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Date: November 16, 2011

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 Manufacturers Association 

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

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

technical questions related to the Section 114 information request sent out in 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, Owens 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, OAQPS

Keith Barnett, U.S. EPA, OAQPS

Dave Reeves, RTI International

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 the discussion focused on questions 

from Form B (in the ICR) and the test methods to be used for emission testing.
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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 furnace 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. Fairchild 

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 version 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.
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Attachment 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 Tomorrow'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 above 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 dimensions 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 

chrome 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, were 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 tests are a combined filterable plus

vaporous (condensable). Filterable and vaporous 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 method 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 analytical methods?