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-0007.xls
FORM A-2

FACILITY INFORMATION

II. Facility Information

 Facility Name Johns Manville Richmond Plant

 Facility Address

 Street 814 Richmond Ave.

 City Richmond

 State Indiana

 Zip Code 47374

 County Wayne

 Facility Coordinates

 Latitude (decimal degrees, six decimal places) 39.834342

 Longitude (decimal degrees, six decimal places) -84.91624

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

of property, etc.) Office Door-Main Building

 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)

Indiana Department of Environmental Management Part 70 Air 

Operating Permit. (177-22598-00006) See attachment A

III. Technical Contact

 Name Dan Stevens

 Technical Contact Title HSE Manager

 Telephone 765-973-5243

 Facsimile (Fax) 765-973-5371

 Email Dan.Stevens@jm.com

EPA-HQ-OAR-2010-1042-DRAFT-0007.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. NA

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

List unit operations, e.g., boiler, and pollutant/emissions. No

EPA-HQ-OAR-2010-1042-DRAFT-0007.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 Process Line 2- 7602 Process Line 3 - 7603

 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)

Installed in 1961, 

modified in 2000 & 

2006

Installed in 1961, 

modified in 2000 & 

2006

 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 Attachment B See Attachment B

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM B-2

PLANT OPERATIONS

II. Process - Raw materials Handling and Storage

 Molten glass preparation

 Raw materials and proportions by wt (%) % by Wt

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

See CBI Submittal

See CBI 

Submittal

See CBI Submittal

See CBI 

Submittal

See CBI Submittal

See CBI 

Submittal

See CBI Submittal

See CBI 

Submittal

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

Gravity feed to weigh/mix hopper, bucket elevator to 

conveyor belt. From conveyor belt into day bin to furnace

 Binder and Additives

 List each raw material, including premixed materials, in the 

binder formulation and its proportion by wt (%) NA

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

and holding time (hrs) No binder used

 Total yearly consumption of binder (gal/yr) 0

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

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

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
 Method of treating vent air from storage and mix tanks NA

 Emission control during liquid raw material transfer from vehicles 

to storage tanks. NA

 Describe future source reduction plans and schedules to 

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

($/gal) for reformulation NA

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM B-3

PLANT OPERATIONS

III. Process - Glass Melting Furnace

 For each Glass Melting Furnace: Furnace 1 Furnace 2 Furnace 3

 Process unit identification name/number Electric Melter

 Process line(s) served (identification name/number) 7602 and 7603

 Latitude (decimal degrees, six decimal places) 39.835002

 Longitude (decimal degrees, six decimal places) -84.945713

 Stack or vent height (units) 50.8 feet

 Stack or vent diameter (units) 2 feet

 Manufacturer and model Sorg 

 Date of original installation 2006

 Estimate of remaining lifetime (yrs)

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.

 Frequency of a major rebuild N/A

 Cost of typical major rebuild N/A

 Date of last major rebuild N/A

 Purpose of last major rebuild N/A

 Increase or decrease in emissions N/A

 Fuel type: electric, gas, or oil Electric

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

glass) See CBI Submittal

 List HAPs that are in refractory material

Chromium 

Compounds

 Design production rate (tons/day) See CBI Submittal

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

 Vent gas flow rate (acfm @ °F) 8476

 Temperature (°F) of molten glass in furnace and 

forehearth (if applicable) See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
 Nature and frequency of routine/preventive maintenance 

procedures See CBI Submittal

 Describe process modification(s) since 1999 that reduce 

emissions

Installation of electric 

melter (replaced 

natural gas melters)

 Describe future source reduction plans and schedules No current plans

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM B-4

PLANT OPERATIONS

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

 For each Forming Operation -- Rotary Spin/Flame Attenuation Forming Operation 1 Forming Operation 2 Forming Operation 3

 Process unit identification name/number

Line 2 Forming and 

Collection Module

Line 3 Forming and 

Collection Module

 Process line(s) served (identification name/number) 7602 7603

 Latitude (decimal degrees, six decimal places) 39.835025 39.834934

 Longitude (decimal degrees, six decimal places) -84.915447 -84.915456

 Stack or vent height (units) 196.8 feet 180.8 feet

 Stack or vent diameter (units) 9 feet 8 feet

 Number of fiber forming devices (spinners) per line. See CBI Submittal See CBI Submittal

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

Indicate type of burner used (if flame). Air Air

 Is there a forehearth between the furnace and the forming 

section? Yes Yes

 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

 If modular, number of modules and plenums Not modular Not modular

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

 Binder applied and application rate (gpm) None None

 Other material applied and application rate (gpm) See CBI Submittal See CBI Submittal

 Temperature of glass fiber when binder is applied (°F) No binder No binder

 Temperature of binder when applied to fibers (°F) No binder No binder

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

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

 Forming air flow rate (acfm @ °F) 131000 112000

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

 Nature and frequency of routine/preventive maintenance 

procedures See CBI Submittal See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
 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-0007.xls
FORM B-5

PLANT OPERATIONS

V. Process - Curing No curing ovens

 For each Curing Oven: Curing Oven 1 Curing Oven 2 Curing Oven 3

 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 (units)

 Stack or vent diameter (units)

 Method of curing 

 Manufacturer and model

 Date of original installation

 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

 Fuel type: electric, gas, or oil 

 Fuel consumption rate (KW/hr or BTU/hr)

 Moisture content wt (%) of formed mat: 

 inlet

 outlet

 Air flow rate (acfm @ °F) from curing

 Exhaust air temperature (°F)

 Residence time of product (mins)

 Binder content of cured product (LOI)

 Nature and frequency of routine/preventive 

maintenance procedures

 Describe process modification(s) since 1999 that 

reduce emissions

 Describe future source reduction plans and 

schedules

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM B-6

PLANT OPERATIONS

VI. Process - Cooling No Cooling

 For each Cooling Operation: Cooling Operation 1 Cooling Operation 2 Cooling Operation 3

 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 (units)

 Stack or vent diameter (units)

 Cooling air flow rate (acfm @ °F) 

 Percentage of cooling air recirculated (if any)

 Cooling air temperature (°F)

 Nature and frequency of routine/preventive 

maintenance procedures

 Describe process modification(s) since 1999 that 

reduce emissions

 Describe future source reduction plans and schedules

EPA-HQ-OAR-2010-1042-DRAFT-0007.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 collection. None

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

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

usage/storage? NA

EPA-HQ-OAR-2010-1042-DRAFT-0007.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 as follows: optimize process water flow rate in 

forming and collection chambers on both process lines.

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM C-1

AIR POLLUTION CONTROL

I. Electrostatic Precipitator (ESP) No ESP

 For each ESP: ESP 1 ESP 2 ESP 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)

 Manufacturer and model

 Date of original installation

 Number of collection plates and configuration

 Gas flow rate to ESP (acfm @ °F)

 Inlet gas temperature (°F)

 Outlet gas temperature (°F)

 Inlet grain loading (gr/dscf)

 Outlet grain loading (gr/dscf)

 Average stack opacity (%)

 Pressure drop across ESP (in. H

2O gauge)

 Plate area (ft

2

)

 Vendor guarantee on ESP efficency (attach copy)

 Method of plate cleaning and frequency

 Flow rate of plate washwater to ESP (gpm), if applicable

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

 Source of plate washwater used for cleaning, if applicable

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

washwater, if applicable

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

applicable

 Amount of wastewater generated (gpd), if applicable

 Amount of wastewater recycled (gpd), if applicable

 Amount of wastewater disposed of (gpd), if applicable

 Method of wastewater disposal, if applicalbe

 Quantity of solid waste collected (lbs/yr)

 Quantitiy of solid waste recycled (lbs/yr)

 Quantity of solid waste disposed of (lbs/yr)

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
 Method of solid waste disposal

 Nature and frequency of routine/preventive maintenance 

procedures

 Problems experienced with control device within the last five 

years; how were problems solved?

 Continuous monitoring method(s) used to monitor ESP 

performance, including parameters monitored

 Describe any plans to replace or upgrade ESP

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM C-2

AIR POLLUTION CONTROL

II. Scrubber

Water spray used (not a 

scrubber)

 For each Scrubber: Scrubber 1 Scrubber 2 Scrubber 3

 Process line(s) (identification name/number)

Line 2 Forming and 

Collection Module

Line 3 Forming and 

Collection Module

 Equipment/process(es) controlled. Include emission point 

designations (e.g., E3, E4 from plot plan) 7602 7603

 Latitude (decimal degrees, six decimal places) 39.835025 39.834934

 Longitude (decimal degrees, six decimal places) -84.915447 -84.915456

 Stack or vent height (units) 196.8 feet 180.8 feet

 Stack or vent diameter (units) 9 feet 8 feet

 Manufacturer and model JM Proprietary JM Proprietary

 Date of original installation Unknown Unknown

 Type (e.g., venturi, orifice) Water spray Water spray

 Gas flow rate to scrubber (acfm @ °F) 131000 112000

 Inlet gas temperature (°F) 200 200

 Outlet gas temperature (°F) 110 162

 Inlet grain loading (gr/dscf) Unknown Unknown

 Outlet grain loading (gr/dscf) 0.0292 0.0171

 Average stack opacity (%) 5% 5%

 Water flow rate to scrubber (gpm) 450 450

 Percent of scrubber water from recycled wastewater 95% 95%

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

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

 HAP composition of wastewater (mg/L) 0 0

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

scrubbing water

Dissolved Solids 10,221 

ppm. 

Suspended Solids 256 

ppm.

Dissolved Solids 10,221 

ppm. 

Suspended Solids 256 

ppm.

 Scrubbing water temperature (°F) 80 80

 Liquid/gas ratio (gal/103 acfm) 3.44 4.02

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
 Pressure drop across scrubber (in. H2O gauge) NA NA

 Amount of wastewater generated (gpd) 0 0

 Amount of wastewater recycled (gpd) 0 0

 Amount of wastewater disposed of (gpd) 0 0

 Method of wastewater disposal 0 0

 Quantity of solid waste collected (lbs/yr) 854131.32 1518455.68

 Quantity of solid waste recycled (lbs/yr) 0 0

 Quantity of solid waste disposed of (lbs/yr) 854131.32 1518455.68

 Method of solid waste disposal Landfill Landfill

 Vendor guarantee on scrubber efficiency (attach copy) NA NA

 Nature and frequency of preventive maintenance procedures As needed As needed

 Problems experienced with control device within the last five years; 

how were problems solved? No No

 Continuous monitoring method(s) used to monitor scrubber 

performance, including parameters monitored Water flow Water flow

 Plans to replace or upgrade scrubber No No

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM C-3

AIR POLLUTION CONTROL

III. Mechanical Collector No mechanical collector

 For each Mechanical Collector: Mechanical Collector 1 Mechanical Collector 2 Mechanical Collector 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)

 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

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
 Plans to replace or upgrade mechanical collector

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM C-4

AIR POLLUTION CONTROL

IV. Fabric Filter 

 For each Fabric Filter: Fabric Filter 1

 Process line(s) (identification name/number) Electric Melter Baghouse

 Equipment/process(es) controlled. Include emission 

point designations (e.g., E3, E4 from plot plan) Electric melter, S166

 Latitude (decimal degrees, six decimal places) 39.835002

 Longitude (decimal degrees, six decimal places) -84.945713

 Stack or vent height (units) 50.8 feet

 Stack or vent diameter (units) 2.0 feet

 Manufacturer and model Luhr Filter

 Date of original installation 6/1/2007

 Number of compartments 4

 Number of bags per compartment 96

 Filter material and coatings applied Fabric

 Fabric weight (oz/yd

2

) 10.32

 Filter surface area (ft2) 3186

 Gas flow rate to filter (acfm @ °F) 5513

 Inlet gas temperature (°F) 185.3

 Outlet gas temperature (°F) 185.3

 Inlet grain loading (gr/dscf) Unknown

 Outlet grain loading (gr/dscf) 0.00612

 Average stack opacity (%) 1.52

 Overall pressure drop (in. H2O gauge) 2-4"

 Method and frequency of bag cleaning Jet Pulse/Continuous

 Vendor guarantee on fabric filter efficiency (attach 

copy) No

 Quantity of solid waste collected (lbs/yr) 182,500

 Quantity of solid waste recycled (lbs/yr) 182,500

 Quantity of solid waste disposed of (lbs/yr) 0

 Method of solid waste disposal 0

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
 Nature and frequency of preventive maintenance 

procedures

Semi-annual inlet feed pipe 

inspection and cleaning. 

Bag replacment 4 to 5 years.

 Problems experienced with control device within the 

last five years; how were problems solved? None

 Continuous monitoring method(s) used to monitor 

performance, including parameters monitored Delta P

 Plans to replace or upgrade fabric filter See CBI Submittal

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM C-5

AIR POLLUTION CONTROL

V. Thermal Incinerator No thermal incinerator

 For each Thermal Incinerator: Thermal Incinerator 1 Thermal Incinerator 2 Thermal Incinerator 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)

 Manufacturer and model

 Date of original installation

 Fuel type: gas or oil

 Fuel consumption rate (BTU/hr)

 Inlet gas flow rate (acfm @ °F)

 Inlet gas temperature (°F)

 Combustion chamber gas temperature (°F)

 Outlet gas temperature (°F)

 Inlet grain loading (gr/dscf)

 Outlet grain loading (gr/dscf)

 Average stack opacity (%)

 Excess air (%)

 Residence time (sec) at temperature (°F)

 Percent heat recovery

 Vendor guarantee on incinerator efficiency (attach 

copy)

 Nature and frequency of preventive maintenance 

procedures

 Problems experienced with control device within the 

last five years; how were problems solved?

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
 Continuous monitoring method(s) used to monitor 

incinerator performance, including parameters monitored

 Plans to replace or upgrade thermal incinerator

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM C-6

AIR POLLUTION CONTROL

VI. High Velocity Air Filter (HVAF) No HVAF

 For each HVAF: HVAF 1 HVAF 2 HVAF 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)

 Manufacturer and model

 Date of original installation

 Inlet gas flow rate (acfm @ °F)

 Inlet gas temperature (°F)

 Outlet gas temperature (°F)

 Inlet grain loading (gr/dscf)

 Outlet grain loading (gr/dscf)

 Average stack opacity (%)

 Water spray pressure (sdig), if applicable

 Water spray rate (gpm), if applicable

 Filter face velocity (acfm/ft2)

 Maximum pressure drop across mat (in. H2O gauge)

 Vendor guarantee on HVAF efficiency (attach copy)

 Method and frequency of filter mad advancement

 Amount of wastewater generated (gpd)

 Amount of wastewater recycled (gpd)

 Amount of wastewater disposed of (gpd)

 Method of wastewater disposal

 Quantity of solid waste collected (lbs/yr)

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
 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 

HVAF performance, including parameters monitored

 Plans to replace or upgrade HVAF

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM C-7

AIR POLLUTION CONTROL

VII. Mist Eliminator

 For each Mist Eliminator: Mist Eliminator 1 Mist Eliminator 2 Mist Eliminator 3

 Process line(s) (identification name/number) 7602

 Equipment/process(es) controlled. Include emission point 

designations (e.g., E3, E4 plot plan) Line 2 Forming & Collection

 Latitude (decimal degrees, six decimal places) 39.835025

 Longitude (decimal degrees, six decimal places) -84.915447

 Stack or vent height (units) 196.8 feet

 Stack or vent diameter (units) 9 feet

 Manufacturer and model JM Proprietary

 Date of original installation 2009

 Type of mist eliminator Chevron

 Gas flow rate to mist eliminator (acfm @ °F) 131000

 Inlet gas temperature (°F) 200

 Outlet gas temperature (°F) 110

 Inlet grain loading (gr/dscf) Unknown

 Outlet grain loading (gr/dscf) 0.039

 Average stack opacity (%) 5%

 Velocity in mist eliminator (ft/sec) Unknown

 Pressure drop (in. H2O gauge) 2-4

 For chevron blade mist eliminators:

 Spacing between blades (in.) 4

 Washing frequency of blades 60 days

 For mesh pad mist eliminators: NA

 Number of pads or elements NA

 Thickness of pad (in.) or element dimensions NA

 Density of pad, (lb/ft3) NA

 Washing frequency of pad NA

 Vendor guarantee on mist eliminator efficiency (attach copy) None

 Amount of wastewater generated (gpd) NA

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
 Amount of wastewater recycled (gpd) NA

 Amount of wastewater disposed of (gpd) NA

 Method of wastewater disposal NA

 Quantity of solid waste collected (lbs/yr) NA

 Quantity of solid waste recycled (lbs/yr) NA

 Quantity of solid waste disposed of (lbs/yr) NA

 Method of solid waste disposal NA

 Nature and frequency of preventive maintenance procedures As needed

 Problems experienced with control device within the last five 

years; how were problems solved? No

 Continuous monitoring method(s) used to monitor mist eliminator 

performance, including parameters monitored NA

 Plans to replace or upgrade mist eliminator See CBI submittal

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM C-8

AIR POLLUTION CONTROL

VIII. Ventilation System 

 For each Ventilation System: Ventilation System 1 Ventilation System 2 Ventilation System 3

 Process line(s) (identification name/number)

 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-0007.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-0007.xls
FORM D

PROCESS LINE STARTUP AND SHUTDOWN

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

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

through J. 

 A. Using the definitions provided above, indicate whether the 

event was a startup or shutdown; Startup in 2007

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

emissions source or sources associated with the startup or 

shutdown; Startup of the new electric melter and process lines 2 & 3

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

permit condition was exceeded; NA

 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; NA

 E. The duration of the event; NA

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

including the use of any backup control systems; NA

 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; NA

 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; NA

 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 NA

 J. All monitoring data, including control system parameter 

monitoring, collected during each period of SS. NA

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-0007.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. NA

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

develop one. NA

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. NA

5. Please provide all monitoring data, including control system 

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

years. NA

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. 

EPA-HQ-OAR-2010-1042-DRAFT-0007.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 Forming Curing Cooling

Particulate Matter (PM, PM 2.5, PM Condensable) NA NA NA NA

Chromium Compounds and Hexavalent Chromium 

(including any Cr speciation data) NA NA NA NA

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

Hydrogen Fluoride (HF) NA NA NA NA

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, 

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

Hydrogen Chloride (HCl) NA NA NA NA

Formaldehyde NA NA NA NA

Phenol NA NA NA NA

Methanol NA NA NA NA

Other organic HAP NA NA NA NA

EPA-HQ-OAR-2010-1042-DRAFT-0007.xls
FORM F-1 

COST

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

 For each Process Unit: Process Unit 1

 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-0007.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. See Above 

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

N/A

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

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

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-0007.xls
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-0007.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-0007.xls