1 Date: August 31, 2011

Subject: Minutes of the August 31, 2011 Meeting with Representatives of the Wool Fiberglass Industry and NAIMA

I. Introduction

A meeting with representatives of the North American Insulation Manufacturer’s Association (NAIMA) and the wool fiberglass manufacturing industries was held at the U.S. Environmental Protection Agency (EPA) facility in Research Triangle Park, NC

, on August 31, 2011 . The purpose of the meeting w as to discuss chromium and hexavalent chromium emissions fr om glass melting furnaces at wool fiberglass facilities

. This memorandum summarizes the major topics discussed during the meeting

.

II. Attendees

Steve Aldridge, Knauf Insulation Lauren Alterman, CertainTeed Brian Baker, Knauf Insulation Ken Gould, Owens Corning Ron Hudson, Johns Manville Mike Metz, Guardian Fiberglass Mike Pettis, Owens Corning Grover Thomas, Guardian Fiberglass Brent Tracy, Johns Manville Angus Crane, NAIMA Christopher Martin, NAIMA Susan Fairchild, U.S. EPA, OAQPS Winifred Okoye, U.S. EPA, OGC Keith Barnett, U.S. EPA, OAQPS Carlos Davis, CertainTeed Cindy Hancy, RTI International Richard Marinshaw, RTI International

III. Discussion

The purpose of this meeting was for EPA to discuss chromium and hexavalent chromium emissions from glas s melting furnaces with the wool fiberglass industry. The discussion focused on the large range of chromium and hexavalent chromium emissions and its relation to chrome

contents in refractories. Prior to the meeting, NAIMA emailed a handout to participants that would be discussed in the meeting, this is included in Attachment 1.

The initial discussion concerned the composition of chrome refractories. According to NAIMA’s

handout

, chromium contents in furnaces are similar across the industry and do not seem to correlate with chromium emissions, which makes it difficult to determine which furnaces have2 high chromium emissions. Industry believes that chromium emissions have more to do with the furnace type than with the chromium content of the r efractory. The following paragraphs highlight the discussion on chromium refractories and glass melting furnaces.

IV. Chromium Refractories

In addition to NAIMA’s handout showing chromium contents of furnaces and emissions , Saint Gobain provided further inf ormation as to why they do not believe chromium emissions are related to chromium contents in refractories. Saint Gobain is one of the primary producers of

chromium refractories in the US, which are used in several industries (insulation glass, container

g lass, and e

- glass). Depending on the industry, these refractories contain different amounts of

chromium. Saint Gobain believe s that these industries have similar emissions profiles

, which

shows that chromium refractory content is not directly correlated wi th chromium emissions. Industry believes that chromium emissions are more related to furnace type. NAIMA also stressed the economic importance of chromium refractories in the wool fiberglass industry.

V. Glass Melting Furnace Information

After Saint Gobain’s discussion of chromium refractories, an Owens Corning representative

discussed

, in detail

, the differences between each furnace type, focusing on oxy

- fuel furnaces. Industry believes that high chromium emissions are related to oxy

- fuel furnaces fo r the following

reasons and proposed to subcategorize furnaces by type.

Oxyfuel Furnace:

• Use the same type of refractories as other furnaces, but contain more “walls” than other

furnaces.

• Contain hotter flames and higher melting temperatures. Cause high er oxidation rates of

chrome.

• Oxyfuel furnaces also have 90% of chrome refractory above the glass line.

• Gives less NOx, but higher chrome emissions.

Participants then discussed the location of chrome refractories with respect to the glass line ; indust ry stated that all refractory above the glass line is chrome refractory and can equal in 20,000 lb/yr of refractory losses. Industry also explained that chromium emissions do not necessarily come from the glass and refractory contact line. EPA proceeded to ask how furnace age correlates

to emissions and i ndustry responded that it is not related to chrome emissions because the part of the refractory that gets “eaten” away is under the glass line and not exposed to oxidizing air. EPA

believes this information is contradictory to pre vious discussions and that they will need more information in order to fully understand what exactly is causing some furnace to have high chrome

emissions . Participants decided that EPA would contact a refractory expert at Clemson U niversity

and Indu stry would aid in this process and that industry would supply any additional information that would be helpful.

VI. General Information3 NAIMA and industry representatives also discussed the phasing out of phenolic binders and

wanted to kno w if they would still be “out” of the rule once facilities phased these binders out. EPA stated that it is not trying to find new ways to make the subject to the rule, but that chromium

emissions are both risk and “brick” issues that need to be addressed a nd subcategorization may or may not be possible. Participants discussed possible requirements that could be proposed (i.e., area source rule, regulated source definition, source tests, etc.) and the possibility of an extension. EPA

felt that an extension w ould be nearly impossible. See also notes from EPA meetings with Certainteed from both the project lead, Susan Fairchild, USEPA/OAQPS/SPPD and Hugh McCullough, Region 7.