From: Angus Crane <acrane@naima.org>

To: Susan Fairchild/RTP/USEPA/US@EPA, Keith Barnett/RTP/USEPA/US@EPA, Peter Tsirigotis/RTP/USEPA/US@EPA, Steve 

Fruh/RTP/USEPA/US@EPA

Cc: "Granta Nakayama (granta.nakayama@kirkland.com)" <granta.nakayama@kirkland.com>

Date: 06/06/2012 12:43 PM

Subject: NAIMA Letter Regarding Voluntary Policing of Chrome Emissions at "Area Sources" and Formaldehyde, Phenol, and Methanol 

Limits

Dear Ms. Fairchild:

Please find attached a letter in response to EPA’s request for an industry proposal on policing chrome emissions at 

“area sources.” This letter will be the basis of the telephone conference call scheduled for Thursday, June 7, 2012 

at 10:30 AM (Eastern). 

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

(See attached file: RR3317.pdf)
44 Canal Center Plaza ▪ Suite 310 ▪ Alexandria, Virginia 22314 ▪ Tel: (703) 684-0084 ▪ Fax: (703) 684-0427

VIA E-MAIL AND OVERNIGHT MAIL

June 6, 2012

Ms. Susan Fairchild

Sector Policies and Programs Division

Metals and Minerals Group (D243-02)

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

109 T.W. Alexander Drive

Research Triangle Park, NC 27711

RE: Wool Fiberglass Manufacturing – Area Sources and Formaldehyde, Phenol, and 

Methanol Issues

Dear Ms. Fairchild:

The North American Insulation Manufacturers Association (“NAIMA”) greatly appreciates the 

ongoing dialogue with the Environmental Protection Agency (“EPA”). NAIMA recognizes the 

significant efforts EPA has undertaken to develop a feasible Rule that delivers pollution 

reduction.

There are really only two remaining issues that NAIMA believes need further resolution before 

the Wool Fiberglass Manufacturing Rule is finalized.

The first issue – area sources – is a matter that EPA specifically requested feedback from 

NAIMA. Pursuant to that request, NAIMA proposes the language set forth below be inserted 

into the Final Rule to indicate the industry’s commitment to monitor and police hex chrome 

emissions. NAIMA’s members are willing to make this commitment even though current 

emissions in the data set EPA used in its risk assessment, which included one outlier result from 

a furnace, showed only a 40-in-one-million excess cancer risk.

Before taking any official action on area sources, EPA must conduct the analysis 

and findings required by Section 112(c)(3) of the Clean Air Act that requires 

regulation of area sources only after a determination that “a threat of adverse 

effects to human health or the environment” warrant further regulation. The 

Preamble to the Proposed Rule acknowledges that EPA needs more information 

before drawing any conclusion about the need, if any, for fiber glass area 

sources. Some of the information provided to EPA by NAIMA and its member 

companies may be useful in fulfilling this information collection requirement, but 
Ms. Susan Fairchild

June 6, 2012

Page 2

EPA must complete the process. To address any concerns about hex chrome 

emissions from the industry absent an Area Source Rule, the industry has 

voluntarily agreed to limit hex chrome emissions.

In the interim, the industry will establish a voluntary emission threshold limit of 

25 lbs. of hex chrome per year for each individual applicable furnace located at a 

minor source or fiber glass insulation manufacturing facility that is not subject to 

NNN. Compliance will be determined based on testing, the timing of which is to 

be mandated by the frequency of particulate testing required in Title V permits or 

other required testing, but not to exceed twice in any single furnace campaign. 

NAIMA fiber glass members’ commitment to test and monitor extends to all 

furnaces, even the non-oxy-fuel furnaces. Non-oxy-fuel furnaces, however, will 

not need to be tested beyond a single furnace campaign due to their lower 

emissions as evidenced by data already obtained by EPA. This testing will 

document the level of hex chrome emissions as measured by EPA Test Method 

0061; those testing results will be provided to EPA upon request. If this voluntary 

threshold is exceeded, the furnace operator will take action to lower the emissions 

or meet a modeled risk criteria of less than one-in-one-million1

or an alternative 

mutually agreeable risk level which in no event will be more stringent than a onein-one-million risk. The exact nature of the responsive action would be at the 

discretion of the individual manufacturer, but may include additional control 

equipment, i.e., scrubbers, or other actions designed to lower emissions or reduce 

the modeled risk threshold. EPA endorses this interim voluntary approach to 

resolving any remaining concerns about hex chrome emissions from these sources 

not included in this Rule.

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

attenuation – has fiber glass manufacturers deeply concerned. The vast majority of wool fiber

glass manufacturers have switched from phenol formaldehyde binders to non-phenol 

formaldehyde. This action has enabled EPA and industry to achieve a massive reduction of the 

only hazardous air pollutant (“HAP”) regulated in the Wool Fiberglass Manufacturing MACT. 

However, those sources continuing to use formaldehyde binders will not be able to meet EPA’s 

revised limits for formaldehyde, phenol, and methanol.

Specific performance requirements for certain products – very different from typical residential 

products – generally mandate that the level of binder be higher than that used for typical 

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

(“LOI”). LOI is defined by the current Wool Fiberglass Manufacturing MACT as follows:

 1 In the Preamble to the Proposed Rule, EPA stated that current risks due to hexavalent chromium were acceptable at 

a 40-in-one-million cancer risk. 76 Fed. Reg. 72,770, 72,786 (November 25, 2011).
Ms. Susan Fairchild

June 6, 2012

Page 3

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.2

Upon reviewing EPA’s revised – improved but still not feasible – limits for rotary spin lines for 

formaldehyde, phenol, and methanol, companies have unequivocally stated that they would not 

be able to continue to manufacture certain products and meet the emission limits for some or all 

of these HAPs. That will cause them to either move these operations to Mexico or Canada or 

simply cease manufacturing those products because the proposed limits cannot be met in a 

financially viable manner. An example of a product that would be impacted is pipe insulation. 

To avoid this disastrous outcome, NAIMA asks that EPA set MACT floors that recognize worstcase reasonably foreseeable circumstances which properly account for variability of sources,3

and that this variability be reflected in the final emission limits. This would require EPA to 

retain the original formaldehyde MACT limit and set phenol and methanol limits based on data 

where higher LOI production was occurring; this will result in feasible and realistic emission 

limits. Moreover, because phenol and methanol emissions data was never collected before, the 

existing phenol and methanol data is limited.

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

to outside of the United States, NAIMA is prepared to present this issue, using all possible 

resources, to the Office of Management and Budget (“OMB”).

Similarly, the formaldehyde, phenol, and methanol limits for flame attenuation are equally 

unachievable. NAIMA is concerned that the MACT floor was set with data from other than 

flame attenuation lines or that the MACT floor was miscalculated. EPA’s mean of sources used 

in the flame attenuation floor is far lower than what NAIMA calculated. NAIMA urges EPA to 

recalculate the MACT floor using only flame attenuation generated data and to ensure that all 

stacks in a given line are included in the calculation.

NAIMA urges that EPA resolve the matter before it reaches OMB.

If you have any questions, please do not hesitate to contact me.

Sincerely,

Angus E. Crane

Executive Vice President, General Counsel

 2 40 C.F.R. Part 63, Subpart NNN, § 63.1381.

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

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

June 6, 2012

Page 4

cc: Mr. Keith W. Barnett

Group Leader, Office of Air Quality and Planning Standards

Sector Policies and Programs Division, Mineral and Manufacturing Group

U.S. Environmental Protection Agency

109 T.W. Alexander Drive (D243-04)

Research Triangle Park, NC 27711

Mr. Steve Fruh

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

109 T.W. Alexander Drive (D205-01)

Research Triangle Park, NC 27711

Mr. Peter Tsirigotis

Director, Sector Policies and Program Division

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

109 T.W. Alexander Drive (C404-04)

Research Triangle Park, NC 27711