From: ALDRIDGE Steve <steve.aldridge@us.knaufinsulation.com>

To: Susan Fairchild/RTP/USEPA/US@EPA

Date: 12/16/2011 03:30 PM

Subject:RE: Knauf Insulation - 114 ICR Attachment 1 A & B

Sorry, but no that is not correct. The Shelbyville facility produces a

significant amount of commercial and industrial (C/I) products that fall

outside of the Building Insulation product definition in 63.1381 used to

determine NNN applicability. We still use PF binders on some of these

products due to market demand. Therefore, we consider the Shelbyville

facility a major source of PF HAPs (phenol, methanol and Formaldehyde)

but not relative to NNN applicability.

At any given time we are running a mix of PF and non-PF binders on the

611, 612, 613 and 614 production lines (all fed glass from the 611

Furnace). The 602 production line is 100% non-PF (glass from the 602

Furnace). >95% of the products that meet the BI definition run on the

613/614 lines are non-PF. The 611 & 612 lines produce an uncured non-BI

product (no curing oven or cooling section).

I hope this helps.

Stephen R. Aldridge

Manager Corporate EH&S

KNAUFINSULATION

Tel: 866-445-2363, Ext. 8408 | Fax: 317-398-5501 | Mobile: 317-401-0564

-----Original Message-----

From: Susan Fairchild [mailto:Fairchild.Susan@epamail.epa.gov]

Sent: Friday, December 16, 2011 3:15 PM

To: ALDRIDGE Steve

Subject: RE: Knauf Insulation - 114 ICR Attachment 1 A & B

Okay, so just to clarify: The Shelbyville facility is not a major

source? but if you go back to using formaldehyde-based binders, as you

reserve the right to do, it would once again be major?
Thanks,

Susan Fairchild

Environmental Scientist

U.S. Environmental Protection Agency

direct line: 919.541.5167

fax: 919.541-3207

email: fairchild.susan@epa.gov

Overnight mail address:

US EPA

Mail Code D243-04

109 TW Alexander Drive

RTP, NC 27709

 From: ALDRIDGE Steve <steve.aldridge@us.knaufinsulation.com>

 To: Susan Fairchild/RTP/USEPA/US@EPA

 Date: 12/16/2011 02:47 PM

 Subject: RE: Knauf Insulation - 114 ICR Attachment 1 A & B

Yes, the Shelbyville facility would be a major source due to the use of

phenol/formaldehyde (PF) resins for non-Building Insulation (BI)

products (Building Insulation as defined in Subpart NNN). A significant

portion of the non-BI products have been converted to

non-phenol/formaldehyde binder, but some products still require the use

of PF binders.

Yes, the furnace refractory data is being submitted as CBI and will be

mailed to EPA next Monday.

Stephen R. Aldridge

Manager Corporate EH&S
KNAUFINSULATION

Tel: 866-445-2363, Ext. 8408 | Fax: 317-398-5501 | Mobile: 317-401-0564

-----Original Message-----

From: Susan Fairchild [mailto:Fairchild.Susan@epamail.epa.gov]

Sent: Friday, December 16, 2011 2:35 PM

To: ALDRIDGE Steve

Subject: Re: Knauf Insulation - 114 ICR Attachment 1 A & B

Thanks for your email. I have a couple of questions at first glance.

Is the facility at Shelbyville a major source? Your answer is (Embedded

image moved to file: pic26299.gif)and I'm unclear as to whether this is

a 'yes' or a 'no'.

Also, the refractory information for each of the glass furnaces is

missing. Are these data being sent under CBI?

Thanks,

Susan Fairchild

Environmental Scientist

U.S. Environmental Protection Agency

direct line: 919.541.5167

fax: 919.541-3207

email: fairchild.susan@epa.gov

Overnight mail address:

US EPA

Mail Code D243-04

109 TW Alexander Drive

RTP, NC 27709