### Enclosure 1

INFORMATION REQUEST FOR FACILITIES THAT MANUFACTURE WOOL FIBERGLASS

I. Introduction

T his information request is to be completed for facilities that are engaged in w ool f iberglass

m anufacturing

. This includes any facility engaged in producing wool fib erglass 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 woo l fiberglass manufacturing

. Complete this information request as fully as possible.

Section II contains general instructions for completing your respon ses and form

- specific guidance. Section I II contains useful definitions and Section I V contains a lis t of key acronyms and units

. Respondents should read this material before attempting to complete the questionnaire provided in Attachment 1

. A completed copy of th e questionnaire in Attachment 1 must be sent to EPA for each wool fiberglass manufacturing facility. C ompleted Form s 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 emissio n testing that is required in Enclosure 2 and does not need to be submitted at the same time as Form s 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 Standard s 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 )
, a ny information considered CBI should be d enoted 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

- 1 0) Research Triangle Park, NC 27711Wool Fiberglass Section 114 Enclosure 1

– Page 2 

### If you have questions regarding this request, please contact M s

. Susan Fairchild at 919

- 541

- 5 167 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 pol lutant 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 respondent s 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 f or each furnace at your wool fiberglass manufacturing facility (ies)

. For furnaces that are not yet operational, provide information on the projected data. Furnaces tha t 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 a long 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 em ission 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 tha n 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 lev el, then provide information about the method (title and source), theWool 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

.

I II

. Key Term Defini tions

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 poll utant 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.
Haz ardous Air Pollutants (HAP): See 42 U.S.C. §7412(a)(6).

Particulate Matter (PM): A complex mixture of extremely small particles and liquid droplets. P M is made up of a number of components, including acids (such as nitrates and sulfates), organic chemic als, metals, and soil or dust particles

. PM includes PM 2.5 

### 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 furnace s and appendages.

I V

. 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 a cf m 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 PollutantsWool 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 S tandards 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 sec onds
scfm standard cubic feet per minute
SPPD Sector Policies and Programs Division
SS s tartup 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 s ources at wool fiberglass manufacturing fac i lities . 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 t o 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 Append ix 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

. O utlet testing for all pollutants should beWool Fiberglass Section 114 Enclosure 2

– Page 2 

### conducted using the methods presented in Table 1.2. If you would like to use a method th at 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/testmeth ods/sw846/index.htm

.

Table 1.2: Summary of Wool Fiberglass Manufacturing Control System Outlet Emissions Measurement Methods and Alternative Methods

Pollutant Re quired 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 / m 3 at 7% O 2 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 l bs /hr and lbs/ton of product mg / m 3 at 7% O 2 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 yo u 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 ar e 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/ch ief/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 cop y 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. I f 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 mus t 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 enclosu re.

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 c alculate and report an in

stack 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 laborato ry’s reported detection level(s); or

• ADL (above detection level)

– all analytical values used to calculate and report an in

stack 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 t he 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 t est 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 an alytical 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 t est s preadsheet 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 t rains) 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 o utlined 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 t est sprea dsheet 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 t est spreadsheet template or ERT format allows; if not (i.e., the format allows reporting only a single sum value):

o For the Excel emission t est spreadsheet template, next to the sum reported as above report in the Notes line the appropriate flag along with the values for t he 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 fo ur fra ction 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 eachWool 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):

− R ecord 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 ave rage:

o As a bracketed “less than” detection level value (e.g., [<20.06]) in the Excel emission t est 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 T est P lan (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 elec tronic copy of the ERT database,

a n electronic copy of the complete emission test report (s) for each furnace tested , and the completed Form C ( in Attachmen t 1 of Enclosure 1 ) that includes each f urnace 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 Environmenta l Protection Agency Office of Air Quality Planning and Standards US EPA Mailroom (C

- 404

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

- 1 0 ) 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

- 5 16 7 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 informat ion needed "for the purpose of (i) developing or assisting in the development of any implementation pl an 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, S ection 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 st andards. 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, how ever, request that EPA treat such information as confidential. Information obtained under Section 114 and covered by su ch 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 c onfidentiality determinations, substantive criteria to be used in such determinations, a nd 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, plea se 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 gua rd 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 s ubstantial, 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 17042 

### Enclosure 4

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

[AD-FRL-3906-3]

Disclosure of Em ission 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 INFORMA nON 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 CO 2 ). 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 6

Page 1 of 5 

# Summary of OAQPS Procedures for Safeguar ding Clean Air Act (CAA) Confidential Business Information (CBI)

January 2002

1. Purpose:

This m emorandum describes policies and proced ures set forth by the Office of Air Quality Planning and Standards (OAQPS) for the handling of informa tion claimed as Confidential Business Information (CBI), whether submitted vol untarily 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 St andards Confidential Business Information Security Manual (January 2009)

3. Exception:

This document was prep ared as a summary of data gathering a nd handling procedures used by the OAQPS, EPA. Nothing in this document shal l be construed as superseding or being in conflict with any applicable regulations, stat utes, or policies to wh ich EPA is subject.

4. Definition:

Confidential Business In formation (CBI) - In formation claimed by the provider to be confidential. This information may be identified with such titles as trade secret, secret, administrative secret, company secret, secret pr oprietary, privileged, admi nistrative confidential, company confidential, confiden tial proprietary, or proprietary . NOTE: These markings should not be confused with the classi fication markings of National Secu rity 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 inform ation obtained under subsection (a) shall be available to the public, except that upon satisfactor ily showing to the Administrato r by any person that records, reports, or information, or partic ular 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 Admi nistrator shall consider such records, report, or information or particular portion thereof conf idential 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 Ac t or when relevant in any proceeding under this Act.”

The treatment of CBI by EPA, including data obtain ed under Section 114 of the Clean Air Act, is governed by 40 CFR, Part 2. These regulations requi re 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 me thod for asserting a claim, and (3) the effect of failure to assert a claim at time of submi ssion. In addition, the regulations: (1) set forth procedures for the safeguarding of confidential information; (2) contai n provisions for providing confidential information to authorize representati ves; (3) contain provisio ns for the release of information to the Congress, Comptroller Gene ral, other Federal agen cies, 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) pr ohibit 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 info rmation under the Freedom of Information Act (5 U.S.C. 552).

6. Procedures:

a. Request for Information

Each request for informa tion made under the provisions of Section 114(a) is signed by the Division Director. The request include s 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 Confiden tial Business Information

Upon receip t of information for which confid ential treatment has been requested, the OAQPS Document Control Officer (DCO) logs in the material and a permanent file is established. If part of the ma terial is claimed to be conf idential, that portion should be marked “Subject to Confid entiality Claim.” In complian ce 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 th e confidentiality claim as prescribed by the sections. If the information is clearly not c onfidential, the Group Lead er prepares a letter

### Page 3 of 5 for the signature of the responsible Divisi on Director to notify the business of this finding.

Inform ation claimed as confidential is ha nd carried to the OAQPS CBI Office to be logged into the OAQPS CAA CBI tracking sy stem 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 pe rsons 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 info rmation must be so marked or designated by the originator. EPA takes additional measures to ensure that the propr ietary designation is uniformly indicated and immediately observable. All unmarked or undesignated information (except as noted below) ma y be authorized for public release.

c. Storage of CAA Confidential Business Information

Folders, documents, or m aterial containi ng CAA CBI (as defined) shall be secured, within the confines of the in structions listed in the OAQPS Security Manual. In addition, the CBI storage area has been identified specif ically for this purpose and is equipped with supplementary locking devices. The storage area and files are under th e direct control of the OAQPS DCO.

Access to the storage area is limited to th e 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 individua l is authorized to receive the information. All c onfidential files must be returned no la ter than close of business on the same day. The intended user must sign the CBI Control Record when checking out files.

Individuals signing out confiden tial files are respons ible 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 author ized 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 notatio n is made in the file’s control record and transf er log indicating what information was transmitted, the date, and the recipient. The authorized representative returns a si gned receipt to the DCO.

### Page 4 of 5 d. Access to CAA Confidential Business Information

Only authorized EPA em ployees 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, mu st sign and date the form shown in Attachment A to certify their access to the document.

The Group Leader having primary respons ibility for the CAA CBI provides a memorandum to the DCO designating those pe rsonnel authorized to access specific CBI. NO person is automatically entitled to access ba sed solely on grade, position, or security clearance. The names of pers ons 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 repr esentatives, contractors may be granted access to CAA CBI. The following conditions apply when it has been determined that disclosure is necessary:

(1) The contractor designate d as a representative and its employees (a) may use such confidential information only for the purpos e of carrying out the work required, (b) must refrain from disclosing the info rmation to anyone other than EPA without having received from EPA prior written appr oval 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 reque st 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 designate d as an authorized represen tative must agree that the conditions in the contract concerning the use and disclosu re of CAA CBI are included for the benefit of, and shall be enforceable by, both EPA and any affected business having a proprietary in terest in the information.

Information may be released to or accesse d 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 Ac t (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 cla im of confidentiality has been asserted or if there is reason to believe that a claim might be made if the business kne w release was intended.

e. Use and Disclosure of CAA Confidential Business Information

The CAA CBI as defined ma y not be used in publications, supporting document, memoranda, etc., that become a part of th e 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 EP A which contain CAA CBI must be stamped “Subject to Confidentiality Claim” and a cove r sheet must be attached to identify the material as CBI.

f. Handling of Other Information

Reports, me moranda, documents, etc., prepared by EPA or its authorized representatives are not normally circulated outside EPA fo r comment or review prior to publication except in such cases as described in secti on 6 above. However, because industrial-datagathering visits, plant inspect ions, and source testing can in volve inadvertent receipt of CAA CBI, it is the policy of OAQPS to prot ect 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 repres entative discusses with a re sponsible 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 th e industry official being consulted.

(2) Following an inspection, visit, or test, a trip report is prep ared to include, as practicable, all information received by EPA or its authorized representative during the visit or test. The report may be pr epared by either EPA or its authorized representative. The draft repor t is clearly identified, with an attached, yellow cover sheet. A second copy of the dr aft trip report is forwarde d by EPA to the responsible industry official for review. The responsible industry official is requested by cover letter to review the report, clearly ma rk 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:

DOCUMENT AUTHOR: DATE OF DOCUMENT:

DESCRIPTION (PROVIDING ORGANIZATION, TITLE, SU BJECT, NUMBER OF COPI ES, 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

C A A Form 1 (Re v

. 0 1 / 0 2 )

### ATTACHMENT B

EXAMPLE RECORD FORM FOR CBI ACCESSCAA 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 dutie s, I will have access to certain Confidential Business Information submitted under the Clean Ai r 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 fals e 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 procedur es 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 procedur es 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 te sting under the ICR) to prepare a site-specific test plan prior to testing. A s ite-specific test plan addresses the planning and quality assurance and quality control procedures and acceptance criteria for all of the testing, including the collect ion 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 assu rance 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: Enter name of the tested cupola (left) Cupola ID

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 Page 1 of 5 Test Plan

### 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

Points Comments Location

Flowrate Method 1 - 4 3 60 0 Cupola Stack Outlet % H2O Method 1 - 4 3 240 0 Cupola Stack Outlet % H2O Method 1 - 4 3 60 0 Cupola Stack Outlet Flowrate Method 1 - 4 3 240 0 Cupola Stack Outlet Hydrogen Chloride Method 26A 3 60 0 Cupola Stack Outlet Hydrogen Fluoride Method 26A 3 60 0 Cupola Stack Outlet Filterable PM2.5 OTM - 27/28 3 240 0 Cupola Stack Outlet Organic

Condensible Particulate OTM - 27/28 3 240 0 Cupola Stack Outlet

Inorganic

(Aqueous) Condensible Part. OTM - 27/28 3 240 0 Cupola Stack Outlet

Antimony Method 29 3 240 0 Cupola Stack Outlet Arsenic Method 29 3 240 0 Cupola Stack Outlet Beryllium Method 29 3 240 0 Cupola Stack Outlet Cadmium Method 29 3 240 0 Cupola Stack Outlet Manganese Method 29 3 240 0 Cupola Stack Outlet Chromium Method 29 3 240 0 Cupola Stack Outlet Cobalt Method 29 3 240 0 Cupola Stack Outlet Lead Method 29 3 240 0 Cupola Stack Outlet Mercury Method 29 3 240 0 Cupola Stack 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 Page 2 of 5 Test Plan

### 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.

Nickel Method 29 3 240 0 Cupola Stack Outlet Filterable

Particulate Method 29 3 240 0 Cupola Stack Outlet Selenium Method 29 3 240 0 Cupola Stack Outlet
Co2 Method 3A CO2 3 240 0 Cupola Stack Outlet Co2 Method 3A CO2 3 60 0 Cupola Stack Outlet
O2 Method 3A O2 3 240 0 Cupola Stack Outlet O2 Method 3A O2 3 60 0 Cupola Stack Outlet Filterable

Particulate Method 5 3 340 0 Cupola Stack Outlet

Test Method Emissions / Concentrations Corrected Analyte Corrected

Percent Location

Method 26A lb/hr 0 Cupola Stack Outlet Method 29 lb/hr 0 Cupola Stack Outlet Method 5 lb/hr 0 Cupola Stack Outlet Method 26A ppm corrected O2 7 Cupola Stack Outlet Method 29 mg/dscm corrected O2 7 Cupola Stack Outlet Method 5 mg/dscm corrected O2 7 Cupola Stack Outlet Method 1 - 4 percent(%) 0 Cupola Stack Outlet Method 3A CO2 percent(%) 0 Cupola Stack Outlet Method 3A O2 percent(%) 0 Cupola Stack Outlet OTM - 27/28 lb/hr 0 Cupola Stack Outlet
OTM - 27/28 mg/dscm corrected O2 7 Cupola Stack Outlet

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

### 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 Page 4 of 5 Test Plan

### Test Plan
Wool Fiberglass ERT Cupola Test Plan

Name:
Title: Company: Sign Date: Name:
Title: Company: Sign Date: Permitted Facility Representative Testing Company Representative Date Date

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