From: gthomas@bp.Guardian.com

To: Susan Fairchild/RTP/USEPA/US@EPA

Date: 03/05/2012 08:57 AM

Subject: Re: Guardian Inwood Preliminary Test Results

Susan, this is written to confirm there is no CBI in the test information we have provided.

Kind regards,

Grover Thomas

Guardian Fiberglass, Inc.

Susan Fairchild

<Fairchild.Susan@

epamail.epa.gov>

To

gthomas@bp.Guardian.com

03/05/2012 08:36

cc

AM

Subject

Re: Guardian Inwood Preliminary

Test ResultsCan you confirm that no CBI is contained in any of these attachments?

Thanks,

Susan Fairchild

Environmental Scientist

U.S. Environmental Protection Agency

direct line: 919.541.5167

fax: 919.541

- 3207

email: fairchild.susan@epa.gov

Overnight mail address:

US EPA

Mail Code D243

- 04

109 TW Alexander Drive

RTP, NC 27709

From: gthomas@bp.Guardian.com

To: S usan Fairchild/RTP/USEPA/US@EPA

Date: 03/02/2012 07:10 PM

Subject: Guardian Inwood Preliminary Test Results

Susan, as you requested, I am forwarding the preliminary test results of the final deliverables you

requested for the Inwood furnace stack. See the pdf files attached to the email below. The QAQC is

completed and so I do not expect any changes in test results, as there were none with the Kingman test

results in the final report we received today.

As the test contractor commented bel ow, the Inwood test results were very good and that is not totally

surprising as the filter media in this baghouse is unique. As you recall, we requested to install PTFE

filters in the Inwood baghouse and it looks like this media does drive down emissions somewhat when

compared to the other furnaces we have tested.

Though you did not require us to conduct a Method 5/202 PM determination, these test methods were

referenced in the proposed rule and we wanted to determine if a baghouse with PTFE filter media would

meet the 0.014 lb/ton

proposed standard. We did not pay the test company to expedite the 202

results but expect to have the 202 results by next Friday, March 9th. I will forward the results to you as

soon as they arrive.T he PM filterable Method 5 and Method 29 are attached below and both test methods resulted in

exactly the same results of 0.008 lb/ton, which is below the 0.014 lb/ton proposed standard and also

lower than the other four

(4) furnaces that were tested at Gua rdian. Though we are elated at the lower emissions with PTFE filter

media, it remains to be seen if we can still meet the proposed standard after adding in the backhalf 202

condensible PM emissions. We will find out a week from now.

You indicated the MA CT floor for PM may be relaxed due to some issues with the original data set.

Nonetheless, it is our understanding the MACT floor was based on filterable emissions only and did not

include condensible PM emissions. If this is the approach to calculate th e MACT floor, the proposed PM

Method should be Method 5 and/or Method 29, not a combination

of Method 5 and Method 202. If Method 5/202 is going to be the

proposed

PM method in the final rule, than the MACT floor needs to be based on Method 5/202 data.

The Method 0061 chrome results for the Inwood furnace were slightly lower compared to the Method

29 chrome results but the same order of magnitude.

The Method 29 chrome results for Inwood were also slightly lower compared to the Method 29 chrome

results f or the other four furnaces already tested (Albion, Inwood, Kingman & Winnsboro) but the same

order of magnitude, but probably slightly lower due to using the PTFE filter media.

Unlike Kingman, the magnitude of the vaporous back half chrome emissions were about the same order

of magnitude as front half filterable emissions.

You may recall in Kingman, the filterable front half represented over 80%

of the chrome. Obviously, the Inwood PTFE filter media is removing

more

filterable chrome and so you would exp ect the filterable front half and vaporous back half to be more

closely the same.

Not surprisingly, the hexavalent chrome emissions continue to be very low, about half the magnitude of

the total chrome emissions and the same order of magnitude of the furn aces already tested (Albion,

Inwood, Kingman & Winnsboro).

We also tested HF and HCL and these emissions were the among the lowest emissions we have seen

compared to the other furnaces tested in Albion,

Inwood, Kingman and Winnsboro and below the proposed standard. We wish

all of our plants were this low but we believe these emissions are more of function of the purchased

cullet and it would be unfortunate that the HF and HCl standard is not relaxed to continue to encourage

recycling of cullet and in so doing, promote energy savings and reduction of greenhouse gases.

We are elated at the emission results for Inwood and that all of our furnace results are fairly consistent.

In sum, the emissions for the five

(5) Guardian furnaces are very low in about every category and the PTFE media results in slightly lower

emissions but about the same order of magnitude.As mentioned above, we received the final Kingman furnace test report today. Next week, I will email

the electronic pdf version of this report an d also mail you a CD of the report in the abundance of

caution.

Our test company is still working on the report in the ERT format and I will forward the ERT's to you

when they arrive.

As we discussed, after we receive the final Inwood test report, which hopefully should be next week, I

will complete populating Form C of the

114

survey request for each of the plants and forward this information to you.

Let me know if you have any questions.

Kind regards,

Grover Thomas

----- Forwarded by Grover Thomas/ BP/Guardian_Industries on 03/02/2012

03:34

PM

-----

"Tony Blanton"

<tony@integrityai

r.net>

To

< GroverThomas@bp.guardian.co m >

03/02/2012 02:55

cc

PM "Jim Lewis"

< jim@integrityair.net >

Subject

Inwood Results

Please respond to

"Tony Blanton"

<tony@integrityai

r.net>Grover,

Please find attached the summary of results for the Inwood sampling. I should have the condensable

portion of the 202 by Friday the 9th. I provided the f ilterable results so that you could compare Method

29 to

5 /202.

Overall, the results look very good.

Thank you

Tony(See attached file: 26A.pdf)(See attached file: 29.pdf)(See attached

file: 0061.pdf)(See attached file: 5202.pdf) [attachment "26A.pdf" deleted by Susan

Fairchild/RTP/USEPA/US] [attachment "29.pdf" deleted by Susan Fairchild/RTP/USEPA/US] [attachment

"0061.pdf" deleted by Susan Fairchild/RTP/USEPA/US] [attachment "5202.pdf" deleted by Susan

Fairchild/RTP/USEPA/US]