Subject: FW: Angus Crane emails

Attachments: RR3145.pdf; RR3145Attachments1-7.pdf; Owens Corning Modeling Sources

06-08-11.xls; RR3182.pdf; pic29744.gif; RR3215.pdf; RR3219.pdf;

EPAMeetingParticipants083111.doc; 083111FGRepsEPA.doc; Antitrust.DOC;

NAIMALtrEPA091411.pdf; Non-CONFIDENTIALChromeSummarySheet (2).xls

From: Angus Crane <acrane@naima.org> 

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

Cc: Bill Neuffer/RTP/USEPA/US@EPA, Jeff Telander/RTP/USEPA/US@EPA 

Date: 05/19/2011 11:35 AM 

Subject: NAIMA Letter Regarding Wool Fiberglass 

Dear Susan,

Please find attached a letter from NAIMA requesting a meeting on wool fiberglass sometime in the 

future. The letter also provides the industry’s perspective on emissions data submitted to EPA.

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: RR3145.pdf)(See attached file:

RR3145Attachments1-7.pdf)

From: Angus Crane <acrane@naima.org> 

 

To: "Hancy, Cindy Wang (chancy@rti.org)" <chancy@rti.org> 

 

Cc: Susan Fairchild/RTP/USEPA/US@EPA, "Reeves, David (dwreeves@rti.org)" dwreeves@rti.org> 

 

Date: 06/08/2011 03:18 PM 

 
Subject: FW: Emission Source Stack Information

Ms. Hancy,

Attached please find the EPA spreadsheet reviewed by Owens Corning. Owens Corning has made 

corrections and, in some instances, added an additional column for clarification purposes. As noted 

below, Owens Corning has asked me to forward this to you.

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

Dear Angus,

Please find attached the EPA spreadsheet that we have reviewed. We have made corrections and added 

a column for clarification in some cases.

As mentioned on the call, we will have supplemental information to be submitted. We anticipate having 

this ready by middle of next week.

Thank you for coordinating the response to this request.

Regards

Robin Edmiston-Bennett

ISB Environmental Network Leader

Fax: 419-325-9778

Phone: 740-328-2479

Cell: 740-323-6664

(See attached file: Owens Corning Modeling Sources 06-08-11.xls)

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

-----

 
From: Angus Crane acrane@naima.org

 

To: "Hancy, Cindy Wang (chancy@rti.org)" <chancy@rti.org> 

Cc: Susan Fairchild/RTP/USEPA/US@EPA, "Reeves, David (dwreeves@rti.org)" 

dwreeves@rti.org> 

Date: 06/08/2011 03:33 PM 

 

Subject: NAIMA's Response for the Fiber Glass Industry to EPA's Formaldehyde and Collection

Questions

 

Dear. Ms. Hancy:

Please find attached NAIMA’s response on behalf of the fiber glass industry to EPA’s questions related to 

formaldehyde and the collection chamber.

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

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: RR3182.pdf)

 

From: Angus Crane <acrane@naima.org> 

 

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

 

Date: 07/24/2011 11:39 AM 

 

Subject: RE: Help needed on Wool Fiberglass 

 

I will start work on this immediately when I return to the office next week (Tuesday).
From: Susan Fairchild [Fairchild.Susan@epamail.epa.gov]

Sent: Thursday, July 21, 2011 4:43 PM

To: Angus Crane

Subject: Help needed on Wool Fiberglass

Hello Angus, Before I go into wool fiberglass, I want to thank you for all your help on Mineral Wool. We 

did finally receive the last financial statement for the industry. I have represented your concerns

to my management and they are very sensitive to the small business impacts and outcomes of the 

regulatory reviews underway.

I have 2 new requests related to Wool Fiberglass to ask your help on:

On Wool fiberglass, we are trying to do something similar. We want to recognize the environmentally 

responsible decisions that wool fiberglass plants are making in phasing out the use of phenolformaldehyde binders in their products, as well as those that have very low chrome emissions that do 

not present a threat of adverse health effects.

I have your June 8, 2011 letter describing the phase-out of the Phenol-Formaldehyde binders. In that 

letter you state that NAIMA can provide documentation that all major sources have already converted 

or have announced plans to convert to non-phenol formaldehyde binders. You go on in that letter to 

identify the conversions and plans by company and site.

1-It would be helpful to receive the documentation on these conversions for the rulemaking record.

2-Additionally, in order to understand the differences between the 'jade green' refractories used at one 

facility and the other types of refractories used within the industry, we need information regarding the

chromium content of the furnace refractories at the time of testing for the following companies and 

sites:

(Embedded image moved to file: pic29744.gif)

Please let me know if you are able to provide information responsive to these 2 requests, and any 

potential timeline for that response.

Thank you again for your efforts on these rulemakings.
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: 07/27/2011 09:33 AM 

 

Subject: Question About Wool Fiber Glass 

 

Will EPA propose HF and HCl limit for wool fiberglass MACT?

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: 07/28/2011 08:54 AM 

 

Subject: NAIMA Response 

 

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

----- 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: 08/01/2011 02:07 PM 

 

Subject: RE: Meeting with Wool Fiberglass industry 

 

I will convey that to them. If I cannot get a group together for the week of August 8th , is the week of 

August 22nd a possibility?

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: Monday, August 01, 2011 1:30 PM

To: Angus Crane

Subject: Meeting with Wool Fiberglass industry

For the upcoming meeting, please advise companies to support statements of hex chrome emissions 

with test results whenever possible.

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: 08/02/2011 03:30 PM 

 

Subject: NAIMA Documentation on Conversion to Non-Formaldehyde Binder and Possible Meeting

Dates 

 

Dear Susan,
Please find attached NAIMA’s letter and documentation setting forth the fiber glass industry’s 

conversion to non-formaldehyde binders.

I greatly appreciate your willingness to meet with NAIMA. The week of August 8, 2011 did not work for 

my members, but I can offer you three dates during the week of August 29th – Tuesday, August 30th; 

Wednesday August 31st; or the first half of the day on Thursday, September 1st . Please tell me if any 

of these dates will work. I assume we will meet with you in Research Triangle Park. If you can give me a 

date, I will notify my members so they can make travel arrangements.

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: RR3215.pdf)

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

-----

 

r: nsreaa@i.g 

 

: s ihdTUPUE 

De 002198M 

 

Subject: Confirmation of Meeting time and date 

 

NAIMA and its members will plan to meet with you on Wednesday, August 31, 2011 at 2-4:00 PM in 

RTP. Thank you for this opportunity!.

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: 08/08/2011 03:06 PM 

 

Subject: A question 

 

With respect to the hex chrome emissions in the fiber glass industry, I know the identity of the largest 

emitter, but can you tell me the second and third highest.

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: 08/10/2011 12:28 PM 

 

Subject: Request for Clarification of Hex Chrome Information 

 

Dear Susan, Please find attached a short letter requesting some clarification of the hex chrome data 

relied upon by EPA and a request for additional information on related matters.

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: RR3219.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: 08/25/2011 09:55 AM 

 

Subject: OC Facility 

 

Dear Susan,

In an earlier conversation, you had identified Owens Corning’s Delmar, New York facility as a high 

emitter of hex chrome, but our data does not show that. Is it possible that another OC facility was of 

concern? Is there some way to confirm the list of plants that are of concern? See my previous letter. 

Could I speak to someone in the CBI office?

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: 08/29/2011 04:14 PM 

 

Subject: Building/Room Number for NAIMA's Meeting with EPA - August 31, 2011 

 

Susan,
Is it possible to provide me with the building and room number for the EPA office on 109 TW Alexander 

Drive where NAIMA’s meeting will be held on Wednesday?

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 

 

Cc: Angus Crane <acrane@naima.org>, Chris Martin <cmartin@naima.org>, Denise Radinovic

<dradinov@naima.org> 

 

Date: 08/30/2011 01:25 PM 

 

Subject: NAIMA Meeting with EPA - August 31, 2011 

 

Dear Susan,

Please find attached a list of NAIMA’s participants for the meeting on Wednesday, August 31, 2011. In 

addition, I have attached an agenda with NAIMA’s Antitrust Guidelines. Lastly, I have included a 

spreadsheet with information on chrome content and chrome emissions divided by furnace type. The 

version I am giving you has company names identified; the same spreadsheet, minus company names, 

has been provided to NAIMA members. The emissions were calculated with hours per year (8,760

hours). This was done, rather than using production rates, to prevent companies from being able to 

identify the production rates of their competitors. NAIMA recognizes that EPA’s numbers were arrived 

at using production data. This exercise of using hours per year, nonetheless, enabled NAIMA to 

differentiate and distinguish chrome emissions by furnace type.

Thank you for this opportunity to meet with you. I believe the discussion will be productive and will be 

responsive to your request for NAIMA to carve out a small problem in a big industry.

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: EPAMeetingParticipants083111.doc)(See attached

file: 083111FGRepsEPA.doc)(See attached file: Antitrust.DOC)(See

attached file: CONFIDENTIAL ChromeSummarySheet.xlsx)

----- 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: 09/07/2011 10:34 AM 

 

Subject: Clemson University Contact 

 

Denis A. Brosnan will be calling you to discuss refractories with 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: 09/07/2011 10:50 AM 
 

Subject: Mr. Brosnan will call you today at 1:00 PM. Do not hesitate to rearrange another time. 

 

To get Mr. Brosnan to agree to make the call, NAIMA agreed to pay him $200.00. We have no other 

existing relationship with him. I want to disclose that so you know everything.

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: 09/07/2011 03:58 PM 

 

Subject: Call with NARCO Representative - September 8, 2011 

 

Susan,

As we discussed, I have set up a dial-in number for the call with Leo Smathers of NARCO on Thursday, 

September 8, 2011 at 4:00 PM (Eastern).

To participate in the call, dial:

 1-888-450-5996 – U.S./Canada Participants

 1-719-955-1371 – International Participants

 PASSCODE: 385178

Please let me know if you have 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> 

 

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

 

Date: 09/08/2011 04:07 PM 

 

Subject: Are you going to be able to join the call? 

 

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: 09/08/2011 04:13 PM 

 

Subject: FW: Call with NARCO Representative - September 8, 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

From: Angus Crane

Sent: Wednesday, September 07, 2011 3:58 PM

To: fairchild.susan@epa.gov

Subject: Call with NARCO Representative - September 8, 2011

Susan,

As we discussed, I have set up a dial-in number for the call with Leo Smathers of NARCO on Thursday, 

September 8, 2011 at 4:00 PM (Eastern).

To participate in the call, dial:

 1-888-450-5996 – U.S./Canada Participants

 1-719-955-1371 – International Participants

 PASSCODE: 385178

Please let me know if you have 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

 

From: Angus Crane <acrane@naima.org> 

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

 

Cc: Angus Crane <acrane@naima.org>, Denise Radinovic <dradinov@naima.org>, Chris Martin

<cmartin@naima.org> 

 

Date: 09/14/2011 05:01 PM 

 

Subject: Letter from NAIMA and Updated Summary Sheet on Chrome Content and Emissions 

 

Dear Susan,

Please find attached a letter that contains very useful and helpful information following up on the joint 

NAIMA/EPA meeting of August 31, 2011. Thank you for your consideration of this letter.

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: NAIMALtrEPA091411.pdf)

 

From: Angus Crane <acrane@naima.org> 

 

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

 

Date: 09/19/2011 03:02 PM 

 

Subject: Susan, can you please confirm that you received my letter. 

 

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