From: gthomas@bp.Guardian.com

To: Susan Fairchild/RTP/USEPA/US@EPA

Date: 03/02/2012 07:10 PM Subject: Guardian Inwood Preliminary Test Results

Susan, as you requested, I am forwarding the preliminary test results of the final deliverables you requested for the Inwood furnace stack. See the pdf files attached to the email below. The QAQC is completed and so I do not expect any changes in test re sults, as there were none with the Kingman test results in the final report we received today.

As the test contractor commented below, the Inwood test results were very good and that is not totally surprising as the filter media in this baghouse is unique . As you recall, we requested to install PTFE filters in the Inwood baghouse and it looks like this media does drive down emissions somewhat when compared to the other furnaces we have tested.

Though you did not require us to conduct a Method 5/202 PM de termination, these test methods were referenced in the proposed rule and we wanted to determine if a baghouse with PTFE filter media would meet the 0.014 lb/ton proposed standard. We did not pay the test company to expedite the 202 results but expect to have the 202 results by next Friday, March 9th. I will forward the results to you as soon as they arrive.

The PM filterable Method 5 and Method 29 are attached below and both test methods resulted in exactly the same results of 0.008 lb/ton, which is bel ow the 0.014 lb/ton proposed standard and also

lower than the other four (4) furnaces that were tested at Guardian. Though we are elated at the lower emissions with PTFE filter media, it remains to be seen if we can still meet the proposed standard after adding in the backhalf 202

condensible PM emissions. We will find out a week from now.

You indicated the MACT floor for PM may be relaxed due to some issues with the original data set. Nonetheless, it is our understanding the MACT floor was based on fil terable emissions only and did not include condensible PM emissions. If this is the approach to calculate the MACT floor, the proposed PM Method should be Method 5 and/or Method 29, not a combination of Method 5 and Method 202. If Method 5/202 is going to be the proposed PM method in the final rule, than the MACT floor needs to be based on Method 5/202 data.

The Method 0061 chrome results for the Inwood furnace were slightly lower compared to the Method 29 chrome results but the same order of magnitude.

The Method 29 chrome results for Inwood were also slightly lower compared to the Method 29 chrome results for the other four furnaces already tested (Albion, Inwood, Kingman & Winnsboro) but the same order of magnitude, but probably slightly lower due to using the PTFE filter media.Unlike Kingman, the magnitude of the vaporous back half chrome emissions were about the same order of magnitude as front half filterable emissions. You may recall in Kingman, the filterable front half represented over 80%

of the chrome. Obviously, the Inwood PTFE filter media is removing

more filterable chrome and so you would expect the filterable front half and vaporous back half to be more closely the same.

Not surprisingly, the hexavalent chrome emissions continue to b e very low, about half the magnitude of the total chrome emissions and the same order of magnitude of the furnaces already tested (Albion, Inwood, Kingman & Winnsboro).

We also tested HF and HCL and these emissions were the among the lowest emissions we h ave seen compared to the other furnaces tested in Albion, Inwood, Kingman and Winnsboro and below the proposed standard. We wish all of our plants were this low but we believe these emissions are more of function of the purchased

cullet and it would be u nfortunate that the HF and HCl standard is not relaxed to continue to encourage recycling of cullet and in so doing, promote energy savings and reduction of greenhouse gases.

We are elated at the emission results for Inwood and that all of our furnace res ults are fairly consistent. In sum, the emissions for the five (5) Guardian furnaces are very low in about every category and the PTFE media results in slightly lower emissions but about the same order of magnitude.

As mentioned above, we received the fi nal Kingman furnace test report today. Next week, I will email the electronic pdf version of this report and also mail you a CD of the report in the abundance of

caution.

Our test company is still working on the report in the ERT format and I will forwa rd the ERT's to you when they arrive.

As we discussed, after we receive the final Inwood test report, which hopefully should be next week, I will complete populating Form C of the

114 survey request for each of the plants and forward this information to y ou.

Let me know if you have any questions.

Kind regards,

Grover Thomas

----- Forwarded by Grover Thomas/BP/Guardian_Industries on 03/02/2012

03:34PM

----- "Tony Blanton" <tony@integrityair.net>

To : < GroverThomas@bp.guardian.com > 03/02/2012 02:55 PM

cc "Jim Lewis" < jim@integrityair.net > Subject : Inwood ResultsPlease respond to "Tony Blanton" <tony@integrityair.net>

Grover,

Please find attached the summary of results for the Inwood sampling. I should have the condensable portion of the 202 by Friday the 9th. I provided the filterable results so that you could compare Method

29 to 5 /202.

Overall, the results look very good.

Thank you

Tony(See attached file: 26A.pdf)(See attached file: 29.pdf)(See attached file: 0061.pdf)(See attached file: 5202.pdf) [attachment "26A.pdf" deleted by Susan

Fairchil d/RTP/USEPA/US] [attachment "29.pdf" deleted by Susan Fairchild/RTP/USEPA/US] [attachment "0061.pdf" deleted by Susan Fairchild/RTP/USEPA/US] [attachment "5202.pdf" deleted by Susan Fairchild/RTP/USEPA/US]