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 regulating 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 are 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 the 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 been 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. 

Given 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 emissions. 

Lauren P. Alterman

Vice President, Environmental, Health and Safety

Saint-Gobain Corporation

750 E. Swedesford Road

Valley Forge, PA 19482

O - 610-341-7838

C - 610-659-1565

Lauren.p.alterman@saint-gobain.com

ZERO ACCIDENTS, INJURIES OR HEALTH AND ENVIRONMENTAL IMPACTS