NAIMA 

NORTH AMERICAN INSULATION 

MANUFACTURERS ASSOCIATION 

VIA E-MAIL AND OVERNIGHT MAIL 

July 30, 2013 

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 

4930 Old Page Road 

Durham, NC 27703 

RE: Operations and Maintenance Work Practices For Wool Fiberglass Manufacturing 

Dear Ms. Fairchild: 

The Environmental Protection Agency ("EPA") stated specifically: "We are proposing work 

practice standards for control of HF and HCl emissions from furnaces, instead of emission limits 

... " (78 Fed. Reg. 22,369, 22,387 (April 15, 2013)) 

During the development of proposed 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 N AlMA members and, as such, have resulted in and will assure 

the continued attainment of the measured emission levels identified in these proceedings. These 

Operations and Maintenance Work Practices are consistent with Best Practices identified by 

governmental and third party entities in other situations. 

Operations and Maintenance Work Practices are the decisions and actions regarding the control 

and upkeep of property, equipment, and manufacturing processes. These include, but are not 

limited to, performance of routine preventive/predictive maintenance actions aimed at preventing 

equipment failure or decline with the objective being maintenance of efficiency, reliability, and 

safety. 

To facilitate the continued operation of wool fiberglass manufacturing facilities at the HF and 

HCl emission levels identified in the preparation of the 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 predetermined time intervals. 

44 CANAL CENTER PLAZA • SUITE 310 • ALEXANDRIA, VA 22314 • TEL 703/684-0084 • FAX 7031684-0421 
Ms. Susan Fairchild 

July 30, 2013 

Page 2 

• Train affected employees in proper operation and maintenance of control equipment and 

on work practices. 

• Follow manufacturer's recommendations for maintaining control equipment. 

• Maintain appropriate control device maintenance logs and records. 

• Use standardized Operations and Maintenance measurement and verification protocols. 

• Assign management of Operations and Maintenance to specific individuals and/or job 

titles. 

• Designate operations staff as the first line of maintenance or assure that they timely notify 

maintenance personnel of issues that need to be addressed. 

• Maintain adherence to operations and maintenance plan as required by 40 C.F.R. 

§ 63.1383(a). 

• Maintain quality assurance records for raw materials and/or records of glass formulations 

indicating the facility is maintaining low HF and HCl emissions. 

Please do not hesitate to contact the undersigned if you have any questions. 

Sincerely, 

;\v\~J [;_C)\/~ Angus E. rdrane 

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 

4930 Old Page Road 

Durham, NC 27703