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June 6 , 2012

Ms. Susan Fairchild Sector Policies and Programs Division Metals and Minerals Group (D243

- 02) Office of Air Quality Planning and Standards U.S. Environmental Protection Agency 109 T

. W

. Alexander Drive Research Triangle Park, NC 27711

RE: Wool Fiberglass Manufacturing

– Area Source s and Formaldehyde, Phenol, and Methanol Issues

Dear Ms. Fairchild :

The North American Insulation Manufacturers Association (“NAIMA”) greatly appreciates the ongoing dialog ue with the Environmental Protection Agency (“EPA”). NAIMA recognizes the significant efforts EPA has undertaken to develop a feasible Rule that delivers pollution reduction.

There are really only two remaining issues that NAIMA believes need further resolution before the Wool Fiberglass Manufacturing Rule is finalized.

The first issue

– area sources

– is a matter that EPA specifically requested feedback from NAIMA. Pursuant to that request, NAIMA proposes the language set forth below be inserted int o the Final Rule to indicate the industry’s commitment to monitor and police hex chrome emissions . NAIMA’s members are willing to make this commitment even though current emissions in the data set EPA used in its risk assessment, which included one outlie r result from a furnace, showed only a 40

- in

- one

- million excess cancer risk.

Before taking any official action on area sources, EPA must conduct the analysis and findings required by Section 112(c)(3) of the Clean Air Act that requires regulation of area sources only after a determination that “a threat of adverse effects to human health or the environment” warrant further regulation. The Preamble to the Proposed Rule acknowledges that EPA needs more information before drawing any conclusion about the nee d, if any, for fiber glass area

sources. Some of the information provided to EPA by NAIMA and its member companies may be useful in fulfilling this information collection requirement, butMs . Susan Fairchild June 6, 2012 Page 2

EPA must complete the process. To address any concerns about hex c hrome emissions from the industry absent an Area Source R ule, the industry has voluntarily agreed to limit hex c hrome emissions.

In the interim, the industry will establish a voluntary emission threshold limit of 25 lbs. of hex c hrome per year for each in dividual applicable furnace located at a minor source or fiber glass insulation manufacturing facility that is not subject to NNN. Compliance will be determined based on testing, the timing of which is to be mandated by the frequency of particulate testin g required in Title V permits or other required testing , but not to exceed twice in any single furnace campaign. NAIMA fiber glass members ’ commitment to test and monitor extends to all furnaces , even the non

- oxy

- fuel furnaces . Non

- oxy

- fuel furnaces , however, will
not need to be tested beyond a single furnace campaign due to their lower emissions as evidenced by data already obtained by EPA

. This testing will document the level of hex c hrome emissions as measured by EPA Test Method 0061; those testi ng results will be provided to EPA upon request. If this voluntary threshold is exceeded, the furnace operator will take action to lower the emissions or meet a modeled risk criteria of less than one

- in

- one

- million 1 or an alternative mutually agreeable ri sk level which in no event will be more stringent than a one

in

- one

- million risk. The exact nature of the responsive action would be at the discretion of the individual manufacturer, but may include additional control equipment, i.e. , scrubbers

, or other actions designed to lower emissions or reduce the modeled risk threshold. EPA endorses this interim voluntary approach to resolving any remaining concerns about hex c hrome emissions from these sources

no t included in this Rule.

The second issue

– formald ehyde, phenol, and methanol limits for rotary spin and flame attenuation

– has fiber glass manufacturers deeply concerned. The vast majority of wool fiber glass manufacturers have switched from phenol formaldehyde binders to non

- phenol formaldehyde. This action has enabled EPA and industry to achieve a massive reduction of the only hazardous air pollutant (“HAP”) regulated in the Wool Fiberglass Manufacturing MACT. However, those sources continuing to use formaldehyde binders will not be able to meet EPA ’s revised limits for formaldehyde, phenol, and methanol.

Specific performance requirements for certain products

– very different from typical residential products

– generally mandate that the level of binder be higher than that used for typical residenti al insulation. Typically, these specialized products have a higher loss on ignition (“LOI”). LOI is defined by the current Wool Fiberglass Manufacturing MACT as follows:

1 In the Preamble to the Proposed Rule, EPA stated that current risks due to hexavalent chromium were acceptable at a 40

- in

- one

- million cancer risk. 76 Fed. Reg. 72,770

, 72,786 (November 25, 2011).Ms . Susan Fairchild June 6, 2012 Page 3

Loss on ignition (LOI) means the percent decrease in weight of wool fiberglass afte r it has been ignited. The LOI is used to monitor the weight percent of binder in wool fiberglass. 2

Upon reviewing EPA’s revised

– improved but still not feasible

– limits for rotary spin lines for formaldehyde, phenol, and methanol, companies have unequ ivocally stated that they would not be able to continue to manufacture certain products and meet the emission limits for some or all of these HAPs. That will cause them to either move these operations to Mexico or Canada or simply cease manufacturing thos e products because the proposed limits cannot be met in a financially viable manner. An example of a product that would be impacted is pipe insulation. To avoid this disastrous outcome , NAIMA asks that EPA set MACT floors that recognize worst

case reason ably foreseeable circumstances which properly account for variability of sources, 3
and that this variability be reflected in the final emission limits. This would require EPA to retain the original formaldehyde MACT limit and set phenol and methanol limit s based on data where higher LOI production was occurring ; this will result in feasible and realistic emission limits. Moreover, because phenol and methanol emissions data was never collected before, the existing phenol and methanol data is limited.

Because of the potential loss of jobs at various locations and the movement of profitable business to outside of the United States, NAIMA is prepared to present this issue, using all possible resources, to the Office of Management and Budget (“OMB”).

Simi larly, the formaldehyde, phenol, and methanol limits for flame attenuation are equally unachievable. NAIMA is concerned that the MACT f loor was set with data from other than flame attenuation lines or that the MACT f loor was miscalculated

. EPA’s mean of sources used in the flame attenuation floor is far lower than what NAIMA calculated. NAIMA urges EPA to recalculate the MACT f loor using only flame attenuation generated data and to ensure that all stacks in a given line are included in the calculation

.

NAIMA urges that EPA resolve the matter before it reaches OMB.

If you have any questions, please do not hesitate to contact me.

Sincerely,

Angus E. Crane Executive Vice President, General Counsel

2 40 C.F.R. Part 63, Subpart NNN, § 63.1381.
3 Cement Kiln Recycling Coalition, et al. v. EPA , 255 F.3d 855, 863 (D.C. Cir. 2001) (citing Sierra Club v. EPA

, 167 F.3d 658, 665 (D.C. Cir. 1999)).Ms . Susan Fairchild June 6, 2012 Page 4

cc: Mr. Keith W. Barnett Group Leader, Office of Air Quality and Planning Standards Sector Policies and Programs Division, Mineral and Manufacturing Group U.S. Environmental Protection Agency 109 T

. W

. Alexander Drive (D243

- 04) Research Triangle Park, NC 27711

Mr. Steve Fruh Office of Air Quality Planning and Standards U.S. Environmental Protection Agency 109 T.W. Alexander Drive (D205

- 01) Research Triangle Park, NC 27711

Mr. Peter Tsirigotis Director , Sector Policies and Program Division Office of Air Quality Planning and Standards U.S. Environmen tal Protection Agency 109 T.W. Alexander Drive (C404

- 04) Research Triangle Park, NC 27711