44 Canal Center Plaza ▪ Suite 310 ▪ Alexandria, Virginia 22314 ▪ Tel: (703) 684-0084 ▪ Fax: (703) 684-0427

VIA E-MAIL

March 26, 2010

Mr. Jeffrey A. Telander

Sector Policies and Programs Division

Metals and Minerals Group (D243-02)

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

109 TW Alexander Drive

Research Triangle Park, NC 27711

Mr. William Neuffer

Sector Policies and Programs Division

Metals and Minerals Group (D243-02)

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

109 TW Alexander Drive 

Research Triangle Park, NC 27711

RE: Draft Information Collection Requests for the Mineral Wool and Wool Fiberglass 

Insulation Manufacturing Industries

Dear Messrs. Telander and Neuffer:

The North American Insulation Manufacturers Association (“NAIMA”) and its member 

companies appreciate the opportunity to discuss with the Environmental Protection Agency 

(“EPA”) on Monday, March 29, 2010 at 3:00 PM (EDT), the appropriate test methods for preexisting and new emissions data to be provided to EPA in response to the draft Information 

Collection Requests (“ICRs”) that we are presently defining for the mineral wool and wool 

fiberglass insulation manufacturing industries’ residual risk review.

To facilitate that discussion, NAIMA and its member companies have reviewed the test methods 

set forth in the draft ICRs and are identifying below alternative test methods that will enable us 

to provide EPA the data it needs while both expediting the information collection process and 

leveraging the use of existing emissions data. The industry is recommending these alternative 

test methods because it has extensive data collected by these alternative methods that are relevant 

to EPA’s requests. The importance of existing data becomes even more important given the fact 

that every company is operating at reduced production due to the significant economic downturn 

in the building industry. Therefore, companies have specific lines that are not operating at this 

time. New data could not be collected for those lines simply because they are not in operation, 
Messrs. Jeffrey A. Telander and William Neuffer

March 26, 2010

Page 2

even though they are currently permitted. Existing data will be essential for providing EPA with 

the requisite data for all point sources.

 EPA Method 318 is used to collect information concerning emissions of formaldehyde, 

phenol, methanol, carbonyl sulfide, and carbon monoxide. While NAIMA members have 

only limited data and experience with Method 318, the vast majority of existing data has 

been collected with other EPA and California methods which EPA has approved for use 

in recent Section 114 emissions data collections, but were not identified in the draft ICRs.

 NAIMA requests that EPA accept the following alternative methods: EPA Method 316 

for formaldehyde; EPA Method 308 for methanol; California Method ST-16/gas 

chromatography, EPA Method TO-8, and SW-846 Method 8270D for phenol; EPA 

Methods 10 and 15 for carbon monoxide; and EPA Methods 10, 15 and 320 and AP-42 

emission factors for carbonyl sulfide. These test methods are as effective as Method 318 

and have the decided advantage of providing reliable results and leveraging extensive 

available data. Moreover, at EPA’s request and in connection with Section 114 requests, 

two NAIMA member companies ran side-by-side comparisons of Method 318 and 

alternative wet chemistry methods which confirmed that the test methods produced 

essentially the same results. NAIMA can provide documentation of these comparison 

tests. In addition, some test companies have limited experience with Method 318, and

the NAIMA member companies and their consultants who have used Method 318 have 

experienced trouble perfecting its application and at times have encountered some 

inaccurate and inconsistent results.

 As noted above, another alternative method to determine methanol is Method 308. While 

Method 318 is designated by EPA to test methanol, there is a reaction called the 

Cannizaro reaction which can generate more methanol in the collection process, or even 

during the process of testing for methanol. In the Cannizaro reaction, when heated, 

formaldehyde in the resin is known to undergo a disproportionate reaction yielding 

methanol and formic acid. Since methanol could be created during the process of 

collecting and testing the emissions and thereby artificially increasing the methanol 

emissions, Method 308 is employed. Method 308 would avoid the creation of artificial 

methanol emissions since it does not use a heated sampling line.

 NAIMA requests that members have the option of using EPA Methods 5 and 202 as well 

as EPA Other Test Method (OTM) 27 and 28. Again, the availability of existing data 

makes acceptance of these alternatives desirable. In addition, OTM 27 and 28 are not 

promulgated methods; therefore, the industry has very limited experience conducting or 

using these test methods. Given EPA’s desire for an expedited response, it makes little 

sense for companies to use a method with which they have limited knowledge and 

experience. Moreover, some stacks might not be able to accommodate an OTM 27 probe

without a significant amount of blockage, which adds variability to the emission testing 

procedure. The vast majority of emissions from these processes are PM2.5, so NAIMA 

and its member companies propose that they can, for ICR testing purposes, stipulate that 

all the PM emissions reported in response to the draft ICR are PM2.5, and that they use 
Messrs. Jeffrey A. Telander and William Neuffer

March 26, 2010

Page 3

Method 5 for filterable emissions and Method 202 for condensable emissions to measure 

them, as alternatives to EPA OTM 27 and 28.

 The draft ICR identifies EPA Method 30B for measuring mercury. NAIMA should be 

allowed to use EPA Method 29 as well. There is no need to separately test for mercury in 

wool fiberglass and mineral wool plants because mercury is not used in the 

manufacturing process. It may be in the raw materials used to make insulation products

in trace amounts. Indeed, if any mercury is present, it will be captured at extremely low 

levels by Method 29 (see section 1.1 (Analytes)).

 The draft ICR identifies EPA Method 0061 be used to determine hexavalent chromium. 

Method 306 and CARB 425 have been approved for determining hexavalent chromium 

emissions, too. NAIMA requests that Method 306 and CARB 425 be allowed for chrome 

emissions data. Existing data using these methods are available. In addition, Method 

0061 cannot be successfully used in high temperature environments. Since the exhaust in 

some stacks have high temperatures, Method 0061 is not practical for our industries.

 EPA Method 26A is irrelevant to the mineral wool and wool fiberglass insulation 

industries, and these industries have no experience with this method. Therefore, it should 

not be used in responding to the draft ICRs.

Finally, with respect to all test methods, NAIMA intends to provide test data acquired from tests

run for the length of time prescribed by the applicable test method, not for some longer period of 

time. To request testing beyond the parameters of the actual test methods undermines the

integrity of the test method, is unnecessary, and would effectively eliminate the use of the 

industries’ extensive existing data. For example, one hour should be more than sufficient for all 

the organics to be measured. Moreover, any deviation from a test method could call into 

question the legitimacy of the data. The majority of these test methods have a one-hour length; 

detection limits are set to work within the designated timeframe. If the detected amount of the 

pollutant is one or two orders of magnitude above the detection limit, extending the time and 

reducing the detection limit does not provide any additional substantive or meaningful 

information because the pollutant in question has already been detected and measured.

Because NAIMA is providing a response for the entire industry, it is requested that both existing 

and newly acquired data not be submitted through the Electronic Reporting Tool.

If you have any questions in advance to the conference call, please do not hesitate to contact me.

Sincerely,

Angus E. Crane

Angus E. Crane

Executive Vice President, General Counsel