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 Triangle Park 

 Washington, DC 20001 

DATE: June 2, 2015 

ATTENDEES AND AFFILIATIONS: 

EPA: 

Keith Barnett, Group Leader of the Minerals and Manufacturing 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 (ICR) for rotary spin (RS) lines at 

wool fiberglass manufacturing facilities. The industry provided 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/formaldehyde (p/f) binder to produce a 

wool fiberglass product on an RS line will be tested, and that 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 operates one such line, with the exception 

of Owens-Corning which operates two such lines. This is a total of 5 such lines in the industry. 

Test methods that will be used: 

The industry requested the use of wet chemistry methods instead of method 318 to conduct the 

emissions testing because the wet chemistry methods are easier for them to use and they are 

familiar with those methods. 

Stef Johnson with the EPA will discuss with the methods development team to consider this, and 

will work with the project lead to develop a testing protocol. 

The EPA stated that emissions test method to be used should be an EPA approved air method, 

should be for the pollutants to be measured (phenol, methanol, 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 produce 15 data points if the standardized 

type of emissions testing is conducted. 

Length of test program: 

Industry added that emissions are seasonally-dependent and vary considerably between summer 

and winter. They further added that winter months can present difficult testing problems, 

especially in the Central North and Midwest US. The EPA 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 least a year, between mid-2015 through 

mid-2016. It was agreed that the industry would conduct a minimum of three tests each 

consisting of three runs on each RS line using a p/f binder 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 FIBERGLASS: 

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 limits for chromium would be increased 

over the proposed limit or remain the same as at proposal. 

The EPA declined to specify the emission limits, but noted that the chromium emission limit 

would be increased to account for new furnaces, and that the proposed MACT emission limits 

for RS bonded lines are planned to be deferred pending the 114 results. 

The EPA asked whether the industry thought the use of cullet would be curtailed under higher 

limits, and the industry replied that this would likely not be an issue for them for compliance 

purposes under a higher limit.