1 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 PM2 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 Questions3 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
VIAE-MAIL AND OVERNIGHTMAIL February 13,2015

Ms. SusanFairchild SectorPolicies and Programs Division Metals and Minerals Group (D243-02) Office ofAir QualityPlanning and Standards U.S. Environmental Protection Agency 4930 OldPage Road Durham, NC 27703
RE: NAIMA Responses To EPA's Questions

- Insulation Products Manufactured On Rotary Spin Lines and Clarification OnUse ofPhenolic Binder
DearMs. Fairchild:
The North American Insulation Manufacturers Association ("NAIMA") appreciates the opportunity to respond to your specific questions regarding insulationproducts manufactured on rotary spin lines and claritywhere phenol-fonnaldehyde ("PF',) binder is used ornotused. MACTDefinition 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 ofless than 8 percent and a density oflessthan 32 kilograms percubic meter (kg/m3) (2pounds per cubic foot [lb/ft3].,,2 The definition ofbuilding insulation captures insulation products that are used in the residential sector and inthe commercial and industrial sector. Rotary Spin Production Approximately 94.2 percent ofthe MACT applicable products, on a weighted-average basis, that were being produced onrotary spin lines have been converted to a non-PF binder.
Itis important to note thatNAIMA companies will not decide to switchbackto 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. SubpartNNN, § 63.1380. 240 C.F.R. SubpartNNN, § 63.1381.

11 CANAL CENTER PLAZA • SUITE 103 • ALEXANDRIA, VA 22314 • TEL 703/684·0084 • FAX 730/684·0427Ms. Susan Fairchild February l3, 2015 Page 2 operating permit, which, ofcourse, would involve the local permitting authority, and for those plants that are Title V facilities, notification and review ofthe 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 SubpartNNN. Approximately 5.8 percent of the MACT applicable products, on a weighted-average basis, beingproduced onrotary spin lines use a PF binder. This relative ratio

- the large percentage ofnon-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 ofMACT lines had been converted to non-PF binder and a very small number oflines 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 ofthose 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 ofproducts which have not been converted to a non-PF binder include OEM insulation, medium density board, duct wrap, basement blanket, appliance insulation, and other insulationtypes. 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 bythe current Wool Fiberglass Manufacturing MACT as follows:
Loss on ignition (LOI) means the percent decrease in weight ofwool fiberglass after it has been ignited. The LOI is used to monitor the weight percent ofbinder inwool fiberglass. 3
The LOI for the products that meetthe Rule's definition of"building insulation" and continue to use PFbinder is variable. The range is verywide, from 3percentto 8percent.

340C.F.R. SubpartNNN, § 63.138l.Ms. SusanFairchild 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 ofThese 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 ofthese 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 cannotbe met in a financially viable manner. Because ofthe potential loss of jobs at various locations and the movement ofprofitablebusiness to outside ofthe United States, this impact from the proposed regulation would be ofinterest to the Office ofManagement and Budget ("OMB"). NAIMA is, therefore, prepared to present this issue should itbecome 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 offormaldehyde binders. As noted in EPA's original proposal, "[d]ue to industry's efforts to replace phenol-formaldehyde binders, more than 95 percentofformaldehyde, phenol, and methanol emissions have beenreduced

... ,,4 This was a significant achievement and gave EPA a far greater reduction ofHAPs than ifthey 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 offormaldehyde or otherpollutants in different MACT Standards.
EPA can avoid such a consequence through either oftwo 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. SusanFairchild February 13,2015 Page 4
the fact that the reduction offormaldehyde was significantly more than EPA projected 

### it would be. Moreover, the phenol and methanol limits could be evaluated as part ofthe 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 ofthe remaining uses ofPF with non-PF binders. Some project that could likely take place within 5 years. This is a legallyjustifiable position because itavoids 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 ofexisting rotary spin lines, the 1.2 lb. perton 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 inNAIMA'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 notbe based on MACT compliance data. Please do not hesitate to contactme with any questions. Sincerely,

# t:rZExecutive Vice President, General Counsel Enclosure

cc: 

### Mr. Keith W. Barnett Group Leader, Office ofAir Quality and Planning Standards Sector Policies and Programs Division, Mineral and Manufacturing Group U.S. Environmental Protection Agency 4930 OldPage Road Durham, NC 27703Ms. SusanFairchild February 13, 2015 Page 5
Mr. PeterTsirigotis Director, Sector Policies and Programs Division Office ofAir Quality Planning and Standards U.S. Environmental ProtectionAgency 4930 Old Page Road 

### Durham, NC 27703KEYEXCERPTS FROMNAIMA'S COMMENTSAND LETTERSTO 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 ofthe fiber glass industry is no longer subject to the MACT. 

### In NAIMA's "Overview ofSource 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 offormaldehyde 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 ofthe 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'srevised limits for formaldehyde, phenol, and methanol. Specific performance requirements for certain products very different from typical residential products

- generally mandate that the level ofbinder 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 beenignited. The LOI is used to monitor the weight percent ofbinder inwool 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 notbe able to continue to manufacture certainproducts and meet the emission limits for some or all ofthese 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 ofthe potential loss ofjobs at various locations and the movement of profitable business to outside ofthe United States, NAIMA is prepared to present this issue, using all possible resources, to the Office ofManagement and Budget ("OMB").

• NAlMA's Comments: May 30, 2013, pp. 34-35 While much ofthe 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 ofthe fact that some formaldehyde and methanol is created from the combustion ofnatural gas used in the wool fiber glass production

.... The vast majority ofthe industry has switched to non-PF binders. Other facilities are in the process ofswitching 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 ofthe 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 onone line, given the products it produces, may not be achievable on other lines producing different products. Moreover, EPA needs to be cognizant ofthe fact that some formaldehyde and methanol is created from the combustion ofnatural gas used in the wool fiber glass production.

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