MEMORANDUM

TO: Wool Fiberglass Rulemaking Docket

S UBJECT : Meeting wi t h North American Insulation Manufacturers Association and Wool

Fiberglass Manufacturing Industry Representatives

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

Washington, DC 20001

D ATE 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 D ivision

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 tec hnology review rulemaking. A meeting agenda and discussion of these three issues is attached.Attachment 1

P ROPOSED 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. Introduct ions

3. Proposed Chromium Emission Limits

4. Formaldehyde, P henol, and M ethanol Proposed Emission Limits

5. HF and HCl “Free of” L anguage

6. Questions and AnswersConcerns of NAIMA and Its Member Companies

ISSUE ONE

– PROPOSED CHROMIUM EMISSION LIMIT

1. The pro posed 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 t he aggregate chromium emissions of the entire industry are 0.6 tons per year; these aggregate emission s 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 s tandard.

iii. NAIMA recommends that EPA rely upon existing PM limits as a surrogate for all heavy metals, in cluding chromium.

b. EPA justifies these stringent limits based on technology options that are not proven technologies an d 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 legitim ate 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 re ach such a conclusion is statistically insignificant.

 The economic costs of losing 1 to 3 years o f a furnace’s life are extremely detrimental t o individual companies . These costs are considerably greater than represented by EPA, and these costs do

not mee t 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 PROPOS ED 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 state d 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 non

fo rmaldehyde binder due to product performance demands . Th e 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 sta ndards 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 calcula ted 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

- phenol

formaldehyde binder , EPA effectively is p unishing the industry, not rewarding it

.

ISSUE THREE

– HF AND HC l “FREE OF” LANGUAGE

1. EPA mandates that cullet be “F ree of ” chloride, fluoride, and fluorine

- bearing

constituents.

a. EPA’s preamble language specifically recognizes that the industry successfu lly 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 pr oving a negative.

c. NAIMA requests th at EPA ’s w ork 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 c onstituents

, 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. I t is i mpossible 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 c ontent.
f. EPA recognizes the benefits of using recycled content and encourages it

.