MEMORANDUM

TO: Wool Fiberglass Rulemaking Docket

SUBJECT: Meeting with North American Insulation Manufacturers Association and Wool 

Fiberglass Manufacturing Industry Representatives

LOCATION: EPA Offices at 109 TW Alexander Drive, Research Triangle Park 

 Washington, DC 20001

DATE OF MEETING: December 5, 2014

ATTENDEES AND AFFILIATIONS:

EPA:

Keith Barnett, Group Leader of the Minerals and Manufacturing Group

Peter Tsirigotis, Director of the Sector Policies and Programs Division

Wool Fiberglass Manufacturing Industry

Angus Crane, North American Insulation Manufacturers Association (NAIMA)

Steve Aldridge, Knauf Insulation

Carlos Davis, CertainTeed Corporation

Ken Gould, Owens Corning

Sherri Livengood, Johns Manville

Granta Nakayama, Kirkland & Ellis

Mike Pettis, representing Owens Corning

Brent Tracy, Johns Manville

The Wool Fiberglass Industry Representatives met with EPA to discuss three issue relating to the 

development of the final wool fiberglass residual risk and technology review rulemaking. A 

meeting agenda and discussion of these three issues is attached.
Attachment 1

PROPOSED AGENDA

NAIMA Meeting With EPA

December 5, 2014

1:00 PM – 2:30 PM (Eastern)

1. Review of NAIMA’s Antitrust Guidelines – A. Crane

2. Introductions

3. Proposed Chromium Emission Limits

4. Formaldehyde, Phenol, and Methanol Proposed Emission Limits

5. HF and HCl “Free of” Language

6. Questions and Answers 
Concerns of NAIMA and Its Member Companies

ISSUE ONE – PROPOSED CHROMIUM EMISSION LIMIT

1. The proposed chromium emission limit is not feasible technologically and is not 

financially viable.

a. MACT applicability is triggered when a stationary source meets the definition of 

“major source,” which means it has the potential to emit, considering controls, in

the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons 

per year or more of any combination of hazardous air pollutants. Yet the 

aggregate chromium emissions of the entire industry are 0.6 tons per year; these 

aggregate emissions should not trigger MACT applicability.

i. These aggregate emissions do not present sufficient risk to justify EPA’s 

stringent limits. EPA stated that, but for one test result – the outlier in 

Kansas City – chromium emissions from this industry would not be a 

concern on the part of the Agency. 

ii. EPA should treat the source of concern as an outlier and not try to pull the 

entire industry back into the MACT standard.

iii. NAIMA recommends that EPA rely upon existing PM limits as a 

surrogate for all heavy metals, including chromium.

b. EPA justifies these stringent limits based on technology options that are not 

proven technologies and not available to the industry.

i. The technologies identified by EPA were taken from NAIMA’s 

comments, but NAIMA’s comments presented them as technologies that 

had never been used in the fiber glass industry and were unproven.

ii. NAIMA is not aware of any data that supports the feasibility of these 

control devices in the fiber glass industry

iii. The accelerated furnace rebuild option has no legitimate connection with 

chromium emissions and as such cannot be considered to be a viable 

control technology.

 NAIMA’s analysis of the data shows no support for EPA’s theory 

that chromium emissions increase as furnaces age.

 EPA’s analysis of limited data to reach such a conclusion is 

statistically insignificant.

 The economic costs of losing 1 to 3 years of a furnace’s life are 

extremely detrimental to individual companies. These costs are 

considerably greater than represented by EPA, and these costs do 

not meet EPA’s cost feasibility requirements.

c. In the alternative, NAIMA recommends that EPA raise the proposed chromium 

emission limit.

i. NAIMA recommends that EPA adopt a chromium limit of 4.6 x 10-4

lbs/ton.
ISSUE TWO – FORMALDEHYDE, PHENOL, AND METHANOL PROPOSED EMISSION 

LIMITS

1. EPA should not set new emission limits for formaldehyde, phenol, and methanol.

a. EPA has determined that the risk presented by formaldehyde is acceptable.

b. The industry has significantly reduced these pollutants. In fact, EPA itself stated 

that “[d]ue to industry’s efforts to replace phenol-formaldehyde binders, more 

than 95 percent of formaldehyde, phenol, and methanol emissions have been

reduced (or will be by 2012).”

c. A few product designs have not been successfully converted to a nonformaldehyde binder due to product performance demands. The proposed 

emission limits are not feasible for these product lines.

i. Some formaldehyde and methanol is created from the combustion of 

natural gas used in wool fiber glass production.

ii. The proposed standards may not be able to be achieved even after 

switching to non-phenol-formaldehyde resins without installing controls 

such as a thermal oxidizer, which itself will emit additional formaldehyde 

as a result of the combustion of natural gas to operate the control device. 

d. This is effectively MACT-on-MACT; EPA is converting existing source 

standards into new source standards and resetting the MACT floor after the 

conversion of most facilities to a non-formaldehyde binder. The new source 

limits were calculated from data that was generated from normal operations and 

not from the methods that are prescribed in detail in the MACT standard.

e. By resetting the MACT floor after the conversion of most facilities to non-phenolformaldehyde binder, EPA effectively is punishing the industry, not rewarding it.

ISSUE THREE – HF AND HCl “FREE OF” LANGUAGE

1. EPA mandates that cullet be “Free of” chloride, fluoride, and fluorine-bearing 

constituents.

a. EPA’s preamble language specifically recognizes that the industry successfully 

keeps HF and HCl emissions largely below detection levels.

b. By imposing “Free of” language, EPA is going beyond what the industry is 

currently doing to achieve such low HF and HCl emissions. “Free of” is 

impossible to demonstrate because it requires proving a negative.

c. NAIMA requests that EPA’s work practice eliminate “Free of” and instead 

require the industry to continue to do what EPA acknowledges the industry is 

doing to maintain currently low HF and HCl emissions.

i. Cullet could have traces of these constituents, and cullet is rinsed with 

chlorine-containing, and likely fluoride-containing, city water.

ii. In fact, all potable waters, unless de-ionized or distilled, have a chloride 

(i.e., salt) content to them.

iii. Once these constituents are incorporated into the glass matrix, few 

emissions result from re-melting.

d. It is impossible to eliminate contaminants in a consumer recycling stream, but 

companies do not buy cullet with high levels of contaminants.

e. Some jurisdictions (California) require a minimum cullet content.

f. EPA recognizes the benefits of using recycled content and encourages it.