NAIMA 


NORiJ'H AMERICAN INSUl.ATION 


MANUFACTURERS AS.OC'IA:,.JON 


Celebrating 75 felli, 

ofEnergyEjJicicncy 

VIAE-MAIL 

April 4, 2012 , 

Ms. Susan Fairchild 

Sector Policies and Programs Division 

Metals and Minerals Group (D243-02) 

Office of Air Quality Planning and Standards 

U.S. Environtnental Protection Agency 

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711 

RE: Follow-Up To March 19, 2012 Meeting 

Dear Ms. Fairchild: 

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

opportunity to meet with tl;te Environmental Protection Agency ("EPA") on March 19, 2012. 

During that meeting with EPA, NAIMA stated EPA's proposed limits on formaldehyde, phenol, 

and methanol could not be met by the majority of facilities. 

EPA was also reminded that the vast majority of wool fiberglass manufacturers have switched 

from phenol formaldehyde binders to non-phenol formaldehyde binders, and, thus, are no longer 

subject to the MACT standard. Those facilities continuing to use formaldehyde binders will 

have a problem meeting EPA's proposed limits. As previously explained to EPA, specific 

performance requirements for certain products generally mandate that the level of binder be 

higher than that used for typical residential insulation. Typically, the specialized products have a 

higher loss on ignition ("LOI"). LOI is defmed 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. 1 

EP A is setting a limit for the manufacture of these more specialized products using the emission 

numbers the lowest emission numbers - from the manufacture of a very different product. 

NAIMA asks that EPA recognize and take into account the differences between these products 

and the differences required when doing compliance testing in the "MACT format," which 

1 40 C.F.R. Part 63, Subpart NNN, § 63.1381. 

44 Canal Center Plaza' Suite 310 • Alexandria, Virginia 22314 • Tel: (703) 684-0084 • Fax: (703) 684-0427 
Ms. Susan Fairchild 

April 4, 2012 

Page 2 

represents the worst-case reasonably foreseeable circlUDstances. EPA should set MACT floors at 

these worst-case reasonably foreseeable circlUDstances to account for variability of sources,2 and 

this variability should be reflected in the final emission limits. To effectively reflect this 

difference, NAIMA urges EPA to set limits based on data where higher LOI was used; this will 

result in feasible and realistic emission limits. 

Please do not hesitate to contact me if you have any questions. 

Sincerely, 

Angus E. Crane 

Angus E. Crane 

Executive Vice President, General Counsel 

cc: 	 Mr. Jeffrey A. Telander 

Sector Policies and Programs Division 

Metals and Minerals Group (D243-02) 

Office ofAir Quality Planning and Standards 

U.S. Environmental Protection Agency 


109 TW Alexander Drive 


Research Triangle Park, NC 27711 


Mr. David Reeves 


R TI International 


P.O. Box 12194 


Research Triangle Park, NC 27709 


2 Cement Kiln Recycling Coalition, et al. v. EPA, 255 F.3d 855, 863 (D.C. Cir. 2001) (citing SierraClub v. EPA, 

167 F.3d 658,665 (D.C. Cir. 1999)). .