1 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 OVERNIGHTMAIL
March 12,2015

Ms. SusanFairchild SectorPolicies andPrograms Division Metals andMinerals Group (D243-02) Office ofAir QualityPlanning and Standards U.S. Environmental ProtectionAgency 4930 OldPageRoad Durham, NC 27703
RE: Possible Subcategorization Options For the Wool Fiberglass Manufacturing MACT Standard
DearMs. Fairchild:
The North American Insulation Manufacturers Association (''NAIMA'') appreciates the opportunityto suggestpossible subcategorizationoptions for the Wool Fiberglass Manufacturing MACT Standard. NAIMA and its members are particularly reluctant to pursue subcategorization options because thevariety and range ofproducts 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 ofthe 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 ofphenol to formaldehyde and methanol to formaldehyde as described below using a subcategory. NAIMA offers these subcategoryoptionsto continue a meaningful dialogue withEPA.
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 ofbuilding 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 inreductions 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 withinthe building insulation defInition. Building insulationproducts made onrotary spin lines withinthe Subcategory 1optionwould be subjectto the limitspreviously proposedby EPA.
NAIMA could support subcategorization if the subcategories described below resulted in the retention ofthe 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 ofits members by establishing feasible limits. It is also importantto recognize thatthe scope ofthese proposed subcategory options is very limited

- less than fIve percent ofthe fIbers manufactured by the industry. There has already been a reduction of 95 percent ofthe formaldehyde emissions from this industry. This is a very small set of productsbeing addressed here.
SUBCATEGORIES Subcategory 1 - Loss onIgnition ("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 ofless than 2 Ibs. per cubic foot).
Products inthis subcategory would betypicalresidential insulationproducts.
NAIMA requests that inthis subcategory, EPA impose its currentlyproposed emissionlimits for formaldehyde, phenol, and methanol.
Subcategory 2 - Loss onIgnition ("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 ofless than2lbs. per cubic foot). SpecifIc performance requirements for products in this subcategory are very different from typical residential insulation products. They generally mandatethat given generally available technology that they be produced using a phenol formaldehyde binder and at a level ofbinder higher thanthatused for residential insulation. As such, these specialized products can have a higher loss onignition. The "loss onignition" ("LO!") would notbe 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 ofthe LOI range for building insulation. LOI is defIned by the current Wool Fiberglass ManufacturingMACT 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 ofbinder inwool fiberglass.2 

### Examples of products covered by this characteristic would include OEM insulation, medium densityboard, ductwrap, basementblanket, and appliance insulation.
NAIMA requests that products in this subcategory currently manufactured with a phenol formaldehyde binderandhaving a 5 

### < 8% LOI wouldretain the currentformaldehyde limitand applytheratios ofphenol 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 wouldberetained for formaldehyde and the phenol and methanol limits would be 1.64 lb. perton (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 InsulationRule (16 C.F.R. Part 460) (As ConstitutedAs of2015) Building insulation (as defined in Subpart NNN § 63.1381) products produced with a phenol formaldehyde binder and not subjectto the FTC Home Insulation Rule (16 C.F.R. Part 460) (as constituted as of2015) (and still with a density ofless 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 ofsubstitute binder. The industry has not been able to develop acceptable substitute binders for many ofthe insulation products that are not subject to the FTC Home Insulation Rule. Examples ofinsulation 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 ofphenol to formaldehyde and methanol to formaldehyde from the SupplementalProposalto the currentformaldehyde limitto derive whatthe phenol and methanol floors would have been in 1999. Using the example ofexisting 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. perton (1.2*(0.26/0.19» and 5.24 lb. perton (1.2* (0.83/0.19»,respectively.

240 C.F.R. SUbpartNNN, § 63.1381.Ms. SusanFairchild March 12,2015 Page4
Subcategory 4

- Insulation Products That Are Currently Produced Using a Phenol FonnaldehydeBinder and ThatAre Faced Using a Water-BasedAdhesive 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. percubic 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 whichreduces its recovery sothatitcannotmeetits requiredR-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 Proposalto the current fonnaldehyde limitto derive what the phenol and methanol floors would have been in 1999. Using the example ofexisting 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. perton (1.2*(0.2610.19)) and 5.24 lb. perton(1.2* (0.83/0.19)), respectively.
Pleasedonothesitateto contactme withany questions. Sincerely,

# ~Z-~ Angus E. Crane Executive Vice President, General Counsel

cc: 

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

# V Mr. PeterTsirigotis Director, SectorPolicies and Programs Division Office ofAirQualityPlanning and Standards U.S. Environmental ProtectionAgency 4930 Old Page Road Durham,NC 27703