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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 industry 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 was 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, CertainTeed

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 chromium 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 emissions and its relation to chromium contents in 

refractories that are used to line glass melting furnaces. Prior to the meeting, NAIMA emailed a 

handout to participants to discuss during the meeting (see Attachment 1). 
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The initial discussion concerned 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 do 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 refractories 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 believes that these industries have similar emissions 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. 

Industry believes that high chromium emissions are associated with oxy-fuel furnaces for the 

following reasons and request that EPA subcategorize furnaces by type. 

Oxyfuel Furnaces:

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

furnaces. 

• Contain hotter flames and higher melting temperatures which cause higher oxidation rates 

of chromium. 

• Have 90% of chromium refractories above the glass line. 

• Have lower NOx emissions, but higher chromium emissions. 

Participants then discussed the location of chromium refractories with respect to the glass line;

industry stated that all refractory above the glass line is chromium 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 to ask how furnace age correlates to emissions

and industry 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 information is contradictory to previous discussions and that they will need more 

information in order to fully understand what exactly is causing some furnaces to have high 

chromium emissions. EPA suggested it may be helpful to contact a refractory expert at Clemson 
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University, industry agreed it would aid in this process and that it 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, Virginia 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, price 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 pricing 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 price.

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 suppliers, 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 other 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 Wednesday, August 31, 2011

Research Triangle Park, NC 2:00 PM – 4:00 PM (Eastern)

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AGENDA

1. Review of NAIMA’s Antitrust Guidelines – Angus 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 On Refractories

b. Oxy Fuel/Gas Furnaces Distinct From Other Fiber Glass Furnaces

• Subcategorization

c. Preserving MACT Non-Applicability for Other Furnaces – Exemption For 

Companies That Have Converted To Non-Phenolic Binder

• Major Source Applicability

4. Discuss Oxy Fuel Furnaces

a. BACT Used on All Furnaces

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