1 Subject: RE: Angus Crane emails

From: Angus Crane <acrane@naima.org>

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

Date: 02/24/2011 11:24 AM

Subject: Rock Wool Manufacturing Data

‐ 3rd and final E

‐ m ail

Dear Susan,

Please find attached the third and final e

‐ mail, which will now have

provided to you via e

‐ mail all of Rock Wool Manufacturing’s BTEC non

–confidential reports, appendices, and data. I will send the

confidential version, via overnight mail, to Robert Morales today. BTEC

had problems getting this t hird e

‐ mail to me, so I need to make certain

that you can open this and access the data. If not, please tell me what

type of format you need it in and I will have BTEC resubmit it to me in

the requested format.

Angus E. Crane

Executi ve 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: rtysar@btecinc.com [mailto:rtysar@btecinc.com]

Sent: Thursday, February 24, 2011 10:49 AM

To: Angus Crane

Subject: RE: Request

Angus,

The last one is having trouble going thr ough. Please try the attached.

Thanks,

Randal J. Tysar

Senior Environmental Engineer

BT Environmental Consulting, Inc. (BTEC)

2615 Wolcott Street

Ferndale, Michigan 482202 DIRECT: (248) 548

‐ 8070

FAX: (248) 548

‐ 8073

CELL: (313) 308

‐ 6891

‐‐‐‐‐‐‐‐ Original Message

‐‐‐‐‐‐‐‐

Subject: RE: Request

From: Angus Crane <acrane@naima.org>

Date: Thu, February 24, 2011 7:31 am

To: "rtysar@btecinc.com" <rtysar@btecinc.com>

Randy, I did not receive the Sixth e

‐ mail. Can you please resend it?

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: rtysar@btecinc.com [mailto:rtysar@btecinc.com]

Sent: Wednesday, February 23, 2011 3:55 PM

To: Angus Crane

Subject: RE: Request

Angus,

Because of the size of the files, I am sending you the Rock Wool

documents as a series of six e

‐ mails. Attached is the fifth file, the

confidental version of the electronic ERT file for Rock Wool.

Thanks,

Randal J. Tysar

Senior Environmental Engineer

BT Environmental Consulting, Inc. (BTEC)

2615 Wolcott Street

Ferndale, Michigan 48220

DIRECT: (248) 548

‐ 8070

FAX: (248) 548

‐ 8073

CELL: (313) 308

‐ 6891

‐‐‐‐‐‐‐‐ Original Message

‐‐‐‐‐‐‐‐ Subject: Request

From: Angus Crane <acrane@naima.org>

Date: Wed, February 23, 2011 1:09 pm

To: "rtysar@btecinc.com" <rtysar@btecinc.com>, "barry boulianne

(bboulianne@sbcglobal.net)" <bboulianne@sbcglobal.net>

This is a follow

‐ up on my call to both of you. I need to have you

send me Rock Wool Manufacturing’s entire test report w/ appendices and

QA, and the confidential portions of the test report. I will then3 forward to the appropriate people at EPA. Thank you.

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

*********************** ATTACHMENT NOT DELIVERED *******************

This Email message contained an attachment named

Rock Wool Leeds database.zip

which may be a computer program. This attached computer program could

contain a computer virus which could cause harm to EPA's computers,

network, and data. The attachment has been deleted.

This was done to limit the distribution of computer viruses introduced

into the EPA network. EPA is deleting all computer program

attachments

sent from the Internet into the agency via Email.

If the message sender is known and the attachment was legitimate, you

should contact the sender and request that they rename the file name

extension and resend the Email with the renamed attachment. After

receiving the revised Email, containing the renamed attachment, you

can

rename the file extension to its correct name.

For further information, please contact the EPA Call Center at

(866) 411

‐ 4EPA (4372). The TDD number is (866) 489

‐ 4900.

*********************** ATTACHMENT NOT DELIVERED

***********************

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 02/24/2011 11:24 AM

Subject: You should have received a total of three e

‐ mails fr o m me forwarding to you Rock Wool

Manufacturing's

BTEC data4 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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 02/24/2011 12:20 PM

Subject: RE: Rock Wool Manufacturing Data

‐ 3rd and final E

‐ m ail

Yes. I will try that.

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@epamail.epa.gov [

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

Sent: Thursday, February 24, 2011 12:12 PM

To: Angus Crane

Subject: Re: Rock Wool Manufacturing Data

‐ 3rd and final E

‐ mail

Thanks for your email and heads up about potential problems with the

attachment. As you predicted, my firewall strips off zipped files.

We found that if you label the extension .abc it will not strip off.

Would you mind renaming the file with .abc as the extension, and then

attaching it to the email.5 Thanks for your help on this work!

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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

From: Angus Crane <acrane@naima.org>

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

Date: 02/24/2011 11:24 AM

Subject: Rock Wool Manufacturing Data

‐ 3rd and final E

‐ mail

Dear Susan,

Please find attached the third and final e

‐ mail, which will now have

provided to you via e

‐ mail all of Rock Wool Manufacturing’s BTEC non

–confidential reports, appendices, and data. I will send the

confidential version, via overnight mail, to Robert Morales today. BTEC

had problems getting this third e

‐ mail to me, so I need to make certain

that you can open this and access the data. If not, please tell me what

type of format you need it in and I will have BTEC resubmit it to me in

the requested format.

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.org6 From: rtysar@btecinc.com [mailto:rtysar@btecinc.com]

Sent: Thursday, February 24, 2011 10:49 AM

To: Angus Crane

Subject: RE: Request

Angus,

The last one is having trouble going through. Please try the attached.

Thanks,

Randal J. Tysar

Senior Environmental Engineer

BT Environmental Consulting, Inc. (BTEC)

2615 Wolcott Street

Ferndale, Michigan 48220

DIRECT: (248) 548

‐ 8070

FAX: (248) 548

‐ 8073

CELL: (313) 308

‐ 6891

‐‐‐‐‐‐‐‐ Original Message

‐‐‐‐‐‐‐‐ Subject: RE: Request

From: Angus Crane <acrane@naima.org>

Date: Thu, February 24, 2011 7:31 am

To: "rtysar@btecinc.com" <rtysar@btecinc.com>

Randy, I did not receive the Sixth e

‐ mail. Can you please resend it?

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: rtysar@btecinc.com [mailto:rtysar@btecinc.com]

Sent: Wednesday, February 23, 2011 3:55 PM

To: Angus Crane

Subject: RE: Request

Angus,

Because of the size of the files, I am sending you the Rock Wool

documents as a series of six e

‐ mails. Attached is the fifth file, the

confidental version of the electronic ERT file for Rock Wool.

Thanks,

Randal J. Tysar

Senior Environmental Engineer

BT Environmental Consulting, Inc. (BTEC)7 2615 Wolcott Street

Ferndale, Michigan 48220

DIRECT: (248) 548

‐ 8070

FAX: (248) 548

‐ 8073

CELL: (313) 308

‐ 6891

‐‐‐‐‐‐‐‐ Original Message

‐‐‐‐‐‐‐‐ Subject: Request

From: Angus Crane <acrane@naima.org>

Date: Wed, February 23, 2011 1:09 pm

To: "rtysar@btecinc.com" <rtysar@btecinc.com>, "barry boulianne

(bboulianne@sbcglobal.net)" <bboulianne@sbcglobal.net>

This is a follow

‐ up on my call to both of you. I need to have you send

me Rock Wool Manufacturing’s entire test report w/ appendices and QA,

and the confidential portions of the test report. I will then forward

to the appropriate people at EPA. Thank you.

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 02/24/2011 12:56 PM

Subject: Rock Wool Manufacturing Data

‐ 3rd and final E

‐ m ail

Dear Susan,

As you requested, we have changed the extension of the attachment

from .zip to .abc. Please let me know if you have any problems with

this version.

Angus E. Crane

Executive Vice President, General Counsel

North American Insulation Manufacturers Association8 Ph: (703) 684

‐ 0084 ext. 123

Fax: (703) 684

‐ 0427

Visit NAIMA online at:

www.naima.org

www.PipeInsulation.org

(See attached file: Rock Wool Leeds database.abc)

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 02/25/2011 09:52 AM

Subject: IIG Schematics or Process Diagram

Dear Susan,

IIG personnel has conducted another extensive search for a plant

schematic or process diagram. It does not exist.

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 02/25/2011 11:17 AM

Subject: FW: UPS Delivery Notification, Tracking Number 1ZAW579601916595119 Please find attached confirmation of the Rock Wool Documents sent to

Robert Morales.

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: UPS Quantum View [mailto:auto

‐ notify@ups.com]

Sent: Friday, February 25, 2011 11:12 AM

To: Angus Crane

Subject: UPS Delivery Notification, Tracking Number 1ZAW57960191659511

***Do not reply to this e

‐ mail. UPS and NAIMA will not receive your

reply.

At the request of NAIMA, this notice is to confirm that the following

shipment has been delivered.

Important Delivery Information

Tracking Number:

1ZAW57960191659511

Delivery Date / Time:

25

‐ February

‐ 2011 / 10:18 AM

Delivery Location: DOCK

Signed by: HARRIS JOHN

Shipment Detail

Ship To:

Roberto Morales, Doc. Control Ofcr

U.S. Environmental Protection Agenc10 109 TW ALEXANDER DR

DURHAM

NC

27709

US

Number of Packages:

1

UPS Service:

NEXT DAY AIR

Shipment Type:

Letter

____2RR2RR2.oVCG9E2oTNVR1w1xAR1VNTWV2RTV2UxcJARAxcNRcUvxVM____

Discover more about UPS:

Visit www.ups.com

Sign Up For Additional E

‐ Mail From UPS

Read Compass Online

© 2011 United Parcel Service of America, Inc. UPS, the UPS brandmark,

and the color brown are trademarks of United Parcel Service of

America, Inc. All rights reserved.

For more information on UPS's privacy practices, refer to the UPS

Privacy Policy.

Please do not reply directly to this e

‐ mail. UPS will not receive any

reply message.

For questions or comments, visit Contact UPS.

This communication contains proprietary information and may be

confidential. If you are not the intended recipient, the reading,

copying, disclosure or other use of the contents of this e

‐ mail is

strictly prohibited and you are instructed to please delete this

e

‐ mail immediately.

Privacy Policy11 Contact UPS

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 03/04/2011 10:37 AM

Subject: RE: Mineral Wool Stack Locations

I will address this promptly.

‐‐‐‐‐ Original Message

‐‐‐‐‐

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

Sent: Friday, March 04, 2011 9:55 AM

To: Angus Crane <acrane@naima.org>

Subject: Fw: Mineral Wool Stack Locations

Angus,

We have mapped all the emission source lat/longs provided by the mineral

wool industry in their ICR responses. They are all mostly within the

facility property, but the points seem to be scattered and do not often

fall on what looks like to be the stack. Sometimes, the lat/longs were

shown off plant property.

This is probably not because the plant personnel did not do their best

to get the lat/longs in their ICR, but it could be the difference

between one satellite and another.

Attached are jpg files that show aerial views of each plant (from Google

Earth). Also attached is a spreadsheet file with a list of the stacks

at each facility. In order to get a precise lat/long of the stacks

themselves for the modeling it would be helpful if the facilities could

physically “mark” the stacks that are listed in the spreadsheet. If

they just make marks on the picture, scan that and return the scanned

file to us, we can then take the marked up photographs and get the

actual lat/longs for each stack.

Is this the sort of thing that NAIMA could take care of, as you

indicated during our last conference call?

The alternative is for us to go to each plant, or to guess the locations12 ourselves, which may not be entirely accurate, and I want to give you

the first option of attaining that accuracy for us.

Thanks and let me know if you have any questions.

Again, I appreciate the assistance you have provided in this effort.

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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 03/09/2011 11:37 AM

Subject: Mineral Wool Stack Locations

Dear Susan:

I have set forth below the responses I received from each company. In

most cases, the company provided a written explanation and provided a

map with markings on it to help identify the emission sources.

∙ AMMEROCK

– “Hope you can make this out, the stack is at

the center of the white X I made, sort of gets lost in the picture

but let me know if you cannot tell where it is and I will try

something else.” See attached map.

∙ INDUSTRIAL INSULATION GROUP

– “The picture is correct.

The stacks are shown at the bottom of the buildings with a small

street coming to them from the right of the picture. The Latitude

& Longitude were determined by using Google Maps. If Ms.13 Fairchild needs better documentation than that, I can try to pull

some of the original Partek drawings and find it.” Attached map

was not modified.

∙ ISOLATEK

– “I have attached a photograph that shows the

location and coordinates of our fabric filter (baghouse) stack.

The coordinates are consistent (+/

‐ 10') with the information

given to the US EPA in our initial filing. You may forward to

directly to Susan Fairchild on our behalf.” See attached map.

∙ ROCK WOOL

– “Attached is a copy of the locations of

Emission units. If you have any other questions please contact

me.” See attached map.

∙ THERMAFIBER

– See attached map.

∙ USG

– MN

– “The afterburner stack location has been

marked.” See attached map.

∙ USG

– WI

– “I put a red spot on the cupola stack.” See

attached map.

Please let me know if I can provide you with additional information.

Sincerely,

Angus E. Crane

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

(See attached file: Amerrock_Products_TX.pdf)(See attached file:IIG_Alabama.pdf)(See attached

file: Isolatek Fabric Filter Stack

Coordinates.pdf)(See attached file: Rock Wool AL.pdf)(See attached file:

Thermafber Stack Location Response.pdf)(See attached file: USG_MN

‐

Afterburner Stack Location.pdf)(See attached file: USG_WI stack

marked.pdf)

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 04/01/2011 04:25 PM

Subject: Your Voice Mail

Dear Susan,14 I picked up your voice mail today. I am returning from three days of

travel, and I will plan on calling you on Monday, April 4, 2011.

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 04/11/2011 09:54 AM

Subject: Voice Mails

Dear Susan,

I left you several voice mails last week responding to your request on

obtaining additional mineral wool financial data. I hope you received

them. I am ready to talk with you when you have the time. I know you

are very busy.

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 04/14/2011 04:55 PM15 Subject: RE: Incorrect contact informat i on for John Dolin

The name is Rick Dolin, but I am going to send new contact information

for IIG and Rock Wool Manufacturing first thing tomorrow morning.

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@epamail.epa.gov [

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

Sent: Thursday, April 14, 2011 4:42 PM

To: Angus Crane

Cc: Barch.Madeline@epamail.epa.gov

Subject: Fw: Incorrect contact information for John Dolin

Can I ask for your assistance, yet again? Madeline Barch of Our Office

of Policy (OP) is leading the outreach with the small business reps and

is getting all the information on the April meeting out to them. The

contact number and email we have for IIG is not working....do you have

updated contact information for John Dolin?

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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 04/14/2011 04:39 PM

‐‐‐‐‐

From: Madeline Barch/DC/USEPA/US

To: Susan Fairchild/RTP/USEPA/US@EPA16 Date: 04/14/2011 04:34 PM

Subject: Incorrect contact information for John Dolin

Hi, Susan:

I've tried emailing and calling John Dolin at Industrial Insulation

Group. It looks like both the email address and phone number are

inaccurate. Do you have any updated contact information?

Madeline Barch

Regulatory Management Division, Office of Policy

USEPA #6440EE Ariel Rios North

P: 202.564.0234

F: 202.564.0965

E: barch.madeline@epa.gov

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Cc: "barch.madeline@epamial.epa.gov" <barch.madeline@epamial.epa.gov>

Date: 04/14/2011 05:20 PM

Subject: Contact Information

‐ IIG and Rock Wool Manufacturing

As requested, please find below information for the IIG and Rock Wool

Manufacturing contacts:

Chris Bullock

Industrial Insulation Group, LLC

3681 Crestside Road

Birmingham, AL 35223

(205) 603

‐ 8498

– Phone

bullockc@iig

‐ llc.com

– E

‐ mail

Tim Scott

Rock Wool Manufacturing

(205) 699

‐ 6121

– Phone

Tims.rockwool@gmail.com

– E

‐ mail17 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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

To: Madeline Barch/DC/USEPA/US@EPA, Susan Fairchild/RTP/USEPA/US@EPA

Date: 04/20/2011 03:26 PM

Subject: RSVP

‐ EPA's Pre

‐ Panel Outreach Meeting with Potential Small Entity Representatives,

Risk and

Technology Review for Mineral Wool Production

‐ A pril 27, 2011

I plan to have Granta Nakayama, Kirkland & Ellis, participate in the

outreach meeting.

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 04/27/2011 04:52 PM

Subject: RE: Mineral Wool testing and potential site visits18 I will get back to you early tomorrow on the best time, but, most

importantly, I will meet with you and get you the answers you need.

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@epamail.epa.gov [

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

Sent: Wednesday, April 27, 2011 4:42 PM

To: Angus Crane

Subject: Mineral Wool testing and potential site visits

I would like to set up a time to discuss with you 3 issues I am facing.

Are you available either Thursday after 4, Friday after 3 or before noon

on Tuesday May 3 ?

Here's the specifics

‐

1

‐ Test Data:

It seems that some of the testing that was sent over was done while the

plants were experimenting with control devices, process changes, or

both. They may have been intended for internal use only. One of these

showed the plant was operating at levels exceeding 5X the MACT PM limit.

I believe the plants were putting forth a good faith effort to provide

EPA with all their test data, but we shouldn't be using data that's not

representative of the processes. I'd like to discuss with you how we

should proceed; there may be better PM data that we can use in our work.

2

‐ Acute factor used in Risk Assessment:

Additionally, I need your help in developing an alternative acute

factor. The acute factor is based upon variability in the process.

These variability factors include things like how much variability is

there in the feedstock (binder ingredients), how much variability is

there in the operating temps, pressures, how continuous is the process

(vs batch), etc.

The acute factor is used to develop the Hazard Quotient, or HQ in the

Risk assessment. The default acute factor used by the risk assessors,

under advisement of the Science Advisory Board (SAB), is a factor of 10.

That means the emissions of the highest risk processes are then

multiplied by a factor of 10 to determine the risk during a 'perfect19 storm' type of situation: the highest emissions at the extreme of the

variability, the worst meteorological events, and a person at the

fenceline to be exposed, etc.. This 10X factor is used as a default in

the absence of precise data. So for the 2 plants with uncontrolled

collection processes, the HQ would be around 30, which is uncomfortably

high. I'd like to get specific information on which we can base this

acute factor. For this industry, it would only be for those 2 plants

(Thermafiber and Rockwool).

The alternative is to accept the 10X acute factor, and amend the MACT

for collection processes.

It could happen that instead of good business practices, MACT could be

amended to require additional control on the 2 plants that do not now

control collection. Or it could be something as simple as restricting

the amount of binder applied to the hot glass fibers to not exceed the

minimum amount needed to produce the bonded product (the 'housekeeping

measures' I'd described earlier). I am sure the companies already use

these 'housekeeping measures' as principles of good business practice

(who would deliberately waste their binder by overspraying? Aren't

these fully computerized so that if no glass entering the collection

chamber, no binder would be spraying?) so that type of change to the

LinkMACT probably wouldn't be a big deal. But we just don't have that

information at our fingertips.

3

‐ Scheduling visits to Isolatek in Huntington, IN and to Thermafiber in

Wabash, IN: I'd like your help in setting up these visits to these 2

plants. Specifically, this is not an enforcement inspection, it is for

my understanding in writing the rules that will apply to these

companies, so the more I understand the better. Rules of CBI apply as

always.

Here is the risk assessment document that I promised:

I will be asking for the other documentation from the risk assessors

(the risk values used for formaldehyde) on Friday during my meeting with

them.

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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐20 From: Angus Crane <acrane@naima.org>

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

Date: 04/27/2011 05:15 PM

Subject: RE: Mineral Wool testing and potential site visits

One question

‐ Can you identify for me the plant or plants with high PM

emissions. This will help me to facilitate getting more accurate data.

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@epamail.epa.gov [

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

Sent: Wednesday, April 27, 2011 4:42 PM

To: Angus Crane

Subject: Mineral Wool testing and potential site visits

I would like to set up a time to discuss with you 3 issues I am facing.

Are you available either Thursday after 4, Friday after 3 or before noon

on Tuesday May 3 ?

Here's the specifics

‐

1

‐ Test Data:

It seems that some of the testing that was sent over was done while the

plants were experimenting with control devices, process changes, or

both. They may have been intended for internal use only. One of these

showed the plant was operating at levels exceeding 5X the MACT PM limit.

I believe the plants were putting forth a good faith effort to provide

EPA with all their test data, but we shouldn't be using data that's not

representative of the processes. I'd like to discuss with you how we

should proceed; there may be better PM data that we can use in our work.

2

‐ Acute factor used in Risk Assessment:

Additionally, I need your help in developing an alternative acute

factor. The acute factor is based upon variability in the process.21 These variability factors include things like how much variability is

there in the feedstock (binder ingredients), how much variability is

there in the operating temps, pressures, how continuous is the process

(vs batch), etc.

The acute factor is used to develop the Hazard Quotient, or HQ in the

Risk assessment. The default acute factor used by the risk assessors,

under advisement of the Science Advisory Board (SAB), is a factor of 10.

That means the emissions of the highest risk processes are then

multiplied by a factor of 10 to determine the risk during a 'perfect

storm' type of situation: the highest emissions at the extreme of the

variability, the worst meteorological events, and a person at the

fenceline to be exposed, etc.. This 10X factor is used as a default in

the absence of precise data. So for the 2 plants with uncontrolled

collection processes, the HQ would be around 30, which is uncomfortably

high. I'd like to get specific information on which we can base this

acute factor. For this industry, it would only be for those 2 plants

(Thermafiber and Rockwool).

The alternative is to accept the 10X acute factor, and amend the MACT

for collection processes.

It could happen that instead of good business practices, MACT could be

amended to require additional control on the 2 plants that do not now

control collection. Or it could be something as simple as restricting

the amount of binder applied to the hot glass fibers to not exceed the

minimum amount needed to produce the bonded product (the 'housekeeping

measures' I'd described earlier). I am sure the companies already use

these 'housekeeping measures' as principles of good business practice

(who would deliberately waste their binder by overspraying? Aren't

these fully computerized so that if no glass entering the collection

chamber, no binder would be spraying?) so that type of change to the

LinkMACT probably wouldn't be a big deal. But we just don't have that

information at our fingertips.

3

‐ Scheduling visits to Isolatek in Huntington, IN and to Thermafiber in

Wabash, IN: I'd like your help in setting up these visits to these 2

plants. Specifically, this is not an enforcement inspection, it is for

my understanding in writing the rules that will apply to these

companies, so the more I understand the better. Rules of CBI apply as

always.

Here is the risk assessment document that I promised:

I will be asking for the other documentation from the risk assessors

(the risk values used for formaldehyde) on Friday during my meeting with

them.

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:22 US EPA

Mail Code D243

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Cc: "Edris, Steve" <sedris@thermafiber.com>, "Lund, Tom" <tlund@isolatek.com>

Date: 04/29/2011 10:42 AM

Subject: Meeting on Tuesday before noon

Dear Susan,

I am hoping you are still available for a meeting on Tuesday, May 3,

2011. I would like to have Steve Edris of Thermafiber on the phone with

us. Both Isolatek and Thermafiber would welcome you for plant tours

sometime in May. We can discuss your specific availability and get the

tours scheduled (the close proximity of the two plants should enable you

to do it in a day). Please let me know about a specific time on

Tuesday. Thank you for the opportunity to discuss these issues and

answer any questions.

Sincerely,

Angus E. Crane

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>23 To: Susan Fairchild/RTP/USEPA/US@EPA

Cc: "Edris, Steve" <sedris@thermafiber.com>

Date: 04/29/2011 12:34 PM

Subject: RE: Meeting on Tuesday before noon

This will work for Steve and me. I will schedule a call in number and

send out a notice with the call number for a meeting at 10:00 AM on

Tuesday, May 3, 2011. You can have other people join the call if you

need. On this end, it will just be Steve Edris (and possibly other

Thermafiber employees) and myself. You will get the notice today.

Thank you for the opportunity to discuss these issues.

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@epamail.epa.gov [

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

Sent: Friday, April 29, 2011 10:53 AM

To: Angus Crane

Subject: Re: Meeting on Tuesday before noon

Thanks for your response; I have reserved Tuesday morning to meet with

you and Mr. Edris of Thermafiber. I'm in the office this morning, then

in meetings this afternoon, but I'll be checking my email remotely. I

suggest a meeting on Tuesday the 3rd around 10 am EST, if possible. I

can make it earlier as needed.

I appreciate your assistance on this work, and we can hopefully sharpen

our pencils on this variability issue.

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

‐ 02

109 TW Alexander Drive

RTP, NC 2770924 "We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

From: Angus Crane <acrane@naima.org>

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

Cc: "Edris, Steve" <sedris@thermafiber.com>, "Lund, Tom"

<tlund@isolatek.com>

Date: 04/29/2011 10:42 AM

Subject Meeting on Tuesday before noon

:

Dear Susan,

I am hoping you are still available for a meeting on Tuesday, May 3,

2011. I would like to have Steve Edris of Thermafiber on the phone with

us. Both Isolatek and Thermafiber would welcome you for plant tours

sometime in May. We can discuss your specific availability and get the

tours scheduled (the close proximity of the two plants should enable you

to do it in a day). Please let me know about a specific time on

Tuesday. Thank you for the opportunity to discuss these issues and

answer any questions.

Sincerely,

Angus E. Crane

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>25 To: Susan Fairchild/RTP/USEPA/US@EPA

Cc: "Edris, Steve" <sedris@thermaf i ber.com>

Date: 04/29/2011 12:53 PM

Subject: Call on Tuesday, May 3, 2011

As I indicated in my previous message, NAIMA has set up a call to take

place on Tuesday, May 3, 2011 at 10:00 AM (Eastern).

To participate in the call, dial:

1

‐ 888

‐ 450

‐ 5996

– U.S./Canada Participants

1

‐ 719

‐ 955

‐ 1371

– International Participants

PASSCODE: 385178

Please don’t hesitate to contact me if you have any questions.

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

To: Madeline Barch/DC/USEPA/US@EPA

Cc: Susan Fairchild/RTP/USEPA/US@E P A, "david.rostker@sba.gov" <david.rostker@sba.gov>

Date: 05/09/2011 05:03 PM

Subject: NAIMA Request for Extension of Time

‐ SBAR Panel: Risk and Technology Revi e w

Ms. Barch,

Please find attached a request for extension of time.26 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

(See attached file: RSWSC3163.docx)

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐

Fom Agu Can <crnenamaor>

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

Date: 05/10/2011 01:59 PM

Subject: RE: Reminder of Acute factor data and Site visits

Dear Susan:

I have placed in overnight mail the Rock Wool Manufacturing information

to Robert Morales. You are copied on the transmittal letter, but you

will not receive the CBI information. Thermafiber has completed the

collection of the data, and I believe they will send it to Mr. Morales

while you are in Indiana. I look forward to meeting you in Indiana.

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@epamail.epa.gov [

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

Sent: Tuesday, May 10, 2011 1:53 PM

To: Angus Crane

Subject: Reminder of Acute factor data and Site visits

Just a friendly reminder:

If you have the time, please remind Rockwool and Thermafiber that we are

awaiting their binder data to be able to come up with an acute factor27 that is less than the default 10X. Without that information, we'll have

no other option than to use the default. Again, we don't need their

binder 'recipe', only the percent formaldehyde, the binder spray rate,

and whether that is a continuous process.

As always, if these data are CBI they should send it through Roberto

Morales in our CBI Office, Mail Code C

‐ 404

‐ 02, Research Triangle Park,

NC 27711, and labeled as Mineral Wool Project data.

Thanks, and I'll be at Thermafiber at 8 am on Thursday, May 12; then at

Isolatek at 1:30 the same day. Thanks also for helping to set these

visits up.

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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Cc: Madeline Barch/DC/USEPA/US@EPA, "david.rostker@sba.gov." <david.rostker@sba.gov>

Date: 05/16/2011 05:19 PM

Subject: NAIMA's Comments and Recommendations on the SBAR Panel Briefing

Dear Ms. Fairchild:

Please find attached NAIMA’s letter addressing comments and

recommendations on the SBAR Panel Briefing.

Sincerely,

Angus E. Crane

Angus E. Crane28 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

(See attached file: RR3161.pdf)(See attached file:

RR3161Attachments1

‐ 8.pdf)

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 06/22/2011 11:04 AM

Subject: Are you available to talk about mineral wool data Thursday afternoon or Friday of

this week?

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 06/22/2011 11:29 AM

Subject: RE: Are you available to talk about mineral wool data Thursday afternoon or Friday of

this week?29 What about Friday at 1:30 PM Eastern?

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@epamail.epa.gov [

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

Sent: Wednesday, June 22, 2011 11:10 AM

To: Angus Crane

Subject: Re: Are you available to talk about mineral wool data Thursday

afternoon or Friday of this week?

Yes, I'm in both days and only Friday morning 9

‐ 10 is now busy.

Whatever time works for you, please let me know and I'll make time for

the meeting.

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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

From: Angus Crane <acrane@naima.org>

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

Date: 06/22/2011 11:04 AM

Subjec Are you available to talk about mineral wool data Thursday

t: afternoon or Friday of this week?30 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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 06/22/2011 12:59 PM

Subject: RE: Are you available to talk about mineral wool data Thursday afternoon or Friday of

this week?

I was thinking it would be just the two of us.

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@epamail.epa.gov [

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

Sent: Wednesday, June 22, 2011 11:56 AM

To: Angus Crane

Subject: RE: Are you available to talk about mineral wool data Thursday

afternoon or Friday of this week?

Friday at 1:30 pm will work fine for me. What other types of people

(economist; risk assessor, etc.) would you want to attend? I can likely

get a conference room if there will be more than just me.31 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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 06/22/2011 02:11 PM

Subject: RE: Are you available to talk about mineral wool data Thursday afternoon or Friday of

this week?

I will do that. Thank you for your flexibility.

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@epamail.epa.gov [

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

Sent: Wednesday, June 22, 2011 2:00 PM

To: Angus Crane

Subject: RE: Are you available to talk about mineral wool data Thursday

afternoon or Friday of this week?

If you'd call me at 1:30 on Friday, I'll be in my office

Susan Fairchild

Environmental Scientist

U.S. Environmental Protection Agency32 direct line: 919.541.5167

fax: 919.541

‐ 3207

email: fairchild.susan@epa.gov

Overnight mail address:

US EPA

Mail Code D243

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

To: Madeline Barch/DC/USEPA/US@EPA

Cc: "david.rostker@sba.gov" <david.rostker@sba.gov>, "cortney_higgins@omb.eop.gov"

<cortney_higgins@omb.eop.gov>, Alexander Cristofaro/DC/USEPA/US@EPA, Susan

Fairchild/RTP/USEPA/US@EPA

Date: 06/30/2011 04:43 PM

Subject: NAIMA's Comments on the Mineral Wool SBAR Panel Meet i ng

Attached please find NAIMA’s comments on the Mineral Wool SBAR Panel

Meeting which took place on June 16, 2011.

Please do not hesitate to contact me with any questions.

Sincerely,

Angus E. Crane

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

(See attached file: NAIMACommentsMineralWoolSBARPanelMeeting063011.pdf)

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>33 To: Susan Fairchild/RTP/USEPA/US@EPA

Date: 07/01/2011 02:44 PM

Subject: RE: Draft Summary of SER comments

Susan

‐

I have looked at the transcript summary and made changes to reflect

NAIMA’s members views. You can find these changes, which were done with

track changes, on the attached pdf.

If you have any questions, please feel free to contact me.

Angus

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@epamail.epa.gov [

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

Sent: Tuesday, June 28, 2011 11:06 AM

To: Barch.Madeline@epamail.epa.gov; Angus Crane

Subject: Draft Summary of SER comments

Angus,

As we discussed last Friday, I am sending off to you (and OP) the

transcript summary of the comments we've received so far. As you

mentioned, a conversational transcription (even if it is from a

briefing) doesn't sound a clear when written up verbatim.

The areas I identified as unclear are either highlighted or a comment

has been added that additional clarification is needed.

In addition, please review to determine whether I accurately captured

the meaning your comments whether I've highlighted or commented on them

or not as I do not want to misrepresent your input.34 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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/05/2011 09:41 AM

Subject: FW: Draft Summary of SER comments

Susan

‐

I have attached the transcript summary for you. I hope that this time

it will be able to open.

Thanks,

Angus

From: Angus Crane

Sent: Friday, July 01, 2011 11:13 AM

Subject: RE: Draft Summary of SER comments

Susan

‐

I have looked at the transcript summary and made changes to reflect

NAIMA’s members views. You can find these changes, which were done with

track changes, on the attached pdf.

If you have any questions, please feel free to contact me.

Angus

Angus E. Crane

Executive Vice President, General Counsel35 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@epamail.epa.gov [

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

Sent: Tuesday, June 28, 2011 11:06 AM

To: Barch.Madeline@epamail.epa.gov; Angus Crane

Subject: Draft Summary of SER comments

Angus,

As we discussed last Friday, I am sending off to you (and OP) the

transcript summary of the comments we've received so far. As you

mentioned, a conversational transcription (even if it is from a

briefing) doesn't sound a clear when written up verbatim.

The areas I identified as unclear are either highlighted or a comment

has been added that additional clarification is needed.

In addition, please review to determine whether I accurately captured

the meaning your comments whether I've highlighted or commented on them

or not as I do not want to misrepresent your input.

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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein(See attached file: DRAFT

SER Comment Summary from NAIMA.docx)

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/05/2011 12:34 PM36 Subject: RE: Draft Summary of SER comments

We resent this. Did the second e

‐ mail have the attachment?

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

Sent: Tuesday, July 05, 2011 8:57 AM

To: Angus Crane

Subject: RE: Draft Summary of SER comments

Angus

‐

There was no attachment to this message...

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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

From: Angus Crane <acrane@naima.org>

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

Date: 07/01/2011 02:44 PM

Subject: RE: Draft Summary of SER comments37 Susan

‐

I have looked at the transcript summary and made changes to reflect

NAIMA’s members views. You can find these changes, which were done with

track changes, on the attached pdf.

If you have any questions, please feel free to contact me.

Angus

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@epamail.epa.gov [

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

Sent: Tuesday, June 28, 2011 11:06 AM

To: Barch.Madeline@epamail.epa.gov; Angus Crane

Subject: Draft Summary of SER comments

Angus,

As we discussed last Friday, I am sending off to you (and OP) the

transcript summary of the comments we've received so far. As you

mentioned, a conversational transcription (even if it is from a

briefing) doesn't sound a clear when written up verbatim.

The areas I identified as unclear are either highlighted or a comment

has been added that additional clarification is needed.

In addition, please review to determine whether I accurately captured

the meaning your comments whether I've highlighted or commented on them

or not as I do not want to misrepresent your input.

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:38 US EPA

Mail Code D243

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/06/2011 10:54 AM

Subject: RE: Draft Summary of SER comments

Did you get my voice mail? If you can, please call me. I would like to

confirm what financial data is missing and get it to you within a few

days.

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

Sent: Tuesday, July 05, 2011 4:03 PM

To: Angus Crane

Subject: RE: Draft Summary of SER comments

Angus

‐‐ Yes, thank you. I don't know what the problem was with a PDF but

it was a lot easier to just accept your changes on the word document.

Also, as you know, cost discussions and the potential requirements and

impacts of the amendments to the mineral wool rule are beginning to

re

‐ surface. We must have this information to address the cost and

economic impacts of the rule.

Most of the companies (with the exception of one) refused to answer the

financial section in the voluntary ICR. So I'll have to send out a 114

to obtain this information from each company.

Feel free to call or email me if you have questions. Thanks39 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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

From: Angus Crane <acrane@naima.org>

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

Date: 07/05/2011 12:34 PM

Subject: RE: Draft Summary of SER comments

We resent this. Did the second e

‐ mail have the attachment?

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

Sent: Tuesday, July 05, 2011 8:57 AM

To: Angus Crane

Subject: RE: Draft Summary of SER comments

Angus

‐

There was no attachment to this message...

Susan Fairchild

Environmental Scientist

U.S. Environmental Protection Agency40 direct line: 919.541.5167

fax: 919.541

‐ 3207

email: fairchild.susan@epa.gov

Overnight mail address:

US EPA

Mail Code D243

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

From: Angus Crane <acrane@naima.org>

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

Date: 07/01/2011 02:44 PM

Subject: RE: Draft Summary of SER comments

Susan

‐

I have looked at the transcript summary and made changes to reflect

NAIMA’s members views. You can find these changes, which were done with

track changes, on the attached pdf.

If you have any questions, please feel free to contact me.

Angus

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.org41 From: Fairchild.Susan@epamail.epa.gov [

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

Sent: Tuesday, June 28, 2011 11:06 AM

To: Barch.Madeline@epamail.epa.gov; Angus Crane

Subject: Draft Summary of SER comments

Angus,

As we discussed last Friday, I am sending off to you (and OP) the

transcript summary of the comments we've received so far. As you

mentioned, a conversational transcription (even if it is from a

briefing) doesn't sound a clear when written up verbatim.

The areas I identified as unclear are either highlighted or a comment

has been added that additional clarification is needed.

In addition, please review to determine whether I accurately captured

the meaning your comments whether I've highlighted or commented on them

or not as I do not want to misrepresent your input.

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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/06/2011 02:41 PM

Subject: NAIMA

‐ Mineral Wool

I have three different companies telling me that they are the one

company that provided complete financial data. Can you please tell me42 who it was? Can I call Roberto Morales and ask him?

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/06/2011 04:36 PM

Subject: RE: NAIMA

‐ Mineral Wool

Ok. Can you tell me the name of the company?

Angus E. Crane

Executive Vice President, General Counsel

North American Insulation Manufacturers Association

Ph: (703) 684

‐ 0084 ext. 123

Fax: (703) 684

‐ 0427

ViNMoi :w.I.gw.pnli.g

r:unacl[ioaclSaemlpg]StWnd,u ,0 3P

:nsreSjtR I

‐ ir o

H,nsenhgt sroo ei

‐ hnefh

mnttridinadain IIotee

or niu eoesf I file with anyone ‐‐ over the

phone or otherwise

‐‐ who is not authorized within EPA to view it.

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

‐ 02

109 TW Alexander Drive43 RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

From: Angus Crane <acrane@naima.org>

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

Date: 07/06/2011 02:41 PM

Subject: NAIMA

‐ Mineral Wool

I have three different companies telling me that they are the one

company that provided complete financial data. Can you please tell me

who it was? Can I call Roberto Morales and ask him?

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/07/2011 09:28 AM

Subject: RE: NAIMA

‐ Mineral Wool

Thank you. This is a relief. I had three

– four after I sent you the

message

– swearing they had provided all of the financial data they

have available. I need to talk to you about the collection44 subcategorization. I will call you later today.

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

Sent: Thursday, July 07, 2011 9:05 AM

To: Angus Crane

Subject: RE: NAIMA

‐ Mineral Wool

Angus

‐‐ It took me a while to go through all the records, and I am eating

crow! There were THREE firms that supplied sufficient and reliable

financial data: Thermafiber, IIG and Amerrock.

There were 3 that did not provide sufficient financial data: USG,

Isolatek, and Rockwool.

USG provided data, but added at the top of each sheet the following

disclaimer: "Financial information provided on the Information

Collection Request Forms F

‐ 1 and F

‐ 2 are estimates and should not be

interpreted as actual cost data." So we can't use that.

So I apologize twice: once for the lateness of this reply and also for

being wrong about the number of companies that provided accurate and

adequate responses. I was relying on team members to provide me with

this information rather than double checking it myself.

All we need from USG, Isolatek, and Rockwool are their shareholders

reports, or the equivalent, such as unredacted consolidated balance

sheets.

Again, please accept my apologies for my incorrect statements. I think

the actual needed data should be easy for the companies to provide.

Also, even though USG is the big company, their information is valuable

to our assessment of the total impacts of the rule.

One other thing, we are going through the small business panel one way

or the other, and I am looking earnestly for ways to lessen the burden

to industry, mostly because the risk assessment alone does not lead us

to conclude amendments are needed to protect the public health. I may

have stumbled on an option that will be win

‐ win, but have to vet this

through my attorney first and management.

Also, I'll need the collection subcategorization information as soon as

it is available.

Thanks, Angus Please feel free to call or email me if you'd like to

discuss further.

Susan Fairchild45 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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

From: Angus Crane <acrane@naima.org>

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

Date: 07/06/2011 04:36 PM

Subject: RE: NAIMA

‐ Mineral Wool

Ok. Can you tell me the name of the company?

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

Sent: Wednesday, July 06, 2011 4:32 PM

To: Angus Crane

Subject: Re: NAIMA

‐ Mineral Wool

Hey, Angus

‐‐ even though the answer to your question

‐ the name of the

company that provided financial data

‐‐ is not CBI, I don't believe

Roberto can discuss the contents of a CBI file with anyone ‐‐ over the

phone or otherwise

‐‐ who is not authorized within EPA to view it.46 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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

From: Angus Crane <acrane@naima.org>

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

Date: 07/06/2011 02:41 PM

Subject: NAIMA

‐ Mineral Wool

I have three different companies telling me that they are the one

company that provided complete financial data. Can you please tell me

who it was? Can I call Roberto Morales and ask him?

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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>47 To: Susan Fairchild/RTP/USEPA/US@EPA

Date: 07/12/2011 04:43 PM

Subject: NAIMA Comments that Identify Sub

‐ c ategorization Options

Dear Susan,

Please find attached the comments submitted to the SBAR Panel on June

30, 2011. Set forth in these comments are recommended alternatives,

including various sub

‐ categorization options. In addition, I have

attached a document that extracts from the aforementioned comments the

specific sub

‐ categorization options recommended by NAIMA. Please let me

know what additional details you need on these sub

‐ categorization

options. It would also be helpful if you could identify those

sub

‐ categorization options that are the most viable. NAIMA could invest

the necessary time and effort into supplementing the viable

sub

‐ categorization options with the critical facts and details.

Sincerely,

Angus E. Crane

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

(See attached file: NAIMACommentsMineralWoolSBARPanelMeeting063011.pdf)

(See attached file: RR3204.pdf)

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/12/2011 04:43 PM

Subject: I have just sent you an e

‐ mail with two attachments. Please let me know if you

receive the e

‐ mail

with the attachments.48 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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/13/2011 03:48 PM

Subject: RE: Cost

‐ Sales and Financial da t a from Mineral Wool Facilities

Susan, Rock Wool sent their data to Robert Morales on Monday. USG

provided their data (Annual Report) directly to you. IIG is planning to

have a conversation with EPA to explain the data they have submitted.

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

Sent: Wednesday, July 13, 2011 12:09 PM

To: Angus Crane

Subject: Cost

‐ Sales and Financial data from Mineral Wool Facilities

As you know, USG, Isolatek, and Rockwool did not send information in

their voluntary ICR on their companies' financial data that we can use

to develop the economic analysis for the Mineral Wool Production MACT

Amendments. I have still not received their data per our conversations

and email last week. So I'm in the position of having to send out a 114

to these 3 companies to compel them to submit their data. I expect

this to be forthcoming from my division director this week.49 If you'd like to discuss this, I can be reached at the following:

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

‐ 02

109 TW Alexander Drive

RTP, NC 27709

"We can not solve our problems by using the same kind of thinking we

used when we created them"

‐‐ Albert Einstein

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/13/2011 03:49 PM

Subject: FW: NAIMA

‐ Mineral Wool

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: Bolden, John [mailto:JBolden@usg.com]

Sent: Monday, July 11, 2011 10:41 AM

To: Fairchild.Susan@epamail.epa.gov

Cc: Angus Crane; Hill, Mike; Curry, Scott

Subject: NAIMA

‐ Mineral Wool

Susan,

Per your request (via NAIMA) last week, please find attached USG’s

annual shareholder’s report for 2010. If you have any questions or50 require additional information please feel free to give me a call. Thank

you.

Regards,

John Bolden

Environmental Services Senior Manager

United States Gypsum Company

550 W Adams St

Chicago IL, 60661

Ph: 312

‐ 436

‐ 5587

Fax: 312

‐ 672

‐ 5587

Cell: 312

‐ 823

‐ 6702

Confidentiality Notice: This email

is intended for the sole use of

the intended recipient(s) and may

contain confidential, proprietary

or privileged information. If you

are not the intended recipient,

you are notified that any use,

review, dissemination, copying or

action taken based on this message

or its attachments, if any, is

prohibited. If you are not the

intended recipient, please contact

the sender by reply email and

destroy or delete all copies of

the original message and any

attachments. Thank you.

(See attached file: USG

‐ 10K2010.pdf)

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/14/2011 04:52 PM

Subject: Rock Wool confrimed the package with economic data was sent to Roberto Morales by

overnight. I will

send you a delivery confirmaiton number.51 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

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/14/2011 05:05 PM

Subject: FW: Certified Mail to Robert Morales EPA

Please find attached confirmation of package to Robert Morales of Rock

Wool's economic data.

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

(See attached file: 20110714165558919.pdf)

‐‐‐‐‐ Forwarded by Susan Fairchild/RTP/USEPA/US on 09/22/2011 01:16 PM

‐‐‐‐‐

From: Angus Crane <acrane@naima.org>

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

Date: 07/28/2011 08:54 AM

Subject: NAIMA Response52 Dear Susan:

NAIMA and its member companies are in the process of collecting the

information on chrome content of refractories, and I will provide you

the documentation on the industry shift to non

‐ formaldehyde binders very

soon. NAIMA requests the opportunity to present the chrome content

information to you and relevant EPA staff in a face

‐ to

‐ face meeting.

The complexity and variability of chrome issues justifies a dialogue

that NAIMA believes will be useful and productive for EPA. Please let

me know when such a meeting could take place. We need at least a week

to complete collection of the chrome content data because of summer

vacation schedules.

Sincerely,

Angus E. Crane

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