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 the wool fiberglass manufacturing industry was held with U.S. Environmental 

Protection Agency (EPA) staff on July 16, 2013. The purpose of the meeting was to discuss

aspects of the supplemental proposal for wool fiberglass manufacturing. This memorandum 

summarizes 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 Livengood, Johns Manville

Bruce Ray, Johns Manville

Steve Aldridge, Knauf

Susan Fairchild, U.S. EPA, OAQPS

Steffan Johnson, U.S. EPA, OAQPS

Keith Barnett, U.S. EPA, OAQPS

Ray Merrill, U.S. EPA, OAQPS

Larry Sorrels, U.S. EPA, OAQPS

Dave Reeves, RTI International

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 scrubber 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. Additionally, 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 these 
2

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 scrubber 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, venture, 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 using 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 chromium 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 green-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 Corning is running a baseline test to see what chromium emissions are using 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 feasible 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% chromium 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, remove 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 products

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 practice 
3

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. 

.