FORM A-1

PARENT COMPANY INFORMATION

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 employees including all 

subsidiaries, branches, and related establishments owned): 6,491 (end of 2009)

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

FACILITY INFORMATION

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 Submittal

 Design capacity of the plant (tons/yr) See CBI Submittal

 Type(s) of process(es) (rotary spin, flame attenuation) at this plant Rotary Spin

 Operation schedule

 hrs/day 24

 days/yr 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 Environmental 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 emissions 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

PLANT OPERATIONS

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

 Type of process line (e.g., rotary spin, flame attenuation) Rotary Spin Rotary Spin

 Maximum annual production rate (tons/yr) See CBI Submittal See CBI Submittal

 Age of process equipment (yrs) 36 29

 Remaining economic life of process line (yrs) Indefinite (due to rebuild 

capabilities)

Indefinite (due to rebuild 

capabilities)

 List of products produced and most recent annual production 

(tons/yr; specify year) for each product See CBI Submittal See CBI Submittal

Please attach detailed schematics of each process line. See CBI Submittal See CBI Submittal

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

PLANT OPERATIONS

II. Process - Raw materials Handling and Storage

 Molten glass preparation Line 122 

 Raw materials and proportions by wt (%) See CBI Submittal

 Method(s) of conveying 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 by wt (%) See CBI Submittal

 List steps in preparing binder, including storage temperature (°F) and 

holding time (hrs) See CBI Submittal

 Total yearly consumption of binder (gal/yr) See CBI Submittal

 Cost of binder ($/gal) for most recent year (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 

eliminates HAP emissions 

from the manufacturing 

process.

 

 

 

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

PLANT OPERATIONS

II. Process - Raw materials Handling and Storage

 Molten glass preparation Line 123 

 Raw materials and proportions by wt (%) See CBI Submittal

 Method(s) of conveying each raw material to furnace/pots Pneumatic conveyance.

 Binder and Additives

 List each raw material, including premixed materials, in the binder 

formulation and its proportion by wt (%) See CBI Submittal

 List steps in preparing binder, including storage temperature (°F) and 

holding time (hrs) See CBI Submittal

 Total yearly consumption of binder (gal/yr) See CBI Submittal

 Cost of binder ($/gal) for most recent year (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 

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 

eliminates HAP emissions 

from the manufacturing 

process.

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

PLANT OPERATIONS

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 (yrs) Indefinite (due to continued 

maintenance)

Indefinite (due to 

continued maintenance)

Indefinite (due to continued 

maintenance)

 Major rebuilds:

 What 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

 Fuel type: electric, gas, or oil Electric Electric Electric

 Fuel consumption rate (KW/ton of glass or Btu/ton of glass) See CBI Submittal See CBI Submittal See CBI Submittal

 List HAPs that are in refractory material See CBI Submittal See CBI Submittal Chromium compounds

 Design production rate (tons/day) See CBI Submittal See CBI Submittal See CBI Submittal

 Actual glass pull rate (tons/day) See CBI Submittal See CBI Submittal See CBI Submittal

 Vent gas flow rate (acfm @ °F) 36296acfm @ 107.6o

F 20,305acfm @ 95.0 oF 29046acfm @ 91.0oF 

 Temperature (°F) of molten glass in furnace and forehearth 

(if applicable) See CBI Submittal See CBI Submittal See CBI Submittal

 Nature and frequency of routine/preventive maintenance 

procedures See CBI Submittal See CBI Submittal See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls
 Describe process modification(s) since 1999 that reduce 

emissions None None None

 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 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:

 What 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 @ 91o

F 

Combined Modules

59,709 acfm @ 91oF 

Combined Modules 46,369 acfm @ 106o

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.xls
 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 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:

 What 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 @ 97o

F 42,335 acfm @ 123o

F 

Combined Modules

42,335 acfm @ 123oF 

Combined Modules

 Percent of forming air recirculated and percent exhausted 100% Exhausted 100% Exhausted 100% Exhausted

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

 What 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 @ 123o

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.xls
 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.

 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-West Conveyor

Originally built by Mid-West 

Conveyor Model No. 73-4007 

changed ducts and replace a 

chain , modified by Kansas 

Industrial

 Date of original installation 1974 1981

 Major rebuilds:

 What 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 @ 127oF

Outlet after HEAF 41,120 acfm 

@ 136oF

 Exhaust air temperature (°F) 127o F 136o

 F

 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.xls
 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.

 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 @ 111o

F 16,121 acfm @ 129oF 16,121 acfm @ 129oF

 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

PLANT OPERATIONS

VII. Process - Use of Solvents

 Use of Solvents

 Volatile solvents used at your facility (where and how used)

By agreement this question 

was limited to HAP 

containing solvents. We 

interpret this question to 

apply to wool fiberglass 

lines, from melting through 

cooling. None

 List each solvent used and quantity (gal/yr) 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 OPERATIONS

VIII. Pollution Prevention

Please describe any work practices, pollution prevention techniques, and 

control strategies evaluated and/or implemented at each process unit at 

your 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 implemented 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. 

We interpret this question, 

like similar questions in the 

ICR, to seek data since 

1999. With 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. H2O gauge)

 Plate area (ft2)

 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.xls
 Continuous 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 (%)

 Water 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/103 acfm)

 Pressure drop across scrubber (in. H2O 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.xls
 Vendor 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. H2O 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

AIR 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

 Equipment/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 Wheelabrator Model No. 120-

3015 RAP

Wheelabrator 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 ft21801 ft21801 ft2

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

F 20,305 acfm @ 101oF 29,046 acfm @ 91oF

 Inlet gas temperature (°F) Ambient Ambient Ambient

 Outlet gas temperature (°F) Ambient Ambient Ambient

 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. H2O 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/yr) 233,584 233,584 700,751

 Quantity of solid waste recycled (lbs/yr) 233,584 233,584 700,751

EPA-HQ-OAR-2010-1042-DRAFT-0005.xls
 Quantity of solid waste disposed of (lbs/yr) 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 items are 

replaced as required.

No specific problems; 

general wear items are 

replaced as required.

No specific problems; general 

wear items 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 Submittal See CBI Submittal See CBI Submittal

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, EU122008Line 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 @ 127oF

Outlet after HEAF 41,120 acfm 

@ 136oF

 Inlet gas temperature (°F) Unknown Unknown

 Outlet gas temperature (°F) 127 o

F 136 oF

 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%

 Water spray pressure (sdig), if applicable 40 - 60 psig 40 - 60p sig

 Water spray rate (gpm), if applicable 1.5 - 5.0 gpm 1.5 - 5.0 gpm

 Filter face velocity (acfm/ft2) Not Available Not Available

 Maximum pressure drop across mat (in. H2O 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.xls
 Nature 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. H2O gauge)

 For chevron blade mist eliminators:

 Spacing between blades (in.)

 Washing frequency of blades

 For mesh pad mist eliminators:

 Number of pads or elements

 Thickness of pad (in.) or element dimensions

 Density of pad, (lb/ft3)

 Washing 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.xls
 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 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 System 

 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 STARTUP AND SHUTDOWN

1. For each startup and shutdown (SS) that occurred during the last five 

years, 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. Whether any permit condition was exceeded and, if so, what permit 

condition was exceeded; N/A

 D. Whether 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. Whether the emission profile of each unit was different during 

startup and shutdown than during normal operating conditions and, if so, 

how emissions 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 time 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.

All 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 types of startup or shutdown events that you have been 

able to eliminate? If so, please describe the type 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 monitoring data, including control system parameter 

monitoring, 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 

emission limitation, work practice, or operational standard) that would 

apply during the period; the basis for the recommended standard; why and 

how the standard would minimize emissions during the event; and how 

would compliance be determined and/or monitored. 

No

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

PRESENCE OF AIR POLLUTANTS IN EMISSION POINTSa

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 

which 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 

 Waste 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.xls
Can your product(s) be substituted by another product(s)? If so, please list your 

product(s) and substituted product(s).

Wool 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. 

Wool 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. Air Pollution Control Device (APCD) 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 

Administrator’s review 

obligations pursuant to 

Clean Air Act Section 

112(d)(6) and 112(f)(2).

 APCD equipment purchase cost and what was included See Above

 List the cost for each piece of auxiliary equipment 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. Annual Operating Costs

 Base year (most recent fiscal year) 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

 Waste 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 

your company's web link to this information.

See Above

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