VIA E-MAIL

March 26, 2010

Mr. Jeffrey A. Telander

Sector Policies and Programs Division

Metals and Minerals Group (D243-02)

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

109 TW Alexander Drive

Research Triangle Park, NC  27711

Mr. William Neuffer

Sector Policies and Programs Division

Metals and Minerals Group (D243-02)

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

109 TW Alexander Drive 

Research Triangle Park, NC  27711

 

RE:	Draft Information Collection Requests for the Mineral Wool and Wool
Fiberglass Insulation Manufacturing Industries

Dear Messrs. Telander and Neuffer:

The North American Insulation Manufacturers Association (“NAIMA”)
and its member companies appreciate the opportunity to discuss with the
Environmental Protection Agency (“EPA”) on Monday, March 29, 2010 at
3:00 PM (EDT), the appropriate test methods for pre-existing and new
emissions data to be provided to EPA in response to the draft
Information Collection Requests (“ICRs”) that we are presently
defining for the mineral wool and wool fiberglass insulation
manufacturing industries’ residual risk review.

To facilitate that discussion, NAIMA and its member companies have
reviewed the test methods set forth in the draft ICRs and are
identifying below alternative test methods that will enable us to
provide EPA the data it needs while both expediting the information
collection process and leveraging the use of existing emissions data. 
The industry is recommending these alternative test methods because it
has extensive data collected by these alternative methods that are
relevant to EPA’s requests.  The importance of existing data becomes
even more important given the fact that every company is operating at
reduced production due to the significant economic downturn in the
building industry.  Therefore, companies have specific lines that are
not operating at this time.  New data could not be collected for those
lines simply because they are not in operation, even though they are
currently permitted.  Existing data will be essential for providing EPA
with the requisite data for all point sources.

EPA Method 318 is used to collect information concerning emissions of
formaldehyde, phenol, methanol, carbonyl sulfide, and carbon monoxide. 
While NAIMA members have only limited data and experience with Method
318, the vast majority of existing data has been collected with other
EPA and California methods which EPA has approved for use in recent
Section 114 emissions data collections, but were not identified in the
draft ICRs.

NAIMA requests that EPA accept the following alternative methods:  EPA
Method 316 for formaldehyde; EPA Method 308 for methanol; California
Method ST-16/gas chromatography, EPA Method TO-8, and SW-846 Method
8270D for phenol; EPA Methods 10 and 15 for carbon monoxide; and EPA
Methods 10, 15 and 320 and AP-42 emission factors for carbonyl sulfide. 
These test methods are as effective as Method 318 and have the decided
advantage of providing reliable results and leveraging extensive
available data.  Moreover, at EPA’s request and in connection with
Section 114 requests, two NAIMA member companies ran side-by-side
comparisons of Method 318 and alternative wet chemistry methods which
confirmed that the test methods produced essentially the same results. 
NAIMA can provide documentation of these comparison tests.  In addition,
some test companies have limited experience with Method 318, and the
NAIMA member companies and their consultants who have used Method 318
have experienced trouble perfecting its application and at times have
encountered some inaccurate and inconsistent results.

As noted above, another alternative method to determine methanol is
Method 308.  While Method 318 is designated by EPA to test methanol,
there is a reaction called the Cannizaro reaction which can generate
more methanol in the collection process, or even during the process of
testing for methanol.  In the Cannizaro reaction, when heated,
formaldehyde in the resin is known to undergo a disproportionate
reaction yielding methanol and formic acid.  Since methanol could be
created during the process of collecting and testing the emissions and
thereby artificially increasing the methanol emissions, Method 308 is
employed.  Method 308 would avoid the creation of artificial methanol
emissions since it does not use a heated sampling line.

NAIMA requests that members have the option of using EPA Methods 5 and
202 as well as EPA Other Test Method (OTM) 27 and 28.  Again, the
availability of existing data makes acceptance of these alternatives
desirable.  In addition, OTM 27 and 28 are not promulgated methods;
therefore, the industry has very limited experience conducting or using
these test methods.  Given EPA’s desire for an expedited response, it
makes little sense for companies to use a method with which they have
limited knowledge and experience.  Moreover, some stacks might not be
able to accommodate an OTM 27 probe without a significant amount of
blockage, which adds variability to the emission testing procedure.  The
vast majority of emissions from these processes are PM2.5, so NAIMA and
its member companies propose that they can, for ICR testing purposes,
stipulate that all the PM emissions reported in response to the draft
ICR are PM2.5, and that they use Method 5 for filterable emissions and
Method 202 for condensable emissions to measure them, as alternatives to
EPA OTM 27 and 28.

The draft ICR identifies EPA Method 30B for measuring mercury.  NAIMA
should be allowed to use EPA Method 29 as well.  There is no need to
separately test for mercury in wool fiberglass and mineral wool plants
because mercury is not used in the manufacturing process.  It may be in
the raw materials used to make insulation products in trace amounts. 
Indeed, if any mercury is present, it will be captured at extremely low
levels by Method 29 (see section 1.1 (Analytes)).

The draft ICR identifies EPA Method 0061 be used to determine hexavalent
chromium.  Method 306 and CARB 425 have been approved for determining
hexavalent chromium emissions, too.  NAIMA requests that Method 306 and
CARB 425 be allowed for chrome emissions data.  Existing data using
these methods are available.  In addition, Method 0061 cannot be
successfully used in high temperature environments.  Since the exhaust
in some stacks have high temperatures, Method 0061 is not practical for
our industries.

EPA Method 26A is irrelevant to the mineral wool and wool fiberglass
insulation industries, and these industries have no experience with this
method.  Therefore, it should not be used in responding to the draft
ICRs.

Finally, with respect to all test methods, NAIMA intends to provide test
data acquired from tests run for the length of time prescribed by the
applicable test method, not for some longer period of time.  To request
testing beyond the parameters of the actual test methods undermines the
integrity of the test method, is unnecessary, and would effectively
eliminate the use of the industries’ extensive existing data.  For
example, one hour should be more than sufficient for all the organics to
be measured.  Moreover, any deviation from a test method could call into
question the legitimacy of the data.  The majority of these test methods
have a one-hour length; detection limits are set to work within the
designated timeframe.  If the detected amount of the pollutant is one or
two orders of magnitude above the detection limit, extending the time
and reducing the detection limit does not provide any additional
substantive or meaningful information because the pollutant in question
has already been detected and measured.

Because NAIMA is providing a response for the entire industry, it is
requested that both existing and newly acquired data not be submitted
through the Electronic Reporting Tool.

If you have any questions in advance to the conference call, please do
not hesitate to contact me.

Sincerely,

Angus E. Crane

Angus E. Crane

Executive Vice President, General Counsel

Messrs. Jeffrey A. Telander and William Neuffer

March 26, 2010

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