# NAIMA

NORTH AMERICAN INSULATION MANUFACTURERS ASSOCIATION VIAE-MAILAND OVERNIGHTMAIL July 30, 2013
Ms. Susan Fairchild SectorPolicies and Programs Division Metals and Minerals Group (D243-02) Office ofAir Quality Planning and Standards U.S. Environmental ProtectionAgency 4930 Old Page Road Durham, NC 27703 RE: Operations and Maintenance WorkPractices For Wool Fiberglass Manufacturing Dear Ms. Fairchild: The Environmental Protection Agency ("EPA") stated specifically: "We are proposing work practice standards for control ofHF and HCl emissions from furnaces, instead ofemission limits

..." (78 Fed. Reg. 22,369, 22,387 (April 15, 2013)) During the development ofproposed rules NNN and NN, emission information was collected by EPA that quantified HF and HCl emissions from wool fiberglass manufacturing glass melting furnaces as being largely below detection limit. These below detection test results support EPA's conclusion that emission limits are impractical, and NAIMA supports EPA's decision to rely upon work practices to address HF and HCl emissions. The following work practices are currently followed by various NAlMA members and, as such, have resulted in and will assure the continued attainment ofthe measured emission levels identified in these proceedings. These Operations and Maintenance Work Practices are consistent with Best Practices identified by governmental and thirdparty entities inother situations. Operations and Maintenance Work Practices are the decisions and actions regarding the control and upkeep ofproperty, equipment, and manufacturing processes. These include, but are not limited to, performance ofroutine preventive/predictive maintenance actions aimed at preventing equipment failure or decline with the objective being maintenance ofefficiency, reliability, and safety. To facilitate the continued operation ofwool fiberglass manufacturing facilities at the HF and HCl emission levels identifiedin the preparationofthe proposed rules, manufacturers will follow individual company Operations and Maintenance Best Practices which typically would include the following:

• Maintain all process and control equipment. • Schedule significant maintenance activities at predeterminedtime intervals.

44 CANAL CENTER PLAZA • SUITE 310 • ALEXANDRIA, VA 22314 • TEL 703/684-0084 • FAX 7031684-0421Ms. SusanFairchild July 30, 2013 Page 2

• Train affected employees in proper operation and maintenance ofcontrol equipment and onwork practices. • Followmanufacturer's recommendations for maintaining control equipment. • Maintain appropriate control device maintenance logs and records. • Use standardized Operations and Maintenance measurement and verificationprotocols. • Assign management of Operations and Maintenance to specific individuals and/or job titles. • Designate operations staffas the first line ofmaintenance or assure thatthey timelynotify maintenance personnel ofissues that needto be addressed. • Maintain adherence to operations and maintenance plan as required by 40 C.F.R. § 63.1383(a). • Maintain quality assurance records for rawmaterials and/or records ofglass formulations indicatingthe facility is maintaining lowHF and HCl emissions. Please do not hesitate to contactthe undersigned ifyouhave any questions. Sincerely,

# ;\v\~J**[;_C)\/~** Angus E. rdrane Executive Vice President, General Counsel

cc: Mr. Keith W. Barnett Group Leader, Office ofAir Quality and Planning Standards SectorPolicies and Programs Division, Mineral and Manufacturing Group U.S. Environmental Protection Agency 4930 Old Page Road Durham, NC 27703