1

Date: July 16, 2013

Subject: Minutes of the July 16, 2013 meeting with Representatives of the Wool Fiberglass

Manufacturing Industry

I. Introduction

A meeting with representatives of the North American Insulation Manufacturers Association (NAIMA) and th e wool fiberglass manufacturing industr y was held with U.S. Environmental Protection Agency (EPA) staff on July 16, 2013 . The purpose of the meeting w as to discuss aspects of the supplemental proposal for wool fiberglass manufacturing

. This memorandum

sum marizes the major topics discussed during the meeting

.

II. Participants

Carlos Davis, CertainTeed

– Saint Gobain Ken Gould, Owens Corning Mike Pettis, Owens Corning Grover Thomas, Guardian Fiberglass Angus Crane, NAIMA Brent Tracy, Johns Manville

Sherri Live ngood, Johns Manville Bruce Ray, Johns Manville Steve Aldridge, Knauf Susan Fairchild, U.S. EPA, OAQPS

Steffan Johnson , U.S. EPA, O AQPS Keith Barnett, U.S. EPA, OAQPS Ray Merrill, U.S. EPA, OAQPS Larry Sorrels, U.S. EPA, OAQPS

Dave Reeves , RTI Internationa l Cindy Hancy, RTI International

III. Discussion

NAIMA supports setting a chromium limit, but is concerned that the limit is too low and that the wet scrubber EPA proposed is not feasible for the wool fiberglass industry. NAIMA believes that

the caustic scrub ber works in other chromium emitting industries because they emit chromium mostly in a vapor form, but because wool fiberglass furnaces emit mostly particulate chromium this type of control is not “transferable” to the wool fiberglass industry. Additionall y, NAIMA

believes EPA has underestimated the cost of caustic scrubbers and has not taken into account other factors such as disposal costs.

Carlos Davis discussed two scrubbers used at CertainTeed . Carlos emphasized that these scrubbers

were not similar to the wet caustic scrubbers proposed by EPA. He described as a dry scrubber upstream from an ESP which is primarily used for PM Control . This scrubber is treated with a caustic mist in order to turn the effluent into an inorganic salt . The second scrubber at CertainTeed is for SO2 control and has a dry effluent. Carlos stated that the installation cost for one of these2

scrubbers was around 1 million dollars (which does not include operational costs ) . He also noted the difficulty and time it took to install the scrubber and noted that a wet scrubber would be difficult to install because of the high inlet temperature (~425F)

. Industry noted that because facilities only need to reduce chromium by a few pounds per year the cost effectiveness of installing a scr

ubber is very high (hundreds of thousands per pound). In response to EPA questions, industry representatives stated that they have gotten several proposals for wet scrubbers from different vendors. These proposals have varied in design (packed bed, HEPA, v enture, etc.) and industry stated the vendors were unsure if it would work and could not guarantee certain

chromium control.

Industry believes that a more feasible way for facilities to meet the chromium limit will be to alter the batch composition by u sing less cullet, specifically green

- bottle cullet. Industry representatives stated that they have always known that recycled cullet contributes to chromium emissions, but did not bring it up in earlier conversations with EPA because those discussions were on trying to reduce hundreds of pounds of chromium from furnaces , which would not be achievable by reducing the amount of cullet used. Industry representatives gave examples of how furnaces with higher cullet batch compositions tend to have higher chromiu m emissions and noted that they are worried that some furnaces that met the limit, have increased cullet use and may not be meeting the limit anymore. Industry emphasized that wool fiberglass is one of the few industries that can use recycled cullet and gr een

- bottle cullet which has a higher percentage of chromium. Industry also stated that cullet providers do not have any testing that shows how much chromium is in the

cullet , but Owens C orning is running a baseline test to see what chromium emissions are u sing no

cullet in the raw material.

NAIMA also raised concerns with the 1 year compliance period and stated it would not be enough time to install a scrubber. Industry stated that a pilot program would be necessary to see if the wet

scrubber would be fea sible and that everything about using a wet caustic scrubber for chromium control would be “experimental” in nature. Industry representatives stated they would need at least a 3 year compliance period. NAIMA noted that they already achieve 97.5

- 99% chrom ium control with ESPs and also discussed that historically

, production of wool fiberglass has never had a liquid effluent, but adding a wet scrubber will lead a liquid effluent high in chromium.

EPA stated that the current chromium limit allows furnaces to emit around 3

- 5 pounds of chromium per year. Industry would like to see a limit that allows 20

- 25 lbs/yr which they calculated would still have low risk implications and stated that even at 12 lb/yr they would likely have to alter their batch chemistry. Industry also noted if the chromium limit was increased they would not need a longer compliance period.

NAIMA also asked EPA keep the original formaldehyde limit, keep the surrogacy for phenol and methanol, clarify the applicability of area sources, rem ove air gas furnaces from having to meet chromium emission limits, and remove oxy

- fuel furnaces with risk of less than 1

- in

- 1million from having to comply with the chromium emission limits. NAIMA also asked for EPA not to change the applicability regarding heavy density and pipe products, because industry only tested product s subject to the rule. Industry is concerned that they have products that will not meet the current limits but cannot test each product. EPA discussed the possibility of a concentration based

standard , but stated only including heavy density and pipe in the original rule may be a discrepancy EPA needs to fix

. Lastly, NAIMA asked for clarification of HF/HCl work practice3

standards. EPA concluded by discussing ways to use the M29 and M0061 testing to find out how much hex chromium is particulate and/or what the composition of the “residual” hex chromium is in order to figure out the best method to control it.

.