# NAIMA

NORTH I\MERlcAH INSULATION MA"IOFACTURERS I\SSOCfATION
Cr:lcbraiil1g15 Yl;llrs Of

EllfrgyEfflcieflCY 

### 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 belowis 

### an industry-wide response t6 EPA's questions related to formaldehyde use and the collectionprocess:
• 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 ofconverting essentiallyall 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 offacilities 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 

### thathave.

### sWitched

## to

## a. rion.;fotrnaldehyclebinder: OWens Corning [)elmar, 

### NY Bloy, AZ Fairburn,GA Kansas City, 

### KS. Newark.OH (Conversion hasbeencompletedon some ofthe manufacturing lines atthisfacility) SaltLake City, UT Santa Clara, CA Waxahachie, 

### TX (Conversion has been completed. on some ofthe manufacturing lines at this facility) KnaufInsulation 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 thisfacility)**Wat~rviUe;** OH (nobipc:ier usedinwoolfiberglass 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 

### itpartofforming? During the production 

### ofglass woo] by the rotary process (the 

### mQst common niethod .used for fiber glass building insulation production); molten glass isJorcedthrough**hol~s** in spinning disksMs. Cindy Wang Hancy June 8, 2011 Page 3

and the resultant fibers are attenuated to the proper size. Atthat 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 similartothat ofmineral wool production.

• Arethc;:resignificantHAP emissions coming from cooling? No. Cooling is thelastphase ofthe production. The cooling process involves dra'Ying ambient airthrough the cured fiberglass pack to cool the product after exitingthe curing oven where the binder was solidified into the finished product. No activitytakes 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 ofHAP emissions in cooling is from the release 

### ofHAPs that might be einbeddedin 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 rninorityoffiber glassproducers and that minority is gtowingsmaUer. Eventhose 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, thefollowing information should be useful;

• On average, the percentage of free fonnaldehyde in the binder 

### as mixed is less 

### than 1percent. 

### • Ifthe mixing operations are working correctly, the percentage offonnaldehyde shouldnot vary. • The application rate for building insulation does not generally vary; theappIication rate does vary

### withhightemperature commercial and industrial products. • Phenollfonnaldehyde binderrecipes have varied little civerthe years. • Variation in applicationrate (see above) and recipe would create problems 

### with important Underwriters Laboratory ("UL") and otherstandardized 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'smember companies can provide certifications 

### (i.e., GreenGuard) thatdocument the low fonnaldehyde emissions from phenoUformaldehyde binder-based fiber glass bonded products.

### ·Ms. Cindy Wang Haney June 8, 20.11

. Page4



### Please do. nothesitate to. contaccme if

### yo.uhaveany**qu~stio.ns .**  

### Sincerely,

# ~~;;~. Angus E. 

### Crane Executive Vice

### President, GeneralCo.unsel


### cc: Ms. Susan Fairchild SectorPo.liciesandPro.grams Divisio.n Metals and MineralsGro.up (D243-o.2) Office o.fAir QualityPlartningand SUindards 

### V.S. Environmental Pro.tectio.n Agency l09T.W. AlexanderDrive ResearchTriangle Park,NC 27711 Mr. DavidReeves RTI Internatio.nal 

### P.O. Box 12194 ResearchTriangle Park, NC 2770.9