NAIMA 


NORTH AMERICAN INSULATION' 

MAN UFACTU RERS ASSOCIAtION 

VIA E-MAIL AND OVERNIGHT MAIL 

November 14,2014 

Ms. Susan Fairchild 

Sector Policies and Programs Division 

Metals and Minerals Group (D243-02) 

Office ofAir Quality Planning and Standards 

U.S. Environmental Protection Agency 


4930 Old Page Road 


Durham, NC 27703 


RE: 	 Second Request For An Extension of Time; Supplemental notice of proposed 

rulemaking: NESHAP Risk and Technology Review for the Mineral Wool and 

Wool Fiberglass Industries; NESHAP for Wool Fiberglass Area Sources (EP A­ t

HQ-OAR-201O-1041 and EPA-HQ-OAR-20l0-1042) 

Dear Ms. Fairchild: 

The North American Insulation Manufacturers Association ("NAIMA") respectfully requests a 


60-day extension of time to submit comments on the above-referenced supplemental notice of 


proposed rulemaking ("Supplemental Proposal"). NAIMA appreciates the additional time 


afforded by the delay between the release of the Rule and actual publication in the Federal 


Register. With a deadline now set for December 15,2014, NAIMA seeks an additional 60 days 


to process the extensive technical documents that were placed in the docket on November 13, 


2014. These technical documents were not previously available. 


The Supplemental Proposal proposes significant amendments in addition to, and in some cases 


different than, those proposed on November 25,2011 and April 15,2013 for the Mineral Wool 


Production and Wool Fiberglass Manufacturing source categories. EP A has, for example, re­


calculated the majority of emission limits (with the exception of chromium) and has made some 


erroneous assumptions about options available to the fiber glass industry to reduce chromium 


emissions. Moreover, numerous technical support documents, including the Draft Residual Risk 


Assessment, Cost Impacts memorandum, and other key documents became available on 


November 13, 2014. With a December 15, 2014 deadline, NAIMA has only 30 days, which 


includes a major holiday, to review, digest, and analyze over 40 documents. Many of these 


documents are voluminous and entail new analytical approaches by EPA. Accordingly, 60 


additional days are requested for the industry to fully understand and analyze the technical 


documents. 


A 60-day extension will not prejudice EPA's ability to complete this rulemaking by the projected 


2015 deadline. Moreover, such an extension is reasonable and warranted given the long history 


11 CANAL CENTER PLAZA • SUITE 103 • ALEXANDRIA, VA 22314 • TEL 703/684-0084 • FAX 730/684-0427 
Ms. Susan Fairchild 

November 14,2014 

Page 2 

of this rulemaking and the cooperative efforts of the fiber glass (Wool Fiberglass Manufacturing) 

and the rock and slag wool (Mineral Wool Production) industries. 

NAIMA has represented the fiber glass and the rock and slag wool industries since the 

commencement of the residual risk review for Mineral Wool Production with the March 29, 

2007 Advanced Notice of Proposed Rulemaking. (See 72 Fed. Reg. 14,734). Over the past 

seven years, the fiber glass and the rock and slag wool industries have cooperated with EPA to 

respond to its data requests and have appreciated EPA's willingness to engage in dialogue and in 

an exchange of information. The industry also has promptly responded to numerous requests for 

additional information and spent well over $2 million gathering extensive existing and new 

emissions data. NAIMA urges EPA to grant this request for this final phase of the rulemaking 

that is so critical to these industries. 

If you have any questions, please do not hesitate to contact me. 

Sincerely,

-Ana 

Angus E. Crane 


t·~ Executive Vice President, General Counsel 


cc: 	 Mr. Keith W. Barnett 


Group Leader, Office of Air Quality and Planning Standards 


Sector Policies and Programs Division, Mineral and Manufacturing Group 


U.S. Environmental Protection Agency 


4930 Old Page Road 


Durham, NC 27703