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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 [mailto: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 anything with 

the PM emission limits. We weren't challenged on that, or the surrogacy of PM for metals. The test is only important to me for the 

purposes of determining normal operating conditions, and variability 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 the test was for PM from the cupola, it could impact our work here 

because we wanted to say that the binder spray rate is dependent 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 exactly 

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 using 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 visits
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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 after 3 or 

before noon on Tuesday May 3 ? 

Here's the specifics1- Test Data: 

It seems that some of the testing that was sent over was done while the plants were experimenting with control 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 provide 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 that 

we can use in our work. 

2- Acute factor used in Risk Assessment: 

Additionally, I need your help in developing an alternative acute factor. The acute factor is based upon variability in the process. 

 These variability factors include things like how much variability is there in the feedstock (binder ingredients), how much variability 

is there in the operating temps, pressures, how 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 risk 

assessors, under advisement of the Science Advisory Board (SAB), is a factor of 10. That means the emissions of the highest 

risk processes are then multiplied by a factor of 10 to determine the risk during a 'perfect storm' type of situation: the highest 

emissions at the extreme of the variability, the worst meteorological events, and a person at the fenceline to be exposed, etc.. 

 This 10X factor is used as a default in the absence of precise data. So for the 2 plants with uncontrolled collection processes, the 

HQ would be around 30, which is uncomfortably high. I'd like to get specific information on which we can base this acute factor. 

 For this industry, it would only be for those 2 plants (Thermafiber and Rockwool). 

The alternative is to accept the 10X acute factor, and amend the MACT for collection processes. 

It could happen that instead of good business practices, MACT could be amended to require additional control on the 2 plants that 

do not now control collection. Or it could be something as simple as restricting the amount of binder applied to the hot glass 

fibers to not exceed the minimum amount needed to produce the bonded product (the 'housekeeping measures' I'd described 

earlier). I am sure the companies already use these 'housekeeping measures' as principles of good business practice (who 

would deliberately waste their binder by overspraying? Aren't these fully computerized so that if no glass entering the collection 

chamber, no binder would be spraying?) so that type of change to the LinkMACT probably wouldn't be a big deal. But we just 

don't have that information at our fingertips. 
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3- Scheduling visits to Isolatek in Huntington, IN and to Thermafiber in Wabash, IN: I'd like your help in setting up these visits to 

these 2 plants. Specifically, this is not an enforcement inspection, it is for my understanding in writing the rules that will apply to 

these companies, so the more I understand the 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 assessors (the risk values used for formaldehyde) on Friday during my 

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 using the same kind of thinking we used when we created them" --Albert Einstein