Date:	July 16, 2013



Subject:	Minutes of the July 16, 2013 meeting with Representatives of
the Wool Fiberglass Manufacturing Industry 



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 July 16, 2013.  The purpose of the meeting was to discuss aspects of
the supplemental proposal for wool fiberglass manufacturing. This
memorandum summarizes the major topics discussed during the meeting.

Participants

Carlos Davis, CertainTeed – Saint Gobain

Ken Gould, Owens Corning

Mike Pettis, Owens Corning

Grover Thomas, Guardian Fiberglass

Angus Crane, NAIMA

Brent Tracy, Johns Manville

Sherri Livengood, Johns Manville

Bruce Ray, Johns Manville

Steve Aldridge, Knauf

Susan Fairchild, U.S. EPA, OAQPS

Steffan Johnson, U.S. EPA, OAQPS

Keith Barnett, U.S. EPA, OAQPS

Ray Merrill, U.S. EPA, OAQPS

Larry Sorrels, U.S. EPA, OAQPS

Dave Reeves, RTI International

Cindy Hancy, RTI International

Discussion

NAIMA supports setting a chromium limit, but is concerned that the limit
is too low and that the wet scrubber EPA proposed is not feasible for
the wool fiberglass industry. NAIMA believes that the caustic scrubber
works in other chromium emitting industries because they emit chromium
mostly in a vapor form, but because wool fiberglass furnaces emit mostly
particulate chromium this type of control is not “transferable” to
the wool fiberglass industry. Additionally, NAIMA believes EPA has
underestimated the cost of caustic scrubbers and has not taken into
account other factors such as disposal costs. 

Carlos Davis discussed two scrubbers used at CertainTeed. Carlos
emphasized that these scrubbers were not similar to the wet caustic
scrubbers proposed by EPA. He described as a dry scrubber upstream from
an ESP which is primarily used for PM Control. This scrubber is treated
with a caustic mist in order to turn the effluent into an inorganic
salt. The second scrubber at CertainTeed is for SO2 control and has a
dry effluent. Carlos stated that the installation cost for one of these
scrubbers was around 1 million dollars (which does not include
operational costs). He also noted the difficulty and time it took to
install the scrubber and noted that a wet scrubber would be difficult to
install because of the high inlet temperature (~425F). Industry noted
that because facilities only need to reduce chromium by a few pounds per
year the cost effectiveness of installing a scrubber is very high
(hundreds of thousands per pound). In response to EPA questions,
industry representatives stated that they have gotten several proposals
for wet scrubbers from different vendors. These proposals have varied in
design (packed bed, HEPA, venture, etc.) and industry stated the vendors
were unsure if it would work and could not guarantee certain chromium
control. 	

Industry believes that a more feasible way for facilities to meet the
chromium limit will be to alter the batch composition by using less
cullet, specifically green-bottle cullet. Industry representatives
stated that they have always known that recycled cullet contributes to
chromium emissions, but did not bring it up in earlier conversations
with EPA because those discussions were on trying to reduce hundreds of
pounds of chromium from furnaces, which would not be achievable by
reducing the amount of cullet used. Industry representatives gave
examples of how furnaces with higher cullet batch compositions tend to
have higher chromium emissions and noted that they are worried that some
furnaces that met the limit, have increased cullet use and may not be
meeting the limit anymore. Industry emphasized that wool fiberglass is
one of the few industries that can use recycled cullet and green-bottle
cullet which has a higher percentage of chromium. Industry also stated
that cullet providers do not have any testing that shows how much
chromium is in the cullet, but Owens Corning is running a baseline test
to see what chromium emissions are using no cullet in the raw material. 

NAIMA also raised concerns with the 1 year compliance period and stated
it would not be enough time to install a scrubber. Industry stated that
a pilot program would be necessary to see if the wet scrubber would be
feasible and that everything about using a wet caustic scrubber for
chromium control would be “experimental” in nature. Industry
representatives stated they would need at least a 3 year compliance
period.   NAIMA noted that they already achieve 97.5-99% chromium
control with ESPs and also discussed that historically, production of
wool fiberglass has never had a liquid effluent, but adding a wet
scrubber will lead a liquid effluent high in chromium. 

EPA stated that the current chromium limit allows furnaces to emit
around 3-5 pounds of chromium per year. Industry would like to see a
limit that allows 20-25 lbs/yr which they calculated would still have
low risk implications and stated that even at 12 lb/yr they would likely
have to alter their batch chemistry. Industry also noted if the chromium
limit was increased they would not need a longer compliance period. 

NAIMA also asked EPA keep the original formaldehyde limit, keep the
surrogacy for phenol and methanol, clarify the applicability of area
sources, remove air gas furnaces from having to meet chromium emission
limits, and remove oxy-fuel furnaces with risk of less than
1-in-1million from having to comply with the chromium emission limits.
NAIMA also asked for EPA not to change the applicability regarding heavy
density and pipe products, because industry only tested products subject
to the rule. Industry is concerned that they have products that will not
meet the current limits but cannot test each product. EPA discussed the
possibility of a concentration based standard, but stated only including
heavy density and pipe in the original rule may be a discrepancy EPA
needs to fix. Lastly, NAIMA asked for clarification of HF/HCl work
practice standards. EPA concluded by discussing ways to use the M29 and
M0061 testing to find out how much hex chromium is particulate and/or
what the composition of the “residual” hex chromium is in order to
figure out the best method to control it. 

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