1 From: Marinshaw, Richard

Sent: Thursday, April 28, 2011 9:58 AM

To: Reeves, David; Hancy, Cindy Wang; Bronstein, Katherine Subject: FW: Mineral Wool testing and potential site visits

Categories: Purple Category



### FYI

From: Fairchild.Susan@epamail.epa.gov [mailt o:Fairchild.Susan@epamail.epa.gov]

Sent: Thursday, April 28, 2011 9:56 AM

To: Angus Crane Subject: RE: Mineral Wool testing and potential site visits

I'm meeting with Rick Marinshaw at RTI in their CBI office this afternoon, and I'll be able to have a better understanding of the problems then. I think I need to clarify that the PM data is not is important in itself because I'm not planning to do anythin g with the PM emission limits. We weren't challenged on that, or the surr ogacy of PM for metals. The te st is only important to me fo r the purposes of determining normal operating conditions, and variabilit y components of those conditions. Which, of course, speaks to

that acute factor that feeds into the risk calculation for hazard quotient.

Formaldehyde is the risk driver for this category. And although t he test was for PM from the cupola, it could impact our work here because we wanted to say that the binder spray rate is depen dent on cupola production, and production is continuous, steady and within known boundaries. So the conclusion would have been that the formaldehyde emissions can not exceed the binder spray rate, which is computerized? automated? or otherwise tied to and dependent on production.

Although the slag/rock/glass, etc. fed into the cupola may vary a lot, it was my (maybe incorrect?) understanding that this is not the case with the binder, which is made according to a specific recipe. It's mixed up in batches at the plant and then sprayed continuously during the collection phase, before curing. I need to understand what factors limit the variability of this part of the

process.

Before I get into the specifics of what that may include, I'd like to have that meeting with Rick so he and I can understand e xactly what we need, and what to ask for from the plants. Remember, that information would only be limited to Thermafiber, Rockwool, and IIG (the 3 bonded lines).

Susan Fairchild

Environmental Scientist U.S. Environmental Protection Agency

direct line: 919.541.5167

fax: 919.541-3207 email: fairchild.susan@epa.gov

Overnight mail address:

US EPA

Mail Code D243-02

109 TW Alexander Drive RTP, NC 27709

"We can not solve our problems by usin g the same kind of thinking we used when we created them" --Albert Einstein

From: Angus Crane <acrane@naima.org>

To: Susan Fairchild/RTP/USEPA/US@EPA

Date: 04/27/2011 05:15 PM

Subject: RE: Mineral Wool testing and potential site visits2 One question ‐ Can you identify for me the plant or plants with high PM emissions. This will help me to facilitate getting more accurate data.

Angus E. Crane

Executive Vice President, General Counsel

North American Insulation Manufacturers Association

Ph: (703) 684

‐ 0084 ext. 123

Fax: (703) 684

‐ 0427

Visit NAIMA online at:

www.NAIMA.org
www.PipeInsulation.org

From: Fairchild.Susan@epamail.epa.gov [ mailto:Fairchild.Susan@epamail.epa.gov ]

Sent: Wednesday, April 27, 2011 4:42 PM

To: Angus Crane Subject: Mineral Wool testing and potential site visits

I would like to set up a time to discuss with you 3 issues I am facing. Are you available either Thursday after 4, Friday afte r 3 or before noon on Tuesday May 3 ?

Here's the specifics1- Test Data:

It seems that some of the testing that wa s sent over was done while the plants were experimenting with co ntrol devices, process changes, or both. They may have been intended for internal use only. One of these showed the plant was operating at levels exceeding 5X the MACT PM limit.

I believe the plants were putting forth a good faith effort to pr ovide EPA with all their test data, but we shouldn't be using data that's not representative of the processes. I'd like to discuss with you how we should proceed; there may be better PM data th at

we can use in our work.

2- Acute factor used in Risk Assessment:

Additionally, I need your help in developing an al ternative acute factor. The acute fact or is based upon variability in the p rocess. These variability factors includ e things like how much variability is there in the feedstock (binder in gredients), how much va riability is there in the operating temps, pressures, ho w continuous is the process (vs batch), etc.

The acute factor is used to develop the Hazard Quotient, or HQ in the Risk assessment. The default acute factor used by the ris k
assessors, under advisement of the Science Advisory Board (SAB) , is a factor of 10. That m eans the emissions of the highest risk processes are then multiplied by a fact or of 10 to determine the risk during a ' perfect storm' type of situation: the high est

emissions at the extreme of the variabilit y, the worst meteorological events, and a per son at the fenceline to be exposed, etc.

. This 10X factor is used as a default in the absence of precis e data. So for the 2 plants with uncontrolled collection process es, the HQ would be around 30, which is uncomfortably high. I'd like to get specific information on which we can base this acute facto r. For this industry, it would only be for those 2 plants (Thermafiber and Rockwool).

The alternative is to accept the 10X acute fact or, and amend the MACT for collection processes. It could happen that instead of good business practices, MACT could be amended to r equire additional control on the 2 plants th at do not now control collection. Or it could be something as si mple as restricting the amount of binder applied to the hot glas s fibers to not exceed the minimum amount needed to produce t he bonded product (the 'housekeeping measures' I'd described earlier). I am sure the companies already use these 'houseke eping measures' as principles of good business practice (who would deliberately waste their binder by overspraying? Aren't t hese fully computerized so that if no glass entering the collec tion
chamber, no binder would be spraying?) so that type of change to the 

### Link MACT probably wouldn't be a big deal. But we just don't have that information at our fingertips.3 3- Scheduling visits to Isolatek in Hunt ington, IN and to Thermafiber in Wabash, IN : I'd like your help in setting up these vi sits to these 2 plants. Specifically, this is not an enforcement inspection, it is for my und erstanding in writing the rules that will apply to these companies, so the more I understand t he better. Rules of CBI apply as always.

Here is the risk assessment document that I promised:

I will be asking for the other documentation from the risk assess ors (the risk values used for fo rmaldehyde) on Fr iday during m y meeting with them.

Susan Fairchild

Environmental Scientist U.S. Environmental Protection Agency

direct line: 919.541.5167

fax: 919.541-3207

email: fairchild.susan@epa.gov

Overnight mail address:

US EPA

Mail Code D243-02

109 TW Alexander Drive RTP, NC 27709

"We can not solve our problems by usin g the same kind of thinking we used when we created them" --Albert Einstein