Date:	December 14, 2011



Subject:	Minutes of the December 13, 2011 Meetings with Representatives
of the North American Insulation Manufacturer’s Association

Wool Fiberglass and Mineral Wool RTR

EPA Contract No. EP-D-11-084; EPA Work Assignment No. 0-10

RTI Project No. 0213199.000.010

From:	David Reeves, RTI



To:	Susan Fairchild

OAQPS/SPPD/MMG (D243-02)

U.S. Environmental Protection Agency

Research Triangle Park, NC  27711

Introduction

Meetings with representatives of the North American Insulation
Manufacturer’s Association (NAIMA) and the wool fiberglass
manufacturing and mineral wool production industries was held at the
U.S. Environmental Protection Agency (EPA) facility in Research Triangle
Park, NC, on December 13, 2011.  The meetings were requested by NAIMA to
present their questions and clarifications related to the recent
proposal for wool fiberglass (subpart NNN) and mineral wool (subpart
DDD).  This memorandum summarizes the major topics discussed during the
meeting.

Attendees

See Attachment 1 (mineral wool) and Attachment 2 (wool fiberglass). 

	

Discussion

Mineral Wool Production 

Ms. Fairchild conducted introductions of everyone and Mr. Crane provided
handouts of “The NAIMA Mineral Wool Industry Presentation to EPA”
which is included as Attachment 3. The following bullets summarize
discussion topics and comments made during the meeting: 

6 of the 7 mineral wool companies are small businesses.

Raw materials could be a source of HF and HCl emissions; rock does have
Cl.

HF and HCl were not on industry’s “radar screen” before;
therefore, they do not have any historical data

It is problematic to switch over to natural rock for several technical
and logistical reasons, including proximity to main raw material
suppliers.

Some operating permits specify that raw materials cannot be changed. .

Caustic sorbents are needed to reduce SO2.

Greater energy would be needed to melt some rock; requiring more coke
(fuel) and would likely result in higher secondary emissions.

Recycled (slag) content is a major marketing issue for the mineral wool
industry. 

Industry requests alternate limits since any add-on control equipment
such as dry or wet scrubbers would be cost prohibitive.

Some of the curing/collection emission limits look like incorrect test
data was used.

Requested clarification on the performance test requirement for any raw
material change greater than 10%.

Startup/shutdown provisions are problematic.  There is no historical
test data related to startups or shutdowns.  Some shutdowns only last 30
minutes and the compliance testing involves three 1-hour test runs.

 

Wool Fiberglass Manufacturing 

Ms. Fairchild conducted introductions of everyone and Mr. Crane provided
handouts of “The NAIMA Wool Fiberglass Industry Presentation to EPA”
which is included as Attachment 4. The following bullets summarize
discussion topics and comments made during the meeting: 

Majority of companies and facilities have switched to non-formaldehyde
binders. 

The hexavalent chrome issue is related to one facility; new testing
results showed 11.91 pounds per year of hexavalent chrome emissions;
additional testing being done on the other furnace at the facility.

Industry recommending subcategorization for glass-melting furnaces.

Industry has conducted their own risk analysis using 25 pounds of
hexavalent chromium to demonstrate cancer risk below 1-in-1 million.

Industry asked why the proposed rule changed the required test method
from method 316 to method 318.

Low-density products require a lot of natural gas to melt the glass. 

Industry asked if any of the test results from non-bonded lines were
used in the MACT floor analyses.

Wet scrubber technology may not be a viable control if the inlet
concentrations are very low; also need to consider secondary impacts.

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