From: "Alterman, Lauren P." < Lauren.P.Alterman@saint

- gobain.com >
To: Jeff Telander/RTP/USEPA/US@EPA, Bill Neuffer/RTP/USEPA/US@EPA, Bill Neuffer/RTP/USEPA/US@EPA, Susan

Fairchild/RTP/USEPA/US@EPA

Date: 07/27/2012 10:32 AM Subject: Chrome emissions and refractory bricks

I received an update from Angus Crane, General Counsel of NAIMA, regarding a call he recently had with Susan Fairchild about the proposed Mineral Wool Production and Wool Fiberglass Manufacturing rulemaking. Based on comments Ms. Fairchild made to Angus, coupled with comments Ms. Fairchild has made in the past to the Wool Fiberglass Manufacturers, as well as comments on EPA’s website about the proposed rulemaking, Saint

- Gobain requests a meeting with the individuals at EPA, and any of its consultants, that are in any way involved with, or have made comments that chrome emissions from the Wool Fiberglass Manufacturing facilities is caused by the refractory bricks in the furnaces used in this industry.

As you know, Saint

- Gobain, through its wholly owned subsidiary, CertainTeed Corporation, manufacturers wool fiberglass insulation. As we have discussed with Ms. Fairchild on several occasions, Saint

- Gobain also manufactures refractory bricks that are used in many different types of glass furnaces (E

- glass, container glass and wool fiberglass). I do not think that EPA has sufficiently researched or understands refractory bricks in glass furnaces, and as a result, EPA’s comments, including comments Ms. Fairchild has made about refractory bricks and their relationship to chrome emissions are misleading and inaccurate and have the potential to adversely affect the refractory brick industry.

As you may recall, when we learned that EPA thought that chrome emissions were caused by refractory bricks,
Saint

- Gobain offered to provide EPA with information about refractory bricks. We offered EPA the opportunity to discuss refractory bricks with a Saint

- Gobain R&D specialist. EPA initially said they would welcome the opportunity to learn more, but then said “they did not have the time.” I realize EPA has obtained some information from Clemson University, but that information is not complete. However, that information supports Saint

- Gobain’s opinion about refractory bricks. Perhaps longing for a quick answer as to where chrome emissions come from, EPA has drawn conclusions about the use of chrome in refractories that was not complete or accurate. I have expressed our concern that EPA did not have adequate information about refractory bricks to EPA.

Saint

- Gobain, CertainTeed and the other members of NAIMA welcomed the decision EPA announced at one of the meetings in North Carolina, as well as on one of the industry groups’ calls with EPA, that EPA had determined it would not consider regula ting or in any way attempting to limit what type of refractory bricks are used in the fiberglass industry. It appeared that EPA had heard our concerns, listened to the limited information from Clemson University, and also recognized that “how” emissions ar e controlled is for industry to decide, not EPA.

However, Ms. Fairchild made a statement to Mr. Crane in the call mentioned above in which she appeared to do an about face on EPA’s decision. Ms. Fairchild stated that EPA is considering requiring the Wool Fiberglass manufacturers to “go to a lower chrome content refractory and that would reduce emissions.” In addition, on EPA’s website there is the following statement:

“It is believed that refractory bricks used in CertainTeed’s manufacturing process are t he source of the facility’s chromium VI emissions. To determine if these emissions may pose health concerns for local residents, EPA Region 7 decided to conduct air monitoring at John Garland Park, located between the facility and nearby residential

areas. ” (That monitoring did not reveal any cause for concern.)

These statements resurrect EPA’s lack of understanding of refractories and the history of glass furnaces in general.It is disappointing that EPA made these statements, not only because they have b een made without adequate research about refractory bricks, but because it is well understood that EPA’s role is to set limits on emissions based on sound science and how an industry or facility meets those limits is up to that industry or facility.

Give n Ms. Fairchild’s recent comments to Mr. Crane Saint

- Gobain and CertainTeed are asking EPA to affirmatively state what their intentions are regarding the attempt to regulate the chrome content in refractory bricks as opposed to setting a limit on chrome em issions.

**Lauren P. Alterman Vice President, Environmental, Health and Safety**  **Saint**

**- Gobain Corporation**  **750 E. Swedesford Road Valley Forge, PA 19482**  **O**

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