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From: Angus Crane <acrane@naima.org>

Sent: Thursday, March 12, 2015 1:02 PM

To: Fairchild, Susan

Cc: Barnett, Keith; Tsirigotis, Peter

Subject: NAIMA Letter Answering Specific EPA Questions

Attachments: RR3794.docx

Dear Ms. Fairchild: 

Please find attached a letter that answers specific questions you have posed to NAIMA and its members. Some of these 

answers have been previously provided to EPA, but the format of this letter more clearly identifies the questions or 

issues and provides the corresponding answer. I will call you to confirm receipt of this letter. 

Sincerely, 

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
NAIMA 


NORTH AMERICAN lNSUL.A'I'ION 

MANU F'ACTlJRERS 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: 	 Possible Subcategorization Options For the Wool Fiberglass Manufacturing 

MACT Standard 

Dear Ms. Fairchild: 

The North American Insulation Manufacturers Association (''NAIMA'') appreciates the 

opportunity to suggest possible subcategorization options for the Wool Fiberglass Manufacturing 

MACT Standard. NAIMA and its members are particularly reluctant to pursue 

subcategorization options because the variety and range of products and characteristics of 

products are so wide and so broad that administering and managing these subcategories 

would be burdensome and unwieldy for both the Environmental Protection Agency 

("EPA") and the industry. NAIMA asks EPA to take the simpler, legally defensible, and the 

most effective option available the preservation of the original MACT formaldehyde limit, 

which is based on a still valid MACT floor, and setting a phenol and methanollirnit based on a 

ratio between these three pollutants as established in EPA's Supplemental Proposal.1 

Alternatively, another option is to set a limit based on ratios of phenol to formaldehyde and 

methanol to formaldehyde as described below using a subcategory. NAIMA offers these 

subcategory options to continue a meaningful dialogue with EPA. 

The subcategory options set forth below would be applicable to new and existing rotary spin 


wool fiber glass manufacturing lines producing a bonded wool fiber glass building insulation (as 


defined in Subpart NNN § 63.1381) product. In other words, each option would carve out a 


subcategory from the existing definition of building insulation and each retains the "building 


I Using the ratio between formaldehyde, phenol, and methanol that was established in EPA's Supplemental 


Proposal's limits for formaldehyde, phenol, and methanol, NAIMA proposes retaining the original MACT 


formaldehyde liinit and setting phenol and methanol limits based on the ratio of phenol to formaldehyde and 


methanol to formaldehyde set forth in EPA's own proposal. In other words, the ratio between formaldehyde, 


phenol, and methanol established in EPA's proposed limits is reproduced/preserved in NAIMA's alternative 


approach. Using this approach for existing rotary spin lines, the 1.2 lb.. per ton limit would be retained for 


formaldehyde and the phenol and methanol limits would be 1.64 lb. per ton (1.2*(0.26/0.19» and 5.24 lb. per ton 


(1.2* (0.83/0.19», respectively. (This avoids a MACT-on-MACT challenge as the reductions in formaldehyde 


resulted in reductions in phenol and methanol.) 


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 

insulation" requirement that the product must have a density less than 2 Ibs. per cubic foot to be 

within the building insulation defInition. Building insulation products made on rotary spin lines 

within the Subcategory 1 option would be subject to the limits previously proposed by EPA. 

NAIMA could support subcategorization if the subcategories described below resulted in the 

retention of the 1999 standard for formaldehyde for the subcategory or subcategories selected 

(other than Subcategory 1), with phenol and methanol limits set based on a ratio to the 1999 

formaldehyde standard. Please keep in mind that NAIMA's objective here is to protect and 

preserve the manufacturing capacity of its members by establishing feasible limits. It is also 

important to recognize that the scope of these proposed subcategory options is very limited - less 

than fIve percent of the fIbers manufactured by the industry. There has already been a reduction 

of 95 percent of the formaldehyde emissions from this industry. This is a very small set of 

products being addressed here. 

SUBCATEGORIES 

Subcategory 1 - Loss on Ignition ("LOr'): 0 - < 5% LOI 

Building insulation (as defIned in Subpart NNN § 63.1381) products produced with a 

phenol formaldehyde binder and having a 0 - 4.9% LOI (and still with a density of less 

than 2 Ibs. per cubic foot). 

Products in this subcategory would be typical residential insulation products. 

NAIMA requests that in this subcategory, EPA impose its currently proposed emission limits for 

formaldehyde, phenol, and methanol. 

Subcategory 2 - Loss on Ignition ("LOI"): 5 - < 8% LOI 

Building insulation (as defIned in Subpart NNN § 63.1381) products produced with a 

phenol formaldehyde binder and having a 5 - < 8% LOI (and still with a density of less 

than 2lbs. per cubic foot). 

SpecifIc performance requirements for products in this subcategory are very different 

from typical residential insulation products. They generally mandate that given generally 

available technology that they be produced using a phenol formaldehyde binder and at a 

level of binder higher than that used for residential insulation. As such, these specialized 

products can have a higher loss on ignition. The "loss on ignition" ("LO!") would not be 

uniform for all products, as it is dependent on the performance requirements of the 

specifIc product, but these specialized products generally run at the upper portion of the 

LOI range for building insulation. LOI is defIned by the current Wool Fiberglass 

Manufacturing MACT as follows: 
Ms. Susan Fairchild 

March 12,2015 

Page 3 

Loss on ignition (LOI) means the percent decrease in weight of wool 

fiberglass after it has been ignited. The LOI is used to monitor the weight 

percent of binder in wool fiberglass.2 

Examples of products covered by this characteristic would include OEM insulation, 

medium density board, duct wrap, basement blanket, and appliance insulation. 

NAIMA requests that products in this subcategory currently manufactured with a phenol 

formaldehyde binder and having a 5 < 8% LOI would retain the current formaldehyde limit and 

apply the ratios of phenol to formaldehyde and methanol to formaldehyde from the Supplemental 

Proposal to the current formaldehyde limit to derive what the phenol and methanol floors would 

have been in 1999. Using the example of existing rotary spin lines, the 1.2 lb. per ton limit 

would be retained for formaldehyde and the phenol and methanol limits would be 1.64 lb. per ton 

(1.2*(0.26/0.19» and 5.24 lb. perton (1.2* (0.83/0.19», respectively. 

Subcategory 3 - Thermal Insulation Not Subject To the Federal Trade Commission 

("FTC") Home Insulation Rule (16 C.F.R. Part 460) (As Constituted As of 2015) 

Building insulation (as defined in Subpart NNN § 63.1381) products produced with a 

phenol formaldehyde binder and not subject to the FTC Home Insulation Rule (16 C.F.R. 

Part 460) (as constituted as of 2015) (and still with a density of less than 2 lbs. per cubic 

foot). 

The fiber glass insulation industry has not fully converted insulation products from 

phenol formaldehyde binder to non-phenol formaldehyde alternative binders. Different 

manufacturers have developed different forms of substitute binder. The industry has not 

been able to develop acceptable substitute binders for many of the insulation products 

that are not subject to the FTC Home Insulation Rule. Examples of insulation products 

not subject to the FTC Home Insulation Rule and still manufactured with a phenol 

formaldehyde binder are OEM insulation, medium density board, and appliance 

insulation. 

NAIMA requests that insulation products not subject to the FTC Home Insulation Rule and that 

are cu..--rently manufactured wit." a phenol formaldehyde binder retain the current formaldehyde 

limit and apply the ratios of phenol to formaldehyde and methanol to formaldehyde from the 

Supplemental Proposal to the current formaldehyde limit to derive what the phenol and methanol 

floors would have been in 1999. Using the example of existing rotary spin lines, the 1.2 lb. per 

ton limit would be retained for formaldehyde and the phenol and methanol limits would be 1.64 

lb. per ton (1.2*(0.26/0.19» and 5.24 lb. per ton (1.2* (0.83/0.19», respectively. 

240 C.F.R. SUbpartNNN, § 63.1381. 
Ms. Susan Fairchild 

March 12,2015 

Page 4 

Subcategory 4 - Insulation Products That Are Currently Produced Using a Phenol 

Fonnaldehyde Binder and That Are Faced Using a Water-Based Adhesive 

Building insulation (as defined in Subpart NNN § 63.1381) products produced with a 

phenol fonnaldehyde binder and that are faced using a waterMbased adhesive (and still 

with a density ofless than 2 lbs. per cubic foot. 

Products in this subcategory are used in specific applications that require that they have 

limited flame spread and smoke generation characteristics. To meet those limitations, 

they are faced with foil or a combination Kraft foil scrim facing which must be adhered 

to the insulation with a glue or adhesive. Non-water-based adhesives cause these 

products to generate excessive amounts of smoke and flame spread in a fire. Using 

water-based adhesives in these products gives them acceptable flame spread and smoke 

generation properties. However, when water-based adhesives are used, unless the 

insulation is produced with a phenol fonnaldehyde binder, it absorbs moisture from the 

adhesive which reduces its recovery so that it cannot meet its required R-value. 

Products in this subcategory are basement wall insulation and duct wrap produced with 

phenol fonnaldehyde binder and faced using a water-based adhesive. 

NAlMA requests that for insulation products that are produced using a phenol fonnaldehyde 

binder that are faced using a water-based adhesive, EPA retain the current fonnaldehyde limit 

and apply the ratios of phenol to fonnaldehyde and methanol to fonnaldehyde from the 

Supplemental Proposal to the current fonnaldehyde limit to derive what the phenol and methanol 

floors would have been in 1999. Using the example of existing rotary spin lines, the 1.2 lb. per 

ton limit would be retained for fonnaldehyde and the phenol and methanol limits would be 1.64 

lb. per ton (1.2*(0.2610.19)) and 5.24 lb. per ton (1.2* (0.83/0.19)), respectively. 

Please do not hesitate to contact me with any questions. 

Sincerely, 

~Z-~ Angus E. Crane 


Executive Vice President, General Counsel 


cc: 	 Mr. Keith W. Barnett 


Group Leader, Office ofAir 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 

PageS 

V 	Mr. 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