                             NAIMA and EPA Meeting
                                April 30, 2012
                              1:00 PM  -  3:00 PM

Wool Fiber Glass Representatives  -  1:00 PM  -  2:00 PM
1. Angus Crane  -  NAIMA
2. Granta Nakayama  -  Kirkland & Ellis
3. Joseph Eisert  -  Kirkland & Ellis
4. Steve Aldridge  -  Knauf Insulation
5. Lauren Alterman  -  CertainTeed Corporation
6. Carlos Davis  -  CertainTeed Corporation
7. Ken Gould  -  Owens Corning
8. Ron Hudson  -  Johns Manville
9. Mike Pettis  -  Owens Corning
10. Grover Thomas  -  Guardian Fiberglass
11. Brent Tracy  -  Johns Manville

Wool Fiberglass Discussion Summary
The EPA reviewed the status of the work and announced that final limits of the rule would not be made available during this meeting.
Industry asked whether EPA was intending to restrict or regulate the use of chromium refractories in the wool fiberglass industry.  NAIMA expressed opposition to such regulation because using chromium refractories to construct furnaces benefits the industry economically by extending the life of wool fiberglass furnaces. The industry asked that chrome limits not be tied to the use of chromium refractories in furnace construction.
Industry asked what decisions EPA has made in regard to HF and HCl emission limits.  The emissions testing indicated that most of the industry could not detect HFand HCl emissions in the stack using the test methods, and that the limits proposed were unattainable. The added that the inlet concentration of HF and HCl to the controls were less than 1 ppm. 
The industry asked for final limits for phenol, formaldehyde and methanol from regulated bonded lines (that is, flame attenuation and rotary spin lines using a phenol/formaldehyde binder). NAIMA added that the formaldehyde limits in the MACT rule should be preserved. EPA addressed this by explaining that retaining the MACT formaldehyde limits does not solve their problem of organic HAP control because of the phenol and methanol limits, which are other organic HAP species for which EPA proposed MACT limits. Further, the 1999 data for formaldehyde and the 2010 data for phenol and methanol could not be used together because they were collected so far apart they would not have been tested on the same products, much less the same batch. Additionally, we are revisiting MACT because it was not properly set in 1999.  Rather than the level of MACT being set at the `floor' level of control, it was set at a level that could be achieved by all sources in the category.  EPA explained that the court opinion on the record in several cases upholds the actions we are taking, specifically that there is a mathematical process to follow in determining the MACT floor. The floor must be calculated based on the average of the best performing 12% of existing sources, and MACT for new sources must be based on the best performing similar source.  It is expected that most of the industry would have to improve their performance to meet the level being achieved by the average of the 12%, aka the MACT floor. EPA added that industry should expect to be impacted and have to meet the MACT floor limits when they are finalized.

Mineral Wool Representatives  -  2:00 PM  -  3:00 PM
1. Angus Crane  -  NAIMA
2. Granta Nakayama  -  Kirkland & Ellis
3. Joseph Eisert  -  Kirkland & Ellis
4. John Bolden  -  USG Interiors Inc.
5. Chris Bullock  -  Industrial Insulation Group, LLC
6. Steve Edris  -  Thermafiber, Inc.
7. Lee Houlditch  -  Amerrock Products LP
8. Tom Lund  -  Isolatek International
9. Michael McLaughlin  -  Roxul Inc.
10. Gerald Miller  -  Rock Wool Manufacturing
11. Tim Scott  -  Rock Wool Manufacturing

Mineral Wool Discussion Summary
The EPA reviewed the status of the work and announced that final limits of the rule would not be made available during this meeting.
Industry asked to discuss the HF and HCl limits for cupolas.  Company representatives stated that when EPA asked for emissions testing for HF and HCl, they conducted solid materials assays on their cupola raw materials in order to determine the source of chlorides and fluorides in the raw materials. Solid material assays could not detect these compounds in the raw materials, and emissions testing showed that the emissions were very low.  One facility operates sorbent injection at their cupola to adsorb SO2, and added that they could not reduce their HF and HCl below the current levels by using the control device.  
Industry added that there are two kinds of cupolas: closed top and open top.  These are different designs for cupolas, and this design affects the flow rate and emissions from the 2 different cupola designs. Industry spokespersons stated they would speak again with EPA on this matter and provide information on each cupola design.
