1 Date: August 31, 2011

Subject: Minutes of the August 31, 2011 Meeting with Representatives of the Wool Fiberglass Industry and NAIMA

From: Cindy Hancy, RTI International

I

. Introduction

A meeting with representatives of the North American Insulation Manufacturer’s Association (NAIMA) and the wool fiberglass manufacturing industr y was held at the U.S. Environmental Protection Agency (EPA) facility in Research Triangle Park, NC

, on August 31, 2011 . The purpose of the meeting w as to discuss chromium and hexavalent chromium emissions from glass melting furnaces at wool fiberglass facilities

. This memorandum summarizes the major topics discussed during the meeting

.

II

. Attendees

Steve Aldridge, Knauf Insulation Lauren Alterman, Ce rtainTeed Brian Baker, Knauf Insulation Ken Gould, Owens Corning Ron Hudson, Johns Manville Mike Metz, Guardian Fiberglass Mike Pettis, Owens Corning Grover Thomas, Guardian Fiberglass Brent Tracy, Johns Manville Angus Crane, NAIMA Christopher Martin, NAIMA Susan Fairchild, U.S. EPA, OAQPS Winifred Okoye, U.S. EPA, OGC Keith Barnett, U.S. EPA, OAQPS Carlos Davis, CertainTeed Cindy Hancy, RTI International Richard Marinshaw, RTI International

III

. Discussion

The purpose of this meeting was to discuss ch romium and hexavalent chromium emissions from glass melting furnaces with the wool fiberglass industry. The discussion focused on the large range of chromium and hexavalent chromium emis sions and its relation to chromium contents in

refractories that are u sed to line glass melting furnaces

. Prior to the meeting, NAIMA emailed a handout to participants to discuss during the meeting (see Attachment 1 )

.2 The initial discussion con cerned the composition of chromium refractories. According to

NAIMA’s handout

, chromium contents in furnaces are similar across the industry and do not seem to correlate with chromium emissions, which makes it difficult to determine which furnaces have high chromium emissions. Industry believes that chromium emissions have more to d o with the furnace type than with the chromium content of the refractory. The following paragraphs highlight the discussion on chromium refractories and glass melting furnaces.

IV

. Chromium Refractories

In addition to NAIMA’s handout showing chromium contents of furnaces and emissions , Saint Gobain provided further information as to why they do not believe chromium emissions are related to chromium contents in refractories. Saint Gobain is one of the primary producers of

chromium refr actories in the US, which are used in several industries (insulation glass, container glass, and e

- glass). Depending on the industry, these refractories contain different amounts of

chromium. Saint Gobain believe s that these industries have similar emissio ns profiles

, which

shows that chromium refractory content is not directly correlated with chromium emissions. Industry believes that chromium emissions are related to furnace type. NAIMA also stressed the economic importance of chromium refractories in the wool fiberglass industry.

V

. Glass Melting Furnace Information

After Saint Gobain’s discussion of chromium refractories, an Owens Corning representative

discussed

, in detail

, the differences between each furnace type, focusing on oxy

- fuel furnaces.

Industr y believes that high chromium emissions are associated with oxy

- fuel furnaces for the following reasons and request that EPA subcategorize furnaces by type.

Oxyfuel Furnace s :

• Use the same type of refractories as other furnaces, but contain more “walls” t han other

furnaces.

• Contain hotter flames a nd higher melting temperatures which cause higher oxidation rates

of chromium

.

• Have 90% of chrom ium refractor ies above the glass line.

• Have lower NOx emissions , but higher chrom ium emissions.

Participants then discussed the location of chrom ium refractories with respect to the glass line ; industry stated that all refractory above the glass line is chrom ium refractory and one industry spokesperson estimated that 20,000 pounds per year of refractory are worn away from the inside walls of one wool fiberglass furnace and ducted to the control device before venting to the atmosphere

. Industry also explained that chromium emissions do not necessarily come from the glass and refractory contact line. EPA proceeded t o ask how furnace age correlates to emissions

and i ndustry responded that it is not related to chromium emissions because the part of the refractory that gets “eaten” away is under the glass line and not exposed to oxidizing air. EPA

believes this informat ion is contradictory to pre vious discussions and that they will need more information in order to fully understand what exactly is causing some furnace s to have high

chrom ium emissions

. EPA suggested it may be helpful to contact a refractory expert at Clem son3 University, i ndu stry agreed it would aid in this process and that i t would supply any additional information that would be helpful.

VI

. General Information

NAIMA and industry representatives also discussed the phasing out of phenolic binders and wanted to know if they would still be “out” of the rule once facilities phased these binders out. EPA stated that it is not trying to find new ways to make facilities subject to the rule, but that

chromium emissions are both risk and “brick” issues that need to be addressed and subcategorization may or may not be possible. Participants discussed possible requirements that could be proposed (i.e., area source rule, regulated source definition, source tests, etc.) and the possibility of an extension. EPA indicated that an extension would be unlikely

. See also notes from EPA meetings with Certainteed from both the project lead, Susan Fairchild, USEPA/OAQPS/SPPD and Hugh McCullough, Region 7.Approved May 26, 1994

44 Canal Center Plaza ▪ Suite 310 ▪ Alexandria, Virgin ia 22314 ▪ Tel: (703) 684

- 0084 ▪ Fax: (703) 684

- 0427 ANTITRUST GUIDELINES FOR NAIMA MEETINGS

DON'Ts

Do not, whether seriously or in jest, in fact or in appearance, discuss or exchange information regarding:

PRICES, INCLUDING:

• Individual company prices, price changes, pr ice differentials, pricing patterns or policies, terms and conditions of sale affecting price such as mark

- ups, discounts, allowances, credit terms, warranties, the content of labels, indemnification agreements, etc.

• Industry pric ing policies, price levels, price changes, pricing procedures, profit margins or other data that bear on price.

• Individual company data on costs, production, capacity, inventory, sales, profit margins or other data that bear on pr ice.

PRODUCTION, INCLUDING:

• Changes in industry production, capacity, inventories (including planned or anticipated changes);

and

• Individual company plans concerning the design, production, distribution or marketing of particular products or product features, including possible or proposed customers or territories;

MARKETING PROCEDURES, INCLUDING:

• Matters relating to dealing or not dealing with actual or potential individual su ppliers, customers, or competitors that might have the purpose or the effect of excluding them from any market, or any part thereof;

• Territorial restrictions, allocations of customers, restrictions on types of products or any othe r kind of market division; and

• Bids on contracts or procedures for responding to bids.North American Insulation Manufacturers Association

MEETING OF NAIMA WITH ENVIRONMENTAL PROTECTION AGENCY

EPA Wednes day

, A ugust 31, 2011 Research Triangle Park, NC 2 : 00 P M

– 4 : 0 0 PM (Eastern)

..................................................................................................................... AGENDA

1

. Review of NA IMA’s Antitrust Guidelines

– A ngus Crane (Attachment)

2

. Introductions and Opening Remarks

– Angus Crane

3

. Presentation of Data on Chrome Content of Refractories and Chrome Emission

a

. Chrome Content of Bricks

• Background O n Refractories

b

. Oxy Fuel / Gas Furnaces Dis tinct From Other Fiber Glass Furnaces

• Subcategorization

c

. Preserving MACT Non

- Applicability for Other Furnaces

– E xemption F or Companies That Have Converted To Non

- Phenolic Binder

• Major Source Applicability

4

. Discuss Oxy Fuel Furnaces

a

. BACT Used on All Furnace s b

. Level of Risk

c

. MACT Floor

d

. Options

• Furnaces Exempted That Do Not Exceed Risk Threshold

• Chrome Content

• Threshold Limit

5

. Presentation of Formaldehyde Data

6

. October 2011

– Federal Register Notice of Proposal

a

. 60 or 90 Day Comment Period

7

. HF or HCl?

a

. Not a Risk Driver

8

. Other Issues

9

. Adjournment