# NAlMA
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EnergyEfficiency 

### VIAE-MAIL April 4, 2012
Ms. Susan Fairchild Sector Policies and Programs Division Metals and Minerals Group (D243-02) Office ofAir Quality Planning and Standards U.S. Environmental ProtectionAgency 109 T.W. Alexander Drive "" Research Triangle Park, NC 27711 RE: Supplemental Mineral Wool Comments Dear Ms. Fairchild: Pursuant to our recent telephone conversation, this letter and attachments supplement the North American Insulation Manufacturers Association's ("NAIMA") previous comments (February 3, 2012). Set forth herein are additional subcategorization options for carbonyl sulfide ("COS"), hydrochloric acid ("HCI"), and hydrogen fluoride ("HF"); a recommendation for adoption of work practices as an alternative to HF and HCllimits; and an alternative calculation method for HF andHCl. Subcategory Option NAIMA urges EPA to consider subcategorizing the industry based on "open top" cupolas and "closed top" cupolas. Open top cupolas are different in that the mineral charge is inserted at the top ofthe cupola rather than the side. "Open top" is a process distinction differing from the other mineral wool cupolas. In addition, the open top cupolas are exposed to the environmental elements; when it rains or snows, the moisture goes through the top. Based on these differences, NAIMA recommends the following subcategories: "OpenTop" Cupolas • Amerrock

- Nolanville, Texas • Rock Wool Manufacturing

- Leeds, Alabama "Closed Top" Cupolas • IIG

- Phenix City, Alabama • Isolatek International

- Huntington, Indiana • Thermafiber

- Wabash, Indiana • USG

- Red Wing, Minnesota • USG

- Walworth, Wisconsin
44 Canal Center Plaza· Suite 310 • Alexandria, Virginia 22314 • Tel: (703) 684-0084 • Fax: (703) 684-0427Ms. Susan Fairchild April4, 2012 Page 2
Subcategory Option NAIMA urges EPA to consider subcategorizing the industry to**refl~ct** the diversity of the industry location in different USDA climate zones. The cHmate zone directly impacts the

.combustion process. Specifically, combustion performance is likely to be impacted by inlet air temperature; humidity; changes in geographic climates; and seasonal weather! Based on these zones, NAIMA recommends the following subcategories: USDA Climate Zone 5a (Attachment) • USG Red Wing, Minnesota USDA Climate Zone 5b (Attachments) • USG

- Walworth, Wisconsin • Thermafiber

- Wabash, Indiana • IsolatekInternational- Huntington, Indiana USDA Climate Zone 8a (Attachments) • IIG

- Phenix City, Alabama • Amerrock

- Nolanville, Texas USDA Climate Zone 7b (Attachment) • Rock Wool Manufacturing

- Leeds, Alabama Subcategory Option NAIMA also urges EPA to subcategorize the industry based on unique·fuels and rawmaterials. A different grade ofcoke is used by different facilities.· Depending on the source ofthe slag, eachbatch ofslag will possess unique attributes and constituents. Similarly, the type ofrock and the rock's constituents will vary. In addition, the combination ofrock and slag wool varies by facility depending upon available raw materials and the product being made. Under this approach, every facility has a singular and distinct combination of fuel and raw materials. Therefore, each facility could be placed in a separate subcategory based on unique fuels and raw materials. Work Practices Alternative NAIMA recommends setting a work practice standard as another alternative approach for HF and HCl. Specifically, NAIMA recommends that instead ofan emission limit, since emissions are so low, a work practice standard or simply following the manufacturers recommended operations and maintenance ("O&M") would adequately keep the HF andHCllimits low. EPA

1 M.C. Janus, G.A. Richards, M.J. Yip, and E.H. Robey, "Effect ofAmbient Conditions and Fuel Composition on Combustion Stability," Conference Proceedings of American Society ofMechanical Engineers/Intemational Gas Turbine Institute Turbo Expo Meeting, 1997.Ms. Susan Fairchild Apri14,2012 Page 3
does have authority to promulgate work practice standards as the court noted in the

### BrickMACT case. Alternative Statistical Method Lastly, a statistician from one ofthe mineral wool companies has offered an alternative method ofcalculationfor HF and HCl. NAIMA forwards this to EPA for their consideration: The output ofthis formula, using Z value of4, is 0.31 for HF and 0.20 for HCl. EPA is using: UPl.99 (Upperconfidence interval foraveragevalue)

This is the Chebychevrule: Atleast 

### I
.. "ofthedatawill likewithink standarddeviationsofthemean**l-~** 

### (k>1) 

### k Z ' , OR 

### lc

# ~llp k numberofstandard deviationsfrom the mean p probability (aka, %confidence)
This uses EPA's formula, but replaces the student's t statistic at 99% with the Chebychev statistic. You can make the UPL rise very quickly by adjustingthe Z level. oft statistic:Ms. SusanFairchild April 4, 2012 Page 4
IfEPA is interested in discussing this statistical formula, NAIMA can put the Agency in contact withthemineral woolrepresentative who created it. Please do not hesitate to contactme ifyouhave any questions. Sincerely, AngusE. Crane Angus E. Crane Executive Vice President, General Counsel

. Attaclnnents
cc: Mr. Jeffrey A. Telander SectorPolicies andPrograms Division Metals and Minerals Group**(D243~02)** Office ofAir QualityPlanning and Standards 

# u.s. Environmental ProtectionAgency

. 109 TWAlexander Drive ResearchTriangle Park, NC 27711 Mr. DavidReeves RTI International P.O. Box 12194 Research Triangle Park,NC 27709Mineral Wool Cupolas: "Open vs. Closed ll EPA does not have enough emissions data for the "Open/ ' facilities. Also1 ifwe were to sub categorize this waythere would likely still be a facility in the "closed ll category that would not be able to meetthe limit. Cupolas: by Climate Zone EPA does no subcategorize based on Climate zones. Cupolas by Raw Material (NAIMA suggests each facility have its own limits) EPA reviewed raw material data and does not agree with NAIMA's suggestion ofsetting a limitfor each facility. Cupolas by Fuel EPA reviewed fuel data and does not agree with NAIMA's suggestion ofsetting a limitfor each facility.