# tblAttachments

AttachDesc:
Alternate Method Request and Approval (Item 8) (optional)


AttachDesc:
EPA Method 1Location Supporting Documentation (Item 9) (optional)


AttachDesc:
Cyclonic Flow Absence Supporting Documentation (Item 10)


AttachDesc:
Sampling Locations Dimensions and Point Locations


AttachDesc:
Run Field Data Sheets (raw data sheets for field sampling)


AttachDesc:
Lab Data (raw data sheets for field and laboratory analysis)


AttachDesc:
Documentation of competence as an AETB and QI for stationary source testing.


AttachDesc:
Results of audit sample analyses and Audit Provider evaluation reports


AttachDesc:
Method 18 data and all supporting information


AttachDesc:
Method 320/321 data and all supporting information


AttachDesc:
Example calculations for reported results


AttachDesc:
PS 12B Facility mercury lab data including QA/QC (as required by 60.8 (f)(2)(v) and 63.7g(2)(v))


# tblComments

Comment:
Montrose is qualified to conduct this test program and has established a quality management system that led to accreditation with ASTM Standard D7036-04 (Standard Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual functional assessments for conformance with D7036-04 which are conducted by the American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose is supervised on site by at least one Qualified Individual (QI) as defined in D7036-04 Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the documented limits in the test methods are met by using approved test protocols for each project as defined in D7036-04 Sections 7.2.1 and 12.10. Additional quality assurance information is included in the report appendices. The content of this report is modeled after the EPA Emission Measurement Center Guideline Document (GD-043).

Please refer to the full test report attached to this ERT submission file for details concerning the test program and any discussion concerning deviations and exceptions. Slight differences in the final calculated values may exist between those calculated in the ERT and those calculated by Montrose spreadsheets due to rounding properties.


# tblMethodParams

TargetPoll:
Total organic compounds (TOC) as Propane

Comments:
Target and/or Minimum Required Sample Duration: Approximately 30 Days

CAS:
Total organic compounds (TOC) as Propane


Comments:
Target and/or Minimum Required Sample Volume: 106 dscf


Comments:
Target and/or Minimum Required Sample Volume: 70 dscf


# tblRunDataITM

FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 1

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 1

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 1

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 1


FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 6

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 6

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 6

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 6


FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 7

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 7

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 7

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 7


FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 2

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 2

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 2

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 2


FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 3

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 3

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 3

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 3


FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 4

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 4

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 4

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 0010 - 4


FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 1

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 1

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 1

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 1


FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 2

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 2

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 2

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 2


FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 3

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 3

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 3

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 3


FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 4

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 4

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 4

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 4


FlowRateRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 5

MoistureRunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 5

CO2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 5

O2RunID:
Banbury Mixer 8 (Mixer 8) - Method 29 - 5


# tblRunLab

Comments:
0.457, [<0.0545] See lab report in test report App. C.1.


Comments:
2.2, [<0.0545] See lab report in test report App. C.1.


Comments:
0.175, [<0.0177] See lab report in test report App. C.1.


Comments:
0.205, [<0.02] See lab report in test report App. C.1.


Comments:
0.335, [<0.0545] See lab report in test report App. C.1.


Comments:
2.17, [<0.0545] See lab report in test report App. C.1.


Comments:
0.111, [<0.0177] See lab report in test report App. C.1.


Comments:
0.0971, [<0.0177] See lab report in test report App. C.1.


Comments:
0.441, [<0.0544] See lab report in test report App. C.1.


Comments:
0.116, [<0.0176] See lab report in test report App. C.1.


Comments:
[<0.25], [<0.0545] See lab report in test report App. C.1.


Comments:
[<0.671], [<0.0545] See lab report in test report App. C.1.


Comments:
[<0.0532], [<0.0177] See lab report in test report App. C.1.


Comments:
[<2.5], 17.3 See lab report in test report App. C.1.


Comments:
[<0.0672], [<0.0186] See lab report in test report App. C.1.


Comments:
[<0.05], [<0.02] See lab report in test report App. C.1.


Comments:
[<0.671], [<0.207] See lab report in test report App. C.1.


Comments:
[<0.0519], 0.0866 See lab report in test report App. C.1.


Comments:
[<0.0562], 0.0526 See lab report in test report App. C.1.


Comments:
[<2.5], 37.2 See lab report in test report App. C.1.


Comments:
[<0.05], 0.0535 See lab report in test report App. C.1.


# tblSubmitActions

Comment:
Rubber Tire ICR ERT Test Plan - The Goodyear Tire & Rubber Company - Fayetteville, NC


# tblTestPlan

TestPurpose:
The purpose of the test program is to perform a temporary continuous emission monitoring (CEM) and stationary source stack testing services in accordance with Enclosure 2, Sections 1.0, 3.0-4.0: Testing Procedures and Methods, and How to Report Data of the Clean Air Act Section 114 Information Collection Request (ICR) for Rubber Tire Manufacturing. The test program will be performed on the Banbury Mixer 4 (BB04-P9-1) and Banbury Mixer 8 (BB08-CE8-1) located at The Goodyear Tire & Rubber Company (Goodyear) Fayetteville facility.

On December 13, 2022, the Environmental Protection Agency (EPA) issued a Clean Air Act Section 114 Information Collection Request (ICR) to multiple entities subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Rubber Tire Manufacturing, codified at Subpart XXXX of Title 40, Part 63 of the Code of Federal Regulations (40 CFR 63). The request seeks specific information about various emission sources, emission inventories, and the manufacturing production processes via a questionnaire (Phase 1; which was issued in June 2022) as well as contains requests for source testing and temporary CEMs (Phase 2).

These rules, which are referred to as the Maximum Achievable Control Technology (MACT) Standards, established emission limits and monitoring requirements for sources considered major under the NESHAP regulations. Major sources are those that emit or have the potential to emit at least 10 tons per year of any single hazardous air pollutant (HAP) or 25 tons per year of any combination of HAPs.

The scope of work which was crafted to comply with the Phase 2 requirements has been designed based on our review and understanding of the US EPA Clean Air Act Section 114 Request Letter, local rules and regulations, related testing procedures set forth in 40 CFR 60, and our experience supporting Rubber Tire Manufacturing.

SourceDesc:
The Goodyear Tire & Rubber Company owns and operates the Fayetteville, NC facility. Air emissions testing will be performed within this facility pursuant to the Clean Air Act Section 114 Information Collection Request.

TestInAccordanceDesc:
EPA Method 25A will actually be modified M25A – modifying Section 8.6.2 of M25A by performing a post-run system bias check and drift assessment every 3 hours for the first 24 hours and then once per day thereafter. Any daily failed QA check will invalidate data back to the last successful QA check.

MeetMinReq:
Please refer to the attached full test report.

CyclonicFlowDesc:
Please refer to the attached full test report.

EquipCalibrationDesc:
Please refer to the attached full test report.

CalibGasCertProcedure:
Please refer to the attached calibraton gas certificates.

TestSchedule:
The Banbury Mixer 4 (Mixer 4) (BB04-P9-1) and Banbury Mixer 8 (Mixer 8) (BB08-CE8-1) ICR testing is Scheduled for January 30 to March 1, 2023.

Please refer to Table 1-1 within the attached full test report for a detailed summary of the test program.

Comments:
ICR requires a minimum sample volume. Run duration and sample point location will be determined during the field testing.

Please refer to the attached full test report for details concerning the test program and any discussion concerning deviations and exceptions. Because the 30-day THC results are being presented on a minute-by-minute basis and the ERT does not support presenting results in that manner, please refer to Appendices A.6 and A.7 of the attached test report for those test data and results at Mixer 4 and Mixer 8, respectively.

PPE:
FR clothing, hard hat, ear plugs, goggles, leather gloves, safety glasses, and steel-toed boots.


# tblWSAttachments

AttachDesc:
Alternate Method Request and Approval Letter


AttachDesc:
Statement about Selling Wood Heaters without an EPA Certificate


