# NAIMA

NORTH AMERICAN INSUL.ATION MANUFACTU R ERS ASSOCIATION VIA E-MAILAND OVERNIGHT MAIL March 12, 2015
Ms. Susan Fairchild SectorPolicies and Programs Division Metals and Minerals Group (D243-02) Office ofAir QualityPlanning and Standards U.S. Environmental Protection Agency 4930 OldPage Road Durham,NC 27703 RE: Specific Answers To EPA's Questions On Formaldehyde, Phenol. and Methanol DearMs. Fairchild: Please find below specific answers to questions you haveraised.

• Emissions data that confirms that theproposed emission limits on formaldehyde, phenol, and methanol arenot feasible for all lines:} Emissions datathat demonstratethe currentlyproposed limits cannotbemet: • Formaldehyde (Proposed Limit for Rotary Spin Existing Sources) 0.19lb/ton • 0.5 1b/ton (raw data to be supplied separately) • 0.52 lb/ton (raw datato be supplied separately) • O.5lb/ton (raw datatobe supplied separately) • Phenol (Proposed Limit forRotary Spin Existing Sources) 0.261b/ton • 0.6 1b/ton (raw datato be supplied separately) • 0.53Ib/ton* • Methanol (Proposed Limit for Rotary Spin Existing Sources) 0.83 Ib/ton • 1.3 1b/ton (raw data to be supplied separately) • 1.12 lb/ton*

• Where are these products made? These products are made by all four fiber glass companies. Specific locations of plants making these products are as follows: • Owens Coming

- VI Line

- Waxahachie, Texas • Other companies will provide additional raw data and specific locations of theirplants.

I Not all lines have data for allpollutants andthose estimates are indicated with an asterisk.

11 CANAL CENTER PLAZA • SUITE 103 • ALEXANDRIA, VA 22314 • TEL 703/684-0084 • FAX 730/684-0427Ms. Susan Fairchild March**12~** 2015 Page 2

• Whatproducts are made? The products are made on "rotary spin" manufacturing lines and are different types ofinsulation that meet the MACT definition of"building insulation." Some examples ofproducts which have not been converted to a non-PF binder include OEM insulation, medium density board, duct wrap, basement blanket, appliance insulation, and other insulation types. In**general~** LOrs vary from 5% to 8% and have densities from less than 0.5 lb/ft cu to more than 1.5 1b/ft cu.
• What properties do theseproductspossess? These products possess a wide and varied array ofphysical properties typical for insulation products beyond those defined in**MACT~** including R-value, recovery, tensile strength, moisture resistance, UL requirements, and others. In addition, they may have to meet specific requirements of how they handle and perform during post-manufacturingprocessing and/or installation.

• What would happen if EPA's proposed limits prohibited the manufacture of these products? Companies have stated that they would not be able to continue to manufacture certain products and meet the emission limits for some or all ofthese hazardous air pollutants ("HAPs") and could never add new lines for these products. That will cause them to either move these operations to Mexico or Canada or simply cease manufacturing those products where the proposed limits cannot be met in a financially viable manner. Because ofthe potential loss ofjobs at various locations and the movement of profitable business to outside ofthe United States, this impact from the proposed regulation would be of interest to the Office of Management and Budget ("OMB"). NAIMA is, therefore, prepared to present this issue should it become necessary. Pleasecontact meifyou have any additional questions. Sincerely,

# ~£.~ Angus E. Crane ExecutiveVice President, General Counsel

cc: 

### Mr. Keith W. Barnett Group Leader, Office ofAir Quality and Planning Standards SectorPolicies and Programs Division, Mineral and Manufacturing Group U.S. Environmental ProtectionAgency 4930 OldPageRoad Durham, NC 27703Ms. SusanFairchild March 12,2015 Page 3 

## VMr. PeterTsirigotis Director, Sector Policies and Programs Division Office ofAir QualityPlanning and Standards U.S. Environmental ProtectionAgency 4930 Old Page Road Durham, NC 27703