### FORM A**-1**

**PA RENT COMPA**  **NY INFORMA TION** 
**I. Parent Company / Legal Corporate Owner Information**
1. Legal Parent Company/ Legal Corporate Name Johns Manville 2. Address 717 17th Street 3. City Denver 4. State Colorado 5. Zip Code 80202 6. County Denver 7. Size of Company (approximate number of employ ees including all subsidiaries, branches, and related establishments owned): 6,491 (end of 2009)

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### FORM A**-2**

**FA CILITY INFORMA** 

**TION**
**II. Facility Information**

Facility Name Johns Manville McPherson, Kansas Facility Facility Address Street 1465 17th Avenue City McPherson State Kansas Zip Code 67460 County McPherson Facility Coordinates Latitude (decimal degrees, six decimal places) 38.386349 Longitude (decimal degrees, six decimal places) -97.614593 Specific location represented (e.g., front door of main building, centroid of property , etc.) Front Door

Number of employees attached to the wool fiberglass manufacturing facility : See CBI Subm ittal
Design capacity

of the plant (tons/y r) See CBI Subm ittal
Ty pe(s) of process(es) (rotary spin, flame attenuation) at this plant Rotary Spin
Operation schedule hrs/day 24 days/y r 365

Identify what state and local air pollution rules and regulations, including permit requirements, your plant is subject to. (Please provide copies of permit(s) and permit IDs) Title V Permit Effective Date June 15, 2009 per K.A.R 28- 19-511 and K.A.R 28-19- 514, Contraction Permit to increase cullet use March 12, 2009. (See Attachment

A)

**III. Technical Contact**

Name Bill Eccles Technical Contact Title Environm ental Coordinator

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### Telephone (620) 241-4843

Facsimile (Fax) (620) 241-4892 Email 

### Billie.Eccles@jm.com

**IV. Other**
Is the facility

a major source of HAP? No
If No, did the facility take a limit of its potential HAP emissions to avoid classification as a major source: No, true minor

Does the facility

manufacture other products in addition to wool fiberglass? No
If Yes, list the other products manufactured at the facility

. NA
Are there any

HAP em issions associated with any co-located facilities? List unit operations, e.g., boiler, and pollutant/emissions. No

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### FORM B-1

**PLA NT OPERA** 

**TIONS**
**I. Overview of Plant Operations**

Number of process lines. Include lines that are currently operational or that are temporarily shutdown. (Do not include lines permanently

shutdown). 2

For each process line: Process Line 1 Process Line 2 Process Line 3 Process line identification names or numbers Line 122 Line 123 Ty pe of process line (e.g., rotary spin, flame attenuation) Rotary Spin Rotary Spin Maximum annual production rate (tons/y r) See CBI Subm ittal See CBI Subm ittal Age of process equipment (y rs) 36 29 Remaining economic life of process line (y rs) Indefinite (due to rebuild capabilities) Indefinite (due to rebuild capabilities) List of products produced and most recent annual production (tons/y r; specify

year) for each product See CBI Subm ittal See CBI Subm ittal Please attach detailed schematics of each process line. See CBI Subm ittal See CBI Subm ittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### FORM B-2

**PLA NT OPERA** 

**TIONS**
**II. Process - Raw materials Handling and Storage**

Molten glass preparation **Line 122** Raw materials and proportions bywt (%) See CBI Submittal Method(s) of convey ing each raw material to furnace/pots pneumatic, mechanical Binder and Additives List each raw material, including premixed materials, in the binder formulation and its proportion bywt (%) See CBI Submittal
List steps in preparing binder, including storage temperature ( ° F) and holding tim e (hrs) See CBI Submittal
Total yearly

consumption of binder (gal/y r) See CBI Submittal Cost of binder ($/gal) for most recent y ear (specify year) See CBI Submittal Are binder storage and mixing tanks vented to outside/inside? Inside Method of treating vent air from storage and mix tanks Charcoal Filter (resin only otherwise none) Emission control during liquid raw material transfer from vehicles to storage tanks. Pressurized unloading with storage tanks vented to atmosphere. The binder for all plant products was converted to a Describe future source reduction plans and schedules to reformulate binders; List each constituent, proportions wt (%), cost ($/gal) for reformulation non-HAP binder in 2002 that significantly

reduces or elim inates HAP emissions from the manufacturing process.

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### FORM B-2

**PLA NT OPERA** 

**TIONS**

**II. Process - Raw materials Handling and Storage**

Molten glass preparation **Line 123**

Raw m aterials and proportions by wt (%) See CBI Subm ittal

Method(s) of convey ing each raw material to furnace/pots Pneum atic conveyance. Binder and Additives List each raw material, including premixed materials, in the binder formulation and its proportion by wt (%) See CBI Subm ittal List steps in preparing binder, including storage temperature (° F) and holding tim e (hrs) See CBI Subm ittal Total yearly

consumption of binder (gal/y r) See CBI Subm ittal Cost of binder ($/gal) for most recent year (specify year) See CBI Subm ittal Are binder storage and mixing tanks vented to outside/inside? Inside Method of treating vent air from storage and mix tanks Charcoal Filter (resin only otherwise none) Emission control during liquid raw material transfer from vehicles to storage tanks. Pressurized unloading with storage tanks vented to

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls 

### atmosphere.

Describe future source reduction plans and schedules to reformulate binders; List each constituent, proportions wt (%), cost ($/gal) for reformulation The binder for all plant products was converted to a non-HAP binder in 2002 that significantly

reduces or elim inates HAP emissions from the manufacturing process.

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### FORM B-3

**PLA NT OPERA** 

**TIONS**

**III. Process - Glass Melting Furnace**
For each Glass Melting Furnace: Furnace 1 Furnace 2 Furnace 3

Process unit identification name/number Line 122 Module 1 Melter EU-122004 Line 122 Module 2 Melter EU-122005 Line 123 Module 1, 2 & 3 Melter EU-123004, EU-123005, EU123006 Process line(s) served (identification name/number) Line 122 Line 122 Line 123 Latitude (decimal degrees, six decimal places) 38.386920 38.386952 38.386990 Longitude (decimal degrees, six decimal places) 97.616308 97.616308 97.616308 Stack or vent height (units) 59.5 ft 59.5 ft 59.5 ft Stack or vent diameter (units) 3.17 ft 3.17 ft 3.19 ft Manufacturer and model JM Proprietary JM Proprietary JM Proprietary Date of original installation 1998 1998 1981 Estimate of remaining lifetime (y rs) Indefinite (due to continued
ma intenance) Indefinite (due to

continued maintenance) Indefinite (due to continued
ma intenance) Major rebuilds:

W hat constitutes a major rebuild JM is not familiar with the term "major rebuild." JM conducts periodic routine
ma intenace. JM is not familiar with

the term "major rebuild." JM conducts periodic routine maintenace. JM is not familiar with the term "m ajor rebuild." JM conducts periodic routine maintenace.
Frequency

of a major rebuild N/A N/A N/A Cost of ty pical major rebuild N/A N/A N/A Date of last major rebuild N/A N/A N/A Purpose of last major rebuild N/A N/A N/A Increase or decrease in emissions N/A N/A N/A Fuel ty pe: electric, gas, or oil Electric Electric Electric Fuel consumption rate (KW /ton of glass or Btu/ton of glass) See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal List HAPs that are in refractory material See CBI Subm ittal See CBI Subm ittal Chromium compounds Design production rate (tons/day) See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Actual glass pull rate (tons/day) See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Vent gas flow rate (acfm @ ° F) 36296acfm @ 107.6 o 

### F 20,305acfm @ 95.0 o 

### F 29046acfm @ 91.0 o 

### F Temperature (° F) of molten glass in furnace and forehearth (if applicable) See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal Nature and frequency of routine/preventive maintenance procedures See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### Describe process modification(s) since 1999 that reduce

em issions None None None Describe future source reduction plans and schedules See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM B-4**

**PLANT OPERATIONS**
**IV. Process - Forming -- Rotary Spin / Flame Attenuation** 

For each Forming Operation -- Rotary Spin/Flame Attenuation Forming Operation 1 Forming Operation 2 Forming Operation 3

Process unit identification name/number 122 M-1 N. Forming/Collection EU-122006a 122 M-1 S. Forming/Collection EU-122006b 122 M-2 N. Forming/Collection EU-122007a Process line(s) served (identification name/number) Line 122-Module 1 Line 122-Module 1 Line 122-Module 2 Latitude (decimal degrees, six decimal places) 38.587144 38.587113 38.587011 Longitude (decimal degrees, six decimal places) -97.615226 -97.615226 -97.615226 Stack or vent height (units) 71.9 ft 71.9 ft 71.9 ft Stack or vent diameter (units) 3.5' X 7.08' 3.5' X 7.08' 3.5' X 7.08' Number of fiber forming devices (spinners) per line. See CBI Submittal See CBI Submittal See CBI Submittal Method of attenuating fiber (e.g., air, flame, or air and flame). Indicate type of burner used (if flame). Air Air Air Is there a forehearth between the furnace and the forming section? Yes Yes Yes Major rebuilds:

W hat constitutes a major rebuild JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. Frequency of a major rebuild N/A N/A N/A Cost of typical major rebuild N/A N/A N/A Date of last major rebuild N/A N/A N/A Purpose of last major rebuild N/A N/A N/A Increase or decrease in emissions N/A N/A N/A If modular, number of modules and plenums Each plenum and module listed separately Each plenum and module listed separately Each plenum and module listed separately Presence of water overspray and application rate (gpm) See CBI Submittal See CBI Submittal See CBI Submittal Binder applied and application rate (gpm) See CBI Submittal See CBI Submittal See CBI Submittal Other material applied and application rate (gpm) See CBI Submittal See CBI Submittal See CBI Submittal Temperature of glass fiber when binder is applied (°F) See CBI Submittal See CBI Submittal See CBI Submittal Temperature of binder when applied to fibers (°F) See CBI Submittal See CBI Submittal See CBI Submittal Method of evenly distributing fibers onto forming conveyor See CBI Submittal See CBI Submittal See CBI Submittal Formed mat thickness (in.) See CBI Submittal See CBI Submittal See CBI Submittal Forming air flow rate (acfm @ °F) 59,709 acfm @ 91 o F Combined Modules 59,709 acfm @ 91 o F Combined Modules 46,369 acfm @ 106 o F Percent of forming air recirculated and percent exhausted 100% Exhausted 100% Exhausted 100% Exhausted Nature and frequency of routine/preventive maintenance procedures See CBI Submittal See CBI Submittal See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xlsDescribe process modification(s) since 1999 that reduce emissions The binder for all plant products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. The binder for all plant

products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. The binder for all plant

products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. Describe future source reduction plans and schedules See CBI Submittal See CBI Submittal See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM B-4**

**PLANT OPERATIONS**

**IV. Process - Forming -- Rotary Spin / Flame Attenuation** 

For each Forming Operation -- Rotary Spin/Flame Attenuation Forming Operation 4 Forming Operation 5 Forming Operation 6

Process unit identification name/number 122 M-2 S. Forming/Collection EU-122007b 123 M-1 Forming/Collection EU-123007 123 M-2 Forming/Collection EU-123008 Process line(s) served (identification name/number) Line 122-Module 2 Line 123-Module 1 Line 123-Module 2 Latitude (decimal degrees, six decimal places) 38.587980 38.387162 38.387054 Longitude (decimal degrees, six decimal places) -97.615226 -97.615470 -97.615470 Stack or vent height (units) 71.9 ft 73.2 77.8 Stack or vent diameter (units) 3.5' X 7.08' 3.21' X 3.21' 3.21' X 3.21' Number of fiber forming devices (spinners) per line. See CBI Submittal See CBI Submittal See CBI Submittal
Method of attenuating fiber (e.g., air, flame, or air and flame). Indicate type of burner used (if flame). Air Air Air

Is there a forehearth between the furnace and the forming section? Yes Yes Yes Major rebuilds:

W hat constitutes a major rebuild JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. Frequency of a major rebuild N/A N/A N/A Cost of typical major rebuild N/A N/A N/A Date of last major rebuild N/A N/A N/A Purpose of last major rebuild N/A N/A N/A Increase or decrease in emissions N/A N/A N/A If modular, number of modules and plenums Each plenum and module listed separately Each plenum and module listed separately Each plenum and module listed separately Presence of water overspray and application rate (gpm) See CBI Submittal See CBI Submittal See CBI Submittal Binder applied and application rate (gpm) See CBI Submittal See CBI Submittal See CBI Submittal Other material applied and application rate (gpm) See CBI Submittal See CBI Submittal See CBI Submittal Temperature of glass fiber when binder is applied (°F) See CBI Submittal See CBI Submittal See CBI Submittal Temperature of binder when applied to fibers (°F) See CBI Submittal See CBI Submittal See CBI Submittal Method of evenly distributing fibers onto forming conveyor See CBI Submittal See CBI Submittal See CBI Submittal Formed mat thickness (in.) See CBI Submittal See CBI Submittal See CBI Submittal Forming air flow rate (acfm @ °F) 59,709 acfm @ 97 o F 42,335 acfm @ 123 o F Combined Modules 42,335 acfm @ 123 o F Combined Modules Percent of forming air recirculated and percent exhausted 100% Exhausted 100% Exhausted 100% Exhausted

EPA-HQ-OAR-2010-1042-DRAFT-0005.xlsNature and frequency of routine/preventive maintenance procedures See CBI Submittal See CBI Submittal See CBI Submittal

Describe process modification(s) since 1999 that reduce emissions The binder for all plant products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. The binder for all plant

products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. The binder for all plant

products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. Describe future source reduction plans and schedules See CBI Submittal See CBI Submittal See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM B-4**

**PLANT OPERATIONS**

**IV. Process - Forming -- Rotary Spin / Flame Attenuation** 

For each Forming Operation -- Rotary Spin/Flame Attenuation Forming Operation 7 Forming Operation 8 Forming Operation 9
Process unit identification name/number 123 M-3 Forming/Collection EU-123009 Process line(s) served (identification name/number) Line 123-Module 3 Latitude (decimal degrees, six decimal places) 38.386946 Longitude (decimal degrees, six decimal places) -97.615470 Stack or vent height (units) 73.2 Stack or vent diameter (units) 3.21' X 3.21' Number of fiber forming devices (spinners) per line. See CBI Submittal Method of attenuating fiber (e.g., air, flame, or air and flame). Indicate type of burner used (if flame). Air Is there a forehearth between the furnace and the forming section? Yes Major rebuilds:

W hat constitutes a major rebuild JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. Frequency of a major rebuild N/A Cost of typical major rebuild N/A Date of last major rebuild N/A Purpose of last major rebuild N/A Increase or decrease in emissions N/A If modular, number of modules and plenums Each plenum and module listed separately Presence of water overspray and application rate (gpm) See CBI Submittal Binder applied and application rate (gpm) See CBI Submittal Other material applied and application rate (gpm) See CBI Submittal Temperature of glass fiber when binder is applied (°F) See CBI Submittal Temperature of binder when applied to fibers (°F) See CBI Submittal Method of evenly distributing fibers onto forming conveyor See CBI Submittal Formed mat thickness (in.) See CBI Submittal Forming air flow rate (acfm @ °F) 42,335 acfm @ 123 o F Combined Modules Percent of forming air recirculated and percent exhausted 100% Exhausted Nature and frequency of routine/preventive maintenance procedures See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xlsDescribe process modification(s) since 1999 that reduce emissions The binder for all plant products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. Describe future source reduction plans and schedules See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM B-5**

**PLANT OPERATIONS**
**V. Process - Curing**

For each Curing Oven: Curing Oven 1 Curing Oven 2 Curing Oven 3
Process unit identification name/number Line 122 Curing Oven EU-122008 Line 123 Curing Oven EU-123010 Process line(s) served (identification name/number) Line 122 Line 123 Latitude (decimal degrees, six decimal places) 38.386611 38.386575 Longitude (decimal degrees, six decimal places) -97.615411 -97.615347

Stack or vent height (units) 64.0 64 Stack or vent diameter (units) 3.5' 3.42' X 3.21' Method of curing Hot air recirculation Hot air recirculation

Manufacturer and model Mid-W est Conveyor Originally built by Mid-W est Conveyor Model No. 73-4007 changed ducts and replace a chain , modified by Kansas

Industrial Date of original installation 1974 1981 Major rebuilds:

W hat constitutes a major rebuild JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. JM is not familiar with the term "major rebuild." JM conducts periodic routine maintenace. Frequency of a major rebuild N/A N/A Cost of typical major rebuild N/A N/A Date of last major rebuild N/A N/A Purpose of last major rebuild N/A N/A Increase or decrease in emissions N/A N/A Fuel type: electric, gas, or oil Natural Gas Natural Gas Fuel consumption rate (KW /hr or BTU/hr) See CBI Submittal See CBI Submittal Moisture content wt (%) of formed mat:

inlet See CBI Submittal See CBI Submittal outlet 0% 0% Air flow rate (acfm @ ° F) from curing Outlet after HEAF 34,852 acfm @ 127 o F Outlet after HEAF 41,120 acfm @ 136 o F Exhaust air temperature (° F) 127 o F 136 oF Residence time of product (mins) See CBI Submittal See CBI Submittal Binder content of cured product (LOI) 3.0 to 7.9% 3.0 to 7.4% Nature and frequency of routine/preventive maintenance procedures See CBI Submittal See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xlsDescribe process modification(s) since 1999 that reduce emissions The binder for all plant products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. The binder for all plant products

was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. Describe future source reduction plans and schedules See CBI Submittal See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM B-6**

**PLANT OPERATIONS**

**VI. Process - Cooling**

For each Cooling Operation: Cooling Operation 1 Cooling Operation 2 Cooling Operation 3
Process unit identification name/number HERM Cooling Line 122 EU-122009 HERM Cooling Line 123 N. EU-123011 HERM Cooling Line 123 S. EU-123011 Process line(s) served (identification name/number) Line 122 Line 123 Line 123 Latitude (decimal degrees, six decimal places) 38.386534 38.386495 38.386453 Longitude (decimal degrees, six decimal places) -97.615294 -97.615456 -97.615456 Stack or vent height (units) 46 46 46 Stack or vent diameter (units) 2.6 2.5 2.5 Cooling air flow rate (acfm @ ° F) 13,291acfd @ 111 o F 16,121 acfm @ 129 o F 16,121 acfm @ 129 o F Percentage of cooling air recirculated (if any) None None None Cooling air temperature (°F) Ambient Ambient Ambient Nature and frequency of routine/preventive maintenance procedures See CBI Submittal See CBI Submittal See CBI Submittal

Describe process modification(s) since 1999 that reduce emissions The binder for all plant products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. The binder for all plant products

was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. The binder for all plant products was converted to a non-HAP binder in 2002 that significantly reduces or eliminates HAP emissions from the manufacturing process. Describe future source reduction plans and schedules See CBI Submittal See CBI Submittal See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### FORM B-7

**PLA NT OPERA** 

**TIONS**

**VII. Process - Use of Solvents**

Use of Solvents

Volatile solvents used at your facility (where and how used) By agreement this question was lim ited to HAP containing solvents. W e interpret this question to apply to wool fiberglass lines, from melting through cooling. None List each solvent used and quantity(gal/y r) N/A Emission control device(s) used to control emissions from solvent usage/storage? N/A

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### FORM B-8

**PROCESS OPERA TIONS** 

VIII. Pollution Prevention

Please describe any

work practices, pollution prevention techniques, and control strategies evaluated and/or implemented at each process unit at yo ur facility

(e.g., binder reformulation, alternative fuels usage, etc.) to reduce emissions of PM and HAPs you identified in Form E. You must specify the year in which the facility im plem ented the practice/technique and identify

the emission reductions (if measured) from these practices/techniques. JM objects to this question in that it is unbounded in time. Weinterpret this question, like similar questions in the ICR, to seek data since 1999. W ith that interpretation, JM responds that the binder was reformulated to a formaldehyde free resin in 2002.

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM C-1**

**AIR POLLUTION CONTROL**
**I. Electrostatic Precipitator (ESP)**

For each ESP: ESP 1 ESP 2 ESP 3
Process line(s) (identification name/number) There is no ESP at this facility Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Manufacturer and model Date of original installation Number of collection plates and configuration Gas flow rate to ESP (acfm @ ° F) Inlet gas temperature (° F) Outlet gas temperature (° F) Inlet grain loading (gr/dscf) Outlet grain loading (gr/dscf) Average stack opacity (%) Pressure drop across ESP (in. H 2 O gauge) Plate area (ft 2 ) Vendor guarantee on ESP efficency (attach copy) Method of plate cleaning and frequency Flow rate of plate washwater to ESP (gpm), if applicable Temperature of plate washwater to ESP (° F), if applicable Source of plate washwater used for cleaning, if applicable Concentration (mg/l) of dissolved and suspended solids in plate washwater, if applicable
Conditioning agents used and amounts (in gpm or lbs/hr), if applicable Amount of wastewater generated (gpd), if applicable Amount of wastewater recycled (gpd), if applicable Amount of wastewater disposed of (gpd), if applicable Method of wastewater disposal, if applicalbe Quantity of solid waste collected (lbs/yr) Quantitiy of solid waste recycled (lbs/yr) Quantity of solid waste disposed of (lbs/yr) Method of solid waste disposal Nature and frequency of routine/preventive maintenance procedures Problems experienced with control device within the last five years; how were problems solved?

EPA-HQ-OAR-2010-1042-DRAFT-0005.xlsContinuous monitoring method(s) used to monitor ESP performance,

including parameters monitored Describe any plans to replace or upgrade ESP

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM C-2**

**AIR POLLUTION CONTROL**

**II. Scrubber**

For each Scrubber: Scrubber 1 Scrubber 2 Scrubber 3
Process line(s) (identification name/number) There is no scrubber at this facility Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Manufacturer and model Date of original installation Type (e.g., venturi, orifice) Gas flow rate to scrubber (acfm @ ° F) Inlet gas temperature (° F) Outlet gas temperature (° F) Inlet grain loading (gr/dscf) Outlet grain loading (gr/dscf) Average stack opacity (%) W ater flow rate to scrubber (gpm) Percent of scrubber water from recycled wastewater Source of scrubbing water and type of pretreatment. Substance(s) added as part of pretreatment and amount used (gpm or lbs/hr) HAP composition of wastewater (mg/L) Concentration (mg/L) of dissolved and suspended solids in scrubbing water Scrubbing water temperature (° F) Liquid/gas ratio (gal/10 3acfm) Pressure drop across scrubber (in. H 2 O gauge) Amount of wastewater generated (gpd) Amount of wastewater recycled (gpd) Amount of wastewater disposed of (gpd) Method of wastewater disposal Quantity of solid waste collected (lbs/yr) Quantity of solid waste recycled (lbs/yr) Quantity of solid waste disposed of (lbs/yr) Method of solid waste disposal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xlsVendor guarantee on scrubber efficiency (attach copy)

Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five years; how were problems solved? Continuous monitoring method(s) used to monitor scrubber performance, including parameters monitored Plans to replace or upgrade scrubber

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM C-3**

**AIR POLLUTION CONTROL**

**III. Mechanical Collector**

For each Mechanical Collector: Mechanical Collector 1 Mechanical Collector 2 Mechanical Collector 3

Process line(s) (identification name/number) There are no mechanical collectors within this facility. Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Manufacturer and model Date of original installation Type of mechanical collector Gas flow rate to collector (acfm @ ° F) Inlet gas temperature (° F) Outlet gas temperature (° F) Inlet grain loading (gr/dscf) Outlet grain loading (gr/dscf) Average stack opacity (%) Overall pressure drop (in. H 2 O gauge) Vendor guarantee on mechanical collector efficiency (attach copy) Quantity of solid waste collected (lbs/yr) Quantity of solid waste recycled (lbs/yr) Quantity of solid waste disposed of (lbs/yr) Method of solid waste disposal Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five years; how were problems solved? Continuous monitoring method(s) used to monitor performance, including parameters monitored Plans to replace or upgrade mechanical collector

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### FORM C-4

**AI R POLLUTION CONTROL** 

**IV. Fabric Filter**

For each Fabric Filter: Fabric Filter 1 Fabric Filter 2 Fabric Filter 3

Process line(s) (identification name/number) Line 122 Line 122 Line 123 Equipm ent/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Melters Dust Collector M-1 EU-122004 Melters Dust Collector M-2 EU-122005 Melters Dust Collector EU123004,5,6 Latitude (decimal degrees, six decimal places) 38.386992 38.386992 38.386990 Longitude (decimal degrees, six decimal places) -97.616452 -97.616452 -97.616367 Stack or vent height (units) 59.5 ft 59.5 ft 59.5 ft Stack or vent diameter (units) 3.17 ft 3.17 ft 3.19 ft
Manufacturer and model Wh eelabrator Model No. 120- 3015 RAP Wh eelabrator Model No. 120- 3015 RAP Aero Pulse Model No. 2C 4321- 10T Date of original installation 1998 1999 1981 Number of compartments 3 3 4 Number of bags per compartment 450 450 864
Filter material and coatings applied 16 oz Polyester needle felt singed 16 oz Polyester needle felt singed 16 oz Polyester needle felt singed Fabric weight (oz/yd 2 

### ) 16 oz/yd 2 

### 16 oz/yd 2 

### 16 oz/yd 2 

### Filter surface area (ft2 

### ) 1801 ft2 

### 1801 ft2 

### 1801 ft2 

### Gas flow rate to filter (acfm @ ° F) 22,065 acfm @ 116 o 

### F 20,305 acfm @ 101 o 

### F 29,046 acfm @ 91 o 

### F Inlet gas temperature (° F) Am bient Am bient Am bient Outlet gas temperature (° F) Am bient Am bient Am bient Inlet grain loading (gr/dscf) Data not available Data not available Data not available

Outlet grain loading (gr/dscf) 0.0017gr/dscf 0.0018gr/dscf 1.90 E-4 - filterable, 6.26 E-4 Condensible, 8.18 E-4 Total

gr/dscf Average stack opacity (%) 0% 0% 0% Overall pressure drop (in. H 2 

### O gauge) 5-6" Normal 5-6" Normal 4-6"

Method and frequency of bag cleaning Pulse air when pressure drop exceeds 6 inches of

water. Pulse air when pressure

drop exceeds 6 inches of

water. Pulse air when pressure drop

exceeds 6 inches of water. Vendor guarantee on fabric filter efficiency (attach copy) None None None Quantity

of solid waste collected (lbs/y r) 233,584 233,584 700,751 Quantity

of solid waste recycled (lbs/y r) 233,584 233,584 700,751

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### Quantity of solid waste disposed of (lbs/y r) 100% of the dust is fed back into the process. 100% of the dust is fed back into the process. 100% of the dust is fed back into the process. Method of solid waste disposal Not Applicable Not Applicable Not Applicable

Nature and frequency of preventive maintenance procedures Monthly inspections of the bag cleaning system, filter bags, condition of the bag house and door leaks. Inspection sheets are filled out and filed. Monthly inspections of the bag cleaning system, filter bags, condition of the bag house and door leaks. Inspection sheets are filled out and filed. Monthly inspections of the bag cleaning system, filter bags, condition of the bag house and door leaks. Inspection sheets are filled out and filed.
Problems experienced with control device within the last five years; how were problems solved? No specific problems; general wear item s are replaced as required. No specific problems; general wear item s are replaced as required. No specific problems; general wear item s are replaced as

required.
Continuous monitoring method(s) used to monitor performance, including parameters monitored Magnehelic gauge monitors pressure drop across the

filter Magnehelic gauge monitors

pressure drop across the

filter Magnehelic gauge monitors

pressure drop across the filter
Plans to replace or upgrade fabric filter See CBI Subm ittal See CBI Subm ittal See CBI Subm ittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM C-5**

**AIR POLLUTION CONTROL**

**V. Thermal Incinerator**

For each Thermal Incinerator: Thermal Incinerator 1 Thermal Incinerator 2 Thermal Incinerator 3
Process line(s) (identification name/number) There is no Thermal Incinerator at this facility Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Manufacturer and model Date of original installation Fuel type: gas or oil Fuel consumption rate (BTU/hr) Inlet gas flow rate (acfm @ ° F) Inlet gas temperature (° F) Combustion chamber gas temperature (° F) Outlet gas temperature (° F) Inlet grain loading (gr/dscf) Outlet grain loading (gr/dscf) Average stack opacity (%) Excess air (%) Residence time (sec) at temperature (° F) Percent heat recovery Vendor guarantee on incinerator efficiency (attach copy) Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five years; how were problems solved? Continuous monitoring method(s) used to monitor incinerator performance, including parameters monitored Plans to replace or upgrade thermal incinerator

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM C-6**

**AIR POLLUTION CONTROL**

**VI. High Velocity**

**Air Filter (HVAF)**

For each HVAF: HEAF 1 HEAF 2 HVAF 3 Process line(s) (identification name/number) Line 122 HEAF (High Energy Air Filtration) Line 123 HEAF (High Energy Air Filtration) Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Line 122 Curing Oven, EU122008 Line 123 Curing Oven EU123010 Latitude (decimal degrees, six decimal places) 38.386611 38.386575 Longitude (decimal degrees, six decimal places) -97.615411 -97.615347 Stack or vent height (units) 64 ft 64 ft Stack or vent diameter (units) 3.5 ft 3.42' X 3.21' Manufacturer and model JM Design and fabrication JM Design and fabrication Date of original installation Jun-74 Mar-81 Inlet gas flow rate (acfm @ ° F) Outlet after HEAF 34,852 acfm @ 127 o F Outlet after HEAF 41,120 acfm @ 136 o F Inlet gas temperature (° F) Unknown Unknown Outlet gas temperature (° F) 127 o F 136 o F Inlet grain loading (gr/dscf) Unknown Unknown
Outlet grain loading (gr/dscf) Front Half 0.0079, Back half 0.0117, Average total = 0.0197 Front Half 0.018, Back half

0.0091, Average total = 0.02 Average stack opacity (%) 5-10% 5-10% W ater spray pressure (sdig), if applicable 40 - 60 psig 40 - 60p sig W ater spray rate (gpm), if applicable 1.5 - 5.0 gpm 1.5 - 5.0 gpm Filter face velocity (acfm/ft 2 ) Not Available Not Available Maximum pressure drop across mat (in. H 2 O gauge) 18-24 inches 20-24 inches Vendor guarantee on HVAF efficiency (attach copy) None None
Method and frequency of filter mat advancement Automatic advancement every 2.5 minutes drum advances for 8 seconds Automatic advancement every 2.5 minutes drum advances for

8 seconds Amount of wastewater generated (gpd) 4,600 4,600 Amount of wastewater recycled (gpd) 100%, actual quantity is not available 100%, actual quantity is not available Amount of wastewater disposed of (gpd) 0% 0% Method of wastewater disposal Not applicable Not applicable Quantity of solid waste collected (lbs/yr) 146,700 lb/yr 146,700 lb/yr Quantity of solid waste recycled (lbs/yr) None None Quantity of solid waste disposed of (lbs/yr) 146,700 lb/yr 146,700 lb/yr Method of solid waste disposal Municipal Landfill Municipal Landfill

EPA-HQ-OAR-2010-1042-DRAFT-0005.xlsNature and frequency of preventive maintenance

procedures Preventative Maintenance done when down for oven cleanouts, every 11-13 weeks, to change chain and clean out solids. Preventative Maintenance done when down for oven cleanouts, every 11-13 weeks, to change chain and clean out solids.
Problems experienced with control device within the last five years; how were problems solved? No specific problems, normal wear and maintenance items. No specific problems, normal wear and maintenance items. Continuous monitoring method(s) used to monitor HVAF performance, including parameters monitored No continuous monitoring; weekly inspection No continuous monitoring; weekly inspection Plans to replace or upgrade HVAF See CBI Submittal See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM C-7**

**AIR POLLUTION CONTROL**

**VII. Mist Eliminator**

For each Mist Eliminator: Mist Eliminator 1 Mist Eliminator 2 Mist Eliminator 3
Process line(s) (identification name/number) There is no mist eliminator at this facility Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Manufacturer and model Date of original installation Type of mist eliminator Gas flow rate to mist eliminator (acfm @ ° F) Inlet gas temperature (° F) Outlet gas temperature (° F) Inlet grain loading (gr/dscf) Outlet grain loading (gr/dscf) Average stack opacity (%) Velocity in mist eliminator (ft/sec) Pressure drop (in. H 2 O gauge) For chevron blade mist eliminators: Spacing between blades (in.) W ashing frequency of blades For mesh pad mist eliminators: Number of pads or elements Thickness of pad (in.) or element dimensions Density of pad, (lb/ft 3 ) W ashing frequency of pad Vendor guarantee on mist eliminator efficiency (attach copy) Amount of wastewater generated (gpd) Amount of wastewater recycled (gpd) Amount of wastewater disposed of (gpd) Method of wastewater disposal Quantity of solid waste collected (lbs/yr) Quantity of solid waste recycled (lbs/yr) Quantity of solid waste disposed of (lbs/yr)

EPA-HQ-OAR-2010-1042-DRAFT-0005.xlsMethod of solid waste disposal

Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five years; how were problems solved? Continuous monitoring method(s) used to monitor mist eliminator performance, including parameters monitored Plans to replace or upgrade mist eliminator

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM C-8**

**AIR POLLUTION CONTROL**

**VIII. Ventilation Sy**

**stem**

For each Ventilation System: Ventilation System 1 Ventilation System 2 Ventilation System 3 Process line(s) (identification name/number) None Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) For general or building ventilation: Ventilation system used Airflow control system used Number of air changes per hour For unit or local ventilation: Enclosure or hood design used Volume of enclosure or hood Capture velocity (ft/sec) Distance between hood and emission source (ft)

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM C-9**

**AIR POLLUTION CONTROL**

**IX. Other**

For each Other Air Pollution Control Device (APCD): Other APCD 1 Other APCD 2 Other APCD 3 Process line(s) (identification name/number) None Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan) Latitude (decimal degrees, six decimal places) Longitude (decimal degrees, six decimal places) Stack or vent height (units) Stack or vent diameter (units) Description

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### FORM D

**PROCESS LINE STA RTUP A**  **ND SHUTDOWN**
1. For each startup and shutdown (SS) that occurred during the last five ye ars, please provide the following information requested in A. through J.

A. Using the definitions provided above, indicate whether the event was a startup or shutdown; **No excess emission events during periods of**  **startup and shutdown.** B. A description of the event, including identification of the emissions source or sources associated with the startup or shutdown; **N/A**
C. W hether any

permit condition was exceeded and, if so, what permit condition was exceeded; **N/A**
D. W hether the event was covered by any contingency

plan for controlling emissions during startup and shutdown events and, if so, whether the plan was followed; if the plan was not followed, why not; **N/A**

E. The duration of the event; **N/A** F. The actions taken to minimize emissions during the event, including the use of any

backup control systems; **N/A** G. Estimates or measurements, if any , of emissions during the event; if you did not have the ability to quantify

emissions during the event, please explain why ; **N/A**

H. W hether the emission profile of each unit was different during startup and shutdown than during normal operating conditions and, if so, how em issions were different and why ; please provide any supporting information; **N/A**

I. All performance test data collected during each period of SS; the test method used for each event; when the testing was conducted and why; the test conditions at the tim e of testing; and whether the tests were associated with a routine startup or shutdown; and **No data available**

J. All monitoring data, including control system parameter monitoring, collected during each period of SS. **Al l required Title V**  **monitoring data would be collected.**  Startup: the setting in operation of an affected source or portion of an affected source for any purpose. Shutdown: the cessation of operation of an affected source or portion of an affected source for any purpose.

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### If this information is contained in periodic and immediate SS reports (either

stand-alone or contained within the periodic excess emissions report) submitted to your permitting authority , you may submit copies of those reports instead.
2. Are there any

ty pes of startup or shutdown events that you have been able to elim inate? If so, please describe the ty pe of event and explain how these events were eliminated. **N/A**
3. Please submit a copy of your SS plan if you are required to develop
one. **No plan required** 4. Please provide all performance test data collected during periods of SS over the last 5 years. Indicate the test method used for each event. **No data available**

5. Please provide all m onitoring data, including control system parameter
mo nitoring, collected during periods of SS over the last 5 years. **N/A**
6. Optional: Do you wish to recommend a standard that would apply during startup or shutdown? If so, please describe the event to which the standard would apply ; the recommended standard (this could be an
em ission limitation, work practice, or operational standard) that would apply during the period; the basis for the recommended standard; why and how the standard would m inim ize em issions during the event; and how would com pliance be determined and/or monitored. **No**

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM E**

**PRESENCE OF AIR POLLUTANTS IN EMISSION POINTS a** 

Please provide any existing emissions information and data covering hazardous air pollutants (HAP) and particulate matter (PM) for each listed process. Identify the appropriate box for wh ich you are providing specific process information and/or pollutant emissions data.

**Melting Furnace Forming**  **Curing Cooling**  Particulate Matter (PM, PM 2.5, PM Condensable) Chromium Compounds and Hexavalent Chromium (including any Cr speciation data) Other metal HAP (As, Be, Cd, Co, Hg, Mn, Ni, Pb, Sb, Se) Hydrogen Fluoride (HF) Hydrogen Chloride (HCl) ##############################################################################################

Formaldehyde
Phenol
Methanol Other organic HAP

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls**FORM F-1**

**COST**
**I. Process Unit (e.g., cupola, curing oven, etc.):**

For each Process Unit: Process Unit 1 Process Unit 2 Process Unit 3 Process Unit ID All Units Process Line ID
**II. Capital Costs**

Base year JM objects to this request in its entirety because it seeks information that is not relevant to the EPA Administrator’s review obligations pursuant to Clean Air Act Section 112(d)(6) and 112(f)(2). Total capital cost, including costs for individual pieces, if available. See Above **III. Annual Operating Costs** Base year (most recent fiscal year) See Above Total annual operating costs See Above Maintenance materials and replacement parts (specify costs by item) See Above Raw materials costs See Above Labor ($/yr) for each labor class See Above (hr/hr) for each labor class See Above Utilities (breakdown for each utility) See Above W aste treatment and/or disposal See Above Costs associated with any work practices and pollution prevention techniques that are employed at your facility See Above Savings associated with heat recovery and wastewater and/or solid waste returned to process from APCD (or sold to another user) See Above
Indirect costs See Above Other (specify) See Above
Please provide the annual report to shareholders or equivalent for the most recent fiscal year. If reports are not available, provide annual sales and profits (or profit margin) for the most recent fiscal year. If company is publicly owned, please provide a web link to this information. See Above

Identify the market range (regional, national, international) of your products. National

EPA-HQ-OAR-2010-1042-DRAFT-0005.xlsCan your product(s) be substituted by another product(s)? If so, please list your

product(s) and substituted product(s). Wo ol fiberglass is used as insulation, as are cellulose (scrap newspaper) treated to resist fires, spray foam, foam boards, cotton treated to resist fires, and sheep wool treated to resist fires. Wo ol fiberglass insulation is preferred over these alternative insulation materials because it is easily, economically, and safety installed in various building settings, has superior fire performance capabilities, and a 70-year history of proven performance and durability.

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### FORM F-2

**COST**

**I. A ir Pollution Control Device (A** **PCD)** See form F-1

For each APCD: APCD 1 APCD ID Process Unit ID

**II. Capital Costs**

Base year JM objects to this request in its entirety

because it seeks information that is not relevant to the EPA Adm inistrator’s review obligations pursuant to Clean Air Act Section 112(d)(6) and 112(f)(2). APCD equipm ent purchase cost and what was included See Above List the cost for each piece of auxiliary equipm ent for each APCD not included above See Above
Installation cost See Above Land purchase cost See Above Total capital cost See Above Method of financing APCD See Above Retrofit installation See Above Field erected or modular See Above

**III. A nnual Operating Costs**  Base year (most recent fiscal year) See Above Maintenance materials and replacement parts (specify costs by item ) See Above Raw m aterials costs See Above Labor ($/yr) for each labor class See Above (hr/hr) for each labor class See Above Utilities (breakdown for each utility) See Above W aste treatment and/or disposal See Above Indirect costs See Above

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls

### Other (specify) See Above

Total annual operating cost (most recent fiscal year) See Above

Attach annual report to shareholders or equivalent for the most recent fiscal year. Alternatively , if company is publicly

owned, you can provide yo ur company's web link to this information. See Above

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls