From: Angus Crane [mailto:acrane@naima.org] 

Sent: Tuesday, December 11, 2012 4:58 PM

To: Fairchild.Susan@epamail.epa.gov

Cc: Keith Barnett (Barnett.Keith@epamail.epa.gov); Reeves, David

Subject: NAIMA Letter Addressing Plants/Lines No Longer Subject to Subpart NNN

Dear Susan, 

Please find attached the letter promised during last week’s plant tours.

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
44 Canal Center Plaza ▪ Suite 310 ▪ Alexandria, Virginia 22314 ▪ Tel: (703) 684-0084 ▪ Fax: (703) 684-0427

VIA E-MAIL AND OVERNIGHT MAIL

December 11, 2012

Ms. Susan Fairchild

Sector Policies and Programs Division

Metals and Minerals Group (D243-02)

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

109 T.W. Alexander Drive

Research Triangle Park, NC 27711

RE: Status of Conversion to Non-Phenol-Formaldehyde Binders

Dear Ms. Fairchild:

The North American Insulation Manufacturers Association (“NAIMA”) and its fiber glass 

manufacturing members greatly appreciated the opportunity to provide EPA tours of four 

different manufacturing facilities and to meet with Agency representatives to discuss various 

issues related to EPA’s supplemental proposals to the Proposed Rule for the National Emission 

Standards for Hazardous Air Pollutants: Wool Fiberglass Manufacturing.

During the plant tours, EPA requested definitive identification of those wool fiber glass 

manufacturing plants that have switched to a non-phenol-formaldehyde binder and, thus, are no 

longer subject to 40 C.F.R. Part 63, Subpart NNN. This letter responds to that request.

Set forth below is a list, organized by company, of the plants that no longer employ phenolformaldehyde binders and, therefore, are not subject to Subpart NNN. In addition, some of the 

listed lines were never subject to NNN as they either were never major sources of HAPs or never 

were affected sources under NNN because they used no binder.

Owens Corning

• Delmar, New York (2 of 2 lines converted and now not subject to NNN)

• Eloy, Arizona (used phenol/formaldehyde binder but has converted and now not subject 

to NNN)

• Fairburn, Georgia (3 of 3 lines converted and now not subject to NNN)

• Kansas City, Kansas (3 of 3 lines converted and now not subject to NNN)

• Lakeland, Florida (used phenol/formaldehyde binder but now uses no binder and not 

subject to NNN)
Ms. Susan Fairchild

December 11, 2012

Page 2

• Mount Vernon, Ohio (unbonded lines and not subject to NNN)

• Nephi, Utah (used phenol/formaldehyde binder but now uses no binder and not subject to 

NNN)

• Newark, Ohio (3 of 4 lines in process of converting but still subject to NNN)

• Salt Lake City, Utah (used phenol/formaldehyde binder but now uses no binder and not 

subject to NNN)

• Santa Clara, California (2 of 2 lines converted and now not subject to NNN)

• Waxahachie, Texas (2 of 3 lines converted; 1 line still subject to NNN)

Johns Manville

• McPherson, Kansas (all lines converted and not subject to NNN)

• Berlin (Penbryn), New Jersey (all lines converted and not subject to NNN)

• Richmond, Indiana (unbonded lines and not subject to NNN)

• Waterville, Ohio (unbonded lines and not subject to NNN)

• Willows, California (all lines converted and not subject to NNN)

• Winder, Georgia (all lines converted and not subject to NNN)

Knauf Insulation

• Lanett, Alabama (all lines converted and not subject to NNN)

• Shasta Lake, California (all lines converted and not subject to NNN)

• Shelbyville, Indiana (some lines periodically use a formaldehyde binder)

Guardian Fiberglass

• Albion, Michigan (1 line converted and 1 line is still subject to NNN)

• Kingman, Arizona (all lines converted and not subject to NNN)

CertainTeed Corporation

• Athens, Georgia (1 unbonded line and 1 converted line and now not subject to NNN)

• Chowchilla, California (all lines not subject to NNN)

• Kansas City, Kansas (2 lines not subject to NNN)

During last week’s plant tours, EPA expressed concern that companies might decide to switch 

back to a formaldehyde-based binder. It is important to know that reverting to formaldehydebased binder is neither a simple nor an easy step. Any such change, under most circumstances,

would require an amendment to the plant’s operating permit, which, of course, would involve the 

local permitting authority, and for those plants that are Title V facilities, notification and review 

by the EPA Regional office. As such, this action would not/could not be accomplished without 

EPA’s knowledge. Additionally, a change to a formaldehyde-based binder would also almost 

certainly cause a facility to again become subject to NNN.
Ms. Susan Fairchild

December 11, 2012

Page 3

The contents of this letter have been reviewed and approved by each wool fiber glass 

manufacturing company identified in this letter. I hope the information provided herein is 

responsive to your request. If you have any additional questions, please do not hesitate to 

contact me.

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

109 T.W. Alexander Drive (D243-04)

Research Triangle Park, NC 27711

Mr. Dave Reeves

RTI International

P.O. Box 12194

3040 East Cornwallis Road

Research Triangle Park, NC 27709-2194