The detailed information can be found in the final compliance report,

Section E.6.3.

Mini mum Temperature: 1292oF

The following procedure will be followed:

During normal operation, the incinerator will be continuously monitored for temperature. In the event that the incinerator temperature drops below the minimum determined during compliance sampling, an alarm will sound and the operator will respond within one hour if product is running through the oven. Reaction procedures include:

 Insure set point has not drifted, adjust as necessary.

 Insure all fans and burners are operating properly.

 Cal l electrician to determine if thermocouple is responding properly.

 If above steps do not fix device, stop production until problem can be resolved.

On an ongoing basis, the facility will maintain records of the incinerator temperature in

two formats. On a weekly basis, a trendchart will be printed showing the continuous data stream. Also, records will be kept in an hourly average format

– 24 datapoints per day. A checklist for a low temperature deviation has been added to the Appendix, Section

E.5.7.3.

D.2.4.2 M aintenance and Calibration
The incinerator thermocouple will be changed out as needed or once every six months at a minimum in conjunction with calibration of the transmitter. The procedure for calibration of the transmitter can be found in the Appendix, Section E.5.7.1.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### D.3 Binder Formulation Monitoring

D.3.1 Binder Formulation

The binder used in the Mineral Wool Manufacturing process is a standard urea

- extended, phenol formaldehyde based binder. A list of the ingredients and purpose is shown below:

Phenolic Res in (Dynea 367.10): main bonding agent

Urea: extender (reacts with formaldehyde to form UF resin)

Ammonia: stabilizing agent used to keep pH elevated

Oil Emulsion: dust suppression agent

Silane: adhesion promoter

Silicone: lubricant / water repellant agent

There is only one binder “formulation” in use at the facility for cured board products. The identification of this binder is simply Line Binder . It is important to note that the level of some ingredients is dictated by the solids level desired and by th e actual % solids of the incoming raw materials. The following chart shows a typical batch formulation for board products. Also shown in the chart are the levels of ingredients used during the performance testing (note that a 40% batch size was used duri ng sampling).

Ingredient Typical

Pounds

in a

Batch % Solids of Ingredient Total %
of Batch

Mix Pounds of
Solid in

Batch Pounds

Used During Testing

Resin 4644 50% 20% 2322 1814

Urea 4954 20% 21% 990.8 1936

Water 12000 0% 51% 0 4775

Ammonia 480 0% 2% 0 200

Silane 16 1% 0% 0.16 5.77

Silicone 8 60% 0% 4.8 4.54

Mulrex 500 45% 5% 540 250

Total 22602 100% 3857.76 8985

The key components of the binder that we believe impact formaldehyde emissions from the curing oven are resin a nd urea content and resin type. The other components of theMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

formulation do not play a significant role in formaldehyde emissions. The Phenix City facility makes a master batch of “premix” which is a mixture of resin and urea. This

master batch is used t o feed all binder formulations each day.

It is the opinion of IIG MinWool LLC that as long as the relative ratio of urea to resin stays the same, the resin free formaldehyde content stays below the performance specification, and the same resin (Dynea or eq uivalent) are used, the level of formaldehyde emissions from the curing oven will be within the MACT compliances

limits.

Changes in these levels beyond that which was used during compliance testing must be followed by performance sampling.

Changes in binde r ingredients, manufacturer, or levels of impurities must be scrutinized by responsible Environmental personnel.



### D.3.2 Monitoring

The facility will keep a running record of premix formulations. Typically, one premix is made per day. This premix is used in all Line Binder formulations.

Based on data supplied during MACT compliance sampling, the ratio of resin to urea can

be determined as follows:

pounds resin used / pounds urea used = resin:urea ratio

2322 lbs solid resin / 990.8 lbs solid urea = 2.34 : 1 ratio

If we assume a good number for each weight is +/

- 2%, then we have a maximum range

of resin to urea as:

2368 lbs solid resin / 971 lbs solid urea = 2.44 : 1 ratio (or +4%)

Since addition of urea to the binder does not constitute a change in “binder formula tion”, there is no minimum value, i.e., more urea can be added without requiring a response.

Monitoring Range => less than or equal to 2.44:1 resin to urea



### D.3.3 Monitoring Parameter Deviation

If the monitoring parameter is higher than 2.44, the operator will a dd enough urea to

reduce the ratio to between 2.25 and 2.44.

If the ratio of resin to urea is higher than 2.44 and the pre

- mix is used to make binder, the operator must make note of the deviation. All attempts must be made to insure the premix falls insid e the monitoring parameter.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



## E AppendicesMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### E.1 Regulations

E.1.1 General Provisions 40CFR63 Subpart A

E.1.2 MACT

– Mineral Wool Production

– 40CFR63 Subpart DDDMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### E.2 Resin Free Formaldehyde

E.2.1 Resin Specification

– Dynea 367.10

E.2.2 Resin Certificate of Analysis

<Attach copies of the C of A’s generated for resin used during performance tests.>Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### E.3 Equipment Documents

E.3.1 Cupola

– General Description

1.1. General : Mineral wool fiber is produced by melting several raw materials in a cupola type melter. At the Phen ix City plant , rockwool is produced as opposed to slagwool which refers to the raw material source. Mined raw minerals are used to produce rockwool while blast furnace slag is used to produce slagwool. The rockwool at Phenix City is made from three ores: basalt, dolomite, and limestone. These three materials are melted in a cupola type furnace that uses coke as it’s fuel to produce a melt which is fiberized to produce mineral wool fiber.

1.2. Cupola Melter : The cupola furnace used to produce the mineral wool ma terial is a vertical shaft type melter. It consists of vertical carbon steel cylinder closed at the bottom except for a channel from which to extract melt and provided with a sealing door at the top to charge raw materials. Combustion air for the solid cok e fuel is injected at the bottom while the flue gases are exhausted at the top of the melter. Materials charged to this style of melter are large in size, being several inches in diameter, to create a porous bed within the melter. This porous bed

allows fo r the flow of hot combustion gases up through the furnace for melting and preheating of the charge while at the same time allowing melt to flow down through the melter to supply the process. The cupola melter is water jacketed in the high temperature areas of the melter to protect the carbon steel shell from thermal damage. In lower temperature areas such as the charge end it is refractory lined. The cupola further can be described as a series of zones running from top to bottom of the furnace. These zones are designated as follows: the raw material charge zone, the raw material preheat zone, the melt zone, the

combustion zone and the coke bed or well zone. These zones are described in

detail below.

1.2.1. Raw material charge zone : Raw materials, which are stored i n remote silos, are charged to the top of the furnace along with the coke used as the fuel source. The raw materials are metered simultaneously using vibratory feeders equipped with load cells unto a belt charge conveyor that takes the charge to the top of the cupola furnace. The material is fed into a pre

- charge chamber located at the top of the furnace. A rotary distribution device distributes the charge across the cross

- section of the melter on entry into the

pre

- charge chamber. The coke is charged in a similar manner and precedes the main charge as it is loaded into the cupola melter. In this way, the vertical shaft of the furnace is filled with alternating charges of raw material and coke. Material is transferred from the pre

- charge area of the cupola t o the main melting chamber on demand, based on the raw material level in the cupola. Raw material from the charge zone enters the preheat zone as raw

material is consumed in the melter.

1.2.2. Preheat zone : Here raw materials are preheated to their melting poin ts by hot combustion gases from the combustion zone as they are drawn upMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

through the melter and vented out of the furnace to the flue gas handling system. In addition to preheating raw materials carbonate compounds

contained in the dolomite and limestone are calcined to alkaline oxides thereby releasing significant amounts of CO2 in this zone.

1.2.3. Melting zone : Here the raw materials are converted to liquid both thermally and through chemical action. Temperatures in this zone can reach 3500 deg F. The melt ra te is controlled both by the available thermal energy (rate at which the coke is combusted) and the volumetric through

- put capability of the furnace.

1.2.4. Combustion zone : At this location, coke, which is charged with the raw material, is reacted with preheate d combustion air to generate the heat release required for melting. The preheated combustion air (900

- 1100 deg F) or blast air as it is referred to enters the cupola at the base of this zone through a series of pipes called tuyeres which are evenly spaced around the perimeter of the cupola. Some of the tuyeres are also provided with pure oxygen, high

- pressure lances that are used to enrich the combustion air and used to help penetrate the coke bed to provide combustion at the cupola

center. Coke consumed in the combustion is replenished by successive charges moving down the shaft of the cupola. The rate of combustion is controlled by the supply of oxygen, which in turn depends on the blast air and the lance oxygen rates. As preheated coke enters the combusti on zone it reacts with carbon dioxide (CO2) from the combustion to form carbon monoxide (CO). This reaction is endothermic and removes heat from the melter. In addition water vapor entering with the combustion air is also reduced to hydrogen and CO. As a r esult depending on the efficiency of the combustion a significant amount of CO can exit the cupola with the flue gases. Melt from the melting zone flows down trough the combustion zone

and is further heated.

1.2.5. Coke bed or well zone : This zone consists of un

- burnt coke, which serves as a heat resistant porous bed which both supports, the burden of the raw material charge above while simultaneously allowing the melt to pass through the bed voids and accumulate for supplying the process. Located in

this zone is the melt siphon which is a melt filled channel extending from just above the base of the cupola to just below the tuyeres that supplies the process with melt. Melt filling this zone is pressurized by the blast air and forced up into the siphon. In this wa y the siphon channel acts as a liquid seal for the blast air entering the melter (it is forced to flow up through the cupola). As melt level continues to build in the cupola bottom, hydrostatic forces allow the melt to overflow the outlet of the siphon sup plying melt to the process. Note the coke bed does not combust for the blast air enters above this zone and flows up towards the flue gas outlet. Therefore the coke

bed is contained in non

- oxidizing environment and remains intact. In addition to the above, this zone also acts as a reservoir to hold molten iron formed from the reduction of the iron oxide containing raw materials. This iron accumulates below the mineral wool melt due to their specific gravityMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

differences. The iron is periodically drawn from t he cupola to prevent plugging of the siphon and to permit continued flow of mineral wool melt. The iron is extracted by creating a drain hole through a small refractory filled area in the cupola bottom. This accomplished through use of an oxygen/magnesium lance that burns through the refractory creating the drain hole. After the iron is drained from the unit (the color of the stream indicating when it is emptied) the hole is resealed with a refractory patch. This operation is referred to as ”tapping the cup ola “ and occurs approximately every 4 hours of normal operation.

1.3. Flue gas Treatment System : Flue gas existing the cupola consists of gases generated by the combustion of the coke and the calcining of the carbonate containing raw materials. These gases con tain significant levels of particulate both from entrained fines from the charge and re

- condensed particulate from the melt. Principal gaseous contaminants to this stream are hydrogen sulfide, other sulfide compounds and carbon monoxide produced by the com bustion of the coke. To treat this exhaust stream, the gases are filtered then oxidized in a thermal oxidizer. The gases are drawn from the cupola by an induced draft fan located after the filtration equipment and prior to the oxidizer. Waste heat from

the oxidizer is passed through a heat exchanger (recuperator) were it heats both the blast air used for combustion in the cupola and preheats the filtered flue gas from the cupola prior to combustion in the thermal oxidizer. The treated gases

are existed to a common tall stack with other process treated exhausts from fiber forming operations. The flue gas system is described in more detail below.

1 .3.1 Flue gas Filtration : This system consists of two major units an inertial separator (designated as the prehea ter/cooler separator) and bag type pulsejet dust collector. The inertial collector is designed to remove large particulate form the stream. The gas is routed through two sets of parallel tube banks and as a result of sudden directional changes particulate is removed from the gas stream. This separated particulate is collected in a hopper, which is integral to the separator, and removed from the system via a screw conveyor and rotary airlock. The removed particulate is collected in portable hoppers. This pre

- separator serves a secondary purpose as it is also used to condition the exhaust gases to the proper temperature for handling throughout the remainder of the filtration equipment. This unit is constructed similar to a shell and tube heat exchanger

with ra w gases flowing through the interior of two sets of tube banks. Either hot exhaust gases from the oxidizer or cool ambient air are circulated on the outside of the tubes (shell

- side) to either heat or cool the cupola exhaust to approximately 350 deg F to m ake it suitable for supply to the dust collector. If too hot gases could destroy the filtration media in the dust collector while if too cool the gases could condense causing both operational and maintenance problems in the collector. Located immediately a fter the inertial collector, is the bag type dust collector. This unit is designed to remove fine particulate from the cupola exhaust. The collector consists of a series long small diameter bags suspended

from a tube

- sheet and housed within a metal enclos ure. The contaminated air enters the enclosure and flows from the bag exterior to the interior leaving the separated particulate on the bag exterior in the form of a dust cake. The cleanedMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

air is combined together in a common plenum above the bag tube shee t and exits the unit. The unit is equipped with felted Nomex filtration media (bags), which is covered with a PTFE membrane providing fine particulate separation capability. This collector is equipped with pulse

- jet cleaning which utilizes burst of

compres sed air admitted to the clean side of the media to remove collected particulate. The cleaning mode of the collector is initiated by a high

- pressure drop across the unit, the pressure drop being continuously monitored and controlled by the process control s ystem. A triboelectric type bag leak detector is provided at the collector outlet to indicate high particulate levels indicating a bag failure or similar condition. The removed particulate is collected in a hopper located below the bags and removed from th e system via a screw conveyor and rotary airlock. The dust is collected in a portable hopper.

1 .3.2 Thermal Oxidizer/ Recuperator : The thermal oxidizer consists of a refractory lined gas fired chamber. Filtered exhaust from the cupola is thermally

oxidized in this unit. Prior to entering the oxidizer, the gases are passed through the recuperator located at the oxidizer outlet, which preheats the gases. The preheated gases are then fed to the oxidizer and mixed with combustion air as it

enters the unit. The oxidizer is supplied with a natural gas burner. This burner modulates to control temperature within the unit to insure the cupola exhaust is adequately oxidized. Much of the heat generated in the unit is from the combustion of the carbon monoxide generated at the cupola. This energy is recovered in the recuperator by exchanging heat from the oxidizer exhaust with the ambient air supplied as blast air and the filtered cupola exhaust gases. Cooling air is injected between the oxidizer and the recuperator to c ool the oxidizer exhaust slightly to help limit blast air temperature going to the cupola.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

E.3.1.1 Cupola and Envirotech P&ID
<Insert copy of P&ID Generated by Ron Cseh.>Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### E.3.2 Curing Oven

– General Description

Mineral Wool Curing Oven : The curing oven is a rectan gular unit 80ft long unit that

handles 8ft wide material. A continuous stream of mineral wool fiber coated with uncured phenolic resin is conveyed into the oven inlet. The function of the oven is to cure the phenolic resin and thereby set the fibers to for m a rigid fiber pack. The mineral fiber pack is approximately 8ft wide and up to 24 inches in thickness as it enters the oven depending on the dimensions and density of the finished product. The fiber material is captured between two horizontal conveyors w ith perforated flights to allow flow through the pack. These conveyors serve to both transport the material through the oven and provide a smooth surface to both sides of the product through compression of the fiber pack. The heat source for the oven is a gas fueled hot air system. Hot air is primarily supplied to the bottom of the oven and forced up through the fiber pack and withdrawn from the top of the unit where it is ducted back to the heat source. The hot air supply stream is distributed

over the e ntire length of the oven. The heated air supplied to the oven is generated in an external gas fired heater, which is used to circulate air as described above. The discharge temperature of the air from the heater (oven inlet temperature) is

used to control the firing rate of the external heater. The discharge air from the oven is collected in a common air plenum and routed back to the heater via a

three

- way damper equipped with a proportional type actuator. This damper is used to divert a portion of the retu rn air to the gas

- fired incinerator. The amount of exhaust gas diverted to the incinerator is controlled via the damper position, which in turn, is controlled by the pressure in the return air plenum. This incinerator is a gas

- fired heater used to destroy VOC’s, which are discharged to the atmosphere via this oven effluent stream. The incinerator temperature is controlled via a thermocouple mounted in the unit, which is used to control the gas firing to the unit. A portion of the incinerator discharge is ro uted back to the oven inlet and distributed across the top of the product as a waste heat source. The reminder of the treated gases from the incinerator are combined with gases from a collection hood at the oven discharge and transported through the No.3 f ilter house and discharged to the 2 nd tall stack. The No.3 filter house is a large replaceable media filter through which the gases pass to remove any large suspended particulate prior to being discharged to the stack.Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

E.3.2.1 Curing Oven Diagram
<Insert diagram of curing oven developed by Frank Kristie.>Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### E.3.3 Baghouse Leak Detector

E.3.3.1 Manufacturer Certification
<Insert letter from ThermoAnderson on Capabilities of PCME probe.>

E.3.3.2 USEPA Guidance on Baghouse Leak Detectors

<Insert document from EPA on Leak Detector Guidanc e.>Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### E.4 Incinerator Inspections

E.4.1 Annual Incinerator Inspection SAP Document

E.4.2 Most Recent Report

<Insert copy of most recent Reliable Incinerator Inspection.>Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### E.5 Required Checklists

E.5.1 Cupola Startup/Shutdown Checklists

E.5.2 Oven Startup/Shutdown Checklist

E.5.3 Pressure Transmitter Calibration Checklist

E.5.4 Baghouse Checklists

E.5.4.1 Monthly Inspection Checklist

E.5.4.2 BHA Bi

- Annual Inspecti on Proposal / Checklist

E.5.4.3 Baghouse High Temperature Alarm

E.5.4.4 Leak Detector Alarm ChecklistMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

E.5.4.5 General Baghouse Bypass Checklist



### E.5.5 Cupola Flue Gas Treatment Maintenance Checklists

E.5.6 Curing Oven System Maintenance Checklists

E.5.7 Incinerator Checklists

E.5.7.1 Incinerator Temperature Calibration Procedure

E.5.7.2 Incinerator Exhaust Fan Failure Checklist

E.5.7.3 Incinerator Low Temperature Alarm



### E.5.8 Malfunction Procedures not Listed: FormMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### E.6 Historic Documents

E.6.1 Notificatio ns

MACT Protocol Notification: Initial notification of intent to test to ADEM and the

USEPA.

Test Method Letter ADEM: Initial notification of request for alterna te sampling method (substituting Method 316

– Wet Method for Method 318

– FTIR).

Phenix City MACT2

– notification to ADEM: Notification to ADEM that time has lapsed for a decision based on 45 day requirement in recently finalized General

Provisions.



### E.6.2 Test Protocol

<Unable to insert Adobe Document in this Word File. Final Notebook will contain the protocol.>



### E.6.3 Final Compliance Report

<Insert Copy of final compliance report into Notebook.>Mineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### E.7 Applicable Requirements: SummaryMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003



### E.8 Version Control Section

Version Date Sections Changed

1.0 June 2, 2002 Initial Document

2.0 June 10, 2002 Not Captured ...

3.0 June 13, 2002 Added E.7 Version Control

Modified D.1.5, D.1.5.1, D.1.5.2

Added Section B.3

– Malfunctions not Listed in Plan

Added Sec tion E.5.8

– Checklist for Malfunctions no listed in plan.

4.0 Aug 19, 2002 Modified Sections E.5.5 and E.5.6

– Removed existing maintenance checklists and replaced with streamlined

versions.

Modified Sections D.1.1 and D.1.2

– simplify startup and

shutdo wn verbiage in document to better reflect checklists.

Combined Sections D.1.1 and D.1.2 into D.1.1. Renamed D.1.1. (Done to be consistent with oven startup and shutdown section.)

Modified Section D.2.4.1

– added statement to describe records being kept f or incinerator temp monitoring.

Modified Section D.1.4.2.4

– changed number of bags to be kept in inventory from 10 to 15 to match BHA inspection.

Corrected Section D.1.4.1 and D.1.4.2

– references to

D.1.4.4 and D.1.4.2.2 were corrected to D.1.3.4 and

D.1 .3.2.2.

Inserted New Section to Appendix

– E.7 Applicable Requirements: Summary / Moved existing E.7 to E.8

Added Section D.2.3.2 and D.2.3.2.1

– Exhaust Fan

Malfunction for Incinerator.

Added checklist to Section E.5.7.2

– Exhaust Fan Failure. Chang ed previous E.5.7 section to E.5.7.1.

Added checklist to Section E.5.7.3

– Low Incinerator Temperature.

Modified verbiage in Section A.

Modified section D.3.2 and added Section D3.3

– Better statement of monitoring and response requirements forMineral Wool MACT SSM/OMM Plan Version 5 June 12, 2003

binder form ulation.

Modified section D.1.3.4

– defined leak detector alarm.

Added E.5.4.5

– General Baghouse Bypass checklist.

Changed B.6.4.2.1 to B.6.4.3 for consistency.

Added header to each checklist to match the Plan Version

and date.

5.0 June 12, 2003 Changed all reference to Owens Corning to IIG MinWool LLC. Plant and all assets purchased by IIG MinWool LLC on May 9, 2003.