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.org44 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: Sta tus of Conversion to Non

- Phenol

- Formaldehyde Binders

Dear Ms. Fairchild:

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

manufacturing members greatly appreciated th e opportunity to provide EPA tour s of four

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

issues related to EPA’s supplemental proposals to the Propose d 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 bi nder and

, thus

, are no

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

S et forth below is a list, organized by company, of th e plants that no longer employ phenol

formaldehyde 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 lin es 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 sub ject 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 subj ect 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 i s still subject to NNN)

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

CertainTeed Corporation

• Athens, Georgia (1 unbonded line and 1 conve rted 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 formaldehyde

based binder is neither a simple nor an easy step. Any such change , under most circumstances,

would require a n 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, th is 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 ha ve 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, p lease do not hesitate to

co ntact 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

Resear ch Triangle Park, NC 27709

- 2194