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May 7 , 2012

Ms. Susan Fairchild Sector Policies and Programs Division Metals and Minerals Group (D243

- 02) Office of Air Quality Planning and Standards U.S. Environmental Protection Agency

109 T

. W

. Alexander Drive Research Triangle Park, NC 27711

RE: Follow

- Up To April 30 , 2012 Meeting with NAIMA’s Wool Fiberglass Members

Dear Ms. Fairchild :

The North American Insulation Manufacturers Association (“NAIMA”) appreciated the opportunity to meet with the Environmental Protection Agency (“E PA”) on April 30 , 2012

. EPA provided additional clarification that was greatly appreciated by NAIMA , namely that : 1) EPA did not intend to regulate the chrome content in refractories; and 2) EPA does not intend to change the definition of affected sources

. This letter provides specific information regarding some of the topics NAIMA was able to discuss during that meeting. This letter is a supplement to NAIMA’s comments filed on February 3, 2012; it is not a replacement of those comments. NAIMA hopes tha t this information will be helpful to you and other s in finalizing the Rule

.

With respect to chrome, EPA has indicated that there is likely to be a lbs/ton of melt chrome limit for some sources. In that context, it is important to note that all affected sources have already installed extensive control equipment, and any additional reduction expectations from

EPA need to be cost

- effective. Moreover, if the new limits are too stringent, available pollution control equipment cannot reliably control the emis sions at such low levels

. As noted in NAIMA’s earlier comments, the control costs EPA cited in the Propos ed Rule are far lower than the actual control costs the industry would experience under the proposed standards, but even

those low costs that EPA esti mated were $600,000 to $24,000,000 per ton of chromium removed. EPA’s cited range, which is lower than what the industry would actually pay, is NOT

cost

- effective. Moreover, as NAIMA’s written comments documented, the fiber glass industry

has been in a s ignificant downturn for several years, along with most of the building industry.

That downturn continues and there is no indication that there will be a dramatic turnaround. Therefore, requiring additional controls for marginal or non

- existent environmen tal benefit jeopardizes the viability of these very companies , the industry in this country, and the jobs the industry afford s to many workers.

Specifically, with respect to EPA ’s proposed limits on HF and HCl, NAIMA, in its comments submitted on February 3, 2012 and during the April 30 meeting, urged EPA to allow workMs . Susan Fairchild May 7 , 2012 Page 2

practices to substitute for an HF and HCl emissions limit. Specifically, NAIMA recommended, and still recommends, adherence to manufacturer’s operations and maintenance (“O&M”). Adoption o f work practices in lieu of emission s limits is particularly appropriate for the W ool

F iberglass M anufacturing S ource C ategory because the entire industry emits a total of 20 tons per year of HF and 12 tons per year of HCl. This very low level of pollutan ts combined with the fact that the inlet concentrations of HF and HCl into the control device would be extremely low ( even sub

- PPM in many cases ) effectively argue against imposition of specific limits. Moreover, the available control devices have very lo w removal efficiencies at very low inlet concentration s

.

Because the emissions are s o low and the concentrations are, by and large, non

- quantifiable, a work practice standard is an appropriate alternative. EPA certainly has the authority to promulgate wo rk practice standards. In the Brick MACT case, the court noted that EPA could set

work practice standards where measuring emission levels are technologically or economically

infeasible. Given the fact nearly all of the HF and HCl data for wool fiberglass were near or

below

- MDL, and given that EPA has recognized that data near or below

- MDL has uncertainty that makes it not possible to meaningfully quantify the concentration, NAIMA asserts that

measurement of HF and HCl emissions is technologically infeasible. Even with extended run times in many cases, a greater percentage of the test results were non

- detectable and virtually none of them would have been quantifiable.

In fact, the majority of HF and HCl data available to EPA was b elow

- MDL. EPA acknowledged during the meeting that at least 55 percent of the test results were below the detection levels.

The M inimum Detection Limit (Level) ( “ MDL ” ) is a basic measure of whether a pollutant parameter has been detected. That measureme nt is the minimum concentration at which there can be confidence that the effluent concentration is greater than zero. The Quantification Level ( “ QL ” ) is the minimum concentration at which there can be confidence that the numerical result

is accurate. Re lying on below

- MDL data is problematic:

The “minimum detection limit” (MDL) represent the point at which a measurement can be said to be distinguished from a blank. In other words, it is simply the threshold at which one can feel confident in saying whet her the pollutant even is present in the sample. At or near the MDL, the uncertainty associated with the measurement will be very high. While one can say that the pollutant is present, it is not possible to meaningfully quantify the concentration. 1

Ther efore, should EPA insist on regulating HF and HCl, a work practice standard is 1) an appropriate means for doing so ; 2) it is feasible ; and 3) it is consistent with EPA’s characterization during the meeting of a circumstance where work practices were prefe rable to a

numerical limit

. EPA has proposed to regulate dioxins/furans and other organic HAPs from electric generating units (“EGOs”) through work practice standards rather than numerical

limitations 2 because emissions of such compounds are generally so low they cannot be accurately measured. The levels of HF and HCl emissions suggested from the Wool Fiberglass

1 RMB Consulting & Research, Inc. Memorandum, Comments on Proposed EGU MACT Rule, July 19, 2011, p. 18.

2 URS, “Assessment of Technology Options Available to Achieve Reductions of Hazardous Air Poll utants,” April 5, 2011, p. 3. See also ERG Memorandum posted on EPA website at www.epa.gov/ttn/atw/boiler/mjr_impacts_memo_reconsideration_proposal_final .pdf

.Ms . Susan Fairchild May 7 , 2012 Page 3

Manufacturing Source Category provide a similar parallel and work practices should be established rather than specific numerical limits.

NAIMA a lso urges EPA to carefully select those plants used to set the MACT floor for formaldehyde, phenol, and methanol. Previously, EPA set the MACT floor for formaldehyde, phenol, and methanol using plants that were area sources, plant data that w as from non

- p henol formaldehyde sources, and data that was not MACT testing data. To the extent any data came from sources that do not meet the definition of an affected source, the calculations should be

revised to exclude that data.

During the meeting, EPA indicate d that another opportunity would be afforded NAIMA to obtain an outline of the Proposed Rule in a conference call held in mid

- May. NAIMA looks forward to that opportunity.

If you have any questions, please do not hesitate to contact me. For the record, the positions set forth herein were first articulated in NAIMA’s comments submitted on February 3, 2012.

Sincerely,

Angus E. Crane Executive Vice President, General Counsel

cc: Mr. Keith W. Barnett Group Leader, Office of Air Quality and Planning Standards Sector Policies and Programs Division, Mineral and Manufacturing Group U.S. Environmental Protection Agency

109 T

. W

. Alexander Drive (D243

- 04) Research Triangle Park, NC 27711

Mr. Steve Fruh Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency 109 T.W. Alexander Drive (D205

- 01) Research Triangle Park, NC 27711

Mr. Peter Tsirigotis

Director , Sector Policies and Program Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency 109 T.W. Alexander Drive (C404

- 04) Research Triangle Park, NC 27711