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ENVIRONMENTAL PROTECTION AGENCY

Transportation Department

CFR Citation: 40 CFR Part 63

RIN ID: RIN 2060-AH89

FRL ID: [FRL-6703-5]

NOTICE: Part III

DOCUMENT ACTION: Proposed rule.

SUBJECT CATEGORY: National Emission Standards for Hazardous Air Pollutants for Wet- Formed Fiberglass Mat Production

DATES: Comments. Public comments on the proposed rule must be received on or before July 25, 2000.

Public Hearing. A public hearing will be held if requests to speak are received by June 12, 2000.

DOCUMENT SUMMARY: The EPA is adding wet-formed fiberglass mat production to the list of categories of major sources of hazardous air pollutants (HAPs) published under section 112(c) of the Clean Air Act (CAA) and to the source category schedule for national emission standards for hazardous air pollutants (NESHAP).

The EPA is, at the same time, proposing the NESHAP for new and existing sources at wetformed fiberglass mat production facilities. The HAPs emitted by the facilities subject to the proposed NESHAP include three organic HAPs (formaldehyde, methanol, and vinyl acetate). Exposure to these HAPs can cause reversible or irreversible adverse health effects including carcinogenic, respiratory, nervous system, developmental, reproductive, and/or dermal health effects. The EPA estimates the proposed NESHAP would reduce nationwide emissions of HAPs from the drying and curing ovens at these facilities by 199 megagrams per year (Mg/yr)(219 tons per year or tons/yr), an approximate 74 percent reduction from the current level of emissions. Under section 112(c)(5) of the CAA, the wetformed fiberglass mat production NESHAP has a promulgation date of May 26, 2002.

The proposed NESHAP are based on the Administrator's determination that wetformed fiberglass mat production facilities emit several of the 188 HAPs listed in the CAA from the various process operations found within the industry, and that these facilities can be major sources of HAPs. The proposed NESHAP protect the public by requiring all wetformed fiberglass mat production facilities that are major sources to meet emission standards reflecting the application of the maximum achievable control technology (MACT).

SUMMARY: Environmental Protection Agency,


SUPPLEMENTAL INFORMATION

Comments. Commenters wishing to submit proprietary information for consideration should clearly distinguish such information from other comments and clearly label it
``Confidential Business Information.'' Submissions containing such proprietary information should be sent directly to the following address, and not to the public docket, to ensure that proprietary information is not inadvertently placed in the docket: Attention: Mr. Juan Santiago, c/o OAQPS Document Control Officer, 411 W. Chapel Hill Street, Room 740B, Durham, North Carolina 27701. Information covered by such a claim of confidentiality will be disclosed by EPA only to the extent allowed and by the procedures set forth in 40 CFR part 2. If no claim of confidentiality accompanies a submission when it is received by EPA, the submission may be made available to the public without further notice to the commenter.

Public Hearing. Anyone requesting to present oral testimony or attend the public hearing must contact Ms. Tanya Medley at (919) 541 5422 no later than June 16, 2000. A verbatim transcript of the hearing and any written statements will be available for public inspection and copying during normal working hours at the EPA's Air and Radiation Docket and Information Center in Washington, DC.

Docket. Docket A9754, containing supporting information used in developing the proposed standards, is available at the Air and Radiation Docket and Information Center, 401 M Street, SW, Room M1500, Waterside Mall, Washington D.C. 20460 and may be inspected from 8 a.m. to 5:30 p.m., Monday through Friday. Copies of this information may be obtained by request from the Air Docket by calling (202) 2607548. A reasonable fee may be charged for copying docket materials.

Electronic Access and Filing Addresses. The official record for this rulemaking has been established under Docket No. A9754 (including comments and data submitted electronically). A public version of this record, including printed, paper versions of electronic comments, which does not include any information claimed as confidential business information (CBI), is available for inspection from 8 a.m. to 5:30 p.m., Monday through Friday, excluding legal holidays.

Electronic comments can be sent directly to the EPA's Air and Radiation Docket and Information Center at: ``AandR Docket@epamail.epa.gov.'' Electronic comments must be submitted in American Standard Code for Information Interchange (ASCII) file format. Avoid the use of special characters and any form of encryption. Comments and data will also be accepted on disks in
WordPerfect Version 5.1, 6.1 or Corel 8 file format or ASCII file format. All comments and data in electronic form must be identified by the docket number (A9754). Electronic comments may be filed online at many Federal Depository Libraries.

Worldwide Web (WWW). The proposed regulatory text will be available on the WWW through the Technology Transfer Network (TTN), a network of the EPA's electronic bulletin boards. The TTN provides information and technology exchange in various areas of air pollution control. The TTN is accessible through the Internet at ``TELNET ttnbbs.rtpnc.epa.gov''. If more information on the TTN is needed, call the HELP line at (919) 5415384.

Regulated Entities. Entities potentially regulated by this action are those industrial facilities that manufacture wetformed fiberglass mat. Wetformed fiberglass mat production is classified under Standard Industrial Classification (SIC) code 3329325, a subset of SIC code 3329, Pressed and Blown Glass, Not Elsewhere Classified. Regulated categories and entities are shown in
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table 1. This table is not intended to be exhaustive, but provides a guide for readers regarding entities likely to be regulated by final action on this proposal. This table lists the types of entities that EPA is now aware could potentially be regulated by final action on this proposal. To determine whether your facility would be regulated by final action on this proposal, carefully examine the applicability criteria in section III.A of this preamble and in Sec. 63.2981 of the proposed rule. If there are any questions regarding the applicability of this action to a particular entity, consult Mr. Juan Santiago (See FOR FURTHER INFORMATION CONTACT).
Table 1.Regulated Categories and Entities Category SIC code Description Industrial............................. 3329325 Wetformed fiberglass mat production facilities.

Incorporation by Reference. A request for approval of the incorporation by reference by the Director of the Office of the Federal Register will be submitted prior to promulgation of this rule for the following material: Chapters 3 and 5 of ``Industrial Ventilation: A Manual of Recommended Practice,'' American Conference of Governmental Industrial Hygienists (22nd edition, 1995). The procedures in this material are used for designing the system for capturing and conveying HAP emissions to the control device. The incorporation by reference of this publication is expected to be approved by the Director of the Office of the Federal Register upon promulgation.

Organization of this Document. The information in this preamble is organized as follows:

I. Introduction

A. Regulatory Background and Addition to Source Category List

B. Solicitation of Comments

C. Source of Authority for National Emission Standards for Hazardous Air Pollutants Development

D. What are the health effects of pollutants emitted from this source category?

E. WetFormed Fiberglass Mat Production Industry Profile and Process Description

F. How were pollution prevention practices considered in the development of these proposed NESHAP?
II. What are the requirements of these proposed NESHAP?

A. Do these proposed NESHAP apply to me?

B. What emission standards must I meet?

C. What operating standards must I meet?

D. What are the performance test and initial compliance provisions of these proposed NESHAP?

E. What monitoring requirements must I meet?

F. What are the notification, recordkeeping, and reporting requirements of these proposed NESHAP?
III. What are the impacts of these proposed NESHAP?

A. What are the air emission impacts?

B. What are the water and solid waste impacts?

C. What are the energy impacts?

D. Are there any additional environmental and health impacts?

E. What are the cost impacts?

F. What are the economic impacts?
IV. How were these proposed NESHAP developed?

A. Selection of Emission Sources

B. Selection of MACT Floor

C. Emission Limits

D. Selection of Test Methods

E. Selection of Operating Standards and Monitoring Requirements V. What are the administrative requirements of these proposed NESHAP?

A. Executive Order 12866Regulatory Planning and Review

B. Executive Order 13045Protection of Children From Environmental Health Risks and Safety Risks

C. Executive Order 13132Federalism

D. Executive Order 13084Consultation and Coordination with Tribal Governments

E. Unfunded Mandates Reform Act

F. Regulatory Flexibility Act

G. Paperwork Reduction Act

H. National Technology Transfer and Advancement Act I. Introduction
A. Regulatory Background and Addition to Source Category List

Section 112(c) of the CAA directs us to list each category of major and area sources, as appropriate, that emits one or more of the 188 HAPs listed in section 112(b) of the CAA. The term ``major source'' is defined in section 112(a)(1) to mean:
* * * any stationary source or group of stationary sources located within a contiguous area under common control that emits or has the potential to emit, considering controls, in the aggregate 10 tons per year or more of any HAP or 25 tons per year or more of any combination of HAPs * * *
We published an initial list of source categories on July 16, 1992 (57 FR 31576). Included on the initial source category list were major sources of HAP emissions from the asphalt roofing and processing industry.

During development of the asphalt roofing and processing NESHAP, industry representatives alerted us about the existence of the wet formed fiberglass mat production industry, and its relationship to the asphalt roofing production industry. They indicated to us that wet formed fiberglass mat production facilities have the potential to be major sources of HAP emissions, and some wetformed fiberglass mat production facilities are collocated with asphalt roofing and processing facilities. They expressed the opinion that there should be a NESHAP for wetformed fiberglass mat production developed separately from the asphalt roofing and processing industry. We have decided to propose a separate NESHAP for wetformed fiberglass mat production because the production processes and pollutant emissions differ from those in the asphalt roofing industry. In addition, wetformed fiberglass mat is produced at both standalone facilities and those collocated with asphalt roofing and processing facilities. The CAA provides that we may amend the list anytime. Consequently, wetformed fiberglass mat production is being added to the source category list under section 112(c) of the CAA.

Wetformed fiberglass mat is the substrate for several asphalt roofing products. In wetformed fiberglass mat production, glass fibers are bonded with an organic resin. The mat is formed as the resin is dried and cured in heated ovens. The majority of HAP emissions associated with wetformed fiberglass mat production are emitted from the drying and curing oven exhaust. Based on HAP emission data obtained during the development of this proposed rule, we have determined that wetformed fiberglass mat production facilities are major sources of HAPs. Nine of the 14 facilities (10 of the 15 production lines) control the drying and curing oven exhaust emissions. All five of the remaining facilities that do not control the drying and curing oven exhaust are major sources of HAPs (Docket No. A9754).

Today's action adds wetformed fiberglass mat production to the list of source categories for which MACT standards are to be developed. Final standards for this source category are required to be promulgated by May 26, 2002.
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B. Solicitation of Comments

We are seeking full public participation in arriving at final decisions and encourage comments on all aspects of this proposal from all interested parties. Full supporting data and detailed analyses should be submitted with comments to allow us to make maximum use of the comments. All comments should be sent according to the information given in the ADDRESSES section. Comments on this proposal must be submitted on or before the date specified in the DATES section. C. Source of Authority for National Emission Standards for Hazardous Air Pollutants Development

Section 112 of the CAA requires us to promulgate standards for the control of HAP emissions from each source category listed under section 112(c). The statute requires the standards to reflect the maximum degree of reduction in emissions of HAPs that is achievable taking into consideration the cost of achieving the emission reduction, any nonair quality health and environmental impacts, and energy requirements. This level of control is commonly referred to as MACT. The MACT standards can be based on the emission reductions achievable through application of measures, processes, methods, systems, or techniques including, but not limited to: (1) Reducing the volume of, or eliminating emissions of, such pollutants through process changes, substitution of materials, or other modifications; (2) enclosing systems or processes to eliminate emissions; (3) collecting, capturing, or treating such pollutants when released from a process, stack, storage, or fugitive emissions point; (4) design, equipment, work practice, or operational standards (including requirements for operator training or certification) as provided in section 112(h) of the CAA; or (5) a combination of the above (see section 112(d)(2) of the CAA).

For new sources, MACT standards cannot be less stringent than the emission control achieved in practice by the bestcontrolled similar source (see section 112(d)(3) of the CAA). The MACT standards for existing sources can be less stringent than standards for new sources. However, they cannot be less stringent than the average emission limitation achieved by the bestperforming 12 percent of existing sources for categories and subcategories with 30 or more sources, or the bestperforming five sources for categories or subcategories with fewer than 30 sources.

In essence, MACT standards are designed to ensure that all major sources of air toxic emissions achieve the level of control already being achieved by the bettercontrolled and loweremitting sources in each category. This approach provides assurance to the public that each major source of toxic air pollution will be required to effectively control its emissions. At the same time, this approach provides a level economic playing field, ensuring that facilities that employ cleaner processes and good emission controls are not disadvantaged relative to competitors with poorer controls.
D. What Are the Health Effects of Pollutants Emitted From This Source Category?

The CAA was created, in part, ``to protect and enhance the quality of the Nation's air resources so as to promote the public health and welfare and the productive capacity of its population'' (see section 101(b) of the CAA). The proposed NESHAP would protect public health by reducing emissions of HAPs from wetformed fiberglass mat production facilities.

Emission data collected during development of the proposed NESHAP show that formaldehyde, vinyl acetate, and methanol are emitted from wetformed fiberglass mat production facilities (Docket No. A9754). The proposed emission limits would reduce emissions of formaldehyde, vinyl acetate, and methanol emitted from drying and curing ovens. As a result of controlling these HAPs, the proposed NESHAP would also reduce emissions of volatile organic compounds (VOC). Following is a summary of the potential health effects caused by exposure to these pollutants.

Exposure to formaldehyde, vinyl acetate, and methanol irritates the eyes, skin, and mucous membranes and can cause conjunctivitis, dermal inflammation, and respiratory symptoms. Formaldehyde exposure has been associated with reproductive effects such as menstrual disorders and pregnancy problems in female workers. We have classified formaldehyde as Class B1, a probable human carcinogen, on the basis of findings of nasal cancer in animal studies and limited human data. Acute exposure to vinyl acetate is known to cause irritation of the lungs and nose, and irritation or blistering of skin. Exposure to very high levels of vinyl acetate can cause dizziness. Data are not sufficient to classify vinyl acetate as a potential human carcinogen.

Acute exposure to methanol (usually by ingestion) is well known to cause blindness and severe metabolic acidosis, sometimes leading to death. Chronic methanol exposure, including inhalation, may cause central nervous system disturbances possibly leading to blindness. Methanol exposure has also been linked to developmental effects in animals. Data are not sufficient to classify methanol as a potential human carcinogen (Docket No. A9754).

The degree of adverse health effects associated with HAP exposure can range from mild to severe. The extent and degree to which the health effects may be experienced are dependent upon: (1) The ambient concentrations observed in the area (e.g., as influenced by emission rates, meteorological conditions, and terrain); (2) the frequency and duration of exposures; (3) characteristics of exposed individuals (e.g., genetics, age, preexisting health conditions, and lifestyles); and (4) pollutantspecific characteristics (e.g., toxicity, halflife in the environment, and bioaccumulation).

Formaldehyde, vinyl acetate, and methanol are also VOC that are precursors to tropospheric ozone formation. Ambient concentrations in excess of the national ambient air quality standards (NAAQS) for ozone can damage lung tissue, reduce lung function, and increase sensitivity of the lung to other irritants. Additional information on the health effects of ozone are included in the EPA's ``Criteria Document'' (three volumes, EPA/600/P93004aF through EPA/600/P93004cF, July 1996), which supports the NAAQS for ozone. Many areas of the country, including several in which wetformed fiberglass mat production facilities are located, are not in compliance with the NAAQS for ozone. E. WetFormed Fiberglass Mat Production Industry Profile and Process Description

Wetformed fiberglass mat is currently produced in the United States by nine companies operating 14 plants (15 production lines) in nine States. These plants may be collocated with asphalt roofing plants because wetformed fiberglass mat can be used as a substrate for manufacturing asphalt roofing shingles and roll roofing products.

Wetformed fiberglass mat is used as a substrate for asphalt shingles and roll roofing, as a reinforcement for reinforced plastic composite products (including thermosets and thermoplastics) and for cement and gypsum products, and in miscellaneous specialty applications such as battery separators and for pipewrapping and flooring.

A typical wetformed fiberglass mat production line consists of the following processes: (1) Preparation of glass fibers;
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(2) formation of fibers into a fiberglass mat; (3) saturation with ureaformaldehyde binder solution; (4) curing and drying the binder coated fiberglass mat; (5) cooling the mat; and (6) trimming, cutting, and packaging.

Fiberglass mat is manufactured by binding glass fibers with urea formaldehyde resin. The glass fibers are mixed with water and emulsifiers in large (several thousand gallons) mixing vats to form an aqueous slurry of fibers and water. The slurry is then pumped to another large vat that acts as a surge tank and then to a third vat that is the supply tank for the mat forming machine.

The mat forming machine consists of a slurry dispenser and moving wire screen belt. The wire screen belt carries the glass fiber mat throughout the production process. The glass fiber slurry is dispensed from a slot onto the screen in a uniform curtain. After the slurry is dispensed onto the screen, the screen passes over a vacuum slot into which the excess water and emulsion are drawn, leaving only a layer of fibers on the screen.

The mat of fibers then passes under a binder dispenser. An aqueous solution of ureaformaldehyde binder is dispensed from a slot or a curtain coater onto the mat of fibers in a uniform curtain. Just after the binder is dispensed onto the mat, the screen passes over another vacuum slot into which the excess binder solution is drawn.

The mat of fibers and binder then passes into a drying and curing oven. This is a multiplestage oven that uses heated, forced air to carry away excess moisture. In the first stage, the moisture is driven from the binder. This causes the binder to migrate to the points where the glass fibers cross each other. In the second and third stages of the oven, the binder cures and hardens. After leaving the oven, the finished mat is wound into large rolls and prepared for shipment.

The information in the Technical Association of the Pulp and Paper Industry (TAPPI) survey responses (Docket No. A9754) and information obtained from a single facility that did not respond to the TAPPI survey (Docket No. A9754) indicate that drying and curing oven emissions from 10 of the 15 glass mat production lines are controlled by thermal oxidizers. Five facilities for which information is available do not have addon emission controls on either the binder application vacuum or the drying and curing oven exhausts. No emission control devices other than thermal oxidizers are used on the drying and curing oven exhausts in this industry.

The thermal oxidizers used in this industry operate at temperatures that range from about 1,000 to 1,500 degrees Fahrenheit ( deg.F) (540 to 820 degrees Celsius ( deg.C)) with residence times from 0.5 to 4.8 seconds. Most existing thermal oxidizers are also designed for energy recovery. Formaldehyde destruction efficiencies, for those facilities for which there are data, range from about 90 percent to greater than 99 percent.
F. How Were Pollution Prevention Practices Considered in the Development of These Proposed NESHAP?

The format of the proposed NESHAP is a mass emission limit (kilograms of formaldehyde per megagram of wetformed fiberglass mat produced) and an equivalent percentage reduction requirement compliance option. The mass emission limit allows for the use of pollution prevention practices in place of addon control devices. A potential pollution prevention practice could be a process modification to reduce the formaldehyde content of binder formulations.
II. What Are the Requirements of These Proposed NESHAP?

A. Do These Proposed NESHAP Apply to Me?

The proposed NESHAP would apply to each existing and newly constructed drying and curing oven located at a wetformed fiberglass mat production facility that is a major source of HAPs or that is collocated with a major source. A major source means any source that has the potential to emit 10 tons/yr or more of any one HAP or 25 tons/ yr or more of any combination of HAPs. If your facility is determined to be an area source, you would not be subject to these proposed NESHAP.

B. What Emission Standards Must I Meet?

The proposed NESHAP regulate emissions of formaldehyde as a surrogate for total HAP emissions. Control of formaldehyde will also result in control of vinyl acetate and methanol. A mass emission limit and a percentage reduction requirement compliance option for formaldehyde are proposed for each new and existing drying and curing oven. The emission limits are the same for new and existing sources. New source and existing source emission standards for the drying and curing oven exhaust are a maximum formaldehyde emission rate of 0.03 kilograms per megagram (kg/Mg) of wetformed fiberglass mat produced (0.05 pounds per ton (lb/ton) of wetformed fiberglass mat produced) or a minimum of 96 percent destruction efficiency of formaldehyde (as shown in table 2). You can choose to comply with either the emission rate limit or the percent reduction requirement. If you use a thermal oxidizer or other control device to achieve the mass emission limit or percentage reduction requirement, you must collect and convey the emissions from each drying and curing oven to the control device according to the procedures specified in chapters 3 and 5 of ``Industrial Ventilation: A Manual of Recommended Practice.'' Table 2.Summary of Proposed Emission Standards for New and Existing Drying and Curing Ovens at WetFormed Fiberglass Mat Manufacturing Plants Process Emission limit Each existing and new drying and curing oven.............. 0.03 kg of formaldehyde per Mg of fiberglass mat (0.05 lb of formaldehyde per ton of fiberglass mat). OR 96 percent reduction of formaldehyde. C. What Operating Standards Must I Meet?

In addition to the emission standards, the proposed NESHAP contain specific operating standards, summarized in Table 3. The operating standards require you to maintain certain process or control device parameters within the levels established during the initial performance test. In general, the parameter values or ranges that must be maintained, must be approved by the
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Administrator based on the performance test demonstrations. You must reference the operating standards in the operating permit that you are required to obtain under 40 CFR part 70.

You must also submit for the Administrator's approval an operations, maintenance, and monitoring (OMM) plan for the facility. The OMM plan specifies the parameters that must be monitored, how they will be monitored, and the corrective actions to follow whenever a monitored parameter deviates from the operating standards. You must also reference the OMM plan in your 40 CFR part 70 operating permit. Table 3.Summary of Operating Standards for New and Existing Sources Affected source Monitor type/operation/process Operating Standards Drying and curing ovens.............. Resin freeformaldehyde content...... Use a resin with a free formaldehyde content no greater than that of the resin used during the performance test, as determined by the resin purchase specification or test method. Binder formulation formaldehyde Use a binder with a formaldehyde content. content no greater than that of the binder formulation used during the performance test. Product ureaformaldehyde resin Do not manufacture a product with solids content. a ureaformaldehyde resin solids content per ton of product higher than that of the product made during the performance test. Lossonignition..................... Do not exceed the lossonignition value of the product made during the performance test. Solids content of ureaformaldehyde Do not exceed the solids content resin. of the ureaformaldehyde resin used in the product made during the performance test. Drying and curing ovens controlled by Thermal oxidizer operating Maintain the average temperature a thermal oxidizer. temperature. for each 3hour period at or above the average operating temperature achieved during the performance test. Thermal oxidizer operation........... Operate the thermal oxidizer in accordance with the operation, maintenance, and monitoring plan; annually inspect the thermal oxidizer for structural and design integrity. Drying and curing ovens controlled by Process or control device parameters. Maintain the process or control modifications or a control device device within the ranges other than a thermal oxidizer. established during the performance test. All affected sources................. Corrective action.................... Initiate corrective action within 1 hour of an established operating parameter excursion and complete and document action per operation, maintenance and monitoring plan.

If the operating parameters deviate from the values or ranges specified in your OMM plan, you would be in violation of the standards. Following the performance test, whenever a monitored parameter deviates from the established operating standards, you must initiate the corrective actions specified in the OMM plan within 1 hour. You must complete the corrective actions in an expeditious manner and implement them as specified in your OMM plan.

If you use a thermal oxidizer to achieve compliance with the emission standards, you must operate the thermal oxidizer so that the average operating temperature in any 3hour block period does not fall below the average temperature established during the performance test. Additionally, an annual inspection of the thermal oxidizer is required to ensure that the structural and design integrity of the combustion chamber is maintained in the same condition as during the performance test. If you use process modifications or an addon control device other than a thermal oxidizer to achieve compliance with the emission standards, you must maintain the process or control device parameter(s) within the required ranges that you established during the performance test.

The operating standards also require you to maintain the resin freeformaldehyde content, the binder formulation formaldehyde content, the solids content of the ureaformaldehyde resin, the urea
formaldehyde resin solids content of the product manufactured, and the lossonignition value of the wetformed fiberglass mat produced within the levels you established during a compliance test and as specified in your OMM plan.
D. What Are the Performance Test and Initial Compliance Provisions of These Proposed NESHAP?

You must conduct a performance test to demonstrate initial compliance with the emission limits. The performance test must be performed initially and every 5 years following the initial performance test. A performance test is also required to change the value or range of an operating standard. Under the proposed NESHAP, you must conduct the performance test while operating at or near the maximum production rate and while making wetformed fiberglass mat with the highest urea formaldehyde resin solids content, lossonignition value, using the resin with the highest freeformaldehyde content, and using the binder with the highest formaldehyde content. You must measure formaldehyde emissions as the average of three test runs using EPA Reference Method 316 in appendix A of 40 CFR part 63, ``Sampling and Analysis for Formaldehyde from Stationary Sources in the Mineral Wool and Wool Fiberglass Industries.'' This proposed method was published in the March 31, 1997 Federal Register (63 FR 15288). You must demonstrate compliance with either the mass emission limit or the percentage reduction requirement using the instructions and equations contained in the performance test requirement section of this proposed NESHAP.

During the performance tests, you must continuously monitor the thermal oxidizer operating temperature and record the average temperature in 15minute blocks during each 1hour test run. After completion of the three required test runs, you must determine the 3 hour average operating temperature of the thermal oxidizer. If you use process modifications or an addon control device other than a thermal oxidizer to comply with the
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emission standards, you must determine the appropriate control device or process monitoring parameters to indicate whether compliance is being achieved. You must include the process or control device parameters, monitoring frequency, and the averaging periods in your sitespecific test plan required by the 40 CFR part 63 general provisions and approved by the permitting agency prior to conducting your initial performance test. You may perform multiple tests to establish the least restrictive value or operating range for the selected parameters that still demonstrate compliance.

During the performance tests, you must also monitor and record the average hourly wetformed fiberglass mat production rate prior to edge trimming, the freeformaldehyde content and the solids content of the ureaformaldehyde resin used to produce the mat, the formaldehyde content of the binder used to produce the mat, the ureaformaldehyde solids content per ton of product, and the lossonignition value of the product manufactured during each of the three test runs.

If you use a thermal oxidizer to comply with these NESHAP, you must conduct a performance evaluation for the thermal oxidizer temperature monitoring device prior to the initial performance test to determine compliance. The evaluation must be conducted according to the procedures in 40 CFR 63.8(e) of the NESHAP general provisions. The temperature monitoring device must meet the following performance and equipment specifications: (1) The temperature monitoring device must be installed at the exit of the combustion zone of each thermal oxidizer; (2) the recorder response range must include zero and 1.5 times the average temperature; and (3) the reference method must be a National Institute of Standards and Technology calibrated reference thermocouplepotentiometer system or an alternate reference, subject to the approval of the Administrator.

The proposed NESHAP would allow facilities subject to the NESHAP to conduct shortterm experimental production runs, where the formaldehyde content or other process parameters deviate from the levels established during previous performance tests, without conducting additional performance tests. You must apply for approval from the Administrator or delegated State agency to conduct such experimental production runs. The application must be made at least 30 days prior to conducting the run. The application would include information on the nature and duration of the test runs including plans to perform emissions testing. Such experimental production runs are important to industry and allow them to develop new products, improve existing products, and determine the effects on emissions of process modifications being considered, such as binder formulation.

E. What Monitoring Requirements Must I Meet?

Continuous compliance is demonstrated after the initial performance test and between subsequent performance tests by monitoring emission control devices and process operating parameters. The allowable monitoring parameter values or ranges are determined during your initial performance test and must be approved by the Administrator.

If a thermal oxidizer is used to achieve compliance with the emission standards, you must monitor the operating temperature of the thermal oxidizer. If you use a thermal oxidizer to achieve compliance with the proposed emission standards, you must: (1) Install, operate, calibrate, and maintain a device that continuously measures the operating temperature of each thermal oxidizer; and (2) determine and record the temperature in 15minute and 3hour block averages. This is typically done using a thermocouple (a standard feature on most thermal oxidizers) and a chart recorder or data logger. You are also required to monitor the resin freeformaldehyde content, the binder formulation formaldehyde content, the solids content of the ureaformaldehyde resin, the ureaformaldehyde resin solids content of the product manufactured, and the lossonignition value of the wetformed fiberglass mat produced. Because these process parameters affect the amount of HAPs emitted from the drying and curing oven, you must monitor them to ensure that operation of the production process is consistent with the conditions of the performance test, and that the production process does not vary in such a way as to increase HAP emissions from the drying and curing oven exhaust.

If process modifications or a control device other than a thermal oxidizer is used to achieve compliance with the emission standards, you must monitor the parameters that were established during the performance test and approved by the Administrator.

The proposed NESHAP contain provisions that would allow you to change the thermal oxidizer operating temperature, addon control devices, and process parameter values from those established using the initial and 5year performance tests. These provisions would allow you to make process changes or to demonstrate that different monitoring parameter values would more appropriately demonstrate compliance with the proposed emission standards. You may revise the monitoring or process parameter values by conducting additional performance tests to verify compliance at the revised operating levels. For example, if you intend to use a ureaformaldehyde resin with a higher freeformaldehyde or solids content, produce a wetformed fiberglass mat with a higher ureaformaldehyde resin solids content, or produce a product with a higher lossonignition value, you must perform additional performance tests to verify compliance at the increased operating or process parameters. You must request and obtain approval from the Administrator to conduct these additional performance tests and must submit performance data that justify and support the expanded parameter ranges before the facility is allowed to operate under the revised monitoring parameters.
F. What Are the Notification, Recordkeeping, and Reporting Requirements of These Proposed NESHAP?

All notification, recordkeeping, and reporting requirements in the 40 CFR part 63 general provisions, as well as additional requirements, apply to wetformed fiberglass mat manufacturing facilities. The notification and reporting requirements include, but are not limited to: (1) Initial notification of applicability of the rule, notification of the dates for conducting the performance test, and notification of compliance status; (2) a report of performance test results; (3) a startup, shutdown, and malfunction plan; (4) reports of any startup, shutdown, and malfunction events that occur; and (5) reports of excess emissions (i.e., monitoring parameter exceedances) and continuous monitoring system performance. When no exceedances occur, you must submit semiannual reports indicating that no exceedances have occurred during the period. If exceedances or deviations from established monitoring parameters occur, the frequency of submitting the excess emission reports becomes quarterly until a request to return to semiannual reporting is approved by the Administrator. You cannot submit the request to reduce the frequency of the reporting period until the affected
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source's excess emissions and continuous monitoring system performance reports remain continually within the established parameter ranges for 1 full year.

You must maintain records of the following, as applicable: (1) Thermal oxidizer operating temperature; (2) process parameters for drying and curing ovens that comply with the emission standards using process modifications or an addon control device other than a thermal oxidizer; (3) freeformaldehyde content of the resin; (4) binder formulation formaldehyde content; (5) lossonignition value of the wetformed fiberglass mat produced; (6) ureaformaldehyde resin solids content per ton of the wetformed fiberglass mat produced; (7) average hourly wetformed fiberglass mat production rate; (8) the date and time an exceedance commenced if a parameter monitoring exceedance occurs, the date and time corrective actions were initiated and completed, a description of the cause of the exceedance, and a description of the corrective actions taken; (9) the approved OMM plan; (10) maintenance and inspections performed on control devices; and (11) any other information required to be recorded in the general provisions.

The NESHAP general provisions require that records be maintained for at least 5 years from the date of each record. You would retain the records onsite for at least 2 years but may retain the records offsite for the remaining 3 years. The records must be readily available and in a form suitable for efficient inspection and review. The files may be retained on paper, on microfilm, on microfiche, on a computer, on computer disks, or on magnetic tape. Reports may be made on paper or on a labeled computer disk using commonly available and compatible computer software.
III. What Are the Impacts of These Proposed NESHAP?

A. What Are the Air Emission Impacts?

At the current level of control, nationwide emissions of HAPs from the 14 facilities in the industry are about 268 Mg/yr (295 tons/yr). Under the proposed NESHAP, it is expected that thermal oxidizers will be added to the five uncontrolled drying and curing ovens, and that existing thermal oxidizers will be replaced with new units for three out of the ten controlled drying and curing ovens. This would result in an estimated reduction in nationwide HAP emissions of 199 Mg/yr (219 tons/yr) (Docket No. A9754).

Formaldehyde emissions from wetformed fiberglass mat manufacturing lines account for about 65 percent of the baseline HAP emissions. Methanol emissions account for approximately 30 percent, with vinyl acetate comprising the remaining 5 percent of the baseline HAP emissions. Estimated nationwide emissions of formaldehyde from existing wetformed fiberglass mat production lines are 174 Mg/yr (192 tons/yr) at the current level of control. Implementing the proposed NESHAP will reduce nationwide formaldehyde emissions from existing sources by about 130 Mg/yr (143 tons/yr) (Docket No. A9754), and combined emissions of vinyl acetate and methanol will be reduced by 70 Mg/yr (77 tons/yr). B. What Are the Water and Solid Waste Impacts?

Because compliance with the proposed NESHAP is based on the use of thermal oxidizers, no water pollution or solid waste impacts would result from the proposed NESHAP.

C. What Are the Energy Impacts?

Thermal oxidizers require electrical energy to operate fans. Additional electrical energy requirements are estimated to be 4,260 megawatt hours per year (MWhr/yr). An additional 275,000 million British thermal units per year (Btu/yr) of natural gas are estimated to be required for eight additional thermal oxidizers that would be added to existing sources. The total additional energy (electricity and natural gas) required as a result of the proposed NESHAP is 290 billion Btu/yr in the fifth year following promulgation of the NESHAP (Docket No. A9754). No new glass mat production lines are projected in the 5 years after promulgation; therefore, no increased energy requirement is expected for new glass mat production lines under the proposed NESHAP. D. Are There Any Additional Environmental and Health Impacts?

Reducing HAP emissions will lower occupational HAP and VOC exposure levels. The operation of thermal oxidizers may increase occupational noise levels in the five facilities that currently do not control HAP emissions.

E. What Are the Cost Impacts?

Cost impacts of the proposed NESHAP for drying and curing ovens were analyzed using sitespecific information included in the TAPPI survey responses coupled with procedures from the ``OAQPS Cost Manual'' (Docket No. A9754). For some facilities where sitespecific data necessary for estimating costs (e.g., a vent flow rate) were not available, average factors developed from industry data were used to estimate the missing data.

The total capital costs to achieve the proposed NESHAP were estimated to be $5,272,000. These capital cost impacts arise from the purchase and installation of eight thermal oxidizersfive thermal oxidizers for the five facilities without existing controls and three thermal oxidizers for three facilities that must replace existing thermal oxidizers that cannot meet the proposed NESHAP. The average capital costs of installing a new thermal oxidizer is $658,000 per oxidizer. The capital costs estimate to install a new thermal oxidizer to achieve compliance includes the cost of auxiliary burners, combustion chambers, primary heat exchangers, weathertight housing and insulation, a fan, flow and temperature controls, a stack, and structural supports.

Ten of the 15 wetformed fiberglass mat production lines have existing thermal oxidizers. We have formaldehyde emissions data for five of the existing thermal oxidizers. Based on an evaluation of the emissions data, four of these five thermal oxidizers are already achieving the formaldehyde control level required by the proposed NESHAP. Therefore, no thermal oxidizer capital costs to comply with the proposed NESHAP were estimated for these four facilities. The fifth facility controls both the drying and curing oven exhaust and the binder application vacuum exhaust. Since this facility is not achieving the formaldehyde control level required by the proposed NESHAP, the cost of a new thermal oxidizer was estimated for this facility. The thermal oxidizer cost estimate is based on the flow rate from the drying and curing oven exhaust only since the proposed NESHAP does not require control of the binder application vacuum exhaust.

No formaldehyde emissions data are available for the remaining five existing thermal oxidizers. Three facilities have thermal oxidizers operating at temperatures and residence times that are as high as those that have achieved the proposed formaldehyde control level. Therefore, we expect that these three facilities will be able to comply with the proposed NESHAP using their existing thermal oxidizers. No increases in capital or annual costs were estimated for these facilities. The two remaining thermal oxidizers have temperatures or residence times lower than those at the facilities that are achieving the proposed control levels. Capital costs were estimated to replace
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these two thermal oxidizers with new thermal oxidizers that are designed to meet the proposed NESHAP.

The proposed monitoring requirements for the thermal oxidizer operating temperature are not current industry practice and are expected to impose additional costs on facilities with existing thermal oxidizers. To estimate the impact of the additional monitoring equipment (i.e., a data logging system), a cost of $7,000 ($1,000 for each of the seven facilities with an existing thermal oxidizer that is achieving the proposed NESHAP) was included in the capital cost estimate (Docket No. A9754). No additional capital costs were estimated for monitoring equipment for the new thermal oxidizers since temperature monitors and recording devices are standard equipment and are included in the cost estimates for new thermal oxidizers.

The total annualized cost of the proposed NESHAP for eight new thermal oxidizers is about $2,414,000. The average annual cost for a typical facility that installs a new thermal oxidizer is $302,000. The annualized cost estimate includes the cost of operation, maintenance, supervisory labor, maintenance materials, utilities, administrative charges, taxes, insurance, and capital recovery.

F. What Are the Economic Impacts?

The goal of the economic impact analysis is to estimate the market response of the wetformed fiberglass mat production industry to the proposed emission standards and to determine the economic effects that may result from the proposed NESHAP. As discussed above, 14 facilities owned by nine different companies produce wetformed fiberglass mat domestically. These facilities may potentially be affected by the proposed NESHAP.

The estimated nationwide annualized cost of the proposed NESHAP is $1.595 million. This cost estimate represents approximately 0.069 percent of the 1995 sales revenues for domestically produced wetformed fiberglass mat. Based upon this estimate, it is reasonable to assume that market price increases and production decreases resulting from the proposed NESHAP are likely to be very small. Thus, we conclude that the proposed NESHAP is not likely to have a significant economic impact on the wetformed fiberglass mat industry as a whole or on secondary markets such as the labor market and foreign trade.

We performed a streamlined economic analysis to determine facility specific impacts. The facilityspecific impacts are examined by calculating the ratio of the estimated annualized costs of emission controls for each facility to the estimated revenues per facility (i.e., a costtosales ratio) to assess the likelihood of facility closures and employment impacts. Costtosales ratios refer to the change in the cost of emission controls divided by the sales revenue of wetformed fiberglass mat, the goods produced in the process for which additional pollution control is required. This ratio can be estimated for either individual firms or as an average for some set of firms such as affected small firms. While it has different significance for different market situations, it is a good rough gauge of potential impact. If costs for the individual (or group of) firms are completely passed onto the purchasers of the good(s) being produced, the ratio is an estimate of the price change (in percentage form after multiplying the ratio by 100). If costs are completely absorbed by the producer, this ratio is an estimate of changes in pretax profits (in percentage form after multiplying the ratio by 100). The distribution of costto sales ratios across the whole market, the competitiveness of the market, and profittosales ratios are among the obvious factors that may influence the significance of any particular costtosales ratio for an individual facility.

For these proposed NESHAP, a costtosales ratio exceeding 1 percent was determined to be an initial indicator of the potential for a significant facility impact. Each of the 14 facilities affected by the proposed NESHAP has costtosales ratios of less than 1 percent of sales. Therefore, the facilityspecific impacts are not considered to be significant for any facility affected by the proposed NESHAP. No facility is likely to close as a result of the proposed NESHAP. Facilities in the wetformed fiberglass mat production industry are likely to increase the price charged for the product in response to market price changes, to absorb the costs with no price increase, or to respond with a combination of these alternatives. The economic impacts to consumers and producers of wetformed fiberglass mat are anticipated to be minimal. The generally small scale of the impacts suggests that there will also be no significant impacts on markets for the products made using wetformed fiberglass mat. For more information, consult the economic impact report entitled ``Economic Impact Analysis for the Proposed National Emission Standard for Hazardous Air Pollutants from the Production of WetFormed Fiberglass Mat,'' January 1999 (Docket No. A9754).
IV. How Were These Proposed NESHAP Developed?

A. Selection of Emission Sources

In the wetformed fiberglass mat production industry, HAPs are emitted from two processes: binder application processes and drying and curing processes. For the reasons described below, we selected the drying and curing processes at new and existing wetformed fiberglass mat production lines for control under the proposed NESHAP.

The drying and curing oven drives off moisture remaining on the fibers and sets the binder using heated air. Fans are used to draw hot air through the mat within each of the oven zones; the hot air may be recycled within each zone to conserve energy. Emissions of formaldehyde, vinyl acetate, and methanol result from vaporization of volatile compounds in the binder. Emissions from ten of the 15 drying and curing ovens on wetformed fiberglass manufacturing lines are controlled by thermal oxidizers. Emissions from the remaining five ovens are uncontrolled.

The emissions from the drying and curing ovens account for approximately 90 percent of the total HAP emissions from wetformed fiberglass mat production facilities. Although one facility controls the vent gases from the binder application vacuum exhaust along with the drying and curing oven exhaust, we do not consider the control of the binder application vacuum exhaust at this facility to represent MACT for new sources. When the binder application vacuum exhaust is controlled using an existing thermal oxidizer designed to control only the drying and curing oven exhaust, the overall HAP reduction achieved by the thermal oxidizer is decreased (Docket No. A9754). Introducing the binder application vacuum exhaust into an existing thermal oxidizer decreases the performance of the thermal oxidizer because of the decreased residence time in the thermal oxidizer and the high moisture content of the binder application vacuum exhaust. No binder application vacuum exhausts are controlled using standalone thermal oxidizers. In addition, the costs of controlling the binder application vacuum exhaust by requiring a standalone thermal oxidizer would be unreasonably high. For these reasons, we propose to regulate HAP emissions at the MACT floor only from the drying and curing oven processes.
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B. Selection of MACT Floor

After identifying the MACT floors for new and existing sources, we must investigate regulatory alternatives. Regulatory alternatives are different levels of emissions control, equal to or more stringent than the MACT floor levels. Information about the industry is analyzed to project national impacts (which include HAP emission reduction levels and cost, energy, and nonair quality health and environmental impacts) and to select the regulatory alternative that best reflects MACT. The selected alternative may be more stringent than the MACT floor, but the control level must be achievable and reasonable in the Administrator's judgement considering cost, nonair quality health and environmental impacts, and energy requirements. The objective is to achieve the maximum degree of emissions reduction without imposing unreasonable impacts (see section 112(d)(2) of the CAA). The regulatory alternatives and emission limits selected for new and existing sources may be different because of different MACT floors.

In establishing the MACT standards, we may distinguish among classes, types, and sizes of sources within a category or subcategory when there are significant differences among the classes or subcategories (see section 112(d)(1) of the CAA). For the wetformed fiberglass mat industry, we examined the processes, the process operations, and other factors to determine if separate classes of units, operations, or other criteria have an effect on air emissions or their controllability that would justify subcategories. Because all the wetformed fiberglass mat production facilities use similar processes and emit the same pollutants, there is no basis for establishing subcategories. Therefore, we decided to regulate wetformed fiberglass mat production as one source category.

Because the wetformed fiberglass mat production industry has fewer than 30 sources, the MACT floor for existing sources is based on the average of the bestperforming five sources. Nine facilities (10 production lines) of the 14 facilities (15 production lines) use a thermal oxidizer to control HAP emissions from the drying and curing oven exhaust. Emission reductions achieved by thermal oxidizers represent the best emissions control technology achieved by sources subject to the proposed standards. Thus, the MACT floor for existing sources is the level of control achieved by a thermal oxidizer.

The new source MACT floor is based on the emission control that is achieved in practice by the bestcontrolled similar source. Because the bestcontrolled drying and curing oven uses a thermal oxidizer and no more effective control technology than thermal oxidation has been achieved to control gaseous HAPs, this is also the MACT floor level of control for new sources.

One facility currently controls the emissions from the binder application vacuum exhaust using a thermal oxidizer originally designed to control only the drying and curing oven exhaust. Because the existing thermal oxidizer was not designed to control the binder application vacuum exhaust along with the drying and curing oven exhaust, a lower overall HAP reduction is achieved at this facility than by facilities controlling only the drying and curing oven exhaust. The overall HAP level of control is compromised due to the decreased residence time in the thermal oxidizer and the high moisture content of the binder application vacuum exhaust. Therefore, because it is not the best controlled source, we do not consider the control of the binder application vacuum exhaust at this facility to represent the MACT floor for new sources.

Currently, we are not aware of any available controls that are better than a thermal oxidizer for controlling gaseous HAP emissions at wetformed fiberglass mat production lines. We considered controlling the binder application vacuum exhaust emissions in addition to the drying and curing oven exhaust emissions. We have determined that controlling the binder application vacuum exhaust emissions with a standalone thermal oxidizer was the only available beyondthefloor option for existing sources. The incremental cost of controlling the binder application vacuum exhaust with a dedicated thermal oxidizer is approximately $39,200/Mg ($35,700/ton) of HAP reduced (Docket No. A97 54). As discussed above, it is not possible to combine the binder application vacuum exhaust with the drying and curing oven exhaust at existing facilities without decreasing the performance of the existing thermal oxidizer. We did not select this control scenario because it achieves a lower overall HAP reduction.

As with existing sources, the only option more stringent than the MACT floor level of control for new sources is control of the binder application vacuum exhaust in addition to controlling the drying and curing oven exhaust. For new sources, a thermal oxidizer could be designed to handle both emission sources. Therefore, for this analysis, we assumed that a single thermal oxidizer would be used to control both the drying and curing oven exhaust and the binder application vacuum exhaust. This assumption was made since controlling the drying and curing oven exhaust and the binder application vacuum exhaust in separate thermal oxidizers would be more expensive than a single thermal oxidizer for both emission sources (Docket No. A9754).

The estimated incremental cost for new sources to control both the drying and curing oven exhaust and the binder application vacuum exhaust with one thermal oxidizer is approximately $12,800/Mg ($11,600/ ton) of HAP reduced. The new source control cost estimates are based on a representative wetformed fiberglass mat production facility controlling both the drying and curing oven exhaust and the binder application vacuum exhaust with a single thermal oxidizer (Docket No. A9754). Based on this evaluation, we concluded that the cost of controlling the binder application vacuum exhaust at new sources is unreasonable at this time.

For each of the cases evaluated above, we did not identify emission control technologies or control of additional emission sources that would reduce emissions to a level below the MACT floor without imposing costs which we concluded are unreasonable at this time. Therefore, we are proposing emission limits at the MACT floor level of control. C. Emission Limits

We have performance data for five facilities in this industry that use thermal oxidizers to control drying and curing oven exhaust streams. Table 4 summarizes the available formaldehyde emissions data from these facilities. However, data from only four thermal oxidizers were used to determine the proposed emission limits. The performance of the thermal oxidizer at the fifth facility was not considered representative of the MACT floor level of control. This facility controls the emissions from the binder application vacuum exhaust using a thermal oxidizer originally designed to control only the emissions from the drying and curing oven exhaust. Because the binder application vacuum exhaust is a cooler and more dilute stream than the drying and curing oven exhaust, the residence time in the combustion chamber is decreased and HAP destruction efficiency is reduced. Therefore, data from plant E in table 4 were not used to determine emission limits for drying and curing ovens.
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Table 4.Summary of Formaldehyde Emission Test Results on WetFormed Fiberglass Mat Production Lines for Drying and Curing Oven Exhaust Average formaldehyde emissions a Calculated Plant Thermal oxidizer parameters b Uncontrolled Controlled control device efficiency (% kg/Mg lb/ton kg/Mg lb/ton destruction) A.................................... 1500 deg.F, 1.25 s RT 1.972 3.945 0.0065 0.013 99.7 B.................................... 1500 deg.F, 1 s RT 0.415 0.830 0.0018 0.0037 99.5 C.................................... 1350 deg.F, 0.75 s RT 0.296 0.591 0.0035 0.0070 98.8 D.................................... 1400 deg.F, 1.2 s RT 0.590 1.18 0.02 0.04 96.4 E c.................................. 1500 deg.F, 0.6 s RT 0.970 1.94 0.095 0.19 90.1 \a\ Emission units are kg (lb) of formaldehyde per Mg (ton) of fiberglass mat product. \b\ RT = Retention time.
\c\ This facility also controls the binder application vacuum exhaust with the thermal oxidizer that was originally designed to control only the drying and curing oven exhaust. Therefore, this thermal oxidizer was not considered representative of the MACT floor level of control.

The controlled emission rates of the four thermal oxidizers that represent the MACT floor level of control range from 0.0018 to 0.02 kg/ Mg (0.0037 to 0.04 lb/ton) and the destruction efficiencies range from 99.7 to 96.4 percent efficiency. We believe that the differences in the performance achieved by the four thermal oxidizers are due to differences in operating temperature, residence time, combustion chamber design, and variations in uncontrolled emissions that occur in this industry. Considering these variables, we consider

FOR FURTHER INFORMATION CONTACT For information concerning the proposed rule, contact Mr. Juan Santiago, Minerals and Inorganic Chemicals Group, Emission Standards Division (MD13), U.S.
Environmental Protection Agency, Research Triangle Park, North Carolina 27711, telephone number (919) 5411084, email address:
santiago.juan@epa.gov. For information regarding Method 316, contact Ms. Rima N. Howell; Emissions, Monitoring, and Analysis Division (MD 19); U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711, telephone number (919) 5410443, email address: howell.rima@epa.gov.


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