# NAIMA

NORTH AMERICAN INSULATION' MAN UFACTU RERS ASSOCIAtION
VIAE-MAIL AND OVERNIGHT MAIL November 14,2014

Ms. SusanFairchild SectorPolicies and Programs Division Metals andMinerals Group (D243-02) Office ofAir QualityPlanning and Standards U.S. Environmental ProtectionAgency 4930 Old Page Road Durham,NC 27703 RE: Second Request For An Extension of Time; Supplemental notice ofproposed rulemaking: NESHAP Risk and Technology Review for the Mineral Wool and Wool Fiberglass Industries; NESHAP for Wool Fiberglass Area Sources (EPA­ t HQ-OAR-201O-1041 andEPA-HQ-OAR-20l0-1042) DearMs. Fairchild: The North American Insulation Manufacturers Association ("NAIMA") respectfully requests a 60-day extension oftime 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 documentswere notpreviously available. The Supplemental Proposal proposes significant amendments in addition to, and in some cases different than, those proposed onNovember 25,2011 and April 15,2013 for the Mineral Wool Production and Wool Fiberglass Manufacturing source categories. EPA has, for example, re­ calculatedthe majority ofemission limits (with the exception ofchromium) 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 ofthese 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 extensionwill not prejudice EPA's abilityto completethis rulemaking bythe projected 2015 deadline. Moreover, such an extension is reasonable and warranted giventhe long history

11 CANAL CENTER PLAZA • SUITE 103 • ALEXANDRIA, VA 22314 • TEL 703/684-0084 • FAX 730/684-0427Ms. SusanFairchild November 14,2014 Page2

ofthis rulemaking and the cooperative efforts ofthe 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 ofthe 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 datarequests and have appreciated EPA's willingness to engage indialogue and in an exchange ofinformation. The industry also has promptlyresponded 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 ofthe rulemaking that is so criticalto these industries. Ifyouhave any questions, please do nothesitate to contactme. Sincerely, 

# -Ana**t·~** Angus E. Crane ExecutiveVice President, General Counsel

cc: 

### Mr. KeithW. Barnett Group Leader, Office ofAir Quality and Planning Standards SectorPolicies and Programs Division, Mineral andManufacturing Group U.S. Environmental ProtectionAgency 4930 OldPage Road Durham,NC 27703