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From: Angus Crane <acrane@naima.org>

Sent: Wednesday, February 18, 2015 2:33 PM

To: Danny Greene; Fairchild, Susan

Subject: RE: NAIMA Responses to EPA's Questions

Importance: High

Yes. 3:00 PM today would work. I would like to also have Mike Pettis on the call, too. Can the call-in number you gave 

me accommodate four different lines? 

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

From: Danny Greene [mailto:Danny.Greene@erg.com] 

Sent: Wednesday, February 18, 2015 1:50 PM 

To: Fairchild, Susan 

Cc: Angus Crane 

Subject: Re: NAIMA Responses to EPA's Questions 

Susan, I'm also working from home today but here's the call-in number and code: 

1 888 346-3659 

51823# 

Just let me know what time is acceptable for everyone. 

Thanks, 

Danny 

From: Fairchild, Susan <Fairchild.Susan@epa.gov> 

Sent: Wednesday, February 18, 2015 12:57 PM 
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To: Danny Greene 

Cc: Angus Crane 

Subject: FW: NAIMA Responses to EPA's Questions

Angus, I am snowed in and am working from home. I wonder if you would be available to discuss this 

issue with me in a 3-way call with our contractor, Danny Greene of ERG. 

Danny, If that is ok, would you initiate a call to Angus Crane regarding our response to him for 

specifics on the phenolic resins lines. I can participate in a 3-way conference call today if your phone 

system is capable of doing that. 

Thanks. I can be reached at 919-280-1801.

Susan Fairchild

Senior Environmental Scientist

(919) 541-5167

USPS Address:

OAQPS/SPPD/MMG

Mail Code D 243-04

Research Triangle Park, NC 27711

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

Sent: Wednesday, February 18, 2015 12:26 PM 

To: Fairchild, Susan 

Subject: RE: NAIMA Responses to EPA's Questions

Susan, I am working on this. I also left you a voicemail message.

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

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

Sent: Tuesday, February 17, 2015 12:26 PM 

To: Angus Crane 

Cc: Danny Greene; Barnett, Keith 

Subject: RE: NAIMA Responses to EPA's Questions
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Angus,

Please identify specifically which test data corresponds to the high-binder products, which lines 

specifically manufacture those products, and identify the specific facilities, test dates, pollutants, and 

process units tested.

Susan Fairchild

Senior Environmental Scientist

(919) 541-5167

USPS Address:

OAQPS/SPPD/MMG

Mail Code D 243-04

Research Triangle Park, NC 27711

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

Sent: Friday, February 13, 2015 3:51 PM 

To: Fairchild, Susan 

Cc: Barnett, Keith; Tsirigotis, Peter 

Subject: NAIMA Responses to EPA's Questions 

Importance: High

Dear Ms. Fairchild:

Please find attached NAIMA’s letter and attachment responding to your questions regarding insulation products 

manufactured on rotary spin lines and clarification on the use of phenolic binder for certain products. This same letter 

and attachment has also been sent to you via overnight mail.

I will follow-up with a telephone call to make certain you received the package and answer any questions you might 

have.

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 INSULATION 

MANUFACTURERS ASSOCIATION 

VIA E-MAIL AND OVERNIGHT MAIL 

February 13,2015 

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: 	 NAIMA Responses To EPA's Questions - Insulation Products Manufactured On 

Rotary Spin Lines and Clarification On Use of Phenolic Binder 

Dear Ms. Fairchild: 

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


opportunity to respond to your specific questions regarding insulation products manufactured on 


rotary spin lines and clarity where phenol-fonnaldehyde ("PF',) binder is used or not used. 


MACT Definition ofBuilding Insulation 

To properly answer your questions, it is essential to understand the parameters of the Wool 

Fiberglass Manufacturing MACT Standard itself. The MACT Standard applies to "[E]ach new 

and existing rotary spin wool fiberglass manufacturing line producing a bonded wool fiberglass 

building insulation product."l Building insulation is defined as follows: "[B]uilding insulation 

means bonded wool fiberglass insulation, having a loss on ignition of less than 8 percent and a 

density ofless than 32 kilograms per cubic meter (kg/m3

) (2 pounds per cubic foot [lb/ft3

].,,2 

The definition of building insulation captures insulation products that are used in the residential 


sector and in the commercial and industrial sector. 


Rotary Spin Production 

Approximately 94.2 percent of the MACT applicable products, on a weighted-average basis, that 

were being produced on rotary spin lines have been converted to a non-PF binder. 

It is important to note that NAIMA companies will not decide to switch back to a formaldehydebased binder. Reverting back to a formaldehyde-based binder is neither a simple nor an easy 

step. Any such change, under most circumstances, would require an amendment to the plant's 

140 C.F.R. Subpart NNN, § 63.1380. 


240 C.F.R. SubpartNNN, § 63.1381. 


11 CANAL CENTER PLAZA • SUITE 103 • ALEXANDRIA, VA 22314 • TEL 703/684·0084 • FAX 730/684·0427 
Ms. Susan Fairchild 

February l3, 2015 

Page 2 

operating permit, which, of course, would involve the local permitting authority, and for those 

plants that are Title V facilities, notification and review of 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 Subpart NNN. 

Approximately 5.8 percent of the MACT applicable products, on a weighted-average basis, 

being produced on rotary spin lines use a PF binder. 

This relative ratio - the large percentage of non-PF or unbonded products compared with the 

smaller percentage of products made with PF binder - validate NAIMA's previously stated 

position that the vast majority of MACT lines had been converted to non-PF binder and a very 

small number of lines continue to use PF binder as set forth in written comments and letters (see 

key excerpts from comments and letters enclosed herewith). 

Products Made With PF Binders 

In the context of those products that are made with PF binder, the Environmental Protection 

Agency ("EPA") has asked what products are being made. 

The products are different types of insulation that meet the MACT definition of "building 

insulation." The variety is so broad that it is difficult to even quantify. For example, one 

company has as many as 16,000 SKUs - or distinctly different products. This is not an anomaly, 

as all companies report large variation in products. Some examples of products which have not 

been converted to a non-PF binder include OEM insulation, medium density board, duct wrap, 

basement blanket, appliance insulation, and other insulation types. 

What Is the LOI? 

Specific performance requirements for certain products very different from typical residential 

insulation products - generally mandate that the level of binder be higher than that used for 

residential insulation. Typically, these specialized products can have a higher loss on ignition. 

The "Loss on Ignition" ("LOI") would not be uniform for all products, as it is dependent on the 

performance requirements ofthe specific product. LOI is defined by the current Wool Fiberglass 

Manufacturing MACT as follows: 

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. 3 

The LOI for the products that meet the Rule's definition of "building insulation" and continue to 

use PF binder is variable. The range is very wide, from 3 percent to 8 percent. 

340 C.F.R. Subpart NNN, § 63.138l. 
Ms. Susan Fairchild 

February 13,2015 

Page 3 

What Are the Emissions? 

NAIMA has provided EPA emissions data for products that continue to use a PF binder. The 

data available shows that EPA's proposed formaldehyde, phenol, and methanol limits are not 

feasible. 

What Would Happen IfEPA Prohibited Manufacture of These Products? 

Companies have stated that they would not be able to continue to manufacture certain products 

and meet the emission limits for some or all of these hazardous air pollutants ("HAPs") and 

could never add new lines for these products. That will cause them to either move these 

operations to Mexico or Canada or simply cease manufacturing those products because the 

proposed limits cannot be met in a financially viable manner. 

Because ofthe potential loss ofjobs at various locations and the movement of profitable business 

to outside of the United States, this impact from the proposed regulation would be of interest to 

the Office ofManagement and Budget ("OMB"). NAIMA is, therefore, prepared to present this 

issue should it become necessary. 

The Best Solution 

Asking for this detailed product information suggests that EPA is contemplating a 

subcategorization option. NAIMA believes that there is a more apparent and more legally 

defensible approach. The wool fiber glass manufacturing industry through voluntary measures 

substituted formaldehyde binder with non-PF binder. The vast majority of the industry 

participated in this successful replacement of formaldehyde binders. As noted in EPA's original 

proposal, "[d]ue to industry's efforts to replace phenol-formaldehyde binders, more than 95 

percent of formaldehyde, phenol, and methanol emissions have been reduced ...,,4 

This was a significant achievement and gave EPA a far greater reduction of HAPs than if they 

had relied exclusively upon the regulatory process. For EPA to then turn around and impose a 

new formaldehyde limit so stringent that the few remaining lines utilizing formaldehyde cannot 

meet those limits would indeed be a bad policy decision - one that would have to be legally 

challenged. Certainly, it would seem that EPA was being punitive and creating a highly visible 

precedent that would certainly discourage industry from pursuing any future voluntary 

reductions of formaldehyde or other pollutants in different MACT Standards. 

EPA can avoid such a consequence through either of two scenarios that have previously been 

discussed. At least one of these two approaches, described below, should be adopted by the 

Agency. 

First, EPA could retain the original MACT limit for formaldehyde and continue to have 

formaldehyde serve as a surrogate for phenol and methanol. This decision can be supported by 

476 Fed. Reg. 72,770,72,803 (November 25,2011). 
Ms. Susan Fairchild 

February 13,2015 

Page 4 

the fact that the reduction of formaldehyde was significantly more than EPA projected it would 

be. Moreover, the phenol and methanol limits could be evaluated as part of the next recurring 

residual risk assessment. This approach is further justified by the fact that· the industry has 

expressed a desire to continue to replace more of the remaining uses of PF with non-PF binders. 

Some project that could likely take place within 5 years. This is a legally justifiable position 

because it avoids MACT-on-MACT legal issues. 

Second, EPA could preserve the original formaldehyde limit and set an emission limit for phenol 

and methanol based on a reliable ratio between formaldehyde, phenol, and methanol emissions 

from the industry. EPA could 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. 

The ratio approach is likely the best alternative as it was identified independently by both EPA 

and NAlMA. These ratios can be established from EPA's Technical Memos related to the 

original MACT for Wool Fiberglass Manufacturing dated February 17, 1995 and October 21, 

1996 (previously provided to EPA in NAIMA's January 14,2015 comments). 

As noted above, this approach also effectively avoids the MACT-on-MACT legal issues raised in 

NAlMA's comments because the original MACT formaldehyde limit would be retained and the 

phenol and methanol limits would not be based on MACT compliance data. 

Please do not hesitate to contact me with any questions. 

Sincerely,

t:rZExecutive Vice President, General Counsel 

Enclosure 

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 


4930 Old Page Road 


Durham, NC 27703 

Ms. Susan Fairchild 

February 13, 2015 

Page 5 

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 
KEY EXCERPTS FROM NAIMA'S COMMENTS AND LETTERS TO EPA 

• NAIMA' Comments: February 3, 2012, p. 38 

EPA's proposed limits for formaldehyde, phenol, and methanol seem superfluous 

given the fact that the majority of the fiber glass industry is no longer subject to 

the MACT. In NAIMA's "Overview of Source Category and MACT Standard" 

set forth above, 23 facilities were specifically identified as having switched to 

Non-PF binders. Most other facilities are in the process of switching to Non-PF 

binders and will have completed that process before the new MACT compliance 

deadline. This means that there has been a virtual elimination of formaldehyde 

emissions from the binder for the vast majority of the fiber glass building 

insulation industry. 

NAIMA is concerned about the approach EPA has taken for formaldehyde, 

phenol, and methanol. While much ofthe industry has voluntarily switched from 

a formaldehyde binder to Non-PF binders, certain products continue to use a 

formaldehyde binder. Therefore, it remains important that the limits for 

formaldehyde, phenol, and methanol can be feasibly achieved when PF binder is 

used. 

• NAIMA's Letter: June 6, 2012, pp. 2-3 

The second issue - formaldehyde, phenol, and methanol limits for rotary spin and 

flame attenuation - has fiber glass manufacturers deeply concerned. The vast 

majority of wool fiber glass manufacturers have switched from phenol 

formaldehyde binders to non-phenol formaldehyde. This action has enabled EPA 

and industry to achieve a massive reduction of the only hazardous air pollutant 

("HAP") regulated in the Wool Fiberglass Manufacturing MACT. However, 

those sources continuing to use formaldehyde binders will not be able to meet 

EPA's revised limits for formaldehyde, phenol, and methanol. 

Specific performance requirements for certain products very different from 

typical residential products - generally mandate that the level of binder be higher 

than that used for typical residential insulation. Typically, these specialized 

products have a higher loss on ignition ("LOI"). LOI is defined by the current 

Wool Fiberglass Manufacturing MACT as follows: 

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. 
Upon reviewing EPA's revised - improved but still not feasible -limits for rotary 

spin lines for formaldehyde, phenol, and methanol, companies have unequivocally 

stated that they would not be able to continue to manufacture certain products and 

meet the emission limits for some or all of these HAPs. That will cause them to 

either move these operations to Mexico or Canada or simply cease manufacturing 

those products because the proposed limits cannot be met in a financially viable 

manner.... 

Because of the potential loss of jobs at various locations and the movement of 

profitable business to outside of the United States, NAIMA is prepared to present 

this issue, using all possible resources, to the Office of Management and Budget 

("OMB"). 

• NAlMA's Comments: May 30, 2013, pp. 34-35 

While much of the industry has voluntarily switched from a formaldehyde binder 

to non-PF binders, certain products continue to use a formaldehyde binder as the 

only alternative available to produce products that must meet specific product 

performance standards. Therefore, it remains important that the limits for 

formaldehyde, phenol, and methanol can be feasibly achieved when PF binder is 

used to produce these products. Moreover, EPA needs to be cognizant of the fact 

that some formaldehyde and methanol is created from the combustion of natural 

gas used in the wool fiber glass production .... 

The vast majority of the industry has switched to non-PF binders. Other facilities 

are in the process of switching to non-PF binders - more will switch as soon as 

they are able to develop replacement binders that produce products that meet 

required performance standards. 

• NAlMA's Comments: January 14,2015, pp. 46-47 

While much of the industry has voluntarily switched from a phenol-formaldehyde 

binder to non-PF binders, certain products continue to use a phenol-formaldehyde 

binder due to customer needs or as the only alternative available to produce 

products that must meet specific product performance standards. Therefore, it 

remains important that the limits for formaldehyde, phenol, and methanol can be 

feasibly achieved when PF binder is used to produce these products. Different 

products are produced on different lines, and what may be achievable on one line, 

given the products it produces, may not be achievable on other lines producing 

different products. Moreover, EPA needs to be cognizant of the fact that some 

formaldehyde and methanol is created from the combustion of natural gas used in 

the wool fiber glass production. 

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