

TECHNICAL MEMORANDUM

TO:	Mary Johnson, U.S. EPA/OAQPS/SPPD  -  Energy Strategies Group

FROM:	Eastern Research Group, Inc.

DATE:	September 2017
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SUBJECT:	Wet-formed Fiberglass: Residual Risk Modeling File Documentation
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 Introduction

The U.S. Environmental Protection Agency (EPA), under section 112 of the Clean Air Act (CAA), promulgated maximum achievable control technology (MACT) standards under a national emission standard for hazardous air pollutants (NESHAP) for the Wet-formed Fiberglass Mat Production source category on April 11, 2002 (40 CFR subpart 63, subpart HHHH). Under section 112(f)(2) of the CAA, the EPA must conduct risk assessments on each source category subject to MACT standards and determine if additional standards are needed to reduce residual risks. 

This memorandum describes the background and methodology used to develop the risk modeling file for the Wet-formed Fiberglass Mat Production source category, including the identification of facilities and emission sources and the development of emission estimates. This memorandum is organized as follows:

      1.0	Introduction
      2.0	Wet-Formed Fiberglass Mat Production Process
      3.0 	Wet-Formed Fiberglass Mat Production NESHAP
      4.0	Residual Risk Modeling File Background 
      5.0	Facility Identification
      6.0	Facility Configuration
      7.0	Facility Emission Release Points
      8.0	Estimation of Emissions
      Appendix A - Summary of Facility Stack Parameters
      Appendix B - Emissions by Release Point
      Appendix C - Detailed Basis of Actual Emissions Estimates
      Appendix D - Detailed Basis of Allowable Emissions Estimates
      Appendix E - Detailed Basis of Acute Emissions Estimates 
 Wet-Formed Fiberglass Mat Production Process

Wet-formed fiberglass mat is used as a substrate for multiple roofing products, as reinforcement for various plastic, cement and gypsum products, and in miscellaneous specialty products. The fiberglass mat is made of glass fibers that have been bonded with a formaldehyde-based resin. In a typical wet-formed fiberglass mat production line, glass fibers are mixed with water and emulsifiers in large mixing vats to form a slurry of fibers and water. The glass fiber slurry is then pumped to a mat forming machine, where it is dispensed in a uniform curtain over a moving screen belt. The mat is then carried beneath a binder saturator, where binder solution is uniformly applied onto the surface of the mat. This resin-binder application process includes the screen passing over a vacuum which draws away the excess binder solution for recycling. The mat of fibers and binder then passes into drying and curing ovens that use heated air to carry away excess moisture and harden (i.e., cure) the binder. Upon exiting the ovens, the mat is cooled, trimmed, wound, and packaged to product specifications. The primary hazardous air pollutant (HAP) emission source in the wet-formed fiberglass mat production source category is the drying and curing oven exhaust, and the primary HAP emitted during production of wet-formed fiberglass mat are formaldehyde and methanol.
 Wet-Formed Fiberglass Mat Production NESHAP

The Wet-Formed Fiberglass Mat Production source category was added to the list of categories of major sources of HAP published under section 112(c) of the CAA in a single action that concurrently promulgated the NESHAP (see 67 FR 17824, April 11, 2002). The NESHAP is applicable to any drying and curing oven at a wet-formed fiberglass mat production facility that has been a major source of HAP emissions after the compliance date of the rule or that has been located at, or part of, a source that has been a major source of HAP emissions after the compliance date. The NESHAP regulates emissions of HAP through emission standards for formaldehyde, which is also used as a surrogate for total HAP emissions. Facilities subject to the NESHAP must demonstrate that each drying and curing oven either meets a percentage reduction requirement (minimum of 96% destruction efficiency of formaldehyde) or meets an emission limit for maximum formaldehyde emissions of 0.03 kg/Mg of wet-formed fiberglass mat produced (0.05 lb/ton of wet-formed fiberglass mat produced). Facilities subject to the NESHAP generally control their drying and curing oven exhausts with thermal oxidizers or similar controls (e.g., regenerative thermal oxidizer (RTO), regenerative catalytic oxidizer (RCO)) and demonstrate compliance with the percent reduction requirement. 
 Residual Risk Modeling File Background

For a residual risk review, section 112(f)(2) of the CAA requires the EPA to assess the health and environmental risks that remain after sources achieve compliance with MACT standards. If additional risk reductions are necessary to protect public health with an ample margin of safety or to prevent adverse environmental effects, the EPA must develop standards to address these remaining risks. 

To perform the risk analyses required by section 112(f)(2) of the CAA, the EPA identifies affected sources and conducts inhalation and multipathway modeling using emissions information available for each known source. To support the modeling analysis, the EPA collects, reviews, and compiles the emissions information into a risk modeling file that contains the following information for each affected source: 

          Facility identification information: This information includes the facility name and associated identification numbers (e.g., EPA Emissions Inventory System ID), parent company or owner name, physical address and coordinates of the facility, facility operating status, and brief descriptions of the facility such as North American Industrial Classification System (NAICS) and Standard Industrial Classification (SIC) codes.
          Facility configuration information: This information consists of emission units and emission processes. For each emission unit, the risk modeling file contains a unit identification number, description, design capacity, applicable regulatory code, and operating status. Each emission process has an assigned identification number, description, and applicable standard classification code (SCC).
          Emission release point information: This information includes the emission release points assigned to each emission unit and emission process combination. Depending on the facility configuration, multiple emission release points may be assigned to a single emission process, or multiple emission processes may be assigned to a single emission release point. Each emission release point has an assigned type (i.e., stack or fugitive) and appropriate parameters (e.g., stack height, diameter, temperature, and velocity or flow rate), in addition to latitude and longitude coordinates. 
          Emissions by pollutant: Emissions by pollutant are assigned to each emission release point. Emissions are calculated as "actual", "allowable", and "acute" on an annual basis. Actual emissions represent the mass emissions that were released from the facility for a period of interest. Allowable emissions represent the maximum amount of emissions that the facility is permitted to release for the period of interest. Acute emissions represent highest emissions that could be released during the facility operating period.
          Control information: Includes information on control measures in use by the facilities. Control measures are assigned on a pollutant and emissions process basis.
The remainder of this memorandum describes the sources of data and the steps taken to identify facilities, collect and compile facility configuration information, identify emission release points, and estimate emission rates for the risk modeling file.
 Facility Identification

To prepare the risk modeling file, multiple sources of information were reviewed to identify active facilities with wet-formed fiberglass mat production operations that are subject to the NESHAP. Affected facilities were first identified through review of several EPA databases, including the Enforcement and Compliance History Online (ECHO) database, National Emission Inventory (NEI) database, and Toxics Release Inventory (TRI) database. To identify affected facilities, the ECHO, NEI, and TRI databases were queried by MACT subpart code, SIC code, and NAICS code. The NEI database were also queried using SCCs for specific processes typically found at affected facilities (i.e., resin-binder application or "forming", and curing ovens). The relevant search criteria are shown in Table 5-1.

Table 5-1. Search Criteria for Identification of Wet-formed Fiberglass Mat Facilities
                                Search Criteria
                          Search Criteria Description
                               Databases Queried
                                                                      MACT Code
MACT Subpart Code HHHH 
ECHO, NEI
                                                                       SIC Code
3296 - Mineral Wool 
3299 - Pressed and Blown Glass and Glassware
ECHO, NEI, TRI
                                                                     NAICS Code
327212 - Other Pressed and Blown Glass and Glassware Manufacturing
313230 - Nonwoven Fabric Mills
327993 - Mineral Wool Manufacturing
ECHO, NEI, TRI
                                                                            SCC
30501214 - Industrial Processes; Mineral Products; Fiberglass Manufacturing; Forming Process (Textile-type Fiber)
30501215 - Industrial Processes; Mineral Products; Fiberglass Manufacturing; Curing Oven (Textile-type Fiber)
NEI

Facilities were also identified from a facility list and additional industry trade materials included in the initial 2002 rulemaking effort, online searches of state operating permit databases, consultation with EPA regional offices, and general web searches for fiberglass mat production facilities.  

Air operating and construction permits were requested from state and regional agencies and reviewed to determine whether the facility is subject to the NESHAP. Additional web searches (online news articles, company websites, and review of Google Earth(R) satellite and street view imagery) were conducted to verify facility acquisition or closure. After developing the final list of affected facilities, the location, operating status, and major source status of each facility were confirmed in consultation with an industry trade organization (the Asphalt Roofing Manufacturers Association, ARMA) and ARMA-member facilities. Table 5-2 presents the seven wet-formed fiberglass mat production facilities with affected sources. 
                                       
   Table 5-2. Facilities with Affected Wet-formed Fiberglass Mat Operations
                                 Facility Name
                                     City
                                     State
Owens Corning Composite Materials LLC
Fort Smith
AR
Johns Manville  -  Plant #01
Waterville
OH
Johns Manville  -  Waterville 07
Waterville
OH
Certainteed/Saint Gobain Adfors America Inc.
North Charleston
SC
GAF Materials Corporation
Chester
SC
Owens Corning Nonwoven Technology LLC
Aiken
SC
Johns Manville, Inc.
Etowah
TN

 Facility Configuration

After identifying facilities that are subject to the NESHAP, emission units and emission processes to be included in the risk modeling file were identified for each facility. Generally, emission units are meant to identify the operating scenario of processes or operations within a facility and emission processes describe specific processes or operations within a facility. Emission units included in the risk modeling file include drying and curing ovens, which are the primary HAP emission sources at wet-formed fiberglass mat production facilities and currently regulated by the NESHAP, and the resin-binder application process. To identify the existing drying and curing ovens and binder application emission release points for each affected facility, the 2014 NEI facility data by NEI emission unit and process descriptions, SCC code, and pollutant type, were reviewed first. Where the NEI lacked specific emission unit or process data for a facility (e.g., if a resin-binder application emission point could not be readily determined from the NEI data), the emission unit ID, process ID, and additional relevant information (i.e., emission release point IDs, stack parameters, emission estimates, and control information) were generated as discussed in sections 7.0 and 8.0 of this document for the modeling file. The emission points were also cross referenced with emission units and processes listed in the facility air operating or construction permits, and each emission unit was confirmed in consultations with facilities. Section 8.0 of this document contains further discussion of the pollutants emitted and assigned to each emission unit and process.

Emissions from other operations outside the source category (e.g., boilers, tanks) are not regulated by the Wet-formed Fiberglass Mat Production NESHAP and are not addressed in this memorandum or included in the risk modeling file. These emissions were included in the facility-wide assessment of risk. 

Table 6-1 of this document lists the facility emission units and processes that were included in the risk modeling file. Five of the affected facilities have single mat lines and two of the affected facilities have two mat lines. 
                                       
Table 6-1. Emission Units and Emission Processes for Wet-formed Fiberglass Mat Operations
                                 Facility Name
                    No. of Wet-Formed Fiberglass Mat Lines
                               Emission Unit ID
                           Emission Unit Description
                              Emission Process ID
                         Emission Process Description
Owens Corning Composite Materials LLC
                                       1
63373313
Oven Vapor Incinerator
87266614
Oven Vapor Incinerator

                                       
103362213
Saturator Vacuums
146464614
Saturator Vacuums
Johns Manville  -  Plant #01
                                       1
4985913
Fiber blend mat line - produces bonded non-woven fiberous mat
100748714
9214 Mat Line

                                       
1004985913
Binder Application
100100748714
9214 Mat Line Binder Application Vacuum
Johns Manville  -  Waterville 07
                                       1
4979513
Wet formed fiberglass mat line 
100751814
9272 Mat Machine (includes binder application and drying and curing)[1]
Certainteed/Saint Gobain Adfors America Inc.
                                       1
214213
Honeycomb Dryer
15250814
Mat Forming Blowers

                                       
10069674113
Binder Application
10096179914
Binder Application Vacuum
GAF Materials Corporation
                                       1
69709913
Glass Mat Line
96301714
Consists of 4 drying ovens and 2 curing ovens

                                       
10069709913
Binder Application
10096301714
Binder Application Vacuum
Owens Corning Nonwoven Technology LLC
                                       2
32103813
02 Mat Line #1 Oven

12153914
#1 Dry/Cure Oven and Incinerator

                                       
10032103813
02 Mat Line #1 Saturator
10012153914
Mat Line #1 Saturator Vacuum

                                       
32104513
04 Mat Line #2 Oven
12471014
#2 Dry/Cure Oven and Incinerator

                                       
10032104513
04 Mat Line #2 Saturator
10012471014
Mat Line #2 Saturator Vacuum
Johns Manville, Inc.
                                       2
88729013
3301 Mat Production Process  -  Forming & Curing
157507514
3301 Wet Mat Ovens/Hood

                                       
88729113
3302 Mat Production Process  -  Forming & Curing
120502214
3302 Mat Production Process  -  Forming & Curing

                                       
10088729013
3301 Mat Production Process  -  Binder Application
100157507514
3301 Binder Application Vacuum

                                       
10088729113
3302 Mat Production Process  -  Binder Application
100120502214
3302 Binder Application Vacuum
 For the Johns Manville  -  Waterville 07 facility, the resin-binder application and mat drying and curing are a single release point, as discussed in section 7.0 of this document. 
 Facility Emission Release Points

Following identification and assignment of emission units and emission processes, specific exhaust locations for emissions units and processes (i.e., emission release points) for each facility were added to the risk modeling file. As described in section 6.0 of this document, emission release points were assigned to each emission unit and emission process combination, depending on a facility's configuration (e.g., a single emission process could have multiple emission release points, or multiple emission processes could have a single emission release point). For example, if an emission unit for a process exhausts to multiple stacks, the emission unit was assigned an emission release point for each stack. In the risk modeling file, a type (e.g., stack or fugitive) was also assigned to each emission release point.  

Emission release points for each facility were identified through review of NEI emission release points, consultation with individual facilities, and review of facility satellite imagery in Google Earth(R). For wet-formed fiberglass mat production at all seven affected facilities, emissions from drying and curing ovens are released through a single point stack. For the resin-binder application process at six of the seven affected facilities, the emission release point refers to the binder application vacuum exhaust, which is generally directed to one or more building or roof vents. One affected facility routes the binder application vacuum exhaust to an RTO controlling the drying and curing oven exhaust. In this case, emissions from binder application and drying and curing processes were assigned to a single emissions release point at the RTO stack.

For each stack emission release point, the risk modeling file must have stack parameters including the height, diameter, temperature, exit gas velocity (or flow rate), and latitude and longitude coordinates. The source of the stack parameters and coordinates are discussed in sections 7.1 and 7.2 of this document. A summary of the stack parameters for each facility is included in Appendix A of this document. Section 8.0 of this document discusses the development and assignment of the pollutant-specific emissions to each release point.

 Drying and Curing Oven Stack Parameters

The affected facilities include nine drying and curing ovens which are each vented to a thermal oxidizer, RTO, or RCO. For drying and curing operations, the emission release point is the exhaust stack for the control device. Stack parameters for each emission release point associated with the control device, including stack height, stack diameter, exit gas temperature, exit gas velocity, and exit gas flow rate, were primarily obtained through review of performance tests. Where performance test data were available, the exit gas temperature, velocity, and flow rate were based on the average of all test runs from the most recent test. Performance test data was supplemented with information from the 2014 NEI database, information obtained from facility air permits, and information collected in consultation with each facility. In one instance, the exit gas velocity was calculated based on the stack diameter and average exit gas flow rate during the most recent performance test. Table 7-1 summarizes the stack test parameters and sources for the drying and curing oven operations at each facility.
                                       
         Table 7-1. Source of Emission Release Point Parameter Inputs
                        Drying and Curing Oven Exhaust
                                 Facility Name
                     Emission Process ID & Description
                           Emission Release Point ID
                       Source of Stack Parameter Inputs
Owens Corning Composite Materials LLC
87266614: 
Oven Vapor Incinerator 
57919112
Stack height based on NEI data; all other parameters based on performance test.
Johns Manville  -  Plant #01
100748714: 9214 Mat Line
68361412
Stack height based on NEI data; all other parameters based on performance test.
Johns Manville  -  Waterville 07
100751814: 9272 Mat Machine[1] 
114838512
Stack height based on NEI data. Stack diameter provided by facility. Temperature, gas velocity, and flow rate based on performance test. 
Certainteed/Saint Gobain Adfors America Inc.
15250814: Mat Forming Blowers/Fugitive
63952812
Stack height provided by facility; all other parameters based on performance test.
GAF Materials Corporation
96301714: Consists of 4 drying ovens and 2 curing ovens
63990312
Stack height based on NEI data; temperature, flow rate, and stack diameter based on performance test. Exit gas velocity calculated. 
Owens Corning Nonwoven Technology LLC
12153914: #1 Dry/Cure Oven and Incinerator
30725812
All parameters based on performance tests.

12471014: #2 Dry/Cure Oven and Incinerator
30725712
All parameters based on performance tests.
Johns Manville, Inc. 
157507514: 3301 Wet Mat Ovens/Hood
85038412
Stack height based on NEI data; all other parameters based on performance test.

120502214: 3302 Mat Production Process 
85038812
Stack height based on NEI data; all other parameters based on performance test.
      [1] Emission release point includes drying and curing oven emissions and binder application vacuum exhaust.

In addition to the stack parameters above, latitude and longitude coordinates were assigned to each emission release point associated with a control device stack. The latitude and longitude coordinates were based on a review of satellite imagery for each facility in Google Earth(R) in consultations with each facility. The EPA also confirmed that each stack parameter was within acceptable QA range check boundaries. Exit gas velocity was flagged in one instance as being out-of-range, but was based on performance tests and, thus, was not changed.  

 Binder Application Vacuum Exhaust Parameters

For the resin-binder application process, the emission release point is the location of the binder application vacuum exhaust, which is most commonly routed to one or more roof vents. At five of the affected facilities, six resin-binder application processes are each exhausted to a single roof vent. For two affected facilities, three resin-binder application processes are exhausted to two or more emission points. With one exception, all emission release points for the resin-binder application process were treated as stack points. The exception is one case in which the process exhausts to a louvered sidewall. The louvered sidewall was modeled as a fugitive release, as discussed below. 

Stack release parameters. The parameters for each emission release stack point associated with the binder application vacuum exhaust include the exhaust vent height, vent diameter, exit gas temperature, exit gas velocity, and exit gas flow rate. Emissions test data for the resin-binder application process was available for one facility currently subject to subpart HHHH. For this facility, the stack parameters were obtained from the available test data, 2014 NEI data, or calculation (e.g., where exit gas velocity may be calculated from vent diameter and flow rate). 

For the other facilities with binder application vacuum emissions that are treated as stack points, stack parameter information for the emission release points were based on information provided by the facility or 2014 NEI data. Where data were not available, a default value was assigned. For example, the exhaust vent height was estimated based on the building height of the facility plus two feet. Where the building height was not provided, the exhaust vent height was assigned the value provided in the 2014 NEI database. If no value was available from the 2014 NEI, a default stack height was assigned based on the MACT source category. Vent diameter, velocity, and flow rate values were assigned based on information provided by the facility, where available, or on default values based on the MACT source category. Table 7-2 of this document lists the MACT category defaults. The exit gas temperature for binder application vacuum emissions was assumed to be ambient (i.e., assigned a default of 72°F). 
                                       
   Table 7-2. MACT Category Stack Parameter Default Values for Subpart HHHH
                               Stack Height (ft)
                              Stack Diameter (ft)
                             Gas Velocity (ft/sec)
                          Gas Flow Rate (cu feet/min)
                                      45
                                      2.5
                                     40.7
                                   199.6844

Fugitive release parameters. For the one facility in which the resin-binder application process exhausts to a louvered sidewall, binder application vacuum emissions were modeled as exhausting from a two-dimensional cross-section. The parameters required to model a fugitive two-dimensional release point include the width of the two-dimensional cross-section and the height of release. 

Table 7-3 of this document summarizes the parameters and sources for the resin-binder application processes at each facility.
                                       
         Table 7-3. Source of Emission Release Point Parameter Inputs
                       Binder Application Vacuum Exhaust
                                 Facility Name
                     Emission Process ID & Description
                           Emission Release Point ID
                          Source of Parameter Inputs
Owens Corning Composite Materials LLC
146464614: Saturator Vacuums
57919312
Vent height based on NEI data. All other parameters based on test data.
Johns Manville  -  Plant #01
100100748714: Binder Application
10068361412
Temperature based on national default. Vent height based on MACT category default. All other parameters based on data provided by facility.


10168361412
Temperature based on national default. Vent height based on MACT category default. All other parameters based on data provided by facility.
Johns Manville  -  Waterville 07
100751814: 9272 Mat Machine[1]
114838512
Stack height based on NEI data. Stack diameter provided by facility. All other parameters based on performance test.
Certainteed/Saint Gobain Adfors America Inc.
10096179914: Binder Application
10063953112
Temperature based on national default. Gas velocity based on MACT category default. All other parameters based on data provided by facility.
GAF Materials Corporation
10096301714: Binder Application Vacuum
10062990312
Temperature based on national default. Vent height based on data provided by facility. All other parameters based on MACT category defaults.
Owens Corning Nonwoven Technology LLC
10012153914: Mat Line #1 Saturator Vacuum
10030725812
Temperature based on national default. Vent height based on data provided by facility. All other parameters based on MACT category defaults.

10012471014: Mat Line #2 Saturator Vacuum
10030725712
Temperature based on national default. Vent height based on data provided by facility. All other parameters based on MACT category defaults.
Johns Manville, Inc.
100157507514: 3301 Binder Application Vacuum
10085038412
Temperature based on national default. All other parameters based on data provided by facility.


10185038412
Temperature based on national default. All other parameters based on data provided by facility.


10285038412
Temperature based on national default. All other parameters based on data provided by facility.

100120502214: 3302 Binder Application Vacuum 
10085038812
Temperature based on national default. Vent height and width based on data provided by facility.
   1 Emission release point includes drying and curing oven emissions and binder application vacuum exhaust.
   
In addition to the parameters above, latitude and longitude coordinates were assigned to each emission release point associated with a binder application vacuum exhaust vent. For the resin-binder application process exhausted to the louvered sidewall, two sets of latitude and longitude coordinates represent midpoints of opposing sides of the release area. Latitude and longitude coordinates were based on a review of satellite imagery for each facility in Google Earth(R) in consultations with each facility. The EPA also confirmed that each stack parameter was within acceptable QA range check boundaries. Exit gas velocity was flagged in one instance as being out-of-range, but was based on fan capacity data provided by the facility and, thus, was not changed.
 Estimation of Emissions

To model individual pollutants for affected facilities, pollutants emitted from each emission unit and process at the affected facilities were assigned to each emission release point. In the development of the 2002 final rule, the EPA also identified methanol and vinyl acetate as potential process HAP in addition to formaldehyde. Three of the seven affected facilities were identified as including methanol in the resin. The NESHAP only requires measurement of formaldehyde emissions. Only one of the three facilities provided test data for methanol emissions, which were limited to measurements from the resin-binder application process. Therefore, estimates of methanol emissions from resin-binder application processes at the other two facilities that use methanol in resin and from drying and curing ovens at all three facilities that use methanol in resin were based on the ratio of methanol to formaldehyde reported in the 2014 NEI, which are based on engineering assumptions. 

Although vinyl acetate was previously considered as a process HAP in the original 2002 rulemaking, the EPA confirmed through consultations with each facility that the resin-based binders currently used no longer contain vinyl acetate. The EPA did not identify any other process HAP in this review. 

For each emission release point, three separate emission estimates for the risk modeling file were developed, including actual annual emissions, allowable annual emissions, and acute annual emissions. Actual annual emissions are the emissions estimated to be released by the facility assuming the facility's standard operating hours and levels of control. Allowable emissions are the emissions that each facility is capable of releasing based on the emissions reduction standards in the Wet-formed Fiberglass Mat Production NESHAP. Acute emissions reflect the highest emissions that may be released by a facility and are used to estimate acute risks. Sections 8.1 through 8.3 of this document describe the methodology for estimating the actual, allowable, and acute emissions from the drying and curing processes and binder application processes. A summary of the emissions estimates for each facility emission release point is included in Appendix B of this document.
 Estimated Actual Emissions

Actual emission estimates for each affected facility were based on available facility stack test data, NEI data, and engineering estimates. For drying and curing ovens, actual formaldehyde emissions were based on the average controlled hourly emissions from the most recent stack test and the 5-year annual average operating hours (i.e., for the years 2012 through 2016). For the three facilities using binders containing methanol in addition to formaldehyde, actual methanol emissions from the four drying and curing ovens were based on the ratio of methanol to formaldehyde emissions reported to the 2014 NEI. 

For estimation of actual formaldehyde emissions from the resin-binder application process, test data were available for one affected facility that tested both the uncontrolled emissions from the drying and curing oven and the emissions from the saturator vacuum exhaust. The 2013 tests provided data to estimate actual formaldehyde emissions from the facility's binder application vacuum exhaust (i.e., saturator vacuum exhaust). Based on the test data, emissions from the saturator vacuum exhaust were 0.2 percent of the uncontrolled emissions at the thermal oxidizer inlet. For the seven resin-binder application processes at five of the six remaining affected facilities, actual formaldehyde emissions from the binder application vacuum exhaust were estimated as 0.2 percent of the average uncontrolled hourly emissions from the most recent stack test for the drying and curing ovens and the 5-year annual average operating hours. The EPA considered this testing to be representative of emissions from these five affected facilities based on the similarities between emission units and processes at each facility. For one facility, the resin-binder application process is controlled by the same RTO controlling the drying and curing operations; for this facility, actual emissions of formaldehyde from the binder application vacuum exhaust were included with the emissions from the drying and curing oven.

For estimation of actual methanol emissions from resin-binder application processes at the three facilities that use binders containing methanol in addition to formaldehyde, test data were available for the saturator vacuum exhaust at one of the facilities. The tests provided data to estimate actual methanol emissions from the facility's binder application vacuum exhaust (i.e., saturator vacuum exhaust). For the two other facilities that use binders containing methanol, the actual methanol emissions from the binder application vacuum exhaust were based on the actual formaldehyde emissions estimates for binder application vacuum exhaust and the ratio of methanol to formaldehyde emissions reported for the drying and curing ovens in the 2014 NEI. 

Table 8-1 of this document summarizes the basis of actual emission estimates for each affected facility. Additional details regarding actual emissions estimates for each facility emission release point are included in Appendix C of this document.
                                       
Table 8-1. Basis of Actual Emissions Estimates from Wet-formed Fiberglass Mat Facilities
                                 Facility Name
            Basis of Actual Emissions from Drying and Curing Ovens
                        Basis of Actual Emissions from
                       Binder Application Vacuum Exhaust
                                       
                                 Formaldehyde 
                                   Methanol
                                 Formaldehyde
                                   Methanol
Owens Corning Composite Materials LLC
Compliance stack test data
Estimated drying and curing oven actual formaldehyde emissions & NEI ratio of methanol/ formaldehyde/
Test data
Test data
Johns Manville  -  Plant #01
Compliance stack test data
NA
0.2% of uncontrolled drying and curing oven emissions
NA
Johns Manville  -  Waterville 07
Compliance stack test data
NA
Compliance stack test data[1]
NA
Certainteed/Saint Gobain Adfors America Inc.
Compliance stack test data
Estimated drying and curing oven actual formaldehyde emissions & NEI ratio of methanol/ formaldehyde
0.2% of uncontrolled drying and curing oven emissions
Estimated binder application vacuum exhaust actual formaldehyde emissions & NEI ratio of methanol/ formaldehyde
GAF Materials Corporation
Compliance stack test data
NA
0.2% of uncontrolled drying and curing oven emissions
NA
Owens Corning Nonwoven Technology LLC[2]
Compliance stack test data
Estimated drying and curing oven actual formaldehyde emissions & NEI ratio of methanol/ formaldehyde
0.2% of uncontrolled drying and curing oven emissions
Estimated binder application vacuum exhaust actual formaldehyde emissions & NEI ratio of methanol/ formaldehyde
Johns Manville, Inc.[2]
Compliance stack test data
NA
0.2% of uncontrolled drying and curing oven emissions
NA
1 Emission release point includes drying and curing oven emissions and binder application vacuum exhaust.
[2] Same basis of actual emissions applies to both mat production lines at facility.
 Estimated Allowable Emissions

Allowable emission estimates for each affected facility were based on the current level of control required by the Wet-formed Fiberglass Mat Production NESHAP. For drying and curing ovens, subpart HHHH requires a 96-percent destruction efficiency for formaldehyde. The allowable formaldehyde emissions for each drying and curing oven were calculated based on the actual formaldehyde emissions (as discussed in section 8.1 of this document), assuming 96 percent control. Allowable methanol emissions from the drying and curing ovens were based on the allowable formaldehyde emissions and the ratio of methanol to formaldehyde emissions reported for the drying and curing ovens in the 2014 NEI. 

For resin-binder application processes, with the exception of the binder application vacuum exhaust at one affected facility, the allowable formaldehyde and methanol emissions were assumed equal to the actual emissions estimates. At the one facility, the resin-binder application process is controlled by the same RTO controlling the drying and curing operations; for this facility, the allowable formaldehyde emissions for the binder application vacuum exhaust are included in the allowable formaldehyde estimate for the drying and curing oven.

Table 8-2 of this document summarizes the basis of allowable emission estimates for each affected facility. Additional details regarding allowable emissions estimates for each facility emission release point are included in Appendix D of this document.
                                       
Table 8-2. Basis of Allowable Emissions Estimates from Wet-formed Fiberglass Mat Facilities
                                 Facility Name
           Basis of Allowable Emissions from Drying and Curing Ovens
                       Basis of Allowable Emissions from
                       Binder Application Vacuum Exhaust
                                       
                                 Formaldehyde 
                                   Methanol
                                 Formaldehyde
                                   Methanol
Owens Corning Composite Materials LLC
Estimated actual emissions assuming 96% control
Estimated drying and curing oven allowable formaldehyde emissions & NEI ratio of methanol/ formaldehyde
Equal to estimated actual emissions
Equal to estimated actual emissions
Johns Manville  -  Plant #01
Estimated actual emissions assuming 96% control
NA
Equal to estimated actual emissions
NA
Johns Manville  -  Waterville 07
Estimated actual emissions assuming 96% control
NA
Estimated actual emissions assuming 96% control[1]
NA
Certainteed/Saint Gobain Adfors America Inc.
Estimated actual emissions assuming 96% control
Estimated drying and curing oven allowable formaldehyde emissions & NEI ratio of methanol/ formaldehyde
Equal to estimated actual emissions
Equal to estimated actual emissions
GAF Materials Corporation
Estimated actual emissions assuming 96% control
NA
Equal to estimated actual emissions
NA
Owens Corning Nonwoven Technology LLC[2]
Estimated actual emissions assuming 96% control
Estimated drying and curing oven allowable formaldehyde emissions & NEI ratio of methanol/ formaldehyde
Equal to estimated actual emissions
Equal to estimated actual emissions
Johns Manville, Inc.[2]
Estimated actual emissions assuming 96% control
NA
Equal to estimated actual emissions
NA
1 Emission release point includes drying and curing oven emissions and binder application vacuum exhaust.
[2] Same basis of actual emissions applies to both mat production lines at facility.
 Estimated Acute Emissions

For drying and curing ovens, acute formaldehyde emissions were estimated using the same approach used to develop the actual formaldehyde emission estimates, except that the acute emissions estimates were based on the highest hourly controlled emissions from the facility, considering all tests runs from the submitted performance tests, and the facility's 5-year annual average operating hours (i.e., for the years 2012 through 2016). For the three facilities using binders containing methanol, acute methanol emission estimates from the drying and curing ovens were based on the ratio of methanol to formaldehyde emissions reported to the 2014 NEI. 

Acute emissions from the resin-binder application process were estimated similarly to actual emissions. For one facility, 2013 test data were used to estimate the acute formaldehyde and methanol emissions from the facility's binder application vacuum exhaust (based on the highest hourly uncontrolled emissions from the 2013 test and the facility's 5-year annual average operating hours). For the seven resin-binder application processes at five of the six remaining affected facilities, acute formaldehyde emissions from the binder application vacuum exhaust were estimated as 0.2 percent of the highest hourly uncontrolled emissions from the drying and curing ovens, considering all tests runs from the submitted performance tests, and the facility's 5-year annual average operating hours. Acute methanol emissions were estimated for the other two facilities that use binders containing methanol based on the acute formaldehyde emissions estimates for binder application vacuum exhaust and the ratio of methanol to formaldehyde emissions from the drying and curing ovens reported to the 2014 NEI. Finally, for one facility that controls the resin-binder application process and drying and curing operations with a single RTO, acute emissions of formaldehyde from binder application vacuum exhaust were included in the acute formaldehyde emissions estimate for the drying and curing oven.

Table 8-3 of this document summarizes the basis of acute emission estimates for each affected facility. Additional details regarding acute emissions estimates for each facility emission release point are included in Appendix E of this document.
                                       
Table 8-3. Basis of Acute Emissions Estimates from Wet-formed Fiberglass Mat Facilities
                                 Facility Name
             Basis of Acute Emissions from Drying and Curing Ovens
                         Basis of Acute Emissions from
                       Binder Application Vacuum Exhaust
                                       
                                 Formaldehyde 
                                   Methanol
                                 Formaldehyde
                                   Methanol
Owens Corning Composite Materials LLC
Compliance stack test data
Estimated drying and curing oven acute formaldehyde emissions & NEI ratio of methanol/ formaldehyde
Test data
Test data
Johns Manville  -  Plant #01
Compliance stack test data
NA
0.2% uncontrolled drying and curing oven emissions
NA
Johns Manville  -  Waterville 07
Compliance stack test data
NA
Compliance stack test data[1] 
NA
Certainteed/Saint Gobain Adfors America Inc.
Compliance stack test data
Estimated drying and curing oven acute formaldehyde emissions & NEI ratio of methanol/ formaldehyde
0.2% uncontrolled drying and curing oven emissions
Estimated binder application vacuum exhaust acute formaldehyde emissions & NEI ratio of methanol/ formaldehyde
GAF Materials Corporation
Compliance stack test data
NA
0.2% uncontrolled drying and curing oven emissions
NA
Owens Corning Nonwoven Technology LLC[2]
Compliance stack test data
Compliance stack test data & NEI ratio of methanol/ formaldehyde
0.2% uncontrolled drying and curing oven emissions
Estimated binder application vacuum exhaust acute formaldehyde emissions & NEI ratio of methanol/ formaldehyde
Johns Manville, Inc.[2]
Compliance stack test data
NA
0.2% uncontrolled drying and curing oven emissions
NA
1 Emission release point includes drying and curing oven emissions and binder application vacuum exhaust.
[2] Same basis of actual emissions applies to both mat production lines at facility.




                                 FACILITY NAME
                               SPPD FACILITY ID
                               EMISSION UNIT ID
                           EMISSION UNIT DESCRIPTION
                                  PROCESS ID
                           EMISSION RELEASE POINT ID
                               STACK HEIGHT (ft)
                           EXIT GAS TEMPERATURE (F)
                              STACK DIAMETER (ft)
                          EXIT GAS VELOCITY (ft/sec)
                        EXIT GAS FLOW RATE (cu ft/sec)
                                 X COORDINATE
                                 Y COORDINATE
GAF MATERIALS CORPORATION
8306011
69709913
GLASS MAT LINE
96301714 
63990312 
50
298.8
5.3
63
1383
-81.129817
34.716701
GAF MATERIALS CORPORATION
8306011
10069709913
BINDER APPLICATION
10096301714 
10062990312 
42
72
2.5
41
200
-81.129865
34.716926
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711
32103813
02 MAT LINE #1 OVEN
12153914 
30725812 
100
370
5.5
30
701
-81.663843
33.54695
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711
32103813
02 MAT LINE #1 OVEN
12153914 
30725812 
100
370
5.5
30
701
-81.663843
33.54695
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711
10032103813
02 MAT LINE #1 SATURATOR
10012153914 
10030725812 
50
72
2.5
41
200
-81.664318
33.546569
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711
10032103813
02 MAT LINE #1 SATURATOR
10012153914 
10030725812 
50
72
2.5
41
200
-81.664318
33.546569
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711
32104513
04 MAT LINE #2 OVEN
12471014 
30725712 
60
409
5.4
53
1236
-81.663416
33.546314
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711
32104513
04 MAT LINE #2 OVEN
12471014 
30725712 
60
409
5.4
53
1236
-81.663416
33.546314
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711
10032104513
04 MAT LINE #2 SATURATOR
10012471014 
10030725712 
50
72
2.5
41
200
-81.6645135
33.54625
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711
10032104513
04 MAT LINE #2 SATURATOR
10012471014 
10030725712 
50
72
2.5
41
200
-81.6645135
33.54625
JOHNS MANVILLE, INC.
4013911
88729013
3301 MAT PRODUCTION PROCESS - FORMING & CURING
157507514 
85038412 
38
385
3.7
64
676
-84.515893
35.370285
JOHNS MANVILLE, INC.
4013911
88729113
3302 MAT PRODUCTION PROCESS - FORMING & CURING
120502214 
85038812 
45
402
6.0
54
1515
-84.515717
35.370145
JOHNS MANVILLE, INC.
4013911
10088729013
3301 MAT PRODUCTION PROCESS - BINDER APPLICATION - P18
100157507514 
10085038412 
40
72
1.2
62
67
-84.516794
35.369449
JOHNS MANVILLE, INC.
4013911
10088729013
3301 MAT PRODUCTION PROCESS - BINDER APPLICATION - P19
100157507514 
10185038412 
40
72
1.2
34
36
-84.516814
35.369396
JOHNS MANVILLE, INC.
4013911
10088729013
3301 MAT PRODUCTION PROCESS - BINDER APPLICATION  -  P20
100157507514 
10185038412 
40
72
1.2
38
41
-84.516806
35.369411
JOHNS MANVILLE, INC.
4013911
10088729113
3302 MAT PRODUCTION PROCESS - BINDER APPLICATION
100120502214 
10085038812 
38
72
52 x 5
N/A
N/A
-84.516196
35.369323
JOHNS MANVILLE - PLANT #01
8055811
4985913
FIBER BLEND MAT LINE
100748714 
68361412 
104
344.7
4.0
60
764
-83.709939
41.52939
JOHNS MANVILLE - PLANT #01
8055811
1004985913
BINDER APPLICATION-S
100100748714 
10068361412 
45
72
1.0
217
171
-83.709813
41.530438
JOHNS MANVILLE - PLANT #01
8055811
1004985913
BINDER APPLICATION-N
100100748714 
10168361412 
45
72
1.0
23
18
-83.709813
41.530451
JOHNS MANVILLE  -  WATERVILLE 07
8055911
4979513
WET FORMED FIBERGLASS MAT LINE
100751814 
114838512 
47.4
305.4
4.9
31
599
-83.721453
41.524226
OWENS CORNING COMPOSITE MATERIALS LLC
262411
63373313
OVEN VAPOR INCINERATOR
87266614 
57919112 
24
753
2.5
166
788
-94.371755
35.303339
OWENS CORNING COMPOSITE MATERIALS LLC
262411
63373313
OVEN VAPOR INCINERATOR
87266614 
57919112 
24
753
2.5
166
788
-94.371755
35.303339
OWENS CORNING COMPOSITE MATERIALS LLC
262411
103362213
SATURATOR VACUUMS
146464614 
57919312 
43
89
2.3
19
82
-94.37135
35.302988
OWENS CORNING COMPOSITE MATERIALS LLC
262411
103362213
SATURATOR VACUUMS
146464614 
57919312 
43
89
2.3
19
82
-94.37135
35.302988
CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC
8305911
214213
HONEYCOMB DRYER
15250814 
63952812 
64
430
2.5
48
227
-80.006311
32.841503
CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC
8305911
214213
HONEYCOMB DRYER
15250814 
63952812 
64
430
2.5
48
227
-80.006311
32.841503
CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC
8305911
10069674113
BINDER APPLICATION
10096179914 
10063953112 
35
72
1.0
41
32
-80.00645
32.841618
CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC
8305911
10069674113
BINDER APPLICATION
10096179914 
10063953112 
35
72
1.0
41
32
-80.00645
32.841618

                                 FACILITY NAME
                           SPPD FACILITY IDENTIFIER
                           EMISSION RELEASE POINT ID
                                   POLLUTANT
                             ACTUAL EMISSIONS TPY
                            ALLOWABLE EMISSIONS TPY
                              ACUTE EMISSIONS TPY
GAF MATERIALS CORPORATION
8306011 
63990312 
Formaldehyde
2.20
5.51
6.4
GAF MATERIALS CORPORATION
8306011 
10062990312 
Formaldehyde
0.27
0.27
0.6
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711 
30725812 
Formaldehyde
0.476
0.907
3.740
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711 
30725812 
Methanol
0.138
0.263
1.084
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711 
10030725812 
Formaldehyde
0.043
0.043
0.211
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711 
10030725812 
Methanol
0.012
0.012
0.061
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711 
30725712 
Formaldehyde
2.921
4.327
2.950
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711 
30725712 
Methanol
0.872
1.292
0.881
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711 
10030725712 
Formaldehyde
0.216
0.216
0.228
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
5045711 
10030725712 
Methanol
0.064
0.064
0.068
JOHNS MANVILLE, INC.
4013911 
85038412 
Formaldehyde
0.828
1.325
1.296
JOHNS MANVILLE, INC.
4013911 
85038812 
Formaldehyde
0.495
4.950
0.528
JOHNS MANVILLE, INC.
4013911 
10085038412 
Formaldehyde
0.044
0.044
0.110
JOHNS MANVILLE, INC.
4013911 
10185038412 
Formaldehyde
0.044
0.044
0.110
JOHNS MANVILLE, INC.
4013911 
10185038412 
Formaldehyde
0.044
0.044
0.110
JOHNS MANVILLE, INC.
4013911 
10085038812 
Formaldehyde
0.256
0.256
0.270
JOHNS MANVILLE - PLANT #01 
8055811 
68361412 
Formaldehyde
0.81
3.60
2.876
JOHNS MANVILLE - PLANT #01 
8055811 
10068361412 
Formaldehyde
0.09
0.09
0.164
JOHNS MANVILLE - PLANT #01 
8055811 
10168361412 
Formaldehyde
0.09
0.09
0.164
JOHNS MANVILLE - WATERVILLE 07 
8055911 
114838512 
Formaldehyde
0.7651
2.354
0.782
OWENS CORNING COMPOSITE MATERIALS LLC
262411 
57919112 
Formaldehyde
0.1457
5.828
0.167
OWENS CORNING COMPOSITE MATERIALS LLC
262411 
57919112 
Methanol
0.1457
5.828
0.167
OWENS CORNING COMPOSITE MATERIALS LLC
262411 
57919312 
Formaldehyde
0.4123
0.4123
0.481
OWENS CORNING COMPOSITE MATERIALS LLC
262411 
57919312 
Methanol
3.41
3.41
3.450
CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC
8305911 
63952812 
Formaldehyde
0.95
3.46
1.05
CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC
8305911 
63952812 
Methanol
6.10
22.19
6.76
CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC
8305911 
10063953112 
Formaldehyde
0.17
0.17
0.285
CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC
8305911 
10063953112 
Methanol
1.11
1.11
1.83
                                       
                   FACILITY NAME / EMISSION RELEASE POINT ID
                                  STACK TEST
                    AVERAGE CONTROLLED FORMALDEHYDE (LB/HR)
                   AVERAGE UNCONTROLLED FORMALDEHYDE (LB/HR)
                    2014 NEI METHANOL TO FORMALDEHYDE RATIO
            AVERAGE ANNUAL OPERATING HOURS FOR 2012 - 2016 (HR/YR)
GAF MATERIALS CORPORATION



                                       

63990312
01/08/2015
0.604
                                     ----
                                     ----
7,300
10062990312 
01/08/2015
                                     ----
37.475
                                     ----
7,300






OWENS CORNING NON-WOVEN TECHNOLOGY LLC
LINE 1





30725812
02/08/2017
0.14

0.29 (0.1033/0.3564)
6,800
10030725812
02/08/2017

6.26
0.29 (0.1033/0.3564)
6,800
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
LINE 2





30725712
02/09/2017
0.99

0.30 (0.7969/2.6694)
5,900
10030725712
02/09/2017

36.56
0.30 (0.7969/2.6694)
5,900






JOHNS MANVILLE, INC
 LINE 3301



                                       

85038412
03/31/2015
0.23

                                     ----
7,200
10085038412
03/31/2015

18.35
                                     ----
7,200
JOHNS MANVILLE, INC.
LINE 3302



                                       

85038812
11/19/2013
0.15

                                     ----
6,600
10085038812
11/19/2013

38.82
                                     ----
6,600






JOHNS MANVILLE - PLANT #01



                                       

68361412
01/24/2017
0.20

                                     ----
8,100
10068361412
01/24/2017

23.1
                                     ----
8,100



                                       
                                       

JOHNS MANVILLE - WATERVILLE 07


                                       
                                       

114838512 [1]
01/05/2017
0.33
                                     ----
                                     ----
4,600






OWENS CORNING COMPOSITE MATERIALS LLC





57919112
10/01/2013
0.047
                                     ----
1.0 (2.75/2.75)
6,200
57919312
10/02/2013
                                     ----
0.133
                                   ---- [2]
6,200






CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC





63952812
06/24/2015
0.24

6.42 (3.66/0.57)
7,800
10063952812
06/24/2015

22.10
6.42 (3.66/0.57)
7,800
     [1] One emission release point for combined exhaust from drying and curing oven and binder application vacuum.
     [2] Data is available for methanol from 10/02/2013 test and is used for estimating emissions. Average methanol value is 1.100 lb/hr.
                                       
                   FACILITY NAME / EMISSION RELEASE POINT ID
                                  STACK TEST
                    AVERAGE CONTROLLED FORMALDEHYDE (LB/HR)
                   AVERAGE EFFICIENCY OF CONTROL DEVICE (%)
                    2014 NEI METHANOL TO FORMALDEHYDE RATIO
            AVERAGE ANNUAL OPERATING HOURS FOR 2012 - 2016 (HR/YR)
GAF MATERIALS CORPORATION



                                       

63990312
01/08/2015
0.604
98.4
                                     ----
7,300






OWENS CORNING NON-WOVEN TECHNOLOGY LLC
LINE 1





30725812
02/08/2017
0.14
97.9
0.29 (0.1033/0.3564)
6,800
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
LINE 2





30725712
02/09/2017
0.99
97.3
0.30 (0.7969/2.6694)
5,900






JOHNS MANVILLE, INC
 LINE 3301



                                       

85038412
03/31/2015
0.23
97.5
                                     ----
7,200
JOHNS MANVILLE, INC.
LINE 3302



                                       

85038812
11/19/2013
0.15
99.6
                                     ----
6,600




                                       

JOHNS MANVILLE - PLANT #01



                                       

68361412
01/24/2017
0.20
99.1
                                     ----
8,100



                                       
                                       

JOHNS MANVILLE - WATERVILLE 07


                                       
                                       

114838512 [1]
01/05/2017
0.33
98.7
                                     ----
4,600






OWENS CORNING COMPOSITE MATERIALS LLC





57919112
10/01/2013
0.047
99.9
1.0 (2.75/2.75)
6,200






CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC





63952812
06/24/2015
0.24
98.9
6.42 (3.66/0.57)
7,800
     [1] One emission release point for combined exhaust from drying and curing oven and binder application vacuum.
                                       
                   FACILITY NAME / EMISSION RELEASE POINT ID
                                  STACK TEST
                    HIGHEST CONTROLLED FORMALDEHYDE (LB/HR)
                                  STACK TEST
                   HIGHEST UNCONTROLLED FORMALDEHYDE (LB/HR)
                    2014 NEI METHANOL TO FORMALDEHYDE RATIO
               AVERAGE ANNUAL OPERATING HOURS FOR 2012  -  2016
                                    (HR/YR)
GAF MATERIALS CORPORATION




                                       

63990312
01/27/2012, run 1
1.76
                                     ----
                                     ----
                                     ----
7,300
10062990312 
                                     ----
                                     ----
05/11/2006, run 2
81.3
                                     ----
7,300







OWENS CORNING NON-WOVEN TECHNOLOGY LLC
LINE 1






30725812
07/21/2010, run 3
1.10
                                     ----
                                     ----
0.29 (0.1033/0.3564)
6,800
10030725812
                                     ----
                                     ----
07/21/2010, run 1
31.1
0.29 (0.1033/0.3564)
6,800
OWENS CORNING NON-WOVEN TECHNOLOGY LLC
LINE 2






30725712
02/09/2017, runs 1 & 3
1.00
                                     ----
                                     ----
0.30 (0.7969/2.6694)
5,900
10030725712
                                     ----
                                     ----
06/14/2012, run 1
38.7
0.30 (0.7969/2.6694)
5,900







JOHNS MANVILLE, INC
 LINE 3301




                                       

85038412
04/14/2010, runs 1, 2 & 3
0.36
                                     ----
                                     ----
                                     ----
7,200
10085038412
                                     ----
                                     ----
04/14/2010, run 1
46.0
                                     ----
7,200
JOHNS MANVILLE, INC.
LINE 3302




                                       

85038812
11/19/2013, run 1
0.16
                                     ----
                                     ----
                                     ----
6,600
10085038812
                                     ----
                                     ----
11/19/2013, run 1
40.9
                                     ----
6,600







JOHNS MANVILLE - PLANT #01




                                       

68361412
09/21/2010, run 2
0.71
                                     ----
                                     ----
                                     ----
8,100
10068361412
                                     ----
                                     ----
09/18/2008, run 1
40.4
                                     ----
8,100



                                       
                                       
                                       

JOHNS MANVILLE - WATERVILLE 07


                                       
                                       
                                       

114838512 [1]
01/05/2017, run 2
0.34
                                       
                                     ----
                                     ----
4,600







OWENS CORNING COMPOSITE MATERIALS LLC






57919112
10/01/2013, run 1
0.054
                                     ----
                                     ----
1.0 (2.75/2.75)
6,200
57919312
                                     ----
                                     ----
10/02/2013, run 1
0.155
                                   ---- [2]
6,200







CERTAINTEED/SAINT GOBAIN ADFORS AMERICA INC






63952812
06/24/2015, run 2
0.27
                                     ----
                                     ----
6.42 (3.66/0.57)
7,800
10063952812
                                     ----
                                     ----
07/13/2005, run 3
36.6
6.42 (3.66/0.57)
7,800
[1] One emission release point for combined exhaust from drying and curing oven and binder application vacuum.
[2] Data is available for methanol from 10/02/2013 test and is used for estimating emissions. Highest methanol value is 1.113 lb/hr (run 1).

