NAIMA 


NORTH AMERICAN INSUL.ATION 

MANUFACTU R ERS ASSOCIATION 

VIA E-MAIL AND OVERNIGHT MAIL 

March 12, 2015 

Ms. Susan Fairchild 

Sector Policies and Programs Division 

Metals and Minerals Group (D243-02) 

Office ofAir Quality Planning and Standards 

U.S. Environmental Protection Agency 

4930 Old Page Road 

Durham, NC 27703 

RE: Specific Answers To EPA's Questions On Formaldehyde, Phenol. and Methanol 

Dear Ms. Fairchild: 

Please find below specific answers to questions you have raised. 

• 	 Emissions data that confirms that the proposed emission limits on formaldehyde, phenol, 

and methanol are not feasible for all lines:} 

Emissions data that demonstrate the currently proposed limits cannot be met: 

• 	 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 data to be supplied separately) 

• 	 O.5lb/ton (raw data to be supplied separately) 

• Phenol (Proposed Limit for Rotary Spin Existing Sources) 0.261b/ton 

• 	 0.6 1b/ton (raw data to 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 

their plants. 

I Not all lines have data for all pollutants and those estimates are indicated with an asterisk. 

11 CANAL CENTER PLAZA • SUITE 103 • ALEXANDRIA, VA 22314 • TEL 703/684-0084 • FAX 730/684-0427 
Ms. Susan Fairchild 


March 12~ 2015 


Page 2 


• 	 What products are made? 

The products are made on "rotary spin" manufacturing lines and are different 

types of insulation that meet the MACT definition of "building insulation." Some 

examples of products 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 these products possess? 

These products possess a wide and varied array of physical 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-manufacturing processing 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 of these 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 of the potential loss of jobs at various locations and the movement of 

profitable business to outside of the 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. 

Please contact me if you have any additional questions. 

Sincerely, 

~£.~ Angus E. Crane 

Executive Vice President, General Counsel 

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 


4930 Old Page Road 


Durham, NC 27703 

Ms. Susan Fairchild 

March 12,2015 

Page 3 

VMr. Peter Tsirigotis 

Director, Sector Policies and Programs Division 

Office ofAir Quality Planning and Standards 

U.S. Environmental Protection Agency 

4930 Old Page Road 

Durham, NC 27703