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April 4, 2012 

Ms. Susan Fairchild 

Sector Policies and Programs Division 

Metals and Minerals Group (D243-02) 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

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 of the 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: 

"Open Top" 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) 684-0427 
Ms. Susan Fairchild 


April 4, 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 

• Isolatek International- 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 raw materials. 

A different grade of coke is used by different facilities.· Depending on the source of the slag, 

each batch of slag will possess unique attributes and constituents. Similarly, the type of rock and 

the rock's constituents will vary. In addition, the combination of rock 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 of an 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 and HCllimits low. EPA 

1 M.C. Janus, G.A. Richards, M.J. Yip, and E.H. Robey, "Effect of Ambient Conditions and Fuel Composition on 

Combustion Stability," Conference Proceedings of American Society of Mechanical 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 Brick MACT 

case. 

Alternative Statistical Method 

Lastly, a statistician from one of the mineral wool companies has offered an alternative method 

of calculation for HF and HCl. NAIMA forwards this to EPA for their consideration: 

The output of this formula, using Z value of4, is 0.31 for HF and 0.20 for HCl. 

EPA is using: 

UPl.99 (Upper confidence interval for average value) 

This is the Chebychev rule: 

At least I .. "ofthe data will like within k standard deviations of the mean l-~ (k>1) k Z ' , 

OR 

lc ~llp k number of standard deviations from 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 adjusting the Z level. 

of t statistic: 
Ms. Susan Fairchild 

April 4, 2012 

Page 4 

If EPA is interested in discussing this statistical formula, NAIMA can put the Agency in contact 

with the mineral wool representative who created it. 

Please do not hesitate to contact me if you have any questions. 

Sincerely, 

Angus E. Crane 

Angus E. Crane 

Executive Vice President, General Counsel 

. Attaclnnents 

cc: 	 Mr. Jeffrey A. Telander 

Sector Policies and Programs Division 

Metals and Minerals Group (D243~02) 

Office ofAir Quality Planning and Standards 

u.s. Environmental Protection Agency 


. 109 TW Alexander Drive 


Research Triangle Park, NC 27711 


Mr. David Reeves 


R TI International 


P.O. Box 12194 


Research Triangle Park,NC 27709 

Mineral Wool 

Cupolas: "Open vs. Closedll EPA does not have enough emissions data for the "Open/

' 

facilities. Also1 if we were to sub categorize this way there 

would likely still be a facility in the "closedll category that 

would not be able to meet the 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 of setting a limit for each facility. 

Cupolas by Fuel EPA reviewed fuel data and does not agree with NAIMA's 

suggestion of setting a limit for each facility.