NAIMA’S PRELIMINARY QUESTIONS FOR EPA ON DRAFT ICR

(RESIDUAL RISK FOR WOOL FIBER GLASS AND

MINERAL WOOL MACT STANDARDS)

General

EPA’s opening letter references Section 114.  Please confirm that the
final letter/agreement will indicate that this effort is being done
cooperatively rather than under a Section 114 order.

The documents provide no “de minimus” levels or thresholds.  Does
EPA expect information on insignificant sources (e.g., small batch dust
collectors, inkjet printers, copy machines, etc.)?

NAIMA wishes to address the requests for cost data and confidential
business information in a separate phone call.  NAIMA and its companies
will provide background information and details on concerns surrounding
the collection of this information.

In responding to Enclosures 1 and 2, will EPA agree that some parts of
the data will be submitted by member companies and other data will be
submitted by NAIMA?

On all forms, EPA seeks degrees, minutes, and seconds on
latitude/longitude data.  Can NAIMA rely on Google Earth or similar
resources to get the data to six decimal places?

What is meant by “source reduction plans?”

There will be more questions as we proceed with completing this ICR.

Enclosure 1

Form A-2

Title V permits include all applicable requirements.  Does EPA need us
to supply copies of the permits and then list in Form A-2 all of the
applicable requirements again?  Would just a copy of the permit suffice?

What is meant by a “co-located facility?”

Form B

Why is the definition of particulate matter for PM2.5 different than
that in the NAAQS?

The definition of “process line” includes material delivery through
waste management.  As it is used later in the forms, it sets up lists of
details unrelated to  air toxics and could be read to include each and
every piece of equipment in the plant.  Please clarify what is meant by
“process line.”

Why is a plot plan necessary?  They likely do not exist and would take
considerable resources to create.  What information does EPA need and
can it be provided in an alternative fashion?

Form B-1

On Form B-1, how detailed does EPA want a list of products?

On Form B-1, would a sufficiently detailed block flow diagram that
indicates all equipment and emission points be acceptable?

Form B-4

On Form B-4, please clarify what is meant by “burner type.”  Some
burners are proprietary company design and do not necessarily conform to
a “burner type.”

On Form B-4, please clarify whether the rebuild information requested
pertains to forehearths.

On Form B-4, please define “modules” and “plenums.”

Form B-5

On Form B-5, please define “oven rebuild.”

Form B-7

On Form B-7, please clarify the conflict between the form which uses the
term “volatile solvents” and the instructions which uses the term
“HAP solvents.”  Also, please clarify that this refers to solvents
used on affected facilities as defined in 40 C.F.R. 63, Subpart NNN.

Form C

On Forms C-1, C-2, C-3, C-4, C-5, C-6, and C-7, what is meant by
“problems” with the control device?

Please clarify the ventilation system form.  Is it only for ventilation
in the area of NNN-affected sources?  Is the local ventilation question
intended to include ventilation that goes through a control device that
would be answered in a prior portion of the C forms?

Forms C-2, C-7

Wastewater is apparently water exiting the scrubber.  Please define
“scrubbing water.”  Is scrubbing water also the water exiting the
scrubber?

Form C-3

Please define “mechanical collector.”

Form C-4

Please define “average stack opacity.”

Form C-6

Please define “High Velocity Air Filter.”

Does “High Velocity Air Filter” refer to a “High Efficiency Air
Filter (HEAF)” control device?  If not, what form should be used for a
HEAF control device?

Form C-8

Please define “Ventilation system.”

Form D

With respect to startup and shutdown information, is EPA referring to
just the melters?

Form E

Is it EPA’s intention to report the data twice?

On Form E, please clarify the timeframe for which the data is being
requested.

Form F-1

On the last question of Form F-1, please clarify if the substitution
mentioned is substitution available to the producer or substitution
available to the consumer.

Enclosure 2

In Table 1.1, collection chamber test data on formaldehyde, phenol, and
methanol is mandated.  Are the collection chambers for unbonded lines
exempt from having any test data on formaldehyde, phenol, and methanol?

Many operations indicate that processes and controls operate the same
during startup and shutdown.  For those facilities, the response simply
would be “not applicable.”

If a company is considered part of the representative subset, can that
representative data be used for future reporting requirements?  This is
similar to how companies use AP-42 tables.

NAIMA is requesting a separate call to focus exclusively on test
methods.  See our “Timeline and Schedule for Preparation of NAIMA Plan
and Schedule for Completing Both Wool Fiber Glass and Mineral Wool
Information Collection Requests.”

Some sources have forming, curing, and cooling combined into one stack. 
It is not possible to sample each process separately and meet test
method requirements.  NAIMA would want to use representative data for
these scenarios.

The listed EPA Method 5 for PM2.5 references a filter temperature of
320°F ( 25°F.  This filter temperature does not comply with Method 5
(250 ( 25) or Modified Method 5 (350 ( 25).  Where does the 320°F come
from?

Why has EPA doubled the minimum time and sample volumes?  This will add
days to the sampling events at the facilities and should be considered
in calculating the time needed to complete the ICR.

Is PM filterable the sum of PM2.5 plus the PM fraction greater than
PM2.5?

Is it even possible to accurately test the inlet?  Does EPA expect the
inlet and outlet testing to all be done simultaneously?

Please define “inlet” and “outlet.”

Please clarify the purpose for deviating from standard run times/number
of runs.

Is the additional PM2.5 testing requested just for the furnace and not
for the collection, curing, and cooling?

For the collection, curing, and cooling emission points, the draft ICR
requests PM2.5.  However, the permits require Method 5E for PM and
Method 5/202 for PM10 at some facilities.  There is also limited data
for PM10 using Method 5/OTM 28 and CTM039 to eliminate ammonium sulfate
artifact.  Could any of this data be provided in lieu of the PM2.5 data
requested?  PM10 data available is for run lengths of 2 hours, not 4
hours.

In the case that filterable and not condensable data is available for
all furnaces, can condensable data be estimated?

In Table 1.2, what is the purpose of reporting “ppmvd@7%O2”?  From
where does the “@7%O2” originate?

March 11, 2010

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March 11, 2010

