NAIMA 


NORTH I\MERlcAH INSULATION 


MA"IOFACTURERS I\SSOCfATION 


Cr:lcbraiil1g15 Yl;llrs 


OfEllfrgy EfflcieflCY 


VIAE-MAIL 

Julie. 8, 2011 

Ms. Cindy Wang Haney 

RTf.lntemational 

P.O. Box 12194 


Research Triangle Park. NC 27709 


RE: .Industry-Wide Response to, EPA's Ouestions - Fiber Glass Formaldehyde Use 

and the Collection Process 

Dear Ms. Haney: 

Set forth below is an industry-wide response t6 EPA's questions related to formaldehyde use and 

the collection process: 

• 	 Any recent changes in binder formulations and a list of facilities that have switched to a 

non-formaldehyde binder: 

Non-formaldehyde binder products' now represent the vast majorityl of the industry. This 

conversion started gradually about 10 years ago. In 1998, 10hnsManville announced it had 

introduced a non-foIlJ1~Idehyde binder to its manufacturing process. By early 2002, Johns 

ManvilIehad converted the production of all its building insulation products to a 

non-formaldehyde binder. This move virtually eliminatedaH formaldehyde, phenol, and 

methanol emissions from the Johns Manville building insulation manufacturing facilities. 

Knauf, CertainTeed, Owens Coming, and Guardian Fiberglass have made similar modifications 

by developing their own substitute 11on-forrrtaldehyde billders. Knauf and Owens Corning have 

or are in the process of converting essentially all manufacturing facilities for building insulation 

to non-formaldehyde binders. CertainTeedhas introduced a non-formaldehyde binder at its 

Chowchilla, California plant and has indicated that this technology will be phased ih at other 

facilities as the market dictates. Guardian Fiberglass has also introduced a non-formaldehyde. 

binder at itS. Albion, Michigan and Kingm.an, Arizona plants and has indicated that this 

technology will be phased in at other facilities. NAIMA can provide· documentation that all 

major sources have already converted orhaveannouncedplails to convert to non.-phenol 

formaldehyde binders . .FlberTEK Insulation, a minor source, is also working ondev¢ioping a 

non-formaldehyde binder. FiberTEK Insulation plans to phase their new teChnology into both 

I Vast majority is based on the number of facilities that have converted or have publicJy announced conversion to 

non;..phenol formaldehyde binders for building insulation prodoction. 

44 	CANAl.. CENTER PL... ZA • S).IITE:!II 0 • ALEXANDRIA, VA 22314 • TEL 703/6B4·0084 • FAX .,oaI664~042" 
Ms. Cindy Wang Haney 


June 8, 2011 


Page 2 


their Lakeland, Florida~ and Nephi, Utah, faciliti¢s as market demand dictates. Essentially 

non"formaldehyde binders .are or will be used industry ..wide. 

iJ;fe:r~dslllh.it 'ofthe sp.ecine•facilities that have.sWitched to a. rion.;fotrnaldehyclebinder: 

OWens Corning 

[)elmar, NY 

Bloy, AZ 

Fairburn,GA 

Kansas City, KS. 

Newark.OH (Conversion hasbeencompleted on some of the manufacturing lines atthisfacility) 

Salt Lake City, UT 

Santa Clara, CA 

Waxahachie, TX (Conversion has been completed. on some of the manufacturing lines at this 

facility) 

Knauf Insulation 


Lanett, AL 


ShaSta Lake, CA 


Shelbyville, IN (> 80 pertent non~phenol/formaldehyde) 

Guardian Fiberglass 


Albibn;MI 


Kingman,AZ 


.Johns Manville 

McPherson,KS 

Penbryn, NJ 

R.iChmond, IN (no binder u$edat this facility) 

Wat~rviUe; OH (nobipc:ier usedinwool fiberglass qperatibns) 

Willows, C;A 

Winder;GA 

CertainTeed C()rporation 


Chowchilla,CA 


FiberTEKlnsulation 

TBD 

• 	 Elabo~te on the"cpll~tion" P:r()CySS for wool fiberglass .. Is.it.different than for mineral wool? Is 

itpart offorming? 

During the production of glass woo] by the rotary process (the mQst common niethod .used for 

fiber glass building insulation production); molten glass is Jorced through hol~s in spinning disks 
Ms. Cindy Wang Hancy 

June 8, 2011 

Page 3 

and the resultant fibers are attenuated to the proper size. At that point, a binder is applied to the 

newly formed fibers. The fibers are collected on a conveyor ·and a blanket of glass wool is 

formed. The blanket is then conveyed to an oven where the binder is cured/dried. 

As this description illustrates, fonning and collection are separate operations, though connected. 

The collection process for fiberglass is very similar to that ofmineral wool production. 

• 	 Arethc;:resignificantHAP emissions coming from cooling? 

No. Cooling is the last phase of the production. The cooling process involves dra'Ying ambient 

air through the cured fiberglass pack to cool the product after exiting the curing oven where the 

binder was solidified into the finished product. No activity takes place in cooling that either adds 

a JIAP-containing material to the product or causes a reaction in the product that generates 

HAPs. The only possible source of HAP emissions in cooling is from the release ofHAPs that 

might be einbedded in the finished product. 

• 	 What can facilities provide in order for EPA to calculate an Acute Factcir (equipment limitations, 

variability in binder and product fonnulations, certification codes or standards product must meet, 

formaldehyde contents, etc.)? 

The most important factor in play here is that the majority of fiber glass building insulation 

manufacturers have switched to a non-formaldehyde binder, so this question is relevllilt for only 

a rninorityof fiber glassproducers and that minority is gtowingsmaUer. Even those companies 

that have not totally converted to a.non,.formaldehyde binder have armounced plans to move 'in 

that direction. 

As to those companies using a formaldehyde-containing binder to produce building insulation, 

the following information should be useful; 

• 	 On average, the percentage of free fonnaldehyde in the binder as mixed is less than 

1 percent. 

• 	 Ifthe mixing operations are working correctly, the percentage offonnaldehyde should not 

vary. 

• 	 The application rate for building insulation does not generally vary; theappIication rate 

does vary with high temperature commercial and industrial products. 

• 	 Phenollfonnaldehyde binder recipes have varied little civer the years. 

• 	 Variation in application rate (see above) and recipe would create problems with important 

Underwriters Laboratory ("UL") and other standardized perfonnance tests. . . 

• 	 NAIMA's members still using fonnaldehyde binders market and promote their products 

as low in formaldehyde content and actually have certifications that attest to low 

fonnaldehyde emissions. 

• 	 NAIMA's member companies can provide certifications (i.e., GreenGuard) that document 

the low fonnaldehyde emissions from phenoUformaldehyde binder-based fiber glass 

bonded products. 
· Ms. Cindy Wang Haney 

June 8, 20.11 . 

Page 4 

Please do. not hesitate to. contaccme ifyo.uhaveany qu~stio.ns. 

Sincerely, 

~~;;~. 

Angus E. Crane 


Executive Vice President, GeneralCo.unsel 


cc: 	 Ms. Susan Fairchild 


SectorPo.liciesandPro.grams Divisio.n 


Metals and Minerals Gro.up (D243-o.2) 


Office o.f Air QualityPlartningand SUindards 


V.S. Environmental Pro.tectio.n Agency 

l09T.W. Alexander Drive 

ResearchTriangle Park,NC 27711 

Mr. David Reeves 


RTI Internatio.nal 


P.O. Box 12194 


Research Triangle Park, NC 2770.9