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April 12, 2010

Mr. Jeffrey 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 Issues

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 Information 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 is operating at reduced production, 

which means that many lines 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 carbonyl sulfide

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 previously 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 318 and ST 16. This 

comparison 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 plant. Part of that request involved testing for 

formaldehyde, methanol, and phenol at the plant’s #70 line in December 2008. A protocol was 

submitted and reviewed by technical experts from EPA headquarters and Region 7 and approved 

by Adam Kushner at EPA headquarters. The approval specifically authorized California Method 

ST 16:

“At Owens Corning’s discretion EPA Method 8270C ‘Semi-volatile Organic 

Compounds by Gas Chromatography/Mass Spectrometry’ may be used in lieu of 

Analytical Procedure Lab-8, BAAQMD Method ST-16.” (EPA letter to Owens 

Corning dated October 27, 2008.)

The protocol identifies 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 gas chromatography. This method 

was employed, and additional Method 318 sampling was run to identify VOC species previously 

undetected. The Method 318 results were evaluated for known and unknown VOC species. The 

1 hour Method 318 test was evaluated for all VOC species including phenol. The Method ST 16 

and the Method 318 phenol results are compared in the chart below.
Messrs. Jeffrey A. Telander and William Neuffer

April 12, 2010

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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 be hard to accurately 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 Method was as effective as Method 318 and has the decided advantage of reliable 

results and leveraging extensive available data. CertainTeed has provided additional analysis on 

the efficacy of EPA Method TO-8 for phenol. Specifically, in response to EPA Section 114 

requests to conduct source testing for specific VOC emissions at several wool fiberglass 

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. Cary 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 three 
Messrs. Jeffrey A. Telander and William Neuffer

April 12, 2010

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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 separately to 

determine sample breakthrough. The phenols were trapped as phenolates. All samples were 

subsequently analyzed by high performance liquid chromatography (HPLC).

The Athens, Georgia, 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 Part 63 – Test Method (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 (formaldehyde, phenol, and methanol) 

at moisture levels up to 15 percent by 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, Georgia, test as an example, is significantly better than the published practical 

detection limit for Method 318, 0.05 vs. 1.5 ppm, respectively. Similarly, the measured phenol 

concentration of approximately 2 ppm is 40 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 

Methods (“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, Method 5 is often required to be used in place of Method 

27 due to the presence of water droplets that cause Method 27 to provide erroneous readings. 

Method 5 has been a reasonable substitute for Method 201A which is similar to Method 27 

because all of the captured emissions were presumed to be PM10 or finer. In fact, Method 5/202 

has been accepted as an alternative in previous ICRs. See EPRI, “Responding to the EPA 

Information Collection Request for Electric Utility Steam Generating Units,” January 2010. 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

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Knauf Shasta Lake, California - 641 Furnace

Method 5/028

08/06/09 08/06/09 08/06/09 Average

Front Half Filter, lb/hr 0.00 0.00 0.00 0.00

Front Half Wash, 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 Shelbyville, Indiana - 602 Furnace

Method 5/202

11/09/07 11/09/07 11/09/07 Average

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 602 Furnace at 

Shelbyville, Indiana, facilities. There is a third TECO cold top furnace with baghouse in 

operation at the Shelbyville plant. The data in the above tables are from testing using EPA 

Method 5 Modified/202 (Shelbyville) and Method 5/028 (Shasta Lake). The Shelbyville 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 248°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/PM10/PM2.5 emissions from a cold top electric furnace with a baghouse. The filterable PM 

emissions are extremely low. It is reasonable to stipulate that all of the measured filterable PM 
Messrs. Jeffrey A. Telander and William Neuffer

April 12, 2010

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from this source category is PM2.5 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 cold top electric furnace with baghouse 

source category for purposes of responding to the draft ICRs. Both of the testing events 

referenced were witnessed by State and/or local agency representatives and submitted to the 

applicable agency as required in Knauf’s operating permits. Copies 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 SO2, there is virtually no 

difference in measurement results when compared to Method 202. The data comparison between 

Method 202 and OTM 28 indicate that the use of OTM 28 is more important on wet sources. 

Therefore, data captured by Method 5/Method 202 is virtually equivalent 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 separately 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 low. Member companies provided any 

mercury emissions test data they had to NAIMA’s outside counsel. Only two companies had 

mercury emissions test data. One fiber glass facility’s four total tests of three different furnaces 

yielded emissions ranging from 0.17 to 6.5 pounds of mercury per year. Similarly, one mineral 

wool facility reported mercury emissions from multiple tests that range from 0.18 to 0.97 pounds

per year. 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 successfully 

used in high temperature environments. EPA was willing to consider these alternatives if a third 

party could 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 using EPA Method 0061 in high temperature environments.

EPA Method 26A

EPA designated EPA Method 26A for testing of hydrochloric acid and hydrogen fluoride. 

Initially 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. Based on member company responses provided 
Messrs. Jeffrey A. Telander and William Neuffer

April 12, 2010

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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 early 

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 hydrogen fluoride or hydrochloric acid 

and that EPA excuse the wool fiberglass industry from testing for hydrochloric acid.

If EPA desires further discussions on these issues, NAIMA would gladly schedule a conference 

call to bring a final resolution to any of 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.

Sincerely,

Angus E. Crane

Angus E. Crane

Executive Vice President, General Counsel

Enclosure