MEMORANDUM

TO: Wool Fiberglass Rulemaking Docket

SUBJECT: Meeting with North American Insulation Manufacturers Association and Wool

Fiberglass Manufacturing Industry Representatives

LOCATION: EPA Offices at 109 TW Alexander Drive, Research Triang le Park

Washington, DC 20001

DATE: June 2, 2015

ATTENDEES AND AFFILIATIONS:

EPA:

Keith Barnett, Group Leader of the Minerals and Manufac turing Group Susan Fairchild, Project Lead Stef Johnson, Measurement and Policy Group Larry Sorrels, Economist, HEID, AEG Hugh McCullough, Environmental Scientist, Region 7 Winifred Okoye, Attorney, Office of General Counsel

Wool Fiberglass Manufacturing Industry

Angus Crane, North American Insulation Manufacturers Association (NAIMA) Steve Aldridge, Knauf Insulation Carlos Davis, Saint Gobain, CertainTeed Corporation Neil Gresham, Saint Gobain, CertainTeed Corporation Ken Gould, Owens Corning Mike Pettis, representing Owens Corning Brent Tracy, Johns Manville

The Wool Fiberglass Industry Representatives met with EPA to discuss emissions testing to be conducted under Section 114 information collection request (IC R) for rotary spin (RS) lines at wool fiberglass manufacturing facilities. The industry provi ded a letter to EPA regarding their preferred approach to the ICR (attached).DISCUSSION ON EMISSION TESTING:

What is to be tested:

EPA stated that all lines that continue to use a phenol/f ormaldehyde (p/f) binder to produce a wool fiberglass product on an RS line will be tested, and t hat lines that have converted to a nonHAP binder do not need to be tested.

The EPA asked how many lines that are still permitted to use a p/f binder are still in operation in the industry. The industry asserted that each company o perates one such line, with the exception of Owens-Corning which operates two such lines. This is a tot al of 5 such lines in the industry.

Test methods that will be used: The industry requested the use of wet chemistry methods i nstead of method 318 to conduct the emissions testing because the wet chemistry methods a re easier for them to use and they are familiar with those methods.

Stef Johnson with the EPA will discuss with the meth ods development team to consider this, and will work with the project lead to develop a testing proto col.

The EPA stated that emissions test method to be used sho uld be an EPA approved air method, should be for the pollutants to be measured (phenol, meth anol, and formaldehyde) and should not be biased (either high or low) for bonded lines.

Dataset size: The EPA wants to avoid obtaining a small dataset. Because only 5 lines are to be tested, and three runs per line, the total emissions testing would pro duce 15 data points if the standardized type of emissions testing is conducted.

Length of test program: Industry added that emissions are seasonally-dependent and va ry considerably between summer and winter. They further added that winter months can pr esent difficult testing problems, especially in the Central North and Midwest US. The EP A suggested 6 months to conduct the emissions testing, which should start in the summer of 2015 and continue into the fall and winter. The industry asked to conduct emissions testing for at lea st a year, between mid-2015 through mid-2016. It was agreed that the industry would conduct a minim um of three tests each consisting of three runs on each RS line using a p/f bind er as follows:

Test 1- July/August 2015 Test 2- December 2015/ January 2016 Test 3- June/July 2016

Timing:

The EPA stated that the ICR will be mailed out before June 18, the signature date of the final rule.DISCUSSION ON THE EMISSION LIMITS FOR WOOL FIBERGLAS S:

The industry asked what EPA planned to promulgate for the final limits in the rule for bonded lines and for gas-fired furnaces, and whether the final l imits for chromium would be increased over the proposed limit or remain the same as at propo sal.

The EPA declined to specify the emission limits, but noted t hat the chromium emission limit would be increased to account for new furnaces, and that t he proposed MACT emission limits for RS bonded lines are planned to be deferred pending the 114 re sults.

The EPA asked whether the industry thought the use of cul let would be curtailed under higher limits, and the industry replied that this would likely no t be an issue for them for compliance purposes under a higher limit.