44 Canal Center Plaza ▪ Suite 310 ▪ Alexandria, Virginia 22314 ▪ Tel: (703) 684
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**VIA E -** **MAIL** March 26, 2010
Mr. Jeff rey 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 Request s 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 pre existing and new emissions data to be provided to EPA in response to the draft In formation Collection Requests ( “ ICRs ” ) that we are presently defining for the mineral wool and wool fiberglas s 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 i s recommending these alternative test methods because it has extensive data collected by these alternative methods that are relevant to EPA ’s request s . The importance of existing data becomes even more important given the fact that every c ompany 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. N ew data could not be collected for those lines simply b ecause 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 l imited data and experience with Method 318, the vast majority of exis ting data has been collected with other EPA and California methods which EPA has approved for use in recent Section 114 emissions data c ollections, 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 S T
- 16/gas chromatography, EPA Method TO
- 8, and SW
- 846 Method 8270 D for phenol ; EPA Method s 10 and 15 for carbon monoxide; and EPA Method s 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. M oreover, at EPA’s request and in connection with S ection 114 request s , two NAIMA member companies ran side
-by
- side comparison s o f Method 318 and alternative wet chemistry m ethod s which confirmed that the test methods produced essentially

the same results. NAIMA can provide documentation of the s e comparison test s . 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 applicati on 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 yi elding methanol and formic acid. S ince methanol could be created during the process of collecting and testing the emissions and thereby artificiall y increas ing the methanol emissions, Method 308 is employed. M ethod 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 o f existing data makes acceptance of these alternatives desirable. Inaddition, OTM 27 and 28 are not promulgated methods; therefore, the industry h as very l imited 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 o f emissions from these processes are PM 2.5 , so NAIMA and its member companies propose that they can , for IC R testing purposes, stipulate that all the PM emissions reported in response to the draft IC R are PM 2 .5 , and that they u seMessrs . 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 separatel y test for mercury in wool fiberglass and mineral wool plants because mercury i s not used in the manufacturing process . It may b e in the raw materials used to make insulation products in trace amounts
. Indeed, if any m ercury is present , it will be captured at extremely low levels by Method 29 (see section 1.1 (Anal ytes)).

 The draft ICR identifies EPA Method 0061 be used to determine hexavalent chromium
. Method 306 and CARB 425 have been approved for determinin g 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
. Inaddition, Method 0061 cannot be successfully used in high temperature environment s . 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 thi s 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. T o request testing beyond the parameters of the actual test methods undermines the integrity of the test method, is unnecessary, and would effectively e liminate the use of the industries’ extensive ex isting 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

o f the data. The majority o f these test methods have a one -hour length; detection limits are set to work within the designated timeframe. I f the detected amount of the pollutant is one or two orders of magnitude above the detection limit, extending the time and reduc ing 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 newl y 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. Sincerel y, **Angus E. Crane** Angus E. Crane Executive Vice President, General Counsel