1 Date: November 16 , 20 11

Subject: Minutes of the November 16 , 2011 Meeting (Conference Call) with

Representatives of the Wool Fiberglass Manufacturing Industry

I. Introduction

A meeting with representatives of the North American Insulation Manufactu rers Association

(NAIMA) and the wool fiberglass manufacturing industr y was held with U.S. Environmental

Protection Agency (EPA) staff on November 16 , 2011 . The purpose of the meeting w as to discuss

technical questions related to the Section 114 informati on request sent out i n October 2011 related

to glass

- melting furnaces in the wool fiberglass manufacturing industry and associated chromium

and hexavalent chromium emissions testing. This memorandum summarizes the major topics

discussed during the meeting

.

II. Participants

Steve Aldridge, Knauf Insulation

Russ Mahin, Knauf Insulation

Lauren Alterman, CertainTeed

– Saint Gobain

Carlos Davis, CertainTeed

– Saint Gobain

Ken Gould, Owens Corning

Mike Pettis, Owens Corning

Rick Cooper, Owens Corning

Roy Owens, Owe ns Corning

Ron Hudson, Johns Manville

Grover Thomas, Guardian Fiberglass

Tony Blanton

, Integrity Air Monitoring

Angus Crane, NAIMA

Susan Fairchild, U.S. EPA, OAQPS

Steffan Johnson , U.S. EPA, O AQPS

Keith Barnett, U.S. EPA, OAQPS

Dave Reeves , RTI Internati onal

III. Discussion

Attachment 1 contains a list of common questions from industry representatives submitted prior to

the meeting (sent via email on November 15, 2011)

. Most of t he discussion focused on questions

from Form B (in the ICR) and the test methods to be used for emission testing.2 Total Surface Area of Furnace Walls . Ms. Fairchild clarified that EPA wants physical dimensions

on the interior of each furnace

– both above and below the glass contact line. She recommended

that a schematic of the furna ce could be submitted with notes or comments explaining special

design characteristics or surface area calculations

. For the furnace area above the glass melt line,

any furnace surface exposed to the exhaust is to be included (including the crown). Ms. F airchild

commented that Form B will be revised to clarify the questions related to furnace surface area.

Retesting Furnaces . Ms. Fairchild commented that furnaces tested last year as part of the

voluntary data collection effort do not have to be retested IF there have been no changes to the

furnace construction (i.e., rebricking or changes to refractory materials).

EPA Test Method 0061

. Mr. Johnson responded to a question about why EPA is requiring a new

(additional) test method for testing the furnace emissions. He indicated that EPA’s view is that

0061 is a better, more robust test method for hexavalent chromium and total chromium from

emission sources operating at high temperatures

.

Emission Reporting Tool (ERT)

. Mr. Johnson recommended using versio n 4 of the ERT for

submitting the new emission test results.

Ms. Fairchild concluded the meeting by stating that if anyone had questions or comments that they

would like to make separately , they could contact her directly.34 Att achment 1

From: Angus Crane <acrane@naima.org>

To: Susan Fairchild/RTP/USEPA/US@EPA

Date: 11/15/2011 11:45 AM

Subject: Company Questions for Tomorr ow's Conference Call

Dear Susan:

The following questions have been identified as common to all or at least several companies.

Individual companies are likely to submit additional questions:

Form B Questions

– Ask for clarification regarding specific cells in Form B

• Cell N10

– Total Area of Surface Walls

- There are questions regarding total surface. Does total surface refer to abov e glass

contact line or below glass contact line? Does it include the crown? There is a need or greater

clarity as to what constitutes total surface.

• Cell O10

– Asks For Dimensions of Furnace

- Is this asking for dimensio ns of glass holding area or all inside areas of furnaces ? If all

inside area, how are cold top electric and steel shell furnaces to be treated?

• The request in its entirety does not seek the total surface area for glass contact or the

chr ome content of that glass contact surface area. In that the question is not directly asked, how

does EPA intend to ascertain that or calculate that information?

• What is EPA’s definition of the different types of melters?

• There has been already significant data collected and provided to EPA. Those data,

which included both total chromium (as the sum of filterable and vaporous, but not broken out)

and hex chrome, w ere collected using methods approved by EPA specifically for the wool fiber

glass rule review. What are the technical bases for requiring other methods?

• What is the meaning of “vaporous”

– condensable?

• Does EPA really intend to have companies retest furnaces where the initial results, from

tests conducted pursuant to EPA’s prescribed test methods in 2009 and 2010, are below detection

limits or in the range of 10

- 3 to

- 5 lbs/hr? Results from these t ests are a combined filterable plus

vaporous (condensable). F ilterable and vapo rous quantification at this level is insignificant.

Could EPA establish a threshold emission level when filterable and vaporous quantification would

be applicable and meaningful?

• What is the technical basis for requesting an SW

- 846 m eth od for analyzing for hex

chrome, especially when that method is inconsistent with the method used in the previous ICR and

with the method in the proposed residual risk revisions? How will EPA account for any

differences in the results due to varying analy tical methods?