From: "Pettis, Mike" <mike.pettis@owenscorning.com>

To: Susan Fairchild/RTP/USEPA/US@EPA

Cc: "Pettis, Mike" <mike.pettis@owenscorning.com>

Date: 02/27/2012 11:06 AM

Subject:RE: Permitting processes surrounding Switching from

 Formaldehyde to Non-Phenolic Binders

Susan, I will need to leave my office between 11:00 and 1:00 but should

be available on my cell.

A couple of points for our discussion.

Angus has asked it we have asked for limits or have permit limits which

would “make our sources minor or prevent them from being major for

HAP’s.”

Our basic responses are - “No”

While that is true – however, our permitting in context limits us from “

changing the mode of operation” or increasing pollutants without

permitting. We represented the Potential to Emit” (PTE) of our HAP’s as

being below the “major” threshold when we converted and identified all

HAP’s and their PTE. That does not limit a facility form being “major”.

In theory if a facility had enough sources even small amounts of HAPS

from the individual sources could aggregate emissions that could exceed

the “major” level. That is not the case except for OC facilities which

have specialty products that have not converted binders. For us that is

our Newark, Ohio plant which for now still makes pipe insulation with

phenolic binder and our Texas plant which still makes Duct Board that

uses phenolic binder. Those products will not change until we have

developed the process for the binder change for those products which

will still be a while. Therefore, those plants are the only “major”

sources we have for HAP’s. To exceed the major level for our other

plants would require us to prepare and file for permits for those

sources and meet the site specific requirements for those HAP’s. That

includes anything the local permitting authority requires including

modeling, BACT, RACT evaluations.

We have also removed the language of applicability on Subpart NNN from

all our State and/or Title V permits which means we cannot make products

which fall under that definition (using Phenol-formaldehyde binder)

without filling for a permit change. Only in California where there is

a time lag between the construction permitting process and the operating

permit/ Title V modification request did we have specific language which

had a specific date when we would stop using the old binder. We have
issued “final MACT” reports for all locations except for Newark and

Texas and even in those plants we have issued “final MACT” report for

manufacturing lines which have made the binder change which would

prevent us from converting back without going through permitting.

 Michael Pettis

 740-328-2468 740-877-7087 (cell)

 Make the World a Better Place

From: Susan Fairchild [mailto:Fairchild.Susan@epamail.epa.gov]

Sent: Friday, February 24, 2012 12:03 PM

To: Angus Crane

Cc: Pettis, Mike

Subject: Re: Permitting processes surrounding Switching from

Formaldehyde to Non-Phenolic Binders

Thanks for this email, Angus...Mike, would you be available to speak

with me on Monday 2/27/2012?

Thanks,

Susan Fairchild

Environmental Scientist

U.S. Environmental Protection Agency

direct line: 919.541.5167

fax: 919.541-3207

email: fairchild.susan@epa.gov

Overnight mail address:

US EPA

Mail Code D243-04

109 TW Alexander Drive

RTP, NC 27709

-----Angus Crane <acrane@naima.org> wrote: -----

To: Susan Fairchild/RTP/USEPA/US@EPA

From: Angus Crane <acrane@naima.org>

Date: 02/24/2012 11:25AM

Cc: "Pettis, Mike" <mike.pettis@owenscorning.com>

Subject: Permitting processes surrounding Switching from Formaldehyde to

Non-Phenolic Binders

Dear Susan,

Based on yesterday’s conversation about permitting changes or

applications for changing major sources to area sources, I think it is
critical and useful for you to speak with Mike Pettis of Owens Corning.

With Owens Corning’s recent shift from formaldehyde to non-phenolic

binder at a large number of facilities, Owens Corning’s experiences with

binder changes and administrative processes connected to that change are

instructive and relevant to the discussion we had about whether there is

an “official” or “written record” of an area source status. Mike can be

reached at (740) 877-7087.

Angus E. Crane

Executive Vice President, General Counsel

North American Insulation Manufacturers Association

Ph: (703) 684-0084 ext. 123

Fax: (703) 684-0427

Visit NAIMA online at:

www.NAIMA.org

www.PipeInsulation.org

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