44 Canal Center Plaza ▪ Suite 310 ▪ Alexandria, Virginia 22314 ▪ Tel: (703) 684
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**VIA E -** **MAIL** April 12 , 2010

Mr. Jeff rey A. Telander Sector Policies and Programs Division Metals and Minerals Group (D243

- 02) Office of Air Quality

Planning and Standards U.S. Environmental Protection Agency 109 TW Alexander Drive Research Triangle Park, NC 27711 Mr. William Neuffer Sector Policies and Programs Division Metals and Minerals Group (D243

- 02) Office of Air Quality

Planning and Standards U.S. Environmental Protection Agency 109 TW Alexander Drive Research Triangle Park, NC 27711 RE : Follow

-Up on Test Method I ssues Dear Messrs. Telander and Neuffer: The North American Insulation Manufacturers Association ( “NAIMA” ) appreciated the opportunity

to discuss with the Environmental Protection Agency ( “ EPA” ) on Monday, March 29 , 2010 the appropriate test methods for emissions data that will be provided to EPA pursuant to the In formation Collection Requests ( “ ICRs ” ) for the wool fiberglass and mineral wool MACT Standards

. In a letter to EPA dated March 26, 2010, NAIMA requested EPA’s consideration of alternative test methods to those identified in the draft ICRs. NAIMA explained that use of alternative test methods was important because of the extensive data collected by these alternative methods and the fact that every company i s operating at reduced production, which means that many

l ines are not operating and new data could not be collected for those non- operating lines.Messrs . Jeffrey A. Telander and William Neuffer April 12, 2010 Page 2 During the March 29, 2010 conference call, EPA agreed to accept data collected by the following alternatives:

 EPA Method 316 for formaldehyde  EPA Method 308 for methanol  SW
- 846 Method 8270D for phenol  EPA Method 10 for carbon monoxide  EPA Methods 15 and 320 for carbonylsulfide NAIMA also asked for EPA to consider other alternatives for which the Agency indicated it would need additional support or explanation as to the relevance and reliability of these test methods. This letter sets forth that additional support for the following alternative test methods: California Method ST 16/Gas Chromatography
– Phenol As previousl y noted, California Method ST 16 is as effective as Method 318 for testing of phenol and has the decided advantage of providing reliable results and leveraging extensive available data. NAIMA specifically referenced side

-by

- side comparisons of Method 3 18 and ST 16. This comparis on is provided by Owens Corning: During December 2008, Owens Corning responded to an EPA Section 114 request to quantify its VOC emissions from its Kansas City p lant. P art of that request involved testing for formaldehyde, methanol, and phenol at the plant’s #70 line in December 2008
. Aprotocol was submitted and reviewed by technical experts from EPA headquarters and Region 7 and approved by Adam Kushner at EPA headquarters . The approval specificall y authorized California Method ST 16 : “At Owens Corning’s discretion EPA Method 8270C ‘ Semi

- volatile Organic Compounds by

G as Chromatography

/Mass Spectrometry ’ may b e use d in lieu of Analy tical Procedure Lab

- 8, BAAQMD Method ST
- 16
. ” (EPA letter to Owens Corning dated October 27, 2008.) The protocol identifie s ST 16 for phenol and a method modification substituting a standard Method 5 train for sample collection. The samples are collected in the impingers which are filled with a solution of 0.1 normal (0.1N) sodium hydroxide which absorbs the phenolic compounds. The phenolic compounds are then analyzed by g as chromatography. This method was employed , and additional Method 318 sampling was run to identify V OC species previously undetected. The Method 318 results were evaluated for known and unknown VOC species. The 1 hour M ethod 318 test was evaluated for all VOC species including phenol. The Method S T 16 and the M ethod 318 phenol results are compared in the chart below.Messrs . Jeffrey A. Telander and William Neuffer April 12, 2010 Page 3 Phenol Comparison Results 70 line Testing December 2008 **Location Phenol Results lbs/hr**  **Modified ST -**  **16 Phenol Results lbs/hr**  **FTIR (M -** **318) Forming**  **Zone A .249**  **< .07 Forming**  **Zone C .436**  **< .09 Forming**  **Zone D .258**  **< .09 Oven Charge**  **.032 < .02**  **Oven Dis -**  **Charge .024**  **< .02 Cooling**  **ND < .03**  The testing results were obtained on the same product during subsequent days because simultaneous testing was not possible

. From this data, there appears to be a large amount of line loss for phenol using Method 318. Phenol also comes off near the water band where for forming sources with saturated levels of water, the phenol peak may b e hard to accuratel y quantify

. The stated range for ST 16 for phenolic compounds is 200 ppb at the sample volume specified in this method ; however, the sample volume was approximately 3 times the standard volume. EPA Method TO

- 8

– Phenol Testing NAIMA also requested that EPA accept Method TO
- 8 as an alternative test method for phenol. Again, this M ethod was as effective as Method 318 and has the decided advantage of reliable results and lev eraging extensive available data. CertainTeed has provided additional anal ys is on the efficac y of EPA Method TO
- 8 for phenol. S pecificall y, in response to EPA Section 114 requests to conduct source testing for specific VOC emissions at several wool f iberglass insulation plants, EPA approved the use of EPA Method TO
- 8 for determining phenol and methyl phenols emissions

. Testing associated with these Section 114 requests was conducted at the following CertainTeed Plants: Mountain Top, PA August 2007 Athens, GA January 2009 Kansas City, KS January 2009 Chowchilla, CA January 2009 The detailed source test reports were submitted to both the applicable Regional (3, 4, 7 and 9) and headquarters offices of EPA. C ary Secrest at EPA headquarters was very involved in these Section 114 test protocols. Phenol Emissions

– EPA Compendium Method TO

- 8 The concentration of phenol in the flue gas stream was collected using sampling procedures outlined in Method TO

- 8. The flue gas was withdrawn at a constant rate through a Teflon probe and passed through a series of glass midget impingers contained in an ice bath. The first threeMessrs . Jeffrey A. Telander and William Neuffer April 12, 2010 Page 4 impingers contained 15 ml of 0.1 N NaOH followed by a dry impinger, and then an impinger containing silica gel. At the completion of each test, the contents of the first two impingers were recovered together in a glass vial and sealed with a Teflon lined screw cap. The contents of the third and fourth impinger were recovered separately in a glass vial and analyzed separatel y to determine sample breakthrough. The phenols were trapped as phenolates. All samples were subsequently

anal yz ed by

high performance liquid chromatography (HPLC). The Athens, G eorgia, sample event, for example, had an ND blank value of 5.5 g per sample for the TO
- 8 sample train. This would equate to in

- stack detection limits of 0.0481 ppm, 0.0677 lb/hr, and 0.00857 lb/ton. The actual samples had “catches” ranging from 241 to 309 g
– well above the detection limits of the method at the ~ 2 ppm range observed in the stack. Section 1.3.2. of Appendix A to P art 63

– T est M ethod (Method 318

– Extractive FTIR Method for the Measurement of Emissions from the Mineral Wool and Wool Fiberglass Industries ) provides: “In general, a 22 meter pathlength cell in a suitable sampling system can achieve practical detection limits of 1.5 ppm for three compounds (formaldehyd e, phenol, and methanol) at moisture leve ls up to 15 percent b y volume.” Based on CertainTeed ’s experience, NAIMA asserts that the use of Method TO
- 8 as an alternative to Method 318 is an appropriate source test method. The in

- stack detection limit, using the Athens, G eorgia, test as an example, is significantl y better than the published practical detection limit for Method 318, 0.05 vs. 1.5 ppm, respectivel y . S imilarly, the measured phenol concentration of approximately 2 ppm is 4 0 times higher than the TO
- 8 detection limit and only slightly above the Method 318 detection limit. EPA Method 5 /202 NAIMA requested that EPA Method 5/202 be allowed as an alternative to EPA Other Test Method s (“OTM”) 27 and 28. NAIMA expressed concern that some stacks might not be able to accommodate an OTM 27 probe without significant blockage, which adds variability to emission test procedures and results . In addition, M ethod 5 is often required to be used in place of M ethod 27 due to the presence of water droplets that cause M ethod 27 to provide erroneous readings. M ethod 5 has been a reasonable substitute for M ethod 201A which is similar to M ethod 27 because all of the captured emission s were presumed to be PM 10 or finer. In fact, Method 5/202 has been accepted as an alternative in previous IC Rs. See EPRI , “Responding to the EPA In formation Collection Request for Electric Utility S team Generating Units,” January 2 010. In comparison testing on furnaces, this has proved to be true as illustrated by the comparison below from Knauf Insulation involving cold top furnaces with baghouses :Messrs . Jeffrey A. Telander and William Neuffer April 12, 2010 Page 5


### Knauf Shasta Lake, California **- 641 Furnace**  **Me thod 5/028**  **08/06/09 08/06/09**  **08/06/09 A**  **verage** Front Half Filter, lb/hr 0.00 0.00 0.00 0.00 Front Half Wa sh, lb/hr 0.06 0.01 0.00 0.02 **Front Half, lb/hr 0.06**  **0.01 0.00**  **0.02** Back Half Aqeous, lb/hr 0.07 0.06 0.05 0.06 Back Half MeCl, lb/hr 0.03 0.09 0.05 0.006 **Back Half, lb/hr 0.10**  **0.15 0.10**  **0.12 Total, lb/hr**  **0.162 0.152**  **0.100 0.14**  

### Knauf Shelby

**ville, Indiana -**  **602 Furnace Me**  **thod 5/202 11/09/07**  **11/09/07 11/09/07**  **Av erage**  Front Half, lb/hr 0.08 0.04 0.06 0.06 Back Half, lb/hr 0.82 0.51 0.56 0.63 **Total, lb/hr 0.990**  **0.55 0.62**  **0.69**
The above tables provide test data from testing events at two TECO cold top electric furnaces with baghouses for PM control: 641 Furnace at Shasta Lake, California , and 60 2 Furnace at Shelby ville, Indiana , facilities

. There is a third TECO cold top furnace with baghouse in operation at the Shelby

ville plant. The data in the above tables are from testing using EPA Method 5 Modified/202 (Shelby ville) and Method 5/028 (Shasta Lake). The Shelby ville data was generated using the Subpart NNN referenced modified Method 5 for front half PM. The modified Method 5 requires a filter temperature of no greater than 350°F +/

- 25°F vs. the standard Method 5 filter temperature of 2 48 °F +/

- 25 °F. The 202 vs. 028 data appears to show the bias between the two methods and would support the move to the proposed revised/modified 202 (OTM 28). Both sets of data support the contention that front half Method 5 data is representative of PM/PM 10/PM2.5 emissions from a c old top e lectric furnace with a baghouse. The filterable PM emissions are extremely

l ow. It is reasonable to stipulate that all of the measured filterable PMMessrs . Jeffrey A. Telander and William Neuffer April 12, 2010 Page 6
from this source category i s PM 2.5 or less due to the low mass collected and the fact that the sampling occurred after a high efficiency baghouse. Therefore, the existing Shasta Lake Method 5/028 data should be accepted as representative for the c old top electric furnace with b aghouse source category

f or purposes of responding to the draft ICRs . B oth of the testing events referenced were witnessed by State and/or local agency representatives and submitted to the applicable agency

a s required in Knauf’s operating permits. C opies of the full test reports are available and will be submitted in the response to the applicable draft ICR questions. OTM 28 is a new method that has not been used extensively in the fiber glass industry

. Limited use of this method indicates that on dry melter sources with little SO 2 , there is virtually no difference in measurement results when compared to M ethod 202. The data comparison between M ethod 202 and OTM 28 indicate that the use of OTM 28 is more important on wet sources. Therefore, data captured by M ethod 5/M ethod 202 is virtually e quivalent to data captured by OTM 27/OTM 28 for electric melters and furnaces. EPA Method 30B NAIMA requested that EPA Method 29 be used to test for mercury . NAIMA pointed out that mercury was not used in the manufacturing process, so there was not a need to separatel y test for mercury . EPA indicated that it would consider NAIMA’s request if it could be demonstrated that the threshold for mercury emissions was sufficiently l ow. Member companies provided any mercury emissions test data they had to NAIMA’s outsi de counsel. O nly two companies had mercury emissions test data. One fiber glass facility ’s four total tests of three different furnaces yi elded emissions ranging from 0.17 to 6.5 pounds of mercury per ye ar. S imilarly, one mineral wool facility

reported mercury

emissions from multiple tests that range from 0.18 to 0.97 pound s per ye ar. Based on the low mercury emissions, separate testing for mercury pursuant to EPA Method 30B is not warranted for the wool fiberglass and mineral wool insulation industries

. EPA Method 306 and CARB 425 NAIMA requested that EPA consider EPA Method 306 and CARB 425 as alternatives to EPA Method 0061 for hexavalent chromium because Method 0061 cannot always be successfull y used in high temperature environments. EPA was willing to consider these alternatives if a third party c ould validate the problems described by NAIMA and its members. NAIMA acquired the opinion of Bureau Veritas, attached hereto , which confirmed NAIMA’s characterization of the possible complications with u sing EPA Method 0061 in high temperature environments. EPA Method 26A EPA designated EPA Method 26A for testing of hydrochloric acid and hydrogen fluoride. Initiall y NAIMA did not believe there was a basis for testing for either of these emissions. EPA requested that NAIMA survey its members to determine if fluorspars or similar minerals are used in the manufacturing process that might trigger hydrogen fluoride emissions or other substances that would trigger hydrochloric acid emissions

. B ased on member company responses providedMessrs . Jeffrey A. Telander and William Neuffer April 12, 2010 Page 7

to NAIMA’s outside counsel, there is a basis for wool fiberglass manufacturers to test for hydrogen fluoride. This data will be included in the industry response. There is not, however, a basis for such a test in the mineral wool industry as mineral wool facilities do not utilize fluorspars or similar minerals which would provide a basis for testing of hydrogen fluoride

. There was a fraction of hydrogen fluoride in a mineral wool facility in a report from the earl y 1990s that was based on an emissions factor. The survey indicated that neither wool fiberglass nor mineral wool have a basis to test for hydrochloric acid

. NAIMA requests that EPA therefore not require the mineral wool industry to test for either hydro gen fluoride or hydrochloric acid and that EPA excuse the wool fiberglass industry from testing for hydrochlori c acid.
If EPA desires further discussions on these issues, NAIMA would gladl y schedule a conference call to bring a final resolution to any o f these remaining issues. Based on this letter, NAIMA requests that EPA allow the use of alternative test methods as described herein in order to expedite completion of the ICR. Sincerel y, **Angus E. Crane** Angus E. Crane Executive Vice President, General Counsel Enc losure