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VIA E-MAIL

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 (“EPA”) 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 that this information will be helpful to you and others 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 emissions at such low levels. As noted in 

NAIMA’s earlier comments, the control costs EPA cited in the Proposed Rule are far lower than 

the actual control costs the industry would experience under the proposed standards, but even 

those low costs that EPA estimated 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 significant 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 environmental benefit 

jeopardizes the viability of these very companies, the industry in this country, and the jobs the 

industry affords 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 work 
Ms. 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 of work practices in lieu of emissions limits is particularly appropriate for the Wool 

Fiberglass Manufacturing Source Category 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 pollutants 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 low removal efficiencies at very low inlet concentrations.

Because the emissions are so 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 work 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 below-MDL. EPA acknowledged 

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

The Minimum Detection Limit (Level) (“MDL”) is a basic measure of whether a pollutant 

parameter has been detected. That measurement 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. Relying 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 whether 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

Therefore, 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 preferable 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 

limitations2 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 Pollutants,” 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 also 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 was from non-phenol 

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 indicated 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