NAIMA and EPA Meeting

April 30, 2012

1:00 PM – 3:00 PM

Wool Fiber Glass Representatives – 1:00 PM – 2:00 PM

1. Angus Crane – NAIMA

2. Granta Nakayama – Kirkland & Ellis

3. Joseph Eisert – Kirkland & Ellis

4. Steve Aldridge – Knauf Insulation

5. Lauren Alterman – CertainTeed Corporation

6. Carlos Davis – CertainTeed Corporation

7. Ken Gould – Owens Corning

8. Ron Hudson – Johns Manville

9. Mike Pettis – Owens Corning

10.Grover Thomas – Guardian Fiberglass

11.Brent Tracy – Johns Manville

Wool Fiberglass Discussion Summary

The EPA reviewed the status of the work and announced that final limits of the rule 

would not be made available during this meeting.

Industry asked whether EPA was intending to restrict or regulate the use of chromium 

refractories in the wool fiberglass industry. NAIMA expressed opposition to such 

regulation because using chromium refractories to construct furnaces benefits the 

industry economically by extending the life of wool fiberglass furnaces. The industry 

asked that chrome limits not be tied to the use of chromium refractories in furnace 

construction.

Industry asked what decisions EPA has made in regard to HF and HCl emission limits. 

The emissions testing indicated that most of the industry could not detect HFand HCl 

emissions in the stack using the test methods, and that the limits proposed were 

unattainable. The added that the inlet concentration of HF and HCl to the controls were 

less than 1 ppm. 
The industry asked for final limits for phenol, formaldehyde and methanol from 

regulated bonded lines (that is, flame attenuation and rotary spin lines using a 

phenol/formaldehyde binder). NAIMA added that the formaldehyde limits in the MACT 

rule should be preserved. EPA addressed this by explaining that retaining the MACT 

formaldehyde limits does not solve their problem of organic HAP control because of the 

phenol and methanol limits, which are other organic HAP species for which EPA 

proposed MACT limits. Further, the 1999 data for formaldehyde and the 2010 data for 

phenol and methanol could not be used together because they were collected so far 

apart they would not have been tested on the same products, much less the same 

batch. Additionally, we are revisiting MACT because it was not properly set in 1999. 

Rather than the level of MACT being set at the ‘floor’ level of control, it was set at a level 

that could be achieved by all sources in the category. EPA explained that the court 

opinion on the record in several cases upholds the actions we are taking, specifically 

that there is a mathematical process to follow in determining the MACT floor. The floor 

must be calculated based on the average of the best performing 12% of existing sources, 

and MACT for new sources must be based on the best performing similar source. It is 

expected that most of the industry would have to improve their performance to meet 

the level being achieved by the average of the 12%, aka the MACT floor. EPA added that 

industry should expect to be impacted and have to meet the MACT floor limits when 

they are finalized.
Mineral Wool Representatives – 2:00 PM – 3:00 PM

1. Angus Crane – NAIMA

2. Granta Nakayama – Kirkland & Ellis

3. Joseph Eisert – Kirkland & Ellis

4. John Bolden – USG Interiors Inc.

5. Chris Bullock – Industrial Insulation Group, LLC

6. Steve Edris – Thermafiber, Inc.

7. Lee Houlditch – Amerrock Products LP

8. Tom Lund – Isolatek International

9. Michael McLaughlin – Roxul Inc.

10.Gerald Miller – Rock Wool Manufacturing

11.Tim Scott – Rock Wool Manufacturing

Mineral Wool Discussion Summary

The EPA reviewed the status of the work and announced that final limits of the rule 

would not be made available during this meeting.

Industry asked to discuss the HF and HCl limits for cupolas. Company representatives 

stated that when EPA asked for emissions testing for HF and HCl, they conducted solid 

materials assays on their cupola raw materials in order to determine the source of 

chlorides and fluorides in the raw materials. Solid material assays could not detect these 

compounds in the raw materials, and emissions testing showed that the emissions were 

very low. One facility operates sorbent injection at their cupola to adsorb SO2, and 

added that they could not reduce their HF and HCl below the current levels by using the 

control device. 

Industry added that there are two kinds of cupolas: closed top and open top. These are 

different designs for cupolas, and this design affects the flow rate and emissions from 

the 2 different cupola designs. Industry spokespersons stated they would speak again 

with EPA on this matter and provide information on each cupola design.