# 800 Oven and 801 Forming and Collection Formaldehyde Compliance Emissions Test Summary Report

Prepared for: 

## Johns Manville

Defiance Plant 925 Carpenter Road Defiance, Ohio

Project No. 08-3738.00 October 23, 2008

BT Environmental Consulting, Inc. 2615 Wolcott Street Ferndale, Michigan 48220 (248) 548-8070Executive Summary BT Environmental Consulting, Inc. (BTEC) was retained by Johns Manville to evaluate exhaust gas flowrates and formaldehyde emission rates from two exhaust stacks serving Unit 800 offline sear roll and curing oven, including its mandrel vacuum, and Unit 801 forming and collection scrubber at the Johns Manville facility in Defiance, Ohio. The compliance test program was conducted on October 7 th , 2008. Testing of the sources consisted of triplicate 60-minute test runs at each sampling location. Sampling was performed utilizing United States Environmental Protection Agency (USEPA) reference test methods. The results of the emissions test program are summarized by Table 1.
Table 1 Overall Emission Rates Source Pollutant Average Test Result (lb/hr) Average Test Result (lb/ton glass) Unit 800 Formaldehyde 0.16 0.58 Unit 801 Scrubber Formaldehyde 0.23 1.11

Johns Manville BTEC Project No. 07-3645.00 Compliance Formaldehyde Test Report 10/23/2008 iTABLE OF CONTENTS

1.0 INTRODUCTION............................................................................................................... 1 2.0 PROCESS DESCRIPTION ............................................................................................... 1 3.0 SAMPLING AND ANALYTICAL METHODOLOGIES.............................................. 1 3.1 E XHAUST GAS V ELOCITY , M OLECULAR W EIGHT , AND M OISTURE C ONTENT ................................................2 3.2 F ORMALDEHYDE (USEPA M ETHOD 316).......................................................................................................2 4.0 TEST RES ULTS ................................................................................................................ . 3

TABLES Table 1 – Overall Emissions Summary Table 2 – Unit 800 Formaldehyde Emission Rates Table 3 – Unit 801 Scrubber Formaldehyde Emission Rates
FIGURES Figure 1 – Unit 800 Exhaust Stack Traverse Point Diagram Figure 2 – Unit 801 Scrubber Exhaust Stack Traverse Point Diagram Figure 3 – USEPA Method 316 Sampling Train Diagram
APPENDICES Appendix A – Field and Computer Generated Raw Data and Field Notes Appendix B – Calibration Data Appendix C – Example Calculations Appendix D – Laboratory Analytical Results Appendix E – Production Data

Johns Manville BTEC Project No. 07-3645.00 Compliance Formaldehyde Test Report 10/23/2008 ii1.0 Introduction BT Environmental Consulting, Inc. (BTEC) was retained by Johns Manville to evaluate exhaust gas flowrates and formaldehyde emission rates from two exhaust stacks serving Unit 800 offline sear roll and curing oven, including its mandrel vacuum, and Unit 801 forming and collection scrubber at the Johns Manville facility in Defiance, Ohio. The compliance test program was conducted on October 7 th , 2008. The following BTEC professionals participated in conducting the testing program: Barry Boulianne, and James Sharp, Senior Project Managers; Thomas Snyder, Project Manager; and Brandon Chase and Jeff Peitzch, Staff Environmental Engineers. The purpose of the project was to evaluate the exhaust gas flow rates and formaldehyde emission rates from two exhaust stacks. The emissions data will be used to determine compliance with the applicable title V permit requirements for Johns Manville facility No. 03-20-01-0005. Mr. Nick Brueckner, and Mr. Jim Smargiassi with Johns Manville, provided the on-site coordination for this project. Mr. Jay Leibrict with the Ohio EPA was on site to witness the test program. 2.0 Process Description Lines 801 through 807 employ a melter that receives glass batch trucked from JM Defiance Plant 02 to a new batch system that serves the pipe manufacturing lines at Defiance 08. The batch is melted using electric current flowing between electrodes within each melter. The heat produced cause the batch to melt to form molten glass. Molten glass from the melters is transported to manufacturing line via an electric forehearth. Molten glass from the forehearth enters one of seven individual manufacturing lines. The first part of each line is the fiber forming and collection unit. This unit consists of a perforated spinner disk through which the molten glass passes to form fine glass fibers. The unit then utilizes flame-attenuation to produce the proper fiber characteristics. Through the use of a suction fan, the fiber laden air stream is directed towards a collection system. Prior to collection, the fibers are sprayed with thermosetting binder that causes the fibers to adhere to one another. The binder consists primarily of a phenolic resin and serves to facilitate collection of extruded fiberglass onto the collection chain via induced draft to form a blanket of uncured wool fiberglass. Emissions from the collection section vent to atmosphere through one stack and is controlled by a venturi scrubber. From the forming and collection unit, the fiber gla ss blanket is transferred to its in-line curing oven or is manually rolled and transferred to the off-line curing unit where it is rolled into a pipe section, seared and cured and finally sent to a finishing process. 3.0 Sampling and Analytical Methodologies Sampling and analytical methodologies for the emissions test program can be separated into two categories as follows: (1) Measurement of exhaust gas velocity, molecular weight, and moisture content;

Johns Manville BTEC Project No. 08-3738.00 Compliance Formaldehyde Test Report 10/23/2008 1(2) Measurement of Formaldehyde Emissions utilizing Method 316 Descriptions of sampling and analytical methodologies by category are summarized by Sections 3.1 through 3.2, respectively. 3.1 Exhaust Gas Velocity, Mo lecular Weight, and Moisture Content Measurement of exhaust gas velocity, molecular weight, and moisture content were conducted using the following reference test methods codified at 40 CFR 60, Appendix A: Method 1 - “Location of the Sampling Site and Sampling Points” Method 2 - “Determination of Stack Gas Velocity and Volumetric Flowrate” Method 3 - “Determination of Molecular Weight of Dry Stack Gas”(Fyrite) Method 4 - “Determination of Moisture Content in Stack Gases” Stack gas velocity traverses were conducted in accordance with the procedures outlined in Methods 1 and 2 (see Figures 1-2 for exhaust stack traverse point diagrams). An S-type pitot tube with a thermocouple assembly, calibrated in accordance with Method 2, Section 4.1.1, was used to measure exhaust gas velocity pressures (using a manometer) and temperatures during testing. The S-type pitot tube dimensions were within specified limits, therefore, a baseline pitot tube coefficient of 0.84 (dimensionless) was assigned. A cyclonic flow check was performed at the sampling location. The existence of cyclonic flow is determined by measuring the flow angle at each sample point. The flow angle is the angle between the direction of flow and the axis of the stack. If the average of the absolute values of the flow angles is greater than 20 degrees, cyclonic flow exists. The null angle was determined to be less than 20 degrees at each sampling point. Molecular weight was determined according to USEPA Method 3, “Gas Analysis for the Determination of Dry Molecular Weight.” The equipment used for this evaluation consisted of a one-way squeeze bulb with connecting tubing and a set of Fyrite ®combustion gas analyzers. Carbon dioxide and oxygen content were analyzed using the Fyrite ®procedure. Exhaust gas moisture content was evaluated using Method 4. Exhaust gas was extracted as part of the Formaldehyde (see figure 3 for a schematic of the sampling train) and passed through (i) two impingers, each with 100 ml ultra-filtered deionized water, (ii) an empty impinger, and (iii) an impinger filled with silica gel. Exhaust gas moisture content is then determined gravimetrically. 3.2 Formaldehyde (USEPA Method 316) 40 CFR 60, Appendix A, Method 316, “Sampling and Analysis for Formaldehyde Emissions from Stationary Sources in the Mineral Wool and Wool Fiberglass Industries” was used to measure formaldehyde concentrations and calculate formaldehyde emission rates (see Figure 3 for a schematic of the sampling train). Triplicate 60 minutes test runs were conducted on all sample locations.

Johns Manville BTEC Project No. 08-3738.00 Compliance Formaldehyde Test Report 10/23/2008 2BTEC’s Nutech ®Model 2010 modular isokinetic stack sampling system consisted of (1) astainless-steel nozzle, (2) a steel probe w/borosilicate glass liner, (3) a set of four GreenburgSmith (GS) impingers with the first and third modified and second standard GS impingers with the first two each containing 100 ml ultra-filtered deionized water, and a fourth modified GS impinger containing approximately 300 g of silica gel desiccant, (5) a length of sample line, and (6) a Nutech®control case equipped with a pump, dry gas meter, and calibrated orifice. A pitot tube and sampling train leak test was conducted before and after each test run. After completion of the final leak test for each test run the nozzle, probe, and filter bypass were triple rinsed with ultra-filtered deionized water which was collected in a pre-cleaned sample container. The impinger solution was measured gravimetrically and collected in the same sample container as the probe/bypass rinse. The impingers were then triple-rinsed with ultra-filtered deionized water and collected. BTEC labeled each container with the test number, test location, and test date, and marked the level of liquid on the outside of the container. In addition a blank sample of the ultra-filtered DI water was collected. All samples were immediately placed in a cooler with ice. The Formaldehyde samples were shipped overnight via fed-ex to Enthalpy Analytical in Durham, North Carolina. Field and computer generated Formaldehyde data is presented in Appendix A.

4.0 Test Results The results of the emissions test program are summarized by Table 1.
Table 1 Overall Emission Rates Source Pollutant Average Test Result (lb/hr) Average Test Result (lb/ton glass) Unit 800 Formaldehyde 0.16 0.58 Unit 801 Scrubber Formaldehyde 0.23 1.11

Field and computer generated data for each test run are available in Appendix A, as well as all other applicable field data. Equipment calibration information is presented in Appendix B. Example calculations for equations used to determine emission rates are presented in Appendix C. Laboratory analysis is available in Appendix D. Production data is available in Appendix E.

Johns Manville BTEC Project No. 08-3738.00 Compliance Formaldehyde Test Report 10/23/2008 3Limitations The information and opinions rendered in this report are exclusively for use by Johns Manville. BTEC will not distribute or publish this report without Johns Manville’s consent except as required by law or court order. BTEC accepts responsibility for the competent performance of its duties in executing the assignment and preparing reports in accordance with the normal standards of the profession, but disclaims any responsibility for consequential damages.
This report was prepared by: Brandon V. Chase Staff Environmental Engineer
This report was reviewed by: Barry P. Boulianne Senior Project Manager

Johns Manville BTEC Project No. 08-3738.00 Compliance Formaldehyde Test Report 10/23/2008 4