FORM A-1

PARENT COMPANY INFORMATION

I. Parent Company / Legal Corporate Owner Information

 1. Legal Parent Company / Legal Corporate Name Johns Manville

 2. Address 717 17th Street

 3. City Denver

 4. State Colorado

 5. Zip Code 80202

 6. County Denver

 7. Size of Company (approximate number of employees including 

all subsidiaries, branches, and related establishments owned):

6,491 (end of 2009)

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM A-2

FACILITY INFORMATION

II. Facility Information

 Facility Name Johns Manville

 Facility Address

 Street 713 Bankhead Hwy

 City Winder

 State GA

 Zip Code 30680

 County Barrow

 Facility Coordinates

 Latitude (decimal degrees, six decimal places) 33.991711

 Longitude (decimal degrees, six decimal places) -83.77145

 Specific location represented (e.g., front door of main building, centroid 

of property, etc.) Entrance roadway to Facility

 Number of employees attached to the wool fiberglass manufacturing 

facility: See CBI submittal

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

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

 Operation schedule

 hrs/day 24

 days/yr 365

 Identify what state and local air pollution rules and regulations, including 

permit requirements, your plant is subject to. (Please provide copies of 

permit(s) and permit IDs) Georgia Title V permit no. 3296-013-0005-V-02-0 (See Attachment A)

III. Technical Contact

 Name Patti Blevins

 Technical Contact Title EHS Manager

 Telephone 770-867-0347

 Facsimile (Fax) 770-867-0344

 Email blevinsp@jm.com

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
IV. Other

 Is the facility a major source of HAP? No

 

 If No, did the facility take a limit of its potential HAP emissions to avoid 

classification as a major source: No, true minor

 Does the facility manufacture other products in addition to wool 

fiberglass? No

 If Yes, list the other products manufactured at the facility. N/A

 Are there any HAP emissions associated with any co-located facilities? 

List unit operations, e.g., boiler, and pollutant/emissions. N/A

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM B-1

PLANT OPERATIONS

I. Overview of Plant Operations

Number of process lines. Include lines that are currently

operational or that are temporarily shutdown. (Do not 

include lines permanently shutdown). 2

For each process line: Process Line 1 Process Line 2 Process Line 3

 Process line identification names or numbers Line 105 Line 106

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

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

 Age of process equipment (yrs) 33 10

 Remaining economic life of process line (yrs)

Indefinite (due to 

rebuild capabilities)

Indefinite (due to 

rebuild capabilities)

 List of products produced and most recent annual 

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

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

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM B-2

PLANT OPERATIONS

II. Process - Raw materials Handling and Storage

 Molten glass preparation

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

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

 Binder and Additives

 List each raw material, including premixed materials, in the 

binder formulation and its proportion by wt (%) See CBI submittal

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

and holding time (hrs) See CBI submittal

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

 Cost of binder ($/gal) for most recent year (specify year) See CBI submittal

 Are binder storage and mixing tanks vented to outside/inside? Inside

 Method of treating vent air from storage and mix tanks None

 Emission control during liquid raw material transfer from vehicles 

to storage tanks. None

 Describe future source reduction plans and schedules to 

reformulate binders; List each constituent, proportions wt (%), cost 

($/gal) for reformulation See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM B-3

PLANT OPERATIONS

III. Process - Glass Melting Furnace

 For each Glass Melting Furnace: Furnace 1 Furnace 2

 Process unit identification name/number 531E, 532E, 533E 631E

 Process line(s) served (identification name/number) Line 105 Line 106

 Latitude (decimal degrees, six decimal places) 33.991162 33.990903

 Longitude (decimal degrees, six decimal places) -83.771822 -83.771684

 Stack or vent height (units) 110 110

 Stack or vent diameter (units) 3.5 4.5

 Manufacturer and model JM Proprietary JM Proprietary

 Date of original installation Sept 21, 1982 2000

 Estimate of remaining lifetime (yrs)

Indefinite (due to 

continued 

maintenance)

Indefinite (due to 

continued 

maintenance)

 Major rebuilds:

 What constitues a major rebuild

JM is not familiar with 

the term "major 

rebuild." JM conducts 

periodic routine 

maintenace.

JM is not familiar with 

the term "major 

rebuild." JM conducts 

periodic routine 

maintenace.

 Frequency of a major rebuild N/A N/A

 Cost of typical major rebuild N/A N/A

 Date of last major rebuild N/A N/A

 Purpose of last major rebuild N/A N/A

 Increase or decrease in emissions N/A N/A

 Fuel type: electric, gas, or oil Electric Electric

 Fuel consumption rate (KW/ton of glass or Btu/ton of 

glass) See CBI submittal See CBI submittal

 List HAPs that are in refractory material

Chromium 

compounds

Chromium 

compounds

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

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

 Vent gas flow rate (acfm @ °F) 32,800 acfm @ 68 °F 50,000 acfm @ 68 °F

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Temperature (°F) of molten glass in furnace and 

forehearth (if applicable) See CBI submittal See CBI submittal

 Nature and frequency of routine/preventive maintenance 

procedures See CBI submittal See CBI submittal

 Describe process modification(s) since 1999 that reduce 

emissions

None None

 Describe future source reduction plans and schedules See CBI submittal See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM B-4

PLANT OPERATIONS

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

 For each Forming Operation -- Rotary Spin/Flame Attenuation

 Process unit identification name/number 541 542 543

 Process line(s) served (identification name/number) Line 105-Module 1 Line 105-Module 2 Line 105-Module 3

 Latitude (decimal degrees, six decimal places) 33.991459 33.991351 33.991243

 Longitude (decimal degrees, six decimal places) -83.771821 -83.771817 -83.771814

 Stack or vent height (ft) 110 110 110

 Stack or vent diameter (ft) 5 4 4

 Number of fiber forming devices (spinners) per line.

 Method of attenuating fiber (e.g., air, flame, or air and flame). 

Indicate type of burner used (if flame).

 Is there a forehearth between the furnace and the forming 

section?

 Major rebuilds:

 What constitues a major rebuild

JM is not familiar with the 

term "major rebuild." JM 

conducts periodic routine 

maintenace.

JM is not familiar with the 

term "major rebuild." JM 

conducts periodic routine 

maintenace.

JM is not familiar with the 

term "major rebuild." JM 

conducts periodic routine 

maintenace.

 Frequency of a major rebuild N/A N/A N/A

 Cost of typical major rebuild N/A N/A N/A

 Date of last major rebuild N/A N/A N/A

 Purpose of last major rebuild N/A N/A N/A

 Increase or decrease in emissions N/A N/A N/A

 If modular, number of modules and plenums

 Presence of water overspray and application rate (gpm) See CBI submittal See CBI submittal See CBI submittal

 Binder applied and application rate (gpm) CBI See CBI submittal See CBI submittal See CBI submittal

 Other material applied and application rate (gpm)

 Temperature of glass fiber when binder is applied (°F) See CBI submittal See CBI submittal See CBI submittal

 Temperature of binder when applied to fibers (°F) See CBI submittal See CBI submittal See CBI submittal

 Method of evenly distributing fibers onto forming converyor See CBI submittal See CBI submittal See CBI submittal

 Formed mat thickness (in.) See CBI submittal See CBI submittal See CBI submittal

Forming Operation 1

See CBI submittal

Air

3

No

None

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Forming air flow rate (acfm @ °F)

 Percent of forming air recirculated and percent exhausted

 Nature and frequency of routine/preventive maintenance 

procedures-CBI See CBI submittal See CBI submittal See CBI submittal

 Describe process modification(s) since 1999 that reduce 

emissions

 Describe future source reduction plans and schedules See CBI submittal See CBI submittal See CBI submittal

100% exhausted

The binder for all plant products was converted to a non-HAP binder in 2002 

that significantly reduces or eliminates HAP emissions from the manufacturing 

process.

< 190,000 acfm @ 137 °F

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM B-4

PLANT OPERATIONS

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

 For each Forming Operation -- Rotary Spin/Flame Attenuation

 Process unit identification name/number

 Process line(s) served (identification name/number)

 Latitude (decimal degrees, six decimal places)

 Longitude (decimal degrees, six decimal places)

 Stack or vent height (ft)

 Stack or vent diameter (ft)

 Number of fiber forming devices (spinners) per line.

 Method of attenuating fiber (e.g., air, flame, or air and flame). 

Indicate type of burner used (if flame).

 Is there a forehearth between the furnace and the forming 

section?

 Major rebuilds:

 What constitues a major rebuild

 Frequency of a major rebuild

 Cost of typical major rebuild

 Date of last major rebuild

 Purpose of last major rebuild

 Increase or decrease in emissions

 If modular, number of modules and plenums

 Presence of water overspray and application rate (gpm)

 Binder applied and application rate (gpm) CBI

 Other material applied and application rate (gpm)

 Temperature of glass fiber when binder is applied (°F)

 Temperature of binder when applied to fibers (°F)

 Method of evenly distributing fibers onto forming converyor

 Formed mat thickness (in.)

641-642 643-644

Line 106-Module 4 Line 106-Module 5

33.991585 33.991342

-83.771424 -83.771417

110 110

8 8

JM is not familiar with the 

term "major rebuild." JM 

conducts periodic routine 

maintenace.

JM is not familiar with the 

term "major rebuild." JM 

conducts periodic routine 

maintenace.

N/A N/A

N/A N/A

N/A N/A

N/A N/A

N/A N/A

See CBI submittal See CBI submittal

See CBI submittal See CBI submittal

See CBI submittal See CBI submittal

See CBI submittal See CBI submittal

See CBI submittal See CBI submittal

See CBI submittal See CBI submittal

Forming Operation 2

See CBI submittal

Air

2

Yes

None

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Forming air flow rate (acfm @ °F)

 Percent of forming air recirculated and percent exhausted

 Nature and frequency of routine/preventive maintenance 

procedures-CBI

 Describe process modification(s) since 1999 that reduce 

emissions

 Describe future source reduction plans and schedules

See CBI submittal See CBI submittal

See CBI submittal See CBI submittal

100% exhausted

The binder for all plant products was converted to a 

non-HAP binder in 2002 that significantly reduces or 

eliminates HAP emissions from the manufacturing 

process.

150,000 acfm per module

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM B-5

PLANT OPERATIONS

V. Process - Curing 

 For each Curing Oven: Curing Oven 1 Curing Oven 2

 Process unit identification name/number 554 654

 Process line(s) served (identification name/number) Line 105 Line 106

 Latitude (decimal degrees, six decimal places) 33.991853 33.991970

 Longitude (decimal degrees, six decimal places) -83.77192 -83.771567

 Stack or vent height (ft) 110 110

 Stack or vent diameter (ft) 4 4

 Method of curing Thermal Thermal

 Manufacturer and model Johns Manville KCI

 Date of original installation 1977 2000

 Major rebuilds:

 What constitues a major rebuild

JM is not familiar with the 

term "major rebuild." JM 

conducts periodic routine 

maintenace.

JM is not familiar with the 

term "major rebuild." JM 

conducts periodic routine 

maintenace.

 Frequency of a major rebuild N/A N/A

 Cost of typical major rebuild N/A N/A

 Date of last major rebuild N/A N/A

 Purpose of last major rebuild N/A N/A

 Increase or decrease in emissions N/A N/A

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

 Fuel consumption rate (KW/hr or BTU/hr) Not separately metered Not separately metered

 Moisture content wt (%) of formed mat: 

 inlet See CBI submittal See CBI submittal

 outlet 0% 0%

 Air flow rate (acfm @ °F) from curing 33,250 acfm @ 120 °F 32,000 acfm @ 350 °F

 Exhaust air temperature (°F) 120 °F 350 °F

 Residence time of product (mins) See CBI submittal See CBI submittal

 Binder content of cured product (LOI) 5% - 7% 4% - 7%

 Nature and frequency of routine/preventive 

maintenance procedures See CBI submittal See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Describe process modification(s) since 1999 that 

reduce emissions

The binder for all plant 

products was converted to a 

non-HAP binder in 2002 that 

significantly reduces or 

eliminates HAP emissions 

from the manufacturing 

process; low NOx burners 

installed

The binder for all plant 

products was converted to a 

non-HAP binder in 2002 that 

significantly reduces or 

eliminates HAP emissions 

from the manufacturing 

process; replace burner with 

smaller MMBtu/hr

 Describe future source reduction plans and 

schedules See CBI submittal See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM B-6

PLANT OPERATIONS

VI. Process - Cooling

 For each Cooling Operation: Cooling Operation 1 Cooling Operation 2

 Process unit identification name/number 553 653

 Process line(s) served (identification name/number) Line 105 Line 106

 Latitude (decimal degrees, six decimal places) 33.992108 33.992184

 Longitude (decimal degrees, six decimal places) -83.771842 -83.77165

 Stack or vent height (ft) 110 110

 Stack or vent diameter (ft) 4 3.17

 Cooling air flow rate (acfm @ °F) 24,000 acfm @ 152 °F 20,000 acfm @ 160 °F

 Percentage of cooling air recirculated (if any) None None

 Cooling air temperature (°F) Ambient Ambient

 Nature and frequency of routine/preventive 

maintenance procedures See CBI submittal See CBI submittal

 Describe process modification(s) since 1999 that 

reduce emissions

The binder for all plant 

products was converted to a 

non-HAP binder in 2002 that 

significantly reduces or 

eliminates HAP emissions 

from the manufacturing 

process.

The binder for all plant 

products was converted to a 

non-HAP binder in 2002 that 

significantly reduces or 

eliminates HAP emissions 

from the manufacturing 

process.

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Describe future source reduction plans and schedules See CBI submittal See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM B-7

PLANT OPERATIONS

VII. Process - Use of Solvents

 Use of Solvents

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

By agreement this question was limited to HAP containing 

solvents. We interpret this question to apply to wool 

fiberglass lines, from melting through cooling. None

 List each solvent used and quantity (gal/yr) N/A

 Emission control device(s) used to control emissions from solvent 

usage/storage? N/A

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM B-8

PROCESS OPERATIONS

VIII. Pollution Prevention

Please describe any work practices, pollution prevention techniques, 

and control strategies evaluated and/or implemented at each process 

unit at your facility (e.g., binder reformulation, alternative fuels usage, 

etc.) to reduce emissions of PM and HAPs you identified in Form E. 

You must specify the year in which the facility implemented the 

practice/technique and identify the emission reductions (if measured) 

from these practices/techniques.

JM objects to this question in that it is unbounded in time. 

We interpret this question, like similar questions in the 

ICR, to seek data since 1999. With that interpretation, JM 

responds that the binder was reformulated to a 

formaldehyde free resin in 2002.

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM C-1

AIR POLLUTION CONTROL

I. Electrostatic Precipitator (ESP)

 For each ESP: ESP 1 ESP 2

 Process line(s) (identification name/number)

 Equipment/process(es) controlled. Include emission point 

designations (e.g., E3, E4 from plot plan)

Module 1: 641E (in series 

after scubber)

Module 2: 643E (in series 

after scubber)

 Latitude (decimal degrees, six decimal places) 33.991585 33.991342

 Longitude (decimal degrees, six decimal places) -83.771424 -83.771417

 Stack or vent height (units) 110 110

 Stack or vent diameter (units) 8 8

 Manufacturer and model GeoEnergy GeoEnergy

 Date of original installation 2000 2000

 Number of collection plates and configuration Tube-Type Wet ESP Tube-Type Wet ESP

 Gas flow rate to ESP (acfm @ °F) 140000 acfm @ 100 °F 140000 acfm @ 100 °F

 Inlet gas temperature (°F) 68 - 138 °F 63 - 82 °F

 Outlet gas temperature (°F) 100 °F 100 °F

 Inlet grain loading (gr/dscf) 0.4 0.4

 Outlet grain loading (gr/dscf) 0.04 0.04

 Average stack opacity (%) 0% 0%

 Pressure drop across ESP (in. H2O gauge) 2-10" Estimated 2-10" Estimated

 Plate area (ft2) Tube-Type Wet ESP Tube-Type Wet ESP

 Vendor guarantee on ESP efficency (attach copy) Not available Not available

 Method of plate cleaning and frequency Wash with water Wash with water

 Flow rate of plate washwater to ESP (gpm), if applicable 435 gpm per WESP 500 gpm per WESP

 Temperature of plate washwater to ESP (°F), if applicable 75 °F 75 °F

 Source of plate washwater used for cleaning, if applicable City water City water

 Concentration (mg/l) of dissolved and suspended solids in plate 

washwater, if applicable 34 - 144 mg/l 34 - 144 mg/l

 Conditioning agents used and amounts (in gpm or lbs/hr), if 

applicable N/A N/A

 Amount of wastewater generated (gpd), if applicable

All water from ESP is 

recycled to other processes

All water from ESP is 

recycled to other processes

 Amount of wastewater recycled (gpd), if applicable 100% 100%

 Amount of wastewater disposed of (gpd), if applicable None None

 Method of wastewater disposal, if applicalbe N/A N/A

 Quantity of solid waste collected (lbs/yr) Not separately identified Not separately identified

Line 106-Forning & Collection

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Quantitiy of solid waste recycled (lbs/yr) Not separately identified Not separately identified

 Quantity of solid waste disposed of (lbs/yr) Not separately identified Not separately identified

 Method of solid waste disposal Landfill Landfill

 Nature and frequency of routine/preventive maintenance 

procedures See CBI submittal See CBI submittal

 Problems experienced with control device within the last five 

years; how were problems solved? No major problems No major problems

 Continuous monitoring method(s) used to monitor ESP 

performance, including parameters monitored

Water flow rate, gas inlet 

temperature, total solids 

content, primary current, 

secondary current, output 

voltage

Water flow rate, gas inlet 

temperature, total solids 

content, primary current, 

secondary current, output 

voltage

 Describe any plans to replace or upgrade ESP See CBI submittal See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM C-2

AIR POLLUTION CONTROL

II. Scrubber

 For each Scrubber: Scrubber 1 Scrubber 2

 Process line(s) (identification name/number)

 Equipment/process(es) controlled. Include emission point 

designations (e.g., E3, E4 from plot plan)

Module 1: 641E (in series 

prior to ESP)

Module 2: 643E (in series 

prior to ESP)

 Latitude (decimal degrees, six decimal places) 33.991585 33.991342

 Longitude (decimal degrees, six decimal places) -83.771424 -83.771417

 Stack or vent height (units) 110 110

 Stack or vent diameter (units) 8 8

 Manufacturer and model GeoEnergy GeoEnergy

 Date of original installation 2000 2000

 Type (e.g., venturi, orifice) Venturi Venturi

 Gas flow rate to scrubber (acfm @ °F) 140,000 acfm @ 100 °F 140,000 acfm @ 100 °F

 Inlet gas temperature (°F) 68 - 138 °F 63 - 82 °F

 Outlet gas temperature (°F) 100 °F 100 °F

 Inlet grain loading (gr/dscf) 0.4 0.4

 Outlet grain loading (gr/dscf) 0.04 0.04

 Average stack opacity (%) < 40% < 40%

 Water flow rate to scrubber (gpm) 120 gpm 165 gpm

 Percent of scrubber water from recycled wastewater 0% 0%

 Source of scrubbing water and type of pretreatment. Substance(s) 

added as part of pretreatment and amount used (gpm or lbs/hr) City water City water

 HAP composition of wastewater (mg/L) Unknown Unknown

 Concentration (mg/L) of dissolved and suspended solids in 

scrubbing water 34 - 144 mg/l 34 - 144 mg/l

 Scrubbing water temperature (°F) 75 °F 75 °F

 Liquid/gas ratio (gal/103 acfm) 0.86 1.18

 Pressure drop across scrubber (in. H2O gauge) 6.5 6.5

 Amount of wastewater generated (gpd)

All water from Scrubber is 

recycled

All water from Scrubber is 

recycled

 Amount of wastewater recycled (gpd) 100% 100%

Line 106-Forming and Collection

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Amount of wastewater disposed of (gpd) None None

 Method of wastewater disposal N/A N/A

 Quantity of solid waste collected (lbs/yr) Not separately identified Not separately identified

 Quantity of solid waste recycled (lbs/yr) Not separately identified Not separately identified

 Quantity of solid waste disposed of (lbs/yr) Not separately identified Not separately identified

 Method of solid waste disposal Landfill Landfill

 Vendor guarantee on scrubber efficiency (attach copy) Not available Not available

 Nature and frequency of preventive maintenance procedures

Preventive maintenance 

checks performed once 

every quarter

Preventive maintenance 

checks performed once 

every quarter

 Problems experienced with control device within the last five years; 

how were problems solved? No major problems No major problems

 Continuous monitoring method(s) used to monitor scrubber 

performance, including parameters monitored

Pressure drop, water flow 

rate

Pressure drop, water flow 

rate

 Plans to replace or upgrade scrubber See CBI submittal See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM C-3

AIR POLLUTION CONTROL

III. Mechanical Collector

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

 Process line(s) (identification name/number) N/A

 Equipment/process(es) controlled. Include emission point 

designations (e.g., E3, E4 from plot plan)

 Latitude (decimal degrees, six decimal places)

 Longitude (decimal degrees, six decimal places)

 Stack or vent height (units)

 Stack or vent diameter (units)

 Manufacturer and model

 Date of original installation

 Type of mechanical collector 

 Gas flow rate to collector (acfm @ °F)

 Inlet gas temperature (°F)

 Outlet gas temperature (°F)

 Inlet grain loading (gr/dscf)

 Outlet grain loading (gr/dscf)

 Average stack opacity (%)

 Overall pressure drop (in. H2O gauge)

 Vendor guarantee on mechanical collector efficiency (attach 

copy)

 Quantity of solid waste collected (lbs/yr)

 Quantity of solid waste recycled (lbs/yr)

 Quantity of solid waste disposed of (lbs/yr)

 Method of solid waste disposal

 Nature and frequency of preventive maintenance procedures

 Problems experienced with control device within the last five 

years; how were problems solved?

 Continuous monitoring method(s) used to monitor performance, 

including parameters monitored

 Plans to replace or upgrade mechanical collector

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM C-4

AIR POLLUTION CONTROL

IV. Fabric Filter 

 For each Fabric Filter: Fabric Filter 1 Fabric Filter 2

 Process line(s) (identification name/number) Line 105 Line 106

 Equipment/process(es) controlled. Include emission 

point designations (e.g., E3, E4 from plot plan) Melter Dust Collector- 530

Melter Dust Collector 631E, 

632E via

631C, 632C

 Latitude (decimal degrees, six decimal places) 33.991162 33.990903

 Longitude (decimal degrees, six decimal places) -83.771822 -83.771684

 Stack or vent height (ft) 110 110

 Stack or vent diameter (ft) 3.5 4.5

 Manufacturer and model Dynamic Air 84A-64 Dynamic Air 84A-36

 Date of original installation 1977 2000

 Number of compartments 2 3

 Number of bags per compartment 320 150

 Filter material and coatings applied Polypropylene felt Polypropylene felt

 Fabric weight (oz/yd

2

) 16 16

 Filter surface area (ft2) 10,172 7,065

 Gas flow rate to filter (acfm @ °F) 32,800 acfm @ 68 °F 50,000 acfm @ 68 °F

 Inlet gas temperature (°F) 190 °F 190 °F

 Outlet gas temperature (°F) 68 °F 68 °F

 Inlet grain loading (gr/dscf) 0.5 0.5

 Outlet grain loading (gr/dscf) 0.005 0.005

 Average stack opacity (%) 0% 0%

 Overall pressure drop (in. H2O gauge) 0.5 0.5

 Method and frequency of bag cleaning Pulse-jet Pulse-jet

 Vendor guarantee on fabric filter efficiency (attach 

copy) None None

 Quantity of solid waste collected (lbs/yr) Not separately identified Not separately identified

 Quantity of solid waste recycled (lbs/yr) Not separately identified Not separately identified

 Quantity of solid waste disposed of (lbs/yr) Not separately identified Not separately identified

 Method of solid waste disposal Landfill Landfill

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Nature and frequency of preventive maintenance 

procedures

Ouside contractor inspects 

quarterly, bags replaced as 

needed.

Ouside contractor inspects 

quarterly, bags replaced as 

needed.

 Problems experienced with control device within the 

last five years; how were problems solved? No major problems No major problems

 Continuous monitoring method(s) used to monitor 

performance, including parameters monitored Prressure drop

Bag leak detection device, 

Pressure drop

 Plans to replace or upgrade fabric filter See CBI submittal See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM C-5

AIR POLLUTION CONTROL

V. Thermal Incinerator

 For each Thermal Incinerator: Thermal Incinerator 1

 Process line(s) (identification name/number) Line 106

 Equipment/process(es) controlled. Include emission 

point designations (e.g., E3, E4 from plot plan)

Curing Oven 654E via

654C

 Latitude (decimal degrees, six decimal places) 33.991970

 Longitude (decimal degrees, six decimal places) -83.771567

 Stack or vent height (ft) 110

 Stack or vent diameter (ft) 4

 Manufacturer and model GeoEnergy

 Date of original installation 2000

 Fuel type: gas or oil Gas

 Fuel consumption rate (BTU/hr) Not separately metered

 Inlet gas flow rate (acfm @ °F) 10,000 scfm

 Inlet gas temperature (°F) 350 F

 Combustion chamber gas temperature (°F) 1515

 Outlet gas temperature (°F) 350

 Inlet grain loading (gr/dscf) 2

 Outlet grain loading (gr/dscf) 0.04

 Average stack opacity (%) < 5%

 Excess air (%) 18%

 Residence time (sec) at temperature (°F) 1 @ 1515

 Percent heat recovery 0%

 Vendor guarantee on incinerator efficiency (attach 

copy) Not Available

 Nature and frequency of preventive maintenance 

procedures

PM on RTO every 1.5 - 2 yrs - 

shutdown, cool, and wash

 Problems experienced with control device within the 

last five years; how were problems solved? No major problems

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Continuous monitoring method(s) used to monitor 

incinerator performance, including parameters monitored

Temperature in combustion 

zone, Pressure drop

 Plans to replace or upgrade thermal incinerator See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM C-6

AIR POLLUTION CONTROL

VI. High Velocity Air Filter (HVAF) High efficiency air filter

 For each HVAF: HEAF 1

 Process line(s) (identification name/number) Line 105

 Equipment/process(es) controlled. Include emission 

point designations (e.g., E3, E4 from plot plan)

Curing Oven 554E via

554C

 Latitude (decimal degrees, six decimal places) 33.991853

 Longitude (decimal degrees, six decimal places) -83.77192

 Stack or vent height (ft) 110

 Stack or vent diameter (ft) 4

 Manufacturer and model Andersen 2000

 Date of original installation 1999

 Inlet gas flow rate (acfm @ °F) 33,250 acfm @ 120 °F

 Inlet gas temperature (°F) 120

 Outlet gas temperature (°F) 120

 Inlet grain loading (gr/dscf) 40

 Outlet grain loading (gr/dscf) 0.04

 Average stack opacity (%) 25%

 Water spray pressure (sdig), if applicable N/A

 Water spray rate (gpm), if applicable N/A

 Filter face velocity (acfm/ft2) Not Available

 Maximum pressure drop across mat (in. H2O gauge) 30

 Vendor guarantee on HVAF efficiency (attach copy) Not Available

 Method and frequency of filter mad advancement Not Available

 Amount of wastewater generated (gpd) None

 Amount of wastewater recycled (gpd) None

 Amount of wastewater disposed of (gpd) None

 Method of wastewater disposal None

 Quantity of solid waste collected (lbs/yr) Not Separately Identified

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Quantity of solid waste recycled (lbs/yr) Not Separately Identified

 Quantity of solid waste disposed of (lbs/yr) Not Separately Identified

 Method of solid waste disposal Landfill

 Nature and frequency of preventive maintenance 

procedures

Daily checks on fire cloth.

At oven cleanouts, all 

mechanical components are 

inspected and 

repaired/replaced as 

necessary.

 Problems experienced with control device within the 

last five years; how were problems solved? No problems encountered

 Continuous monitoring method(s) used to monitor 

HVAF performance, including parameters monitored Pressure drop

 Plans to replace or upgrade HVAF See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM C-7

AIR POLLUTION CONTROL

VII. Mist Eliminator

 For each Mist Eliminator: Mist Eliminator 1 Mist Eliminator 2

 Process line(s) (identification name/number) N/A

 Equipment/process(es) controlled. Include emission point 

designations (e.g., E3, E4 plot plan)

 Latitude (decimal degrees, six decimal places)

 Longitude (decimal degrees, six decimal places)

 Stack or vent height (units)

 Stack or vent diameter (units)

 Manufacturer and model

 Date of original installation

 Type of mist eliminator

 Gas flow rate to mist eliminator (acfm @ °F)

 Inlet gas temperature (°F)

 Outlet gas temperature (°F)

 Inlet grain loading (gr/dscf)

 Outlet grain loading (gr/dscf)

 Average stack opacity (%)

 Velocity in mist eliminator (ft/sec)

 Pressure drop (in. H2O gauge)

 For chevron blade mist eliminators:

 Spacing between blades (in.)

 Washing frequency of blades

 For mesh pad mist eliminators:

 Number of pads or elements

 Thickness of pad (in.) or element dimensions

 Density of pad, (lb/ft3)

 Washing frequency of pad

 Vendor guarantee on mist eliminator efficiency (attach copy)

 Amount of wastewater generated (gpd)

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Amount of wastewater recycled (gpd)

 Amount of wastewater disposed of (gpd)

 Method of wastewater disposal

 Quantity of solid waste collected (lbs/yr)

 Quantity of solid waste recycled (lbs/yr)

 Quantity of solid waste disposed of (lbs/yr)

 Method of solid waste disposal

 Nature and frequency of preventive maintenance procedures

 Problems experienced with control device within the last five 

years; how were problems solved?

 Continuous monitoring method(s) used to monitor mist eliminator 

performance, including parameters monitored

 Plans to replace or upgrade mist eliminator 

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM C-8

AIR POLLUTION CONTROL

VIII. Ventilation System 

 For each Ventilation System: Ventilation System 1

 Process line(s) (identification name/number)

 Equipment/process(es) controlled. Include emission point 

designations (e.g., E3, E4 from plot plan)

 Latitude (decimal degrees, six decimal places)

 Longitude (decimal degrees, six decimal places)

 Stack or vent height (units)

 Stack or vent diameter (units)

 For general or building ventilation:

 Ventilation system used

 Airflow control system used

 Number of air changes per hour

 For unit or local ventilation:

 Enclosure or hood design used

 Volume of enclosure or hood

 Capture velocity (ft/sec)

 Distance between hood and emission source (ft)

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM C-9

AIR POLLUTION CONTROL

IX. Other 

 For each Other Air Pollution Control Device (APCD): Other APCD 1 Other APCD 2 Other APCD 3

 Process line(s) (identification name/number)

 Equipment/process(es) controlled. Include emission point 

designations (e.g., E3, E4 from plot plan)

 Latitude (decimal degrees, six decimal places)

 Longitude (decimal degrees, six decimal places)

 Stack or vent height (units)

 Stack or vent diameter (units)

 Description

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM D

PROCESS LINE STARTUP AND SHUTDOWN NESHAP not applicable

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

five years, please provide the following information requested in A. 

through J. 

 A. Using the definitions provided above, indicate whether the 

event was a startup or shutdown; No excess emission events during periods of startup and shutdown.

 B. A description of the event, including identification of the 

emissions source or sources associated with the startup or 

shutdown;

N/A

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

permit condition was exceeded; N/A

 D. Whether the event was covered by any contingency plan for 

controlling emissions during startup and shutdown events and, if so, 

whether the plan was followed; if the plan was not followed, why not;

N/A

 E. The duration of the event; N/A

 F. The actions taken to minimize emissions during the event, 

including the use of any backup control systems; N/A

 G. Estimates or measurements, if any, of emissions during the 

event; if you did not have the ability to quantify emissions during the 

event, please explain why;

N/A

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

startup and shutdown than during normal operating conditions and, if 

so, how emissions were different and why; please provide any

supporting information;

N/A

 I. All performance test data collected during each period of SS; 

the test method used for each event; when the testing was 

conducted and why; the test conditions at the time of testing; and 

whether the tests were associated with a routine startup or shutdown; 

and

No data available

 J. All monitoring data, including control system parameter 

monitoring, collected during each period of SS. All required Title V monitoring data would be collected.

Startup: the setting in operation of an affected source or portion of an affected source for any purpose.

Shutdown: the cessation of operation of an affected source or portion of an affected source for any purpose.

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
If this information is contained in periodic and immediate SS reports 

(either stand-alone or contained within the periodic excess emissions 

report) submitted to your permitting authority, you may submit copies 

of those reports instead.

2. Are there any types of startup or shutdown events that you have 

been able to eliminate? If so, please describe the type of event and 

explain how these events were eliminated.

N/A

3. Please submit a copy of your SS plan if you are required to 

develop one. No plan required

4. Please provide all performance test data collected during periods 

of SS over the last 5 years. Indicate the test method used for each 

event.

No data available

5. Please provide all monitoring data, including control system 

parameter monitoring, collected during periods of SS over the last 5 

years. 

N/A

6. Optional: Do you wish to recommend a standard that would apply

during startup or shutdown? If so, please describe the event to 

which the standard would apply; the recommended standard (this 

could be an emission limitation, work practice, or operational 

standard) that would apply during the period; the basis for the 

recommended standard; why and how the standard would minimize 

emissions during the event; and how would compliance be 

determined and/or monitored. 

No

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM E

PRESENCE OF AIR POLLUTANTS IN EMISSION POINTSa

Please provide any existing emissions information and data 

covering hazardous air pollutants (HAP) and particulate matter 

(PM) for each listed process. Identify the appropriate box for 

which you are providing specific process information and/or 

pollutant emissions data.

Melting Furnace Forming Curing

Particulate Matter (PM, PM 2.5, PM Condensable) 

Chromium Compounds and Hexavalent Chromium (including 

any Cr speciation data)

Other metal HAP (As, Be, Cd, Co, Hg, Mn, Ni, Pb, Sb, Se)

Hydrogen Fluoride (HF)

Hydrogen Chloride (HCl)

Formaldehyde

Phenol

Methanol

Other organic HAP

The existing data requested here has been provided to EPA by the industry’s trade association, the Nor

Insulation Manufacturers Association (“NAIMA”). The existing data provided by NAIMA was set forth in 

2010 letter to EPA. The representative existing emissions data provided from fiber glass companies in

for the following pollutants: formaldehyde, methanol, phenol, particulate matter, hydrogen fluoride, meta

arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel, and selenium), mercury, and 

chromium. The representative existing emissions data provided from mineral wool companies included 

the following pollutants: formaldehyde, methanol, phenol, particulate matter, carbon monoxide, carbony

hydrogen fluoride, metals (antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, 

selenium), mercury, and hexavalent chromium. The scope of the existing data provided was the result 

reached by EPA, NAIMA, and industry representatives. In addition to the existing data submitted to EP

emissions data is being collected from virtually all companies through the “BTEC, Inc.

Quality Assurance Project Plan for the Mineral Wool and Wool Fiberglass Emissions Test Program.”

This Test Program will collect and submit to EPA, through EPA’s Electronic Reporting Tool, 

representative emissions data for the following pollutants: formaldehyde, methanol, 

phenol, particulate matter, carbon monoxide, carbonyl sulfide, hydrogen fluoride, 

metals (antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, 

nickel, and selenium), mercury, and hexavalent chromium.

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM E

PRESENCE OF AIR POLLUTANTS IN EMISSION POINTSa

Please provide any existing emissions information and data 

covering hazardous air pollutants (HAP) and particulate matter 

(PM) for each listed process. Identify the appropriate box for 

which you are providing specific process information and/or 

pollutant emissions data.

Particulate Matter (PM, PM 2.5, PM Condensable) 

Chromium Compounds and Hexavalent Chromium (including 

any Cr speciation data)

Other metal HAP (As, Be, Cd, Co, Hg, Mn, Ni, Pb, Sb, Se)

Hydrogen Fluoride (HF)

Hydrogen Chloride (HCl)

Formaldehyde

Phenol

Methanol

Other organic HAP

Cooling

The existing data requested here has been provided to EPA by the industry’s trade association, the North American 

Insulation Manufacturers Association (“NAIMA”). The existing data provided by NAIMA was set forth in NAIMA’s May 5, 

2010 letter to EPA. The representative existing emissions data provided from fiber glass companies included test results 

for the following pollutants: formaldehyde, methanol, phenol, particulate matter, hydrogen fluoride, metals (antimony, 

arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel, and selenium), mercury, and hexavalent 

chromium. The representative existing emissions data provided from mineral wool companies included test results for 

the following pollutants: formaldehyde, methanol, phenol, particulate matter, carbon monoxide, carbonyl sulfide, 

hydrogen fluoride, metals (antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel, and 

selenium), mercury, and hexavalent chromium. The scope of the existing data provided was the result of consensus 

reached by EPA, NAIMA, and industry representatives. In addition to the existing data submitted to EPA, extensive new 

emissions data is being collected from virtually all companies through the “BTEC, Inc.

Quality Assurance Project Plan for the Mineral Wool and Wool Fiberglass Emissions Test Program.”

This Test Program will collect and submit to EPA, through EPA’s Electronic Reporting Tool, 

representative emissions data for the following pollutants: formaldehyde, methanol, 

phenol, particulate matter, carbon monoxide, carbonyl sulfide, hydrogen fluoride, 

metals (antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, 

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM F-1 

COST

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

 For each Process Unit: Process Unit 1 Process Unit 2 Process Unit 3

 Process Unit ID All Units

 Process Line ID

II. Capital Costs

 Base year

JM objects to this request 

in its entirety because it 

seeks information that is 

not relevant to the EPA 

Administrator’s review 

obligations pursuant to 

Clean Air Act Section 

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

 Total capital cost, including costs for individual pieces, if available. See Above 

III. Annual Operating Costs

 Base year (most recent fiscal year) See Above 

 Total annual operating costs See Above 

 Maintenance materials and replacement parts (specify costs by item)

 See Above 

 Raw materials costs See Above 

 Labor

 ($/yr) for each labor class See Above 

 (hr/hr) for each labor class See Above 

 Utilities (breakdown for each utility) See Above 

 Waste treatment and/or disposal See Above 

 Costs associated with any work practices and pollution prevention 

techniques that are employed at your facility See Above 

 Savings associated with heat recovery and wastewater and/or solid waste 

returned to process from APCD (or sold to another user) See Above 

 Indirect costs See Above 

 Other (specify) See Above 

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
Please provide the annual report to shareholders or equivalent for the most 

recent fiscal year. If reports are not available, provide annual sales and 

profits (or profit margin) for the most recent fiscal year. If company is 

publicly owned, please provide a web link to this information.

N/A

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

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

your product(s) and substituted product(s).

Wool fiberglass is used 

as insulation, as are 

cellulose (scrap 

newspaper) treated to 

resist fires, spray foam, 

foam boards, cotton 

treated to resist fires, and 

sheep wool treated to 

resist fires. Wool 

fiberglass insulation is 

preferred over these 

alternative insulation 

materials because it is 

easily, economically, and 

safety installed in various 

building settings, has 

superior fire performance 

capabilities, and a 70-

year history of proven 

performance and 

durability.

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
FORM F-2

COST

I. Air Pollution Control Device (APCD) See form F-1

 For each APCD: APCD 1

 APCD ID

 Process Unit ID

II. Capital Costs

 Base year 

JM objects to this 

request in its entirety

because it seeks 

information that is not 

relevant to the EPA 

Administrator’s review 

obligations pursuant 

to Clean Air Act 

Section 112(d)(6) and 

112(f)(2).

 APCD equipment purchase cost and what was included See Above 

 List the cost for each piece of auxiliary equipment for each APCD 

not included above See Above 

 Installation cost See Above 

 Land purchase cost See Above 

 Total capital cost See Above 

 Method of financining APCD See Above 

 Retrofit installation See Above 

 Field erected or modular See Above 

III. Annual Operating Costs

 Base year (most recent fiscal year) See Above 

 Maintenance materials and replacement parts (specify costs by

item) See Above 

 Raw materials costs See Above 

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls
 Labor

 ($/yr) for each labor class See Above 

 (hr/hr) for each labor class See Above 

 Utilites (breackdown for each utility) See Above 

 Waste treatment and/or disposal See Above 

 Indirect costs See Above 

 Other (specify) See Above 

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

Attach annual report to shareholders or equivalent for the most 

recent fiscal year. Alternatively, if company is publicly owned, you 

can provide your company's web link to this information. See Above 

EPA-HQ-OAR-2010-1042-DRAFT-0004.xls