
MEMORANDUM


TO:	Docket No.: EPA-HQ-OAR-2004-0309

FROM:	Mary Johnson, EPA/Office of Air Quality Planning and Standards (OAQPS)

DATE:	February 12, 2018

SUBJECT:	Summary of Communications with Industry and Stakeholder Input for Risk Modeling of the Wet-Formed Fiberglass Mat Production Source Category
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 Introduction

This memorandum summarizes the communications between EPA and affected facilities to discuss EPA's risk and technology review (RTR) for the Wet-formed Fiberglass Mat Source Category under section 112(f)(2) of the Clean Air Act (CAA).  This memorandum is organized as follows:

 Introduction
 Communications with Industry Trade Groups and Trade Group Members on the Regulatory Process
 Communications with Affected Facilities to Discuss Modeling Inputs 
 Industry Review of Modeling Inputs 
      Attachments A  -  Communications with Industry Trade Groups 
          A.1 Summary of Conference Call between the U.S. Environmental Protection Agency (EPA), the Asphalt Roofing Manufacturers Association (ARMA), February 16, 2017
          A.2 Action Item from EPA-ARMA Call  -  Plaintiffs and Case # for 13 Category RTR Deadline Suit
          A.3 ARMA Response to EPA Facility List and Additional Fiberglass Questions
          A.4 Draft Facility List with ARMA Input (February 2017)
          A.5	Summary of Conference Call between the U.S. Environmental Protection Agency (EPA), the Asphalt Roofing Manufacturers Association (ARMA), May 5, 2017
          A.6	Wet-Formed Fiberglass Process Flow Diagram (for ARMA)
      Attachments B - Communications with Affected Facilities to Discuss Modeling Inputs
          B.1 Owens Corning (Aiken Facility) Risk Modelling Inputs Discussion - Meeting Agenda
          B.2 Johns Manville (Etowah and Waterville Facilities) Risk Modelling Inputs Discussion - Meeting Agenda
          B.3 Owens Corning (Fort Smith Facility) Risk Modelling Inputs Discussion - Meeting Agenda
          B.4 CertainTeed/Saint Gobain ADFORS (North Charleston Facility) Risk Modelling Inputs Discussion - Meeting Agenda
      Attachments C  -  Industry Review of Modeling Inputs
      	C.1 GAF Materials Model Inputs - Industry Review Draft
      	C.2 Owens Corning (Aiken Facility) Model Inputs - Industry Review Draft
      	C.3 Owens Corning (Fort Smith Facility) Model Inputs - Industry Review Draft
      	C.4 Johns Manville (Waterville Plant #1) Model Inputs - Industry Review Draft
      	C.5 Johns Manville (Waterville Plant #7) Model Inputs - Industry Review Draft
      	C.6 Johns Manville (Etowah Facility) Model Inputs - Industry Review Draft
      	C.7 CertainTeed/Saint Gobain ADFORS (North Charleston) Model Inputs - Industry Review Draft
      	C.8 Modeling Inputs with Facility Review Comments
      
 CommunicationS WITH Industry trade groups and trade group members ON THE REGULATORY PROCESS 

EPA met with the Asphalt Roofing Manufacturers Association (ARMA) and ARMA member companies via teleconference on February 16, 2017 to notify them that EPA had begun work on the RTR for the Wet-Formed Fiberglass Mat source category, provide information on the rulemaking process, and discuss areas where EPA could benefit from additional input from stakeholders. Following the teleconference, EPA provided information requested by ARMA during the call. EPA forwarded a draft list of facilities to ARMA on Feb. 22, 2017. ARMA provided updates to the facility list on March 6, 2017, with following limited exchanges to confirm and clarify updates to the facility list. (The information provided is included in Attachments A.1 through A.4 of this document.)

EPA provided facility-specific National Emissions Inventory (NEI) information to ARMA for distribution to four ARMA member companies (GAF Materials, Certainteed, Johns Manville, and Owens Corning) and subsequently met with ARMA and the member companies via teleconference on May 5, 2017 (see Attachment A.5). EPA explained the process of gathering data for the modeling file, which includes identifying emission units and HAP emissions from NEI data. EPA proposed reviewing a simplified process diagram and the compiled NEI data with each company through individual calls or site visits to confirm the emission units, data, and resolve any follow-up questions. EPA confirmed that it does not intend to send questionnaires to each facility because the inputs for modeling were generally expected to be available from existing sources (e.g., test data, NEI, permits, Google Earth(R)). EPA forwarded a process flow diagram to ARMA on May 8, 2017 to be shared with each of the four companies (see Attachment A.6). EPA met with ARMA via teleconference on February 1, 2018 and February 13, 2018 to provide updates on the status of the RTR proposal.
 COMMUNICATIONS WITH Affected Facilities TO Discuss modeling inputs 

The data inputs for modeling include facility identification information, facility configuration information, emission release point information, emissions by pollutant, and control information.  The memorandum, "Wet-formed Fiberglass: Residual Risk Modeling File Documentation" in Docket ID. No. EPA-HQ-OAR-2004-0309 provides additional information regarding modeling inputs and EPA's approach for developing the modeling file. EPA met with facility representatives as described in Table 1 to discuss facility operations, clarify publicly-available data, and confirm any additional data used to inform the modeling file. In some cases, EPA exchanged short follow-up emails with facilities to clarify or confirm this information. Additional materials (i.e., agendas) provided for each conference are included in Attachments B.1 through B.4.

Table 1. Communications Between EPA and Affected Facilities for Compilation of Modeling Inputs
                  Company/Facility Representatives Contacted
                              Affected Facilities
                                     Date
                          Summary of Items Discussed
GAF Materials
Mark McAteer, Plant Manager 

Steve Emmons, 
Corporate Director of Environmental
GAF Materials (Chester, SC)
May 24, 2017
EPA met with facility representatives on a site visit[1] to clarify the following information: facility emission sources and process flow, emission points and stack information listed in the 2014 NEI, the most current stack test data available, standard operating hours, and startup, shutdown, and malfunction procedures. 
Owens Corning
Jesse Edgar, Environmental, Health & Safety Leader                                                                                                                                     
Owens Corning Nonwoven Technology LLC (Aiken, SC)
June 22, 2017
Via teleconference, EPA clarified the following information with facility representatives:  facility emission sources and process flow, emission points and stack information listed in the 2014 NEI, the most current stack test data available, standard operating hours, and startup, shutdown, and malfunction procedures.

Owens Corning Composite Materials (Fort Smith, AR)
July 17, 2017
Via teleconference, EPA clarified the following information with facility representatives: emission points and stack information listed in the 2014 NEI, the most current stack test data available, the type of oxidizer used at the facility, standard operating hours, and startup, shutdown, and malfunction procedures.
Johns Manville
Sara Nuttall, Regional Environmental Manager 

Brent Tracy, Senior Director & Associate General Counsel, EHS
Johns Manville  -  Plant #01 (Waterville, OH)
June 29, 2017
Via teleconference, EPA clarified the following information with facility representatives: emission points, stack information, and HAP emissions listed in the 2014 NEI, the most current stack test data available for each facility, standard operating hours, and startup, shutdown, and malfunction procedures.

Johns Manville  -  Waterville 07 (Waterville, OH)



Johns Manville International, Inc.  -  Etowah Facility
(Etowah, Tennessee)


Saint Gobain Corporation
Lauren Alterman, Vice President, Environmental Health and Safety 

Melissa Spittler, Environmental, Health, & Safety Manager

John Bedell, General Manager
Certainteed/Saint Gobain Adfors America Inc.
(North Charleston, SC)
July 17, 2017
Via teleconference, EPA clarified the following information with facility representatives: emission points, stack information, and HAP emissions listed in the 2014 NEI, the most current stack test data, standard operating hours, and startup, shutdown, and malfunction procedures.
[1] In lieu of teleconference, EPA conducted a site visit to GAF Materials in Chester, SC on May 24, 2017 to discuss facility operations and modeling inputs. See the memorandum "Summary of Site Visit to GAF Materials, Inc., Chester, SC" in Docket ID. No. EPA-HQ-OAR-2004-0309 for additional information.
 INDUSTRY REVIEW OF MODELING INPUTS

Following facility input and EPA compilation of the modeling file, EPA provided key modeling inputs to each affected source for review and confirmation. EPA prepared facility review files in Microsoft Excel(R) format with fields for facilities to enter or revise information. EPA included the following information in each file: 

          Facility identification information: Facility name and associated identification numbers (e.g., EPA Facility Registry System ID and EPA Emissions Inventory System ID), physical address, county name, facility category (major, synthetic minor, or area), North American Industrial Classification System (NAICS) codes, applicable regulatory codes, and annual operating hours.
          Facility configuration information: The assigned emission process group for the wet-formed fiberglass category (i.e., Mat Drying and Curing, or Resin-Binder Application), emission units, and emission processes. For each emission unit, an emission unit identification number and unit description. For each emission process, an assigned process identification number, process description, and applicable standard classification code (SCC).
          Emission release point information: The emission release points assigned to each emission unit and emission process combination. For each emission release point, the emission release point identification number; emission point type (i.e., stack or fugitive) and release parameters (e.g., stack height, diameter, temperature, and velocity or flow rate); and emission point latitude and longitude coordinates. For review of latitude and longitude coordinates, a map of each facility generated from Google Earth(R) identifying the associated release points and assigned coordinates.
          Emissions by pollutant: For each emissions release point, the start and end dates of the emissions period of interest and EPA's pollutant-specific estimate for "actual" emissions (annual emissions released from the facility). 
          Control information:  The control measures used for each emission unit and process, including the control status (controlled or uncontrolled) and control measure codes and associated descriptions.
EPA also provided fields in each facility file for the reviewer to provide contact information and any additional comments regarding the modeling inputs. EPA provided review files for each of seven affected sources to facility representatives via email on August 11, 2017. EPA also provided an instructions sheet to assist with completing the review file. These files are included in Attachments C.1 through C.7 of this document. Table 2 of this document provides information regarding the affected facilities, the facility contacts receiving the materials, and a summary of responses and materials provided by the contacts. Following confirmation of the individual changes, EPA updated inputs in the risk modeling file based on the responses received. A copy of the revised modeling inputs with comments and revisions from facilities is provided in Attachment C.8 of this document.
      Table 2. Communications and Responses to Facility Review Materials
                  Company/Facility Representatives Contacted
                              Affected Facilities
                              Response Received 
                                       
                                       
                                     Date
                              Summary of Response
GAF Materials
Mark McAteer, Plant Manager 

Steve Emmons, 
Corporate Director of Environmental
GAF Materials (Chester, SC)
                                August 17, 2017
No comments on provided materials.
Owens Corning
Jesse Edgar, Environmental, Health & Safety Leader

Paul Lewandowski, Director, Regulatory Law
Owens Corning Nonwoven Technology LLC (Aiken, SC)
                             No response received.

 Owens Corning Composite Materials (Fort Smith, AR)

Johns Manville
Sara Nuttall, Regional Environmental Manager 

Brent Tracy, Senior Director & Associate General Counsel, EHS
Johns Manville  -  Plant #01 (Waterville, OH)
August 18, 2017

Provided a revised facility file with stack parameters and latitude and longitude coordinates for an additional stack for the binder application operations.

Johns Manville  -  Waterville 07 (Waterville, OH)

Provided a revised facility file with updated stack diameter, exit gas velocity and exit gas flowrates for the combined regenerative thermal oxidizer (RTO) and binder application stack.

Johns Manville International, Inc.  -  Etowah Facility 
(Etowah, Tennessee)

Provided a revised facility file with parameters for 2 additional stacks for the binder application operation for Line 3301. Updated the emission release point type and revised stack parameters for each of 3 stacks from the regulatory defaults.  Updated the emission release point type and revised stack parameters for the binder application operation for Line 3302 from the regulatory defaults. Provided a photograph of the emission release point for clarification as a two-dimensional (2D) fugitive source. Updated latitude and longitude coordinates from all emission release points.
Saint Gobain Corporation
Lauren Alterman, Vice President, Environmental Health and Safety 

Melissa Spittler, Environmental, Health, & Safety Manager
Certainteed/Saint Gobain Adfors America Inc. 
(North Charleston, SC)
August 22, 2017
Provided a revised facility file with updated stack parameters for the binder application operations, updated stack height for the Honeycomb Dryer, revised latitude and longitude coordinates for the Honeycomb Dryer, and updated annual operating hours.



