Enclosure 1

INFORMATION REQUEST FOR FACILITIES THAT MANUFACTURE

WOOL FIBERGLASS 

I. Introduction 

This information request is to be completed for facilities that are engaged in wool fiberglass 

manufacturing. This includes any facility engaged in producing wool fiberglass from sand, 

feldspar, sodium sulfate, anhydrous borax, boric acid or any other materials. 

We are requesting information regarding PM and chromium compounds that are used in or 

emitted by any glass-melting furnaces at facilities that engage in wool fiberglass manufacturing.

Complete this information request as fully as possible. 

Section II contains general instructions for completing your responses and form-specific 

guidance. Section III contains useful definitions and Section IV contains a list of key acronyms 

and units. Respondents should read this material before attempting to complete the questionnaire

provided in Attachment 1. 

A completed copy of the questionnaire in Attachment 1 must be sent to EPA for each wool 

fiberglass manufacturing facility. Completed Forms A and B of the questionnaire must be sent to 

the address below and postmarked no later than 60 days after the postmark date on this Section 

114 information request. Form C of the questionnaire includes information from the emission 

testing that is required in Enclosure 2 and does not need to be submitted at the same time as 

Forms A and B. Form C can be submitted along with the requirements of Enclosure 2 no later 

than 120 days after the postmark date on this Section 114 information request. Please e-mail the 

completed non-confidential survey response (Forms A and B) and the emission test results 

(Form C) as electronic file attachments to:

Susan Fairchild (Fairchild.Susan@epa.gov)

U.S. EPA Office of Air Quality Planning and Standards

Sector Policies and Program Division

Mail Code D243-02

Research Triangle Park, NC 27711

Since some of the data requested will likely be considered confidential business information 

(CBI), any information considered CBI should be denoted by highlighting the data. Clearly mark 

the disk and/or the materials with the words “Confidential Business Information” and send either 

via U.S. Postal Service Express Mail, registered mail, or private courier to:

US Environmental Protection Agency 

Office of Air Quality Planning and Standards 

US EPA Mailroom (C-404-02) 

Attn: Mr. Roberto Morales, DCO (Project 0-10)

Research Triangle Park, NC 27711
Wool Fiberglass Section 114 

Enclosure 1 – Page 2

If you have questions regarding this request, please contact Ms. Susan Fairchild at 919-541-5167

or email to Fairchild.Susan@epa.gov.

II. Instructions for Completing the Survey Forms in Attachment 1

A sample response for most questions has been provided in blue as guidance on the 

questionnaire. 

Form A – Company and Facility Information 

• Complete Form A for each wool fiberglass manufacturing facility owned by your company. 

• On Form A, respondents are asked to identify whether they operate a major source of 

HAP(s). Section 112(a)(1) of the CAA defines a major source as any stationary source or 

group of stationary sources located within a contiguous area and under common control that 

emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or 

more of any hazardous air pollutant or 25 tons per year or more of any combination of 

hazardous air pollutants. For facilities that are not major sources of HAP emissions, the 

respondents are asked to identify if they have taken a limit for their potential HAP emissions 

to avoid being classified as a major source. 

Form B – Furnace Information

• You must complete Form B for each furnace at your wool fiberglass manufacturing 

facility(ies). For furnaces that are not yet operational, provide information on the projected 

data. Furnaces that are temporarily not operating must also be included in Form B. 

• Form B requests the chromium oxide and chromite percentages of the refractory products 

used (or planned to be used) at each section of every furnace at all facilities. Owners and 

operators must provide this information for all glass-melting furnaces at each facility. A 

purchase order or other similar documentation of chromium oxide and chromite 

percentages in each area (e.g., crown, back wall, floor, etc.) of each furnace must be 

submitted along with your questionnaire response. This document must also indicate 

the manufacturer of the various furnace refractory products. 

Form C – Emission Stack Testing Information

• Form C of the questionnaire does not need to be completed until after the emission testing 

required is performed and does not need to be submitted at the same time as Form A and B. 

Form C can be submitted along with the requirements of Enclosure 2 no later than 120 days 

after the date on this Section 114 information request.

• NOTE: For the purposes of this survey, all PM and chromium compounds 

concentrations and emissions are to be quantified. Do not report concentrations or 

emissions as “trace” or “minimal.” If a concentration is at or below the applicable 

method’s detection level, then provide information about the method (title and source), the 
Wool Fiberglass Section 114 

Enclosure 1 – Page 3

calculated detection level in units of the applicable raw material or emissions concentration 

or mass rate, and the procedure for determining the detection level. 

III. Key Term Definitions 

The following definitions are provided for the purpose of the survey only. They are not intended 

to replace statutory definitions or regulatory definitions developed elsewhere. 

Control equipment: Any equipment that reduces the quantity of a pollutant that is emitted 

to the air. The device may destroy or secure the pollutant for 

subsequent recovery. Examples include, but are not limited to, thermal 

and catalytic oxidizers, electrostatic precipitators, absorbers/scrubbers, 

and fabric filters. 

Hazardous Air 

Pollutants (HAP): 

See 42 U.S.C. §7412(a)(6). 

Particulate Matter 

(PM):

A complex mixture of extremely small particles and liquid droplets. 

PM is made up of a number of components, including acids (such as 

nitrates and sulfates), organic chemicals, metals, and soil or dust 

particles. PM includes PM2.5 which are particles that are 2.5 

micrometers in diameter and smaller.

Refractory Products Bricks and shapes as well as castables and cementitious materials used 

to construct glass-melting furnaces and appendages.

IV. Key Acronyms and Units of Measure

% percent 

acfm actual cubic feet per minute 

acfm/ft

2 actual cubic feet per minute per square foot 

batches/yr batches per year 

Btu/scf British thermal units per standard cubic foot 

CAA Clean Air Act 

day/yr days per year 

DC District of Columbia 

dscfm dry standard cubic feet per minute 

EPA U.S. Environmental Protection Agency 

ft feet 

ft/s feet per second 

ft

3

/1,000 acfm cubic feet per thousand actual cubic feet per minute 

gpm U.S. gallons per minute 

gr/dscf grains per dry standard cubic foot 

HAP Hazardous Air Pollutants 
Wool Fiberglass Section 114 

Enclosure 1 – Page 4

hr/day hours per day 

in inches 

in H

2

O inches of water 

kPa kilopascals 

LAER lowest achievable emission rate 

lb/day pounds (mass) per day 

lb/gal pounds (mass) per U.S. gallon 

MACT maximum achievable control technology 

mg/l milligrams per liter 

MMlb/yr million pounds (mass) per year 

NAICS North American Industry Classification System 

NESHAP National Emission Standards for Hazardous Air Pollutants 

OAQPS Office of Air Quality Planning and Standards 

oC degrees Celsius 

oF degrees Fahrenheit 

ohm-cm ohm-centimeter 

ppmv parts per million, by volume 

ppmw parts per million, by weight 

s second or seconds 

scfm standard cubic feet per minute 

SPPD Sector Policies and Programs Division 

SS startup and shutdown

ton/yr tons per year, or short tons per year 

vol% volume percent, or percent by volume 

wt% weight percent, or percent by weight 
Enclosure 2

Summary of Test Procedures, Methods, 

and Reporting Requirements for

Wool Fiberglass Manufacturing Emission Points 

This document provides an overview of approved methods, target pollutant units of measure, and 

reporting requirements for wool fiberglass manufacturing facilities required to provide emission 

test data based on the section 114 letter. The purpose for this testing is to gather data on

particulate matter and chromium compound emissions from emission sources at wool fiberglass 

manufacturing facilities. The document is organized as follows: 

1.0 Stack Testing Procedures and Methods 

2.0 How to Report Data 

3.0 How to Submit Data 

4.0 Contact Information for Questions on Test Plan and Reporting 

1.0 Stack Testing Procedures and Methods 

If you operate a wool fiberglass manufacturing facility, you are required to conduct sampling on 

each glass-melting furnace to determine your emissions, if any, of the following pollutants: 

Chromium (7440-47-3)

Filterable – EPA Method 29

Vaporous – EPA Method 29

Total – EPA Method 29 and SW-846 Method 0061

Hexavalent Chromium (1854-02-99)

SW-846 Method 0061

Particulate Matter 

EPA Method 29

1.1 How to Select Sample Location and Gas Composition Analysis Methods 

U.S. EPA Method 1 of Appendix A of Part 60 must be used to select the locations and number of 

traverse points for sampling. See http://www.epa.gov/ttn/emc/methods/method1.html for a copy 

of the method and guidance information. 

Analysis of flue gas composition, including oxygen concentration, must be performed using U.S. 

EPA Methods 3A or 3B of Appendix A of Part 60. See 

http://www.epa.gov/ttn/emc/methods/method3a.html for Method 3A or 

http://www.epa.gov/ttn/emc/methods/method3b.html for Method 3B information.

1.2 Wool Fiberglass Manufacturing Test Methods and Reporting 

Testing should be conducted on the outlet from the control systems used to control emissions 

from each glass-melting furnace. If the furnace you are testing does not have a control system, 

test the outlet exhaust stream from your furnace. Outlet testing for all pollutants should be 
Wool Fiberglass Section 114 

Enclosure 2 – Page 2

conducted using the methods presented in Table 1.2. If you would like to use a method that is 

not specified on this list, please contact EPA for approval of an alternative method.

For copies of the recommended U.S. EPA methods and additional information, please refer to 

EPA’s Emission Measurement Center website: http://www.epa.gov/ttn/emc/. For copies of the 

recommended U.S. EPA SW-846 methods, please refer to EPA’s SW-846 Online website: 

http://www.epa.gov/waste/hazard/testmethods/sw846/index.htm. 

Table 1.2: Summary of Wool Fiberglass Manufacturing Control System Outlet Emissions 

Measurement Methods and Alternative Methods 

Pollutant Required Method

Alternative 

Method

Minimum No. of 

Test Runs and 

Duration

Target Reported 

Units of Measure*

Filterable PM

EPA Method 29 None

Three 4 hour runs 

with a minimum 

sample volume of 3.4 

cubic meters

lbs/hr and lbs/ton of 

product

mg / m3 at 7% O2

Filterable 

Chromium

Vaporous 

Chromium

Total Chromium

Total Chromium 

EPA Method 0061 with 

SW 846 Method 7199 None

Three 4 hour runs 

with a minimum 

sample volume of 3.4 

cubic meters

provided the method 

required minimum 

pH can be met at this 

volume

lbs /hr and lbs/ton of 

product

mg / m3 at 7% O2

Hexavalent 

Chromium (Cr+6)

* lbs/hr = pounds per hour; lbs/ton = pounds per ton

2.0 How to Report Data 

The method for reporting the results of any testing and monitoring requests depend on the type of 

tests and methods used to complete the test requirements. This section discusses the requirements 

for reporting the data. 

2.1 Reporting Stack Test Data

If you conducted a stack test using one of the methods listed in Table 2.1, shown below, you 

must report your data using the EPA Electronic Reporting Tool (ERT) Version 3. ERT is a 

Microsoft® Access database application. Two versions of the ERT application are available. If 

you are not a registered owner of Microsoft® Access, you can install the runtime version of the 

ERT Application. Both versions of the ERT are available at 

http://www.epa.gov/ttn/chief/ert/index.html. The ERT supports an Excel spreadsheet application 

(which is included in the files downloaded with the ERT) to document the collection of the field 

sampling data. After completing the ERT, you will also need to attach an electronic copy of the 

emission test report (PDF format preferred) to the Attachments module of the ERT.
Wool Fiberglass Section 114 

Enclosure 2 – Page 3

Table 2.1: List of Test Methods Supported by ERT

Test Methods Supported by ERT

Methods 1 through 4

Method 3A

Method 5

Methods 5B and 5F

Method 6C

Method 7E

Method 12

Method 10

Method 12 

Methods 13A and 13B 

Method 17

OTM28

Method 23

Method 25A

Method 26A

Method 29

Method 101

Method 101A

Method 201A

Method 202

Method 0061

CT Method 39

CT Method 40

OTM27

If you conducted a stack test using a method not currently supported by the ERT, you must 

report the results of this test in a Microsoft® Excel Emission Test Template. You must report the 

results of each test on the appropriately labeled worksheet corresponding to the specific tests 

requested at your facility. If more than one source at your facility was tested using methods not 

currently supported by the ERT, you must make a copy of the worksheet and update the source 

ID in order to distinguish between each separate test. After completing the worksheet, you must 

also submit an electronic copy of the emission test report (PDF format preferred).

In addition to the ERT, facilities must also complete Form C located in Attachment 1 of 

Enclosure 1. Form C should be submitted along with the ERT and the complete emission test 

report. Detailed information on the submittal requirements is included in Section 3.0 of this 

enclosure.

2.2 Reporting measured values below the detection level

Identify the status of measured values relative to detection levels on the spreadsheet or in the 

ERT using the following descriptions:

• BDL (below detection level) – all analytical values used to calculate and report an instack emissions value are less than the laboratory’s reported detection level(s); 

• DLL (detection level limited) – at least one but not all values used to calculate and report 

an in-stack emissions value are less than the laboratory’s reported detection level(s); or

• ADL (above detection level) – all analytical values used to calculate and report an instack emissions value are greater than the laboratory’s reported detection level(s).

For each reported emissions value, insert the appropriate flag (BDL, DLL, or ADL) in the Notes 

line of Excel emission test spreadsheet template or in the Comments line of the Electronic 

Reporting Tool (ERT).
Wool Fiberglass Section 114 

Enclosure 2 – Page 4

When reporting and calculating individual test run data:

• For analytical data reported from the lab as “nondetect” or “below detection level;”

− Include a brief description of the procedures used to determine the analytical 

detection and in-stack detection levels:

o In the Notes line of Excel emission test spreadsheet template; or

o In the Comments line of Lab Data tab in the Run Data Details in the ERT.

− Describe these procedures completely in a separate attachment including the 

measurements made, the standards used, and the statistical procedures applied.

− Calculate in-stack emissions rate for any analytical measurement below detection 

level using the relevant detection level as the “real” value.

− Report the calculated emissions concentration or rate result:

o As a bracketed “less than” detection level value (e.g., [<0.0105]) in the 

Excel emission test spreadsheet template and include the appropriate flag 

in the Notes line; or

o As a “real” value in the ERT with the appropriate flag in the Comments 

line.

− Report as “real” values (i.e., no brackets or < symbol) any analytical data 

measured above the detection level including any data between the analytical 

detection level and a laboratory-specific reporting or quantification level (i.e., flag 

as ADL).

• For pollutant measurements composed of multiple components or fractions (e.g., Hg and 

other metals sampling trains) when the result for the value for any component is 

measured below the analytical detection level: 

− Calculate in-stack emissions rate or concentrations as outlined above for each 

component or fraction;

− Sum the measured and detection level values as outlined above using the in-stack 

emissions rate or concentrations for all of the components or fractions; and

− Report the sum of all components or fractions:

o As a bracketed “less than” detection level value (e.g., [<0.0105]) in the 

Excel emission test spreadsheet template and include the appropriate flag 

in the Notes line; or

o As a “real” value in the ERT with the appropriate flag in the Comments 

line.

− Report also the individual component or fraction values for each run if the Excel 

emission test spreadsheet template or ERT format allows; if not (i.e., the format 

allows reporting only a single sum value):

o For the Excel emission test spreadsheet template, next to the sum reported 

as above report in the Notes line the appropriate flag along with the values 

for the measured or detection level value for each component or fraction 

as used in the calculations (e.g., 0.036, [<0.069], 1.239, [<0.945] for a four 

fraction sample).

o For the ERT, next to the sum reported as above, report on the Comments 

line the appropriate flag and the measured or detection level value for each 
Wool Fiberglass Section 114 

Enclosure 2 – Page 5

component or fraction as used in the calculations (e.g., 0.036, [<0.069], 

1.239, [<0.945] for a four fraction sample).

• For measurements conducted using instrumental test methods (e.g., Method 3A):

− Record gaseous concentration values as measured including negative values and 

flag as ADL; do not report as BDL.

− Calculate and report in-stack emissions rates using these measured values.

− Include relevant information relative to calibration gas values or other technical 

qualifiers for measured values in Comments line in the ERT.

• When reporting and calculating average emissions rate or concentration for a test when 

some results are reported as BDL:

− Sum all of the test run values including those indicated as BDL or DLL as “real” 

values.

− Calculate the average emissions rate or concentration (e.g., divide the sum by 3 

for a three-run test).

− Report the average emissions rate or concentration average:

o As a bracketed “less than” detection level value (e.g., [<20.06]) in the 

Excel emission test spreadsheet template and include the appropriate flag 

in the Notes line.

o As a “real” value in the ERT and include the appropriate flag in the 

Comments line.

2.3 Required Fields for ERT Reporting

Enclosure 8 provides an EPA ERT Version 3 example Quality Assurance Test Plan (QA Test 

Plan), lists each field within the ERT, and notes whether or not the field is required or optional.

3.0 How to Submit Data

For each facility, EPA is requesting a CD or DVD with an electronic copy of the ERT database, 

an electronic copy of the complete emission test report(s) for each furnace tested, and the 

completed Form C (in Attachment 1 of Enclosure 1) that includes each furnace at a facility. 

Because some of the information requested will likely contain some data that may be considered 

confidential (i.e., process rates), The CD(s) or DVD (s) should be mailed to the EPA address 

below. Clearly mark the disk and/or materials with the words “Confidential Business 

Information.” 

For the security of your data, EPA recommends sending your confidential files to Mr. Morales at 

the address below via Registered U.S. Mail using return receipt requested, Federal Express, or 

other method for which someone must provide a signature upon receipt. Do not electronically 

transmit confidential business information (CBI) to EPA. E-mail and facsimile are not secure 

forms of communication and should never be used to transmit CBI.
Wool Fiberglass Section 114 

Enclosure 2 – Page 6

US Environmental Protection Agency 

Office of Air Quality Planning and Standards 

US EPA Mailroom (C-404-02) 

Attn: Mr. Roberto Morales, DCO (Project 0-10) 

Research Triangle Park, NC 27711 

4.0 Contact Information for Questions on Test Plan and Reporting 

For questions on how to report data using the ERT, contact:

Ron Myers (U.S. EPA)

(919) 541-5407

Myers.Ron@epa.gov

Barrett Parker (U.S. EPA)

(919) 541-5635

Parker.Barrett@epa.gov

For questions on the test methods contact: 

Steffan Johnson (U.S. EPA) 

919-541-4790

Johnson.Steffan@epa.gov

Peter Westlin (U.S. EPA) 

919-541-1058 

Westlin.Peter@epa.gov

For questions on the information request and reporting mechanisms other than the ERT, 

contact:

Susan Fairchild (U.S. EPA)

(919) 541-5167

Fairchild.Susan@epa.gov
EPA's Information Gathering Authority 

Under Section 114 of the Clean Air Act 

 Under Section 114 of the Act (42 U.S.C. 7414), Congress has given the U.S. Environmental 

Protection Agency broad authority to secure information needed "for the purpose of (i) developing or 

assisting in the development of any implementation plan under Section 110 or 111(d), any standard of 

performance under Section 111, or any emission standard under Section 112, (ii) determining whether any 

person is in violation of any such standard of any requirement of such a plan, or (iii) carrying out any 

provision of this Act." Amount other things, Section 114 authorizes EPA to make inspections, conduct 

tests, examine records, and require owners or operators of emission sources to submit information 

reasonably required for the purpose of developing such standards. In addition, the EPA Office of General 

Counsel has interpreted Section 114 to include authority to photograph or require submission of 

photographs of pertinent equipment, emissions, or both. 

 Under Section 114, EPA is empowered to obtain information described by that section even if 

you consider it to be confidential. You may, however, request that EPA treat such information as 

confidential. Information obtained under Section 114 and covered by such a request will ordinarily be 

released to the public only if EPA determines that the information is not entitled to confidential 

treatment.1

 Procedures to be used for making confidentiality determinations, substantive 

criteria to be used in such determinations, and special rules governing information obtained under 

Section 114 are set forth in 40 CFR Part 2 published in the Federal Register on September 1, 1976 

(40 FR 36902). 

 Pursuant to § 2.204(a) of EPA's Freedom of Information Act (FOIA) regulation, in the event a 

request is received, or it is determined that a request is likely to be received, or EPA desires to determine 

whether business information in its possession is entitled to confidential treatment even though no request 

for release of the information has been received, please be advised that EPA will seek, at that time, the 

following information to support your claim as required by § 2.204(e)(4) of EPA's FOIA regulations: 

 1. Measures taken by your company to guard against undesired disclosure of the 

information to others; 

 2. The extent to which the information has been disclosed to others, and the precautions 

taken in connection therewith; 

3. Pertinent confidentiality determinations, if any, by EPA or other Federal agencies, and a copy 

of any such determinations, or reference to it, if available; and 

4. Whether your company asserts that disclosure of the information would be likely to result in 

substantial harmful effects on the business' competitive position, and if so, what those 

harmful effects would be, why they should be viewed as substantial, and an explanation of 

the causal relationship between disclosure and such harmful effects.1

 

1

Section 114 requires public availability of all emission data and authorizes disclosure of confidential information in 

certain circumstances. See 40 FR 36902 - 36912 (September 1, 1976). 

1 of 1 

Enclosure 3
7042

Enclosure 4

Federal Register I Vol 56. No. 35 I Thursday, February 21, 1991 I Notices

[AD-FRL-3906-3]

Disclosure of Emission Data Claimed as

Confidential Under Sections 110 and 114(c)

of the Clean Air Act

AGENCY: Environmental Protection

Agency (EPA)

ACTION: Notice of policy on public release

of certain emission data submitted under

sections 110 and I l4(c) of the Clean Air Act

(CAA).

SUMMARY: Section 114(c) of the CAA

excludes emission data from the general

definition of trade secret information.

Certain classes of data submitted to the EPA

under sections 110 and 114(a) of the CAA

are emission data, and, as such, cannot be

withheld from disclosure as confidential

pursuant to section 1905 of title 18 of the

United States Code. This notice clarifies

EPA's current policy, and solicits comment

regarding that policy and categories of data

which it considers excluded from a trade

secret definition.

DATES: Written comments pertaining to this

notice are requested by April 22, 1991.

ADDRESSES: Submit comments to: Nancy

D. Riley, U.S. Environmental Protection

Agency, Emission Standards Division,

Pollutant Assessment Branch (MD-I3),

Research Triangle Park, NC 21111.

FOR FURTHER INFORMAnON

CONTACT: Timothy Mohin (telephone:

(919) 541·5349 commercial/FTS 629-5349)

or Karen Blanchard (telephone: (919) 541-

5503 commerciallFTS 629-5503), Pollutant

Assessment Branch (MD-I3), Emission

Standards Division; or Thomas Rosendahl

(telephone: (919) 541-5404 commerciallFTS

629-5404), National Air Data Branch

(MD-14), Technical Support Division;

U.S. Environmental Protection Agency,

Research Triangle Park, North Carolina

27111.

SUPPLEMENTARY INFORMATION: The

EPA routinely uses the authority of sections

110 and 114(a) of the CAA to gather

technical information from industries

involved in operations that lead to emission

of pollutants to the ambient air. This

information has been used, among other

things, to better characterize emitting

facilities and to evaluate the need for and

impacts of potential regulation.

Information requests under sections 110

and 114(a) of the CAA typically include

questions on uncontrolled and controlled

emission rates and emission parameters of

the pollutant or group of pollutants of

concern. The respondents sometimes claim

that its response constitutes trade secret

information, and thus, should be treated as

confidential. Claims of confidentiality may

be made under section 114(c) of the CAA,

which states no 0 0 upon a showing

satisfactory to the Administrator by any

person that records, reports, or information,

or a particular part thereof, (other than

emission data) to which the Administrator

has access under this section ifmade public,

would divulge methods or processes entitled

to protection as trade secrets of such person,

the Administrator shall consider such 0 0 0

confidential in accordance with the purposes

of section 1905 of title 18 of the United

States Code 0 0 0." [fthe Administrator so

determines, the information is not

disclosable to the public.

However, section 114(c) of the CAA

provides that information claimed to be a

trade secret but which constitutes emission

data may not be withheld as confidential.

Although typically the EPA evaluates

whether information constitutes emission

data on a case-by-case basis, it believes that

some kinds of data will always constitute

emission data within the meaning of section

114(c). The purpose of this notice is to

describe, without attempting to be

comprehensive, that information which the

EPA generally considers to be emission data,

and which cannot qualify as confidential

under either section 114(c) or section 110 (as

set forth in 41 CFR 51.321, 51.322, and

51.323) of the CAA. The EPA is issuing this

notice to clarify its policy and procedures, to

facilitate the use of these data in automated

data systems and computer-based simulation

models, and to expedite processing of claims

for confidentiality or requests for disclosure.

The EPA presently determines that data

submitted to it as emission data does not

qualify as confidential if it meets the

following definition under 40 CFR

2.30 I(a)(2)(i):

a. Definitions. For the purpose of this

section, (I) Act means the Clean Air Act, as

amended, 42 U.S.C. 1401 et seq. (2)(i)

Emission data means, with reference to any

source of emission of any substance into the

air-

(A) Information necessary to determine

the identity, amount, frequency,

concentration, or other characteristics (to the

extend related to air quality) of any emission

which has been emitted by the source (or of

any pollutant resulting from any emission by

the source), or any combination of the

foregoing:

(B) Information necessary to determine

the identity, amount, frequency,

concentration, or other characteristics (to the

extent related to air quality) of the emission

which, under an applicable standard or

limitation, the source was authorized to emit

(including, to the extent necessary for such

purposes, a description of the manner or rate

of operation of the source), or any

combination of the foregoing.

(C) A general description of the location

and/or nature of the source to the extent

necessary to identify the source and to

distinguish it from other sources (including,

to the extent necessary for such purposes, a

description of the device, installation, or

operation constituting the source).

The table below lists the specific data

fields which the EPA presently considers to

constitute emission data and provides a brief

description of what each data field describes.

The descriptions are intended to provide

general information. This list is not

exhaustive, and, therefore, other data might

be found, in a proper case, to constitute

emission data.

Emission Data Fields

Facility Identification: The following data

fields are needed to establish the identity and

location of emission sources. This shall also

include a description or an identifier of the

device, installation, or operation constituting

the source. These data are used to locate

sources for dispersion evaluation and

exposure modeling.

Plant Name and related point identifiers

Address

City

County

AQCR (Air Quality Control Region)

MSA, PMSA, CMSA (Metropolitan

Statistical Areas)

State

Zip Code

Ownership and point of contact information

Locational Identifiers:
Federal Register I Vol 56. No. 35 I Thursday, February 21, 1991 I Notices 7043

Latitude & Longitude, or UTM Grid

Coordinates

SIC (Standard Industrial Classification)

Emission point, device or operation

description information

SCC (Source Classification Codes)

Emission Parameters: The following data

fields are needed to establish the

characteristics of the emissions. This

information is needed for the analyses of

dispersion and potential control equipment.

Emission type

(e.g., nature of emissions such as CO2).

particulate or a specific toxic

compound, and origin of emissions

such as process vents, storage tanks or

equipment leaks)

Emission rate

(e.g., the amount released to the

atmosphere over time such as kglyr or

Ibs/yr)

Release height

(e.g., height above ground level where the

pollutant is emitted to the atmosphere)

Description of terrain and surrounding

structures

(e.g., the size of the area associated with

adjacent structures in square meters and

terrain descriptions such as

mountainous. urban, or rural)

Stack or vent diameter at point of emissions

(e.g., the inside diameter of vent at the

point of emission to the atmosphere in

meters)

Release velocity

(e.g., velocity ofrelease in m1sec)

Release temperature

(e.g., temperature of release at point of

release in degrees Kelvin)

Frequency of release

(e.g., how often a release occurs in events

per year)

Duration of release

(e.g., the time associated with a release to

the atmosphere)

Concentration

(e.g., the amount of an emission stream

constituent relative to other stream

constituents expressed as parts per

million (ppm), volume percent. or

weight percent)

Density of the emissions stream or average

molecular weight

(e.g., density expressed as fraction or

multiple of the density of air: molecular

weight in gig-mole)

Boiler or process design capacity

(e.g.•the gross heating value of fuel input

to a boiler at its maximum design rate)

Emission estimation method

(e.g., the method by which an emission

estimate has been calculated such as

material balance, source test, use of AP42 emission factors, etc.)

Percent space heat

(e.g., the percent of fuel used for space

heating)

Hourly maximum design rate

(e.g., the greatest operating rate that would

be expected for a source in a l-hour

period)

The EPA has determined that these data

are emission data and releasable upon

request. This determination applies to data

currently held by EPA as well as to

information submitted to EPA in the future.

Future requests for information under

sections 110 and 114 of the CM will

indicate that these emission data will not be

held confidential. This determination applies

only to the data listed in the table.

Determinations will continue to be made on

a case-by-case basis for data not specified in

this generic determination.

After consideration of comments on this

policy, a revised policy/determination may

be published.

Dated: February 8, 1991.

Michael Shapiro.

Acting Assistant Administrator for Air and

Radiation.

[FR Doc. 91-4114 Filed 2-20-91: 8:45 am]
Enclosure 5
 Enclosure 6 

Page 1 of 5 

Summary of OAQPS 

 Procedures for Safeguarding Clean Air Act (CAA) 

Confidential Business Information (CBI) 

January 2002 

1. Purpose: 

This memorandum describes policies and procedures set forth by the Office of Air Quality 

Planning and Standards (OAQPS) for the handling of information claimed as Confidential 

Business Information (CBI), whether submitted voluntarily or obtained under Section 114 of the 

Clean Air Act (CAA), and governed by U.S. Environmental Protection Agency (EPA) 

regulations in 40 Code of Federal Regulations (CFR), Part 2, Subpart B, and other EPA 

regulations. 

2. Reference Documents: 

a. Clean Air Act as amended. 

b. 40 CFR, Chapter 1, Part 2, Subpart B - Confidentiality of Business Information. 

c. EPA Information Security Manual 2195A1 

d. Office of Air Quality Planning and Standards Confidential Business Information 

Security Manual (January 2009) 

3. Exception: 

This document was prepared as a summary of data gathering and handling procedures used by 

the OAQPS, EPA. Nothing in this document shall be construed as superseding or being in 

conflict with any applicable regulations, statutes, or policies to which EPA is subject. 

4. Definition: 

Confidential Business Information (CBI) - Information claimed by the provider to be 

confidential. This information may be identified with such titles as trade secret, secret, 

administrative secret, company secret, secret proprietary, privileged, administrative confidential, 

company confidential, confidential proprietary, or proprietary. NOTE: These markings should 

not be confused with the classification markings of National Security information identified in 

Executive Order 11652. 
 

Page 2 of 5 

5. Background: 

Section 114 (c) of the Clean Air Act as amended reads as follows: 

 “Any records, reports, or information obtained under subsection (a) shall be available to the 

public, except that upon satisfactorily showing to the Administrator by any person that records, 

reports, or information, or particular part thereof (other than emission data), to which the 

Administrator has access under this section if made public, would divulge methods or processes 

entitled to protection as trade secrets of such person, the Administrator shall consider such 

records, report, or information or particular portion thereof confidential in accordance with the 

purposes of Section 1905 of Title 18 of the United States Code, except that such record, report, 

or information may be disclosed to other officers, employees, or authorized representatives of the 

United States concerned with carrying out this Act or when relevant in any proceeding under this 

Act.” 

The treatment of CBI by EPA, including data obtained under Section 114 of the Clean Air Act, is 

governed by 40 CFR, Part 2. These regulations require EPA offices to include a notice with each 

request for information to inform the business of: (1) its right to assert a claim of confidentiality 

covering part or all of the information, (2) the method for asserting a claim, and (3) the effect of 

failure to assert a claim at time of submission. In addition, the regulations: (1) set forth 

procedures for the safeguarding of confidential information; (2) contain provisions for providing 

confidential information to authorize representatives; (3) contain provisions for the release of 

information to the Congress, Comptroller General, other Federal agencies, State and local 

governments, and Courts; (4) permit the disclosure of information within EPA to employees with 

an official need for the information; and (5) prohibit wrongful use of such information and cite 

penalties for wrongful disclosure. Further, the regulations contain the Agency’s basic rule 

concerning the treatment of requests for information under the Freedom of Information Act 

(5 U.S.C. 552). 

6. Procedures: 

a. Request for Information 

Each request for information made under the provisions of Section 114(a) is signed by 

the Division Director. The request includes standard enclosure “EPA’s Information 

Gathering Authority under Section 114 of the Clean Air Act,” which was designed to 

meet the requirement of 40 CFR Part 2 discussed above. 

b. Receipt of CAA Confidential Business Information 

Upon receipt of information for which confidential treatment has been requested, the 

OAQPS Document Control Officer (DCO) logs in the material and a permanent file is 

established. If part of the material is claimed to be confidential, that portion should be 

marked “Subject to Confidentiality Claim.” In compliance with Sections 2.204 and 2.208 

of 40 CFR Part 2, the Group Leader responsible for the requested information reviews the 

information to determine the validity of the confidentiality claim as prescribed by the 

sections. If the information is clearly not confidential, the Group Leader prepares a letter 
 

Page 3 of 5 

for the signature of the responsible Division Director to notify the business of this 

finding. 

Information claimed as confidential is hand carried to the OAQPS CBI Office to be 

logged into the OAQPS CAA CBI tracking system and filed for safekeeping. The 

OAQPS CAA CBI tracking system provides a brief description of the material 

(submitter, subject, number of pages, etc.), identifies it with the correct project number, 

or work assignment number, and lists those persons who are authorized to have access to 

the information. record of personnel accessing the information (Attachment A) is also 

kept on filed. By regulation, confidential information must be so marked or designated by 

the originator. EPA takes additional measures to ensure that the proprietary designation is 

uniformly indicated and immediately observable. All unmarked or undesignated 

information (except as noted below) may be authorized for public release. 

c. Storage of CAA Confidential Business Information 

Folders, documents, or material containing CAA CBI (as defined) shall be secured, 

within the confines of the instructions listed in the OAQPS Security Manual. In addition, 

the CBI storage area has been identified specifically for this purpose and is equipped with 

supplementary locking devices. The storage area and files are under the direct control of 

the OAQPS DCO. 

Access to the storage area is limited to the Document Control Officer DCO, Document 

Control Officer Assistant (DCOA) and the minimum number of persons required to 

effectively maintain normal business operations as directed by the Director, Central 

Operations and Resources (CORE). 

Files may be issued upon confirmation that the requesting individual is authorized to 

receive the information. All confidential files must be returned no later than close of 

business on the same day. The intended user must sign the CBI Control Record when 

checking out files. 

Individuals signing out confidential files are responsible for their safekeeping. Files must 

never be left unattended. The information must not be disclosed to any non-authorized 

personnel. 

Storage procedures for CAA CBI by an authorized representative of EPA (see Section d. 

below) must be, at a minimum, as secure as those established for EPA offices within 

OAQPS. Whenever CBI is removed from the EPA files to be transmitted to an authorized 

representative, a notation is made in the file’s control record and transfer log indicating 

what information was transmitted, the date, and the recipient. The authorized 

representative returns a signed receipt to the DCO. 
 

Page 4 of 5 

d. Access to CAA Confidential Business Information 

Only authorized EPA employees may open or distribute CAA CBI. 

Only employees who require, have a need to know and are authorized access to CAA 

CBI in the performance of their official duties are permitted to review documents and, 

upon receiving a confidential document, must sign and date the form shown in 

Attachment A to certify their access to the document. 

The Group Leader having primary responsibility for the CAA CBI provides a 

memorandum to the DCO designating those personnel authorized to access specific CBI. 

NO person is automatically entitled to access based solely on grade, position, or security 

clearance. The names of persons granted access to CAA CBI are placed on the CAA CBI 

access list. The CAA CBI access list indicates the “specific” CBI each person is 

permitted to see. The Access List is reviewed and updated periodically. 

Companies under contract to perform work for the EPA may be designated authorized 

representatives of EPA. As authorized representatives, contractors may be granted access 

to CAA CBI. The following conditions apply when it has been determined that disclosure 

is necessary: 

(1) The contractor designated as a representative and its employees (a) may use such 

confidential information only for the purpose of carrying out the work required, 

(b) must refrain from disclosing the information to anyone other than EPA without 

having received from EPA prior written approval of each affected business or of an 

EPA legal office, and (c) must return to EPA all copies of the information (and any 

abstracts or excerpts there from) upon request or whenever the information is no 

longer required for the performance of the work. 

(2) The authorized contractor designated as a representative must obtain a written 

confidentiality agreement from each of its employees who will have access to the 

information. 

 A copy of each employee agreement (Attachment B) must be furnished to EPA 

before access is permitted. 

(3) The contractor designated as an authorized representative must agree that the 

conditions in the contract concerning the use and disclosure of CAA CBI are 

included for the benefit of, and shall be enforceable by, both EPA and any affected 

business having a proprietary interest in the information. 

Information may be released to or accessed by EPA employees other than OAQPS employees 

only upon approval of the Director, CORE. 

Requests for CAA CBI from other Federal agencies, Congress, the Comptroller General, Courts, 

etc., are processed in accordance with 40 CFR 2, Subpart B. 
 

Page 5 of 5 

Requests under the Freedom of Information Act (FOIA) are handled in accordance with 

40 CFR 2, Subpart A. The Freedom of Information Act Coordinator must be consulted prior to 

responding to any request for information if a claim of confidentiality has been asserted or if 

there is reason to believe that a claim might be made if the business knew release was intended. 

e. Use and Disclosure of CAA Confidential Business Information 

The CAA CBI as defined may not be used in publications, supporting document, 

memoranda, etc., that become a part of the public domain, except as provided for in 

40 CFR 2 Subpart B. CAA CBI may not be summarized without the approval of the 

Group Leader responsible for the CAA CBI. Any authorized reproductions must be 

logged into the CAA CBI document tracking system and treated according to the same 

procedures applicable to the original confidential material. Documents, materials, or 

extracts of information generated by EPA which contain CAA CBI must be stamped 

“Subject to Confidentiality Claim” and a cover sheet must be attached to identify the 

material as CBI. 

f. Handling of Other Information 

Reports, memoranda, documents, etc., prepared by EPA or its authorized representatives 

are not normally circulated outside EPA for comment or review prior to publication 

except in such cases as described in section 6 above. However, because industrial-datagathering visits, plant inspections, and source testing can involve inadvertent receipt of 

CAA CBI, it is the policy of OAQPS to protect all parties involved in the following 

manner: 

(1) Prior to or at the inception of a plant inspection, data-gathering visit, or source test, 

EPA or its authorized representative discusses with a responsible industry official 

the information sought, how it is to be used, and how it is to be protected. A copy of 

this summary is usually provided to the industry official being consulted. 

(2) Following an inspection, visit, or test, a trip report is prepared to include, as 

practicable, all information received by EPA or its authorized representative during 

the visit or test. The report may be prepared by either EPA or its authorized 

representative. The draft report is clearly identified, with an attached, yellow cover 

sheet. A second copy of the draft trip report is forwarded by EPA to the responsible 

industry official for review. The responsible industry official is requested by cover 

letter to review the report, clearly mark any information considered to be 

confidential, and return the marked up-report to the responsible EPA employee 

within the time specified. The original draft is kept in the CBI file until the markedup copy is returned by the business firm. 

(3) When the reviewed copy of the report, as marked by the responsible plant official, 

is received by EPA, information designated confidential is placed in the CBI files as 

described above. The original draft of the trip report is edited to delete the 

confidential information and the trip report is authorized for release. 
ATTACHMENT A 

EXAMPLE RECORD FORM FOR CBI ACCESS 
CAA CONFIDENTIAL BUSINESS INFORMATION 

CONTROL RECORD

DATE RECEIVED: RESPONSIBLE GROUP: CONTROL NUMBER:

DATE OF DOCUMENT: DOCUMENT AUTHOR:

DESCRIPTION (PROVIDING ORGANIZATION, TITLE, SUBJECT, NUMBER OF COPIES, NUMBER OF PAGES)

RETURN DATE: DESTRUCTION DATE: INITIALS:

EACH PERSON WHO IS GIVEN ACCESS TO THIS DOCUMENT MUST FILL IN THE INFORMATION BELOW.

SIGNATURE DATE SIGNATURE DATE

CHECK-OUT CHECK-IN

TIME TIME

CAA Form 1 (Rev. 01/02)
ATTACHMENT B 

EXAMPLE RECORD FORM FOR CBI ACCESS 
CAA CBI Security Manual (Appendix A)

I. AUTHORIZATION FOR ACCESS TO CAA CBI FOR FEDERAL EMPLOYEES

FULL NAME POSITION

SSN OFFICE

It is the responsibility of each Authorizing Official* to ensure that the employees under his/her supervision who

require access to CAA CBI:

 1. Sign the Confidentiality Agreement for Federal Employees

 2. Are fully informed regarding their security responsibilities for CAA CBI.

 3. Obtain access only to that CAA CBI required to perform their official duties

SIGNATURE OF AUTHORIZING OFFICIAL* TELEPHONE NO. DATE

TITLE LOCATION

II. CONFIDENTIALITY AGREEMENT FOR FEDERAL EMPLOYEES

I understand that, in accordance with my official duties, I will have access to certain Confidential Business

Information submitted under the Clean Air Act (CAA) (42 U.S.C. 7401 et seq.)

I understand that, under 18 U.S.C. 1905 and 18 U.S.C 1924I am liable for a possible fine of up to $1,000 and/or

imprisonment for up to one year, if I willfully disclose CAA Confidential Business Information to any person not

authorized to receive it. Additionally, I understand that, I may be subject to disciplinary action for violation of

this agreement with penalties ranging up to and including dismissal.

I am aware that, I may be subject to criminal penalties under 18 U.S.C. 1001 if I have made any statement of

material facts knowing that such statement is false or if I willfully conceal any material fact. 

I agree that, upon the termination of my duties, transfer or departure from the Environmental Protection Agency, 

I will return all materials containing CAA Confidential Business Information in my possession to the OAQPS

CBI Office.

I certify that I have read and understand these procedures and those outlined in the CAA CBI Security Manual.

SIGNATURE TELEPHONE NO. DATE

III. THE UNDERSIGNED CERTIFIES THE ALL TRAINING AND TEST

REQUIREMENTS HAVE BEEN MET BY THE EMPLOYEE. 

 

 SIGNATURE CBI MANAGER/DCO TELEPHONE NO. DATE

IV. ANNUAL RE-CERTIFICATION: I certify that, in conjunction with my duties, I require access to

CAA CBI. I am current with all CBI handling procedures and security guidelines as outlined in the CCA CBI

Security Manual.

 

Date Date Date Date Date Date

Initial Initial Initial Initial Initial Initial

Date Date Date Date Date Date

Initial Initial Inital Initial Initial Initial

 CAA CBI From 2 (Rev. 01/02) * Must be Division Director (or equivalent) or above. 

A-1
 Enclosure 7 

Site-Specific Test Plan Development Guidance

This information collection request (ICR) provides specific additional instructions for each 

prescribed test method to ensure that the collected data will meet the objectives of the ICR. To 

ensure that all data submitted in fulfillment of this ICR are of sufficient and known quality, EPA 

believes it is highly advisable for each facility (subject to emissions testing under the ICR) to 

prepare a site-specific test plan prior to testing. A site-specific test plan addresses the planning 

and quality assurance and quality control procedures and acceptance criteria for all of the testing, 

including the collection of process and fuel data. 

You may find guidance for developing such a site-specific test plan at 

http://www.epa.gov/ttn/emc/guidlnd/gd-042.pdf. Such a test plan would provide a means for 

you to verify that the quality assurance protocols, contained in the various test methods, are met. 

You need not submit the test plan to EPA; however, much of the information in a complete sitespecific test plan consists of data that are used for required fields in Version 3 of the EPA 

Electronic Reporting Tool (ERT) (see Enclosure 8). 
Test Plan

Wool Fiberglass ERT Cupola Test Plan

Facility Information:

Enter Plant Name

Enter physical Address

Enter physical City Stat Zip Code

Contact: Person to contact for more detail

Phone: Of above person

Fax: Of above person

Email: Of above person

Testing Company:

Name of primary testing organization

US postal address of above

Contact: Field test leader

Phone: Of above person

Fax: Of above person

Email: Of above person

Air Permit Number:

Enter your facility's ORIS Number here

Permitted Source ID/Name:

Cupola ID Enter name of the tested cupola (left)

Permitted Maximum Process Rate:

N/A

Max. Normal Operation Process Rate:

N/A

Target Process Test Rate

N/A

1. What is the specific purpose for the proposed testing?

The primary reasons for performing this emissions test is to provide emissions data to develop emission standards for 

HAP.

3. Will the test results be used for other regulatory purposes (e.g., emission inventories, 

 permit applications, etc.) beyond that stated above? If yes, explain.

List any secondary purposes that you will use the data from this emissions test to address. If known, list those 

pollutants that are of secondary interest.

5a. Please give a brief description of the source (including control equipment) and attach source or

 process flow diagram:

This description should describe the process and associated controls to differentiate this facility from, or document 

similarity with others of same SCC. An example is: This source is a glass melting furnace.

5b. Control Devices:

Industry NAICS: 327993

4a. Enter the process data to be documented during testing.

4b. Enter the process lab data to be documented during testing.

AFS #: Enter AFS Number FRS #: Enter FRS ID

SCC / Description 30501207 Industrial Processes - Mineral Products - Fiberglass Manufacturing - Unit Melter 

Furnace (Wool-type Fiber) 

2. List all state and federal regulations that apply to the proposed testing:

Process Parameter Units Target Value Comments

Glass Pulled Tons/hr 0

Wednesday, March 24, 2010 Test Plan Page 1 of 5

Enclosure 8
Test Plan

Wool Fiberglass ERT Cupola Test Plan

7. Please provide the following information for each test parameter.

6. Please enter sampling location information.

Control Device Name

List all emissions control devices in order of process flow. Choose from

drop down lists. If not on list add description and provide detailed

description in section 5a.

Target

Parameter 

Test

Method

Number of

Test Runs

Test Run

Duration

Sample 

Location Points Comments

Cupola Stack Flowrate Method 1 - 4 3 60 0

Outlet

Cupola Stack % H2O Method 1 - 4 3 240 0

Outlet

Cupola Stack % H2O Method 1 - 4 3 60 0

Outlet

Cupola Stack Flowrate Method 1 - 4 3 240 0

Outlet

Cupola Stack Hydrogen Chloride Method 26A 3 60 0

Outlet

Cupola Stack Hydrogen Fluoride Method 26A 3 60 0

Outlet

Cupola Stack Filterable PM2.5 OTM - 27/28 3 240 0

Outlet

Organic 

Condensible 

Particulate

Cupola Stack OTM - 27/28 3 240 0

Outlet

Inorganic 

(Aqueous) 

Condensible Part.

Cupola Stack OTM - 27/28 3 240 0

Outlet

Cupola Stack Antimony Method 29 3 240 0

Outlet

Cupola Stack Arsenic Method 29 3 240 0

Outlet

Cupola Stack Beryllium Method 29 3 240 0

Outlet

Cupola Stack Cadmium Method 29 3 240 0

Outlet

Cupola Stack Manganese Method 29 3 240 0

Outlet

Cupola Stack Chromium Method 29 3 240 0

Outlet

Cupola Stack Cobalt Method 29 3 240 0

Outlet

Cupola Stack Lead Method 29 3 240 0

Outlet

Cupola Stack Mercury Method 29 3 240 0

Outlet

Location

Round

Duct

Diam.

Distance from 

upstream dist.

Distance from

downstream dist.

Number of

Traverse Ports

Equiv. 

Diam

Min.Travers 

Points

Rect. Duct 

Length /Width

Cupola Stack 

Outlet

0 0 0 0 0 0 0 0

Wednesday, March 24, 2010 Test Plan Page 2 of 5
Test Plan

Wool Fiberglass ERT Cupola Test Plan

8. Describe below or attach complete documentation of all modifications and/or deviations to

 the applicable test methods. If alternative methods requested, attach documentation of 

request 

In this section, identify the promulgation date of any specified test method that you use for determining the 

procedures followed. This field is also used to document any modifications that are necessary to conduct the 

emissions test if they are outside the requirements of the cited method. If this modification was approved verbally by 

a regulatory agency, the name and date of approval should be included. Written formal approval should be attached 

to this file using the "Attach File" button. Test procedures that are different from those published in the Federal 

Register should be attached using the "Attach File" button.

9. Does the proposed sampling location meet the minimum EPA Method 1 criteria for 

acceptable 

 measurement sites? Please list below or attach the supporting documentation.

Yes No

7b. Please select the Emissions / Concentrations for each location.

Cupola Stack Nickel Method 29 3 240 0

Outlet

Filterable 

Particulate

Cupola Stack Method 29 3 240 0

Outlet

Cupola Stack Selenium Method 29 3 240 0

Outlet

Cupola Stack Co2 Method 3A CO2 3 240 0

Outlet

Cupola Stack Co2 Method 3A CO2 3 60 0

Outlet

Cupola Stack O2 Method 3A O2 3 240 0

Outlet

Cupola Stack O2 Method 3A O2 3 60 0

Outlet

Filterable 

Particulate

Cupola Stack Method 5 3 340 0

Outlet

Test

Method

Emissions /

 Concentrations

Corrected 

Analyte

Corrected

Location Percent

Cupola Stack Method 26A lb/hr 0

Outlet

Cupola Stack Method 29 lb/hr 0

Outlet

Cupola Stack Method 5 lb/hr 0

Outlet

Cupola Stack Method 26A ppm corrected O2 7

Outlet

Cupola Stack Method 29 mg/dscm corrected O2 7

Outlet

Cupola Stack Method 5 mg/dscm corrected O2 7

Outlet

Cupola Stack Method 1 - 4 percent(%) 0

Outlet

Cupola Stack Method 3A CO2 percent(%) 0

Outlet

Cupola Stack Method 3A O2 percent(%) 0

Outlet

Cupola Stack OTM - 27/28 lb/hr 0

Outlet

Cupola Stack OTM - 27/28 mg/dscm corrected O2 7

Outlet

Wednesday, March 24, 2010 Test Plan Page 3 of 5
Test Plan

Wool Fiberglass ERT Cupola Test Plan

9. Does the proposed sampling location meet the minimum EPA Method 1 criteria for 

acceptable 

 measurement sites? Please list below or attach the supporting documentation.

In this section, provide documentation about the compliance of the sampling location to Method 1 critera AND if the 

site meets these requirements, change the check box to "Yes". If the sampling location does not meed Method 1 

requirements indicate the method used to make the sampling location representative of the emissions from the source.

10. Has absence of cyclonic flow been verified per EPA Method 1 (Section 2.4)? If no,

 absence of cyclonic flow must be verified prior to testing. If yes, please attach

 supporting documentation.

This field is for the documentation of the absence of cyclonic flow that is available at the time of the Test Plan 

generation. If this documentation is not availbable at the time, documentation is required during the performance of 

the emissions test. If cyclonic flow exists at the testing location describe the procedures used to obtain representative 

samples. If there is an absence of cyclonic flow, check the "Yes" box.

11. Select the method that will determine the oxygen concentration : M3A-instrumental

13. Has all testing equipment been calibrated within the past year? If no, please 

explain.

It is expected that the response to this question will be "Yes". This highlights the need to attach the documentation of 

the calibrations for all equipment used during the condust of the emissions test. If all the equipment has been 

calibrated, check the "Yes" box.

17. What is the proposed test schedule? 

This field is primarily to advise the regulator authority and facility the dates that emissions testing will be performed 

including any set up dates.

18. Additional comments:

Yes No

Yes No

Yes No

Yes No

14. Will all calibration gases be certified by EPA Traceability Protocol

 procedures? If No, describe certification procedure below.

15. Is a dilution system (via EPA Method 205) proposed?

19. Required Personal Protection Equipment:

This field is primarily to advise the regulatory authority of the type of personal protective equipment that will be 

required for them to use to access the sampling location and any other locations that are addociated with the 

performance of the test program. It will also serve to inform the facility of the source testers knowledge of the 

required protective equipment that they will use during the source test program.

Yes No N/A

Yes No N/A

16. If applicable, list the expected calibration gas concentrations for all proposed instrumental

 test methods. Include as much information as is known at this time.

12. Do any of the proposed test methods require analysis of EPA audit samples? If

 yes, notify Regional Office at least 45 days prior to testing to allow for audit

 sample preparation and shipment.

Wednesday, March 24, 2010 Test Plan Page 4 of 5
Test Plan

Wool Fiberglass ERT Cupola Test Plan

Name:

Title:

Company:

Sign Date:

Name:

Title:

Company:

Sign Date:

Permitted Facility Representative Date Testing Company Representative Date

Wednesday, March 24, 2010 Test Plan Page 5 of 5