VIA E-MAIL

May 5, 2010

Mr. Jeffrey A. Telander Sector Policies and Programs Division Metals and Minerals Group (D243-02) Office of Air Quality Planning and Standards U.S. Environmental Protection Agency

109 TW Alexander Drive Research Triangle Park, NC 27711

Mr. William Neuffer Sector Policies and Programs Division Metals and Minerals Group (D243-02) Office of Air Quality Planning and Standards U.S. Environmental Protection Agency

109 TW Alexander Drive Research Triangle Park, NC 27711

RE: Proposed Collection of Representative Wool Fiberglass and Mineral Wool Test Data Responsive to Draft Information Collection Requests

Dear Messrs. Telander and Neuffer:

INTRODUCTION

The following is a revised and significantly expa nded data collection and testing plan for the wool fiber glass and mineral w ool insulation manufacturing industr ies to provide both existing

test data and new test data in response to the draft Information Collection Requests (“ICRs”). In response to the Environmenta l Protection Agency’s (“EPA”) comments during a telephone conference between industry and EPA on April 14, 2010, this plan more than quadruples the amount of data proposed for submission to EPA, and where new or existing data is used as representative of other sources , the bases for that representativeness has been strengthened. 1 In addition, a specific testing plan for non-phenol formaldehyde binders has been included.

1 In the draft ICRs, EPA states that “[i]n lieu of new te sting, existing and well documented test data from your current operations that you consider representative . . . can be submitted.” This statement is repeated in the “Summary of Test Procedures, Methods, and Reporting Requirements” for each ICR.

44 Canal Center Plaza ▪ Suite 310 ▪ Alexandria, Virginia 22314 ▪ Tel: (703) 684-0084 ▪ Fax: (703) 684-0427Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 2

The proposed collection of data is separated into two general groups: wool fiber glass and mineral wool. The data to be provided is further segregated into subgroups as follows:

WOOL FIBER GLASS MINERAL WOOL

Furnaces Cupolas

Pollutants To

Be Tested: PM 2.5 , Total PM, Metal HAPs, Mercury, Hex Chrome, Hydrogen Fluoride, Hydrochloric

Acid Pollutants To

Be Tested: Carbon Monoxide, Carbonyl Sulfide

Oxy Fuel Cupola – With Baghouse

and Incinerator

Air Gas Cupola – With Baghouse Only Cold Top Electric – With Baghouse Cold Top Electric – With Batch Wetting Cupolas

Electric Steel Shell Melter – With Baghouse Pollutants To

Be Tested: PM 2.5 , Total PM, Metal HAPs, Mercury, Hex Chrome, Hydrogen Fluoride, Hydrochloric

Acid

Electric Steel Shell Melter

With Gas Assist and

Marble Feed – No Batch

Forming, Curing, and Cooling Collection Operation – Bonded

Pollutants To

Be Tested: Formaldehyde, Methanol,

Phenol Pollutants To

Be Tested: Formaldehyde, Phenol,

Methanol

Bonded – Formaldehyde Curing Operation – Bonded

Bonded – Non-Phenol Formaldehyde Pollutants To

Be Tested: Formaldehyde, Phenol,

Methanol Unbonded – No Testing Cooling Operation – Bonded

Pot & Marble Flame Attenuated Pollutants To

Be Tested: Formaldehyde, Phenol,

Methanol

Pollutants To

Be Tested: PM 2.5 , Total PM, Metal HAPs, Mercury, Hex Chrome, Hydrogen Fluoride, Hydrochloric Acid, Formaldehyde, Phenol, Methanol Unbonded – No Testing of Collection, Curing, and Cooling OperationsMessrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 3

TESTING METHODS

All new and existing emissions data supplied to EPA will have been collected by test methods

identified in the draft ICR or test methods subs equently approved by EPA for this specific ICR. Allowing the use of existing data is particularly important because every company is operating at reduced production due to the significant economic downturn in the building industry. New data, therefore, could not be co llected from the many production lin es that are not in operation, even though they are currently permitted. Moreover, new data also cannot be collected from certain lines in the coming months because of sc heduled rebuilds. Use of existing data will be essential for providing EPA with the requisite data for all point sources. As indicated below, in each furnace category, there are a specific number of lines idled or mothballed.

The test methods to be used for collection of specific pollutants are set forth below:

POLLUTANT RECOMMENDED

METHOD ACCEPTED

ALTERNATIVE

METHOD

Formaldehyde EPA Method 318 EPA Method 316

Phenol EPA Method 318 SW-846 Method

827D

California Method ST16

EPA Method T0-8

Methanol EPA Method 318 EPA Method 308

Carbon Monoxide EPA Method 318 EPA Method 10 Carbonyl Sulfide EPA Method 318 EPA Methods 15 and 320

PM 2.5 (Filterable) Without Water Droplets EPA OTM 27

PM 2.5 (Filterable) With Water Droplets EPA Method 5

PM 2.5 (Condensable) EPA OTM 28

HAPs Metals EPA Method 29 None

Hexavalent Chromium EPA Method 0061

SW 846 Method 7199 None

Mercury EPA Method 30B None Hydrogen Fluoride; Hydrochloric Acid EPA method 26A EPA Method 320

By this letter, the North American Insulati on Manufacturers Associa tion (“NAIMA”) requests EPA’s approval of the data collection plan set forth below and summarized in the enclosed tables so that we can develop a final plan and schedule and commence the collection of the data and other information responsi ve to both draft ICRs.Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 4

DESCRIPTION OF GLASS AND MINERA L WOOL MANUFACTURING PROCESSES

Fiber glass insulation starts with raw materials such as sand, soda ash, limestone, and borax. Broken or recycled glass, known as cullet, is added to the mixture of raw materials to accelerate the melting process. These ingredients are mixed in the batch house and then transferred to and melted in refractory-lined furnaces, or in some cases, electric steel-shelled melters. The heat from the furnace converts these raw materials into a homogenous molten liquid. 2 The melting of glass and forming it into a fiber consists of two distinct stages. The fi rst involves the chemical reaction between the ingredients and results in a sticky molten mass of glass. In the second stage, the glass is cooled until it has the requi red viscosity for fiberization. The molten glass flows from the furnace through the channel to the forehearth, where, after losing a good deal of heat along the way, the glass drains through bushings into the fiberizing equipment.

Mineral wool follows a similar process, with the raw materials being different.

NEW AND EXISTING DATA TO BE PROVIDED

To identify and organize the data to be supplied to EPA, this letter arranges by MACT Standard the point sources and pollutants for which we will supply existing test data or newly collected data and our bases for concluding that such data should be deemed representative.

2 F.J. Terence Maloney, Glass in the Modern World , at 74 (New York: Doubleday, 1968).Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 5

Wool Fiberglass

Furnaces

Process Unit: Oxy Fuel

Pollutants To Be Tested: PM 2.5 (Filterable and Condensable ), Total PM (Filterable and Condensable), Metals, Merc ury, Hex Chrome, Hydrogen Fluoride, Hydrochloric Acid Data To Be Supplied: There are 12 oxy fuel furnaces permitted in the industry. Six

of those furnaces are idle. New PM 2.5, total PM, metals, mercury, hex chrome, hydrogen fluo ride, and hydrochloric acid data will be collected from the following facilities: Owens Corning’s Kansas City, Kansas facility (K5 Furnace); Owens Corning’s Waxahachie, Texas facility (V1 Furnace); Knauf’s Lanett, Alabama facility (621 Furnace); and CertainTeed’s Kansas City, Kansas facility (K2 Furnace). Existing PM and metals data will be provided from the following facilities: CertainTeed’s Athens, Georgi a facility (A2 Furnace); CertainTeed’s Chowchilla, California facility (C1 Furnace); and CertainTeed’s Kansas City, Kansas facility (K1 and K2 Furnaces). New or existing emissions data is being provided by the majority of the facilities using oxy fuel furnaces. Only

two facilities are not providing new or exis ting data – Delmar, New York; and Cleburne, Texas. As described below, the data collected at these plants is re presentative of the two facilities for which data will not be provided. Location/Lines Represented: Knauf – Lanett, Alabama (621 Fu rnace (with DEP) and 622 Furnace (with DEP))

CertainTeed – Athens, Georgia (A2 Furnace (with DEP)); Chowchilla, California (C1 Furnace (with DEP)); Kansas City, Kansas (K1 Furnace and K2 Furnace (with DEP))

Johns Manville – Cleburne, Texas (1902 Furnace (has Scrubber and DEP)) Owens Corning – Delmar, New York (DM1 Furnace (with DEP) and DM2 Furnace (with DEP)); Kansas City, Kansas (J6/U3 Furnace (with Electric B oost and DEP) and K5 Furnace (with DEP)); Waxahachie, Texas (V1 Furnace (with DEP)) Bases For Representativeness: The data collected is representative ba sed on the following: all of the oxy fuel furnaces are powered by natural gas; all of the oxy fuel furnaces use a dry electrost atic precipitator; all of the oxy fuel furnaces make borosilicate glass using the same raw materials (soda ash 9%; borax 12 %; cullet 34%; limestone 9%; sand 31%); 3 all of the oxy fuel furnaces are the same class size

3 This is the industry average for constituents. Binder makes up five percent of the total constituents, but because it is not part of the melting process, it is not included in this list.Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 6

of furnaces; all of the furnaces use chrome refractories 4 and operate at temperatures in exces s of 2000°F; all the facilities use the same fiber glass manuf acturing process (as described on page 4 above); and three of the furnaces for which data is not being provided are operated by Owens Corning whose Kansas City and Waxahachie data would be representative of these furnaces because opera ting practices are the same throughout the company. The Johns Manville’s Cleburne, Texas furnace is not currently operating and has no recent test data. The primary source of hex chrome emissions from all of

these furnaces is their chrome refractories and their constant contact with molten glass at te mperatures in excess of 2000°F

and not the batch materials.

Process Unit: Air Gas

Pollutants To Be Tested: PM 2.5 (Filterable and Condensable ), Total PM (Filterable and Condensable), Metals, Merc ury, Hex Chrome, Hydrogen Fluoride, Hydrochloric Acid Data To Be Supplied: There are six air gas furnaces permitted in the industry. Three

of those furnaces are idle. New PM 2.5, total PM, metals, mercury, hex chrome, hydrogen fluo ride, and hydrochloric acid

data will be collected from J ohns Manville’s Defiance, Ohio facility (2603 Furnace) and Owe ns Corning’s Newark, Ohio facility (F6 Furnace). Existing da ta from both of CertainTeed’s Mountain Top, Pennsylvania facility furnaces will also be provided. The basis for selec ting these facilities for new testing is the fact that these furnaces are operating. Mountain Top, Pennsylvania M1 and M2 Furnaces and Defiance, Ohio Furnace 2601 are currently idled. Location/Lines Represented: CertainTeed – Mountain Top, Pennsylvania (M1 Furnace and M2 Furnace and these furnaces share a common DEP)

Johns Manville – Defiance, Ohio (2601 & 2603 Furnaces (have common DEP and Baghouse in series)) Owens Corning – Newark, Ohio (F6 Furnace (with Electric Boost and Baghouse), A3 Furnace (with DEP)) Bases For Representativeness: The data collected is representative ba sed on the following: all of the air gas furnaces are powered by natural gas; all of the air gas furnaces make borosilicate glass using the same raw materials (soda ash 9%; borax 12 %; cullet 34%; limestone 9%; sand 31%); all of the furnaces use chrome refractories 5 and operate at temperatures in excess of 2000°F; and all the

4 Some raw materials contain trace elements of chromi um; however, hex chrome emissions from raw materials would be insignificant compared to t hose contributed from the refractory.

5 Some raw materials contain trace elements of chromi um; however, hex chrome emissions from raw materials would be insignificant compared to t hose contributed from the refractory.Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 7

facilities use the same fiber gl ass manufacturing process (as described on page 4 above). The primary source of hex

chrome emissions from all of these furnaces is their chrome refractories and their constant contact with molten glass at temperatures in excess of 2000°F and not the batch materials.

Process Unit: Cold Top Electric – With Baghouse

Pollutants To Be Tested: PM 2.5 (Filterable and Condensable ), Total PM (Filterable and Condensable), Metals, Merc ury, Hex Chrome, Hydrogen Fluoride, Hydrochloric Acid Data To Be Supplied: There are eight co ld top electric furnaces permitted in the industry. One of those furnaces is idle. New PM 2.5 , total PM, metals, mercury, hex chrome, hydrogen fluoride, and hydrochloric acid data will be co llected from Johns Manville’s Richmond, Indiana facility (M elter) and Johns Manville’s Defiance, Ohio facility (three 800 Series Melters). Additional new metals, mercury, hex ch rome, hydrogen fluoride, and hydrochloric acid data will be co llected from Knauf’s Shasta Lake, California facility. Existing PM 2.5 will be provided from Knauf’s Shasta Lake, California facility. Existing PM 2.5 , total PM, and metals data will be provided from CertainTeed’s Athens, Georgia facility. Existing PM 2.5 , total PM, metals, hydrogen fluoride, and hydrochloric acid data will be provided from Knauf’s Shelbyville, Indiana facility. This data will be representative of all cold top furnaces with baghouses, as

described below. Location/Lines Represented: Knauf – Shelbyville, Indiana (611 Furnace and 602 Furnace); Shasta Lake, California (641 Furnace)

CertainTeed – Athens, Georgia (A1 Furnace)

Johns Manville – Richmond, Indiana (Mel ter); Defiance, Ohio (Three 800 Series Melters)

Owens Corning – Owens Corning does not operate any cold top electric melters with baghouses Bases For Representativeness: The data collected is representative ba sed on the following: all of the furnaces are operated with electricity and no natural gas;

all of the furnaces use chrome refractories 6 and operate at temperatures in excess of 2000°F; all of the furnaces are either being tested or are the same desi gn as the ones being tested; all

of the furnaces make borosil icate glass using the same materials (soda ash 9%; borax 12 %; cullet 34%; limestone 9%; sand 31%); all of the furnaces have a baghouse; all of the filters in those baghouses are made of similar synthetic fiber fabric;

6 Some raw materials contain trace elements of chromi um; however, hex chrome emissions from raw materials would be insignificant compared to t hose contributed from the refractory.Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 8

and all of the facilities use th e same fiber gla ss manufacturing process (as described on page 4 above). The primary source of

hex chrome emissions from all of these furnaces is their

chrome refractories and their constant contact with molten glass at temperatures in ex cess of 2000°F and not the batch

materials.

Process Unit: Cold Top Electric – With Batch Wetting

Pollutants To Be Tested: PM 2.5 (Filterable and Condensable ), Total PM (Filterable and Condensable), Metals, Merc ury, Hex Chrome, Hydrogen Fluoride, Hydrochloric Acid Data To Be Supplied: There are 10 cold top electric furnaces with batch wetting permitted in the industry. Four of those furnaces are currently

idle. New PM 2.5 , total PM, metals, mercury, hex chrome, hydrogen fluoride, and hydrochloric acid data will be collected from Owens Corning’s Kansas City, Kansas facility (70 Furnace) and Owens Corning’s Newark, Ohio facility (C4). The most recent existing data will be provided from the Fairburn, Georgia; Santa Clara, California; and Waxahachie, Texas facilities. This data will be representative of all cold top furnaces with batch wetting. Location/Lines Represented: Owens Corning – Fairburn, Georgia (FG1, FG2, FG3 Furnaces (With Batch Wetting)); Newark, Ohio (C4 and B4 Furnaces (With Batch Wetting)); Kansas City, Kansas (70 Furnace (With Batch Wetting)); Waxahachie, Texas (V2 Furnace, V3 Furnace (With Batch Wetting)); Santa Clara, California (M and O Furnaces (With Batch Wetting)) Bases For Representativeness: The data collected is representative ba sed on the following: all of the facilities are operated by a single company and use the same fiber glass manufacturing pr ocess (as described on page 4 above); all of the furnaces are operated with electricity and no natural gas; all of the furnaces use chrome refractories 7 and operate at temperatures in exces s of 2000°F; all of the furnaces are the same basic design; all of the furnaces make borosilicate glass using identical materials; all of the furnaces are operated without a baghouse and use batch wetting; all of the furnaces are operated by the same comp any using the same operating temperature and have similar pull factors. The primary source

of hex chrome emissions from all of these furnaces is their

chrome refractories and their constant contact with molten glass at temperatures in ex cess of 2000°F and not the batch

materials.

7 Some raw materials contain trace elements of chromi um; however, hex chrome emissions from raw materials would be insignificant compared to t hose contributed from the refractory.Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 9

Process Unit: Electric Steel Shell Melter – With Baghouse

Pollutants To Be Tested: PM 2.5 (Filterable and Condensable ), Total PM (Filterable and Condensable), Metals, Merc ury, Hex Chrome, Hydrogen Fluoride, Hydrochloric Acid Data To Be Supplied: There are 30 elec tric steel shell melters with baghouses permitted in the industry. 14 of those furnaces are currently

idled. New PM 2.5 , total PM, metals, mercury, hex chrome, hydrogen fluoride, and hydrochloric acid data will be collected from FiberTEK’s Lakeland, Florid a facility (Middle and West Melters); Guardian’s Albion, Mich igan facility (Line 1, 2, and 4 Furnaces, which exhaust to a common stack); Guardian’s Winnsboro, South Carolina facility (Line 1 Furnace); Guardian’s Mineral Wells, Mississippi facility (Line 2 Furnace); Johns Manville’s Defiance, Ohio facility (Line 89 Melter); Johns Manville’s Clebur ne, Texas facility (Line 91 Melter); Johns Manville’s Willows, California facility (Line 133); and Owens Corning’s Mount Vernon, Ohio facility (Furnace 1). Existing PM 2.5, total PM, and metals data from Johns Manville’s Willows, California facility will be provided. Existing PM data from Owens Corning’s Eloy, Arizona and Salt Lake City, Utah faci lities will be provided. Location/Lines Represented: FiberTEK – Lakeland, Florida (Middle Melter and West Melter); Nephi, Utah (Middl e Melter and West Melter)

Guardian – Albion, Michigan (Line 1 Furnace, Line 2 Furnace, Line 3 Furnace, Line 4 Furnace); Kingman, Arizona (Line 1 Furnace); Inwood, West Vi rginia (Line 1 Furnace, Line 2 Furnace); Winnsboro, South Carolina (Line 1 Furnace); Mineral Wells, Mississippi (Line 1 Furnace, Line 2 Furnace)

Johns Manville – Penbryn, New Jersey (L58 Melter); Winder, Georgia (Line 105 and 106 Melter s); McPherson, Kansas (Line 122 and 123 Melters); Willows, California (Line 132 and 133 Melters); Cleburne, Texas (Lines 91, Melter); Defiance, Ohio (Line 89 Melter) Owens Corning – Eloy, Arizona (Furnaces 1 and 2); Salt Lake City, Utah (Furnaces 1 and 2) ; Mount Vernon, Ohio (Furnaces 1, 2, and 3) Bases For Representativeness: The data collected is representative ba sed on the following: all of the melters are operated with electricity and no natural gas;

all of the furnaces use chrome refractories 8 and operate at temperatures in excess of 2000°F; all of the furnaces are steel shell pot-type containers with refractory liners; all of the

8 Some raw materials contain trace elements of chromi um; however, hex chrome emissions from raw materials would be insignificant compared to t hose contributed from the refractory.Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 10

furnaces use a baghouse; all of the filters in those baghouses are made from a polyester fabr ic; all of the furnaces make borosilicate glass using the same raw materials (soda ash 9%; borax 12%; cullet 34%; limestone 9%; sand 31%); and all the facilities use the same fiber gl ass manufacturing process (as described on page 4 above). The primary source of hex

chrome emissions from all of these furnaces is their chrome refractories and their constant contact with molten glass at temperatures in excess of 2000°F and not the batch materials.

Process Unit: Electric Steel Shell Melter with Gas Assist and Marble Feed –

No Batch

Pollutants To Be Tested: PM 2.5 , Total PM, Metals, Mercur y, Hex Chrome, Hydrogen Fluoride, Hydrochloric Acid Data To Be Supplied: There are six electri c steel shell melter w ith gas assist and marble feed – no batch melters permitted in the industry. Three of those melters are currently idle. New PM 2.5 , total PM, metals, mercury, hex chrome, hydrogen fluoride, and hydrochloric acid data will be collected from one of Johns Manville’s Waterville, Ohio f acility’s three stacks. Johns Manville’s Waterville, Ohio Plant 07 operates steel-shelled melters that re-melt glass marbles and feed no batch. They are electric with gas assist. There ar e four such lines that total six

melters. These are unbonded lin es that have common ducting of melter and forming emissions from all lines to three parallel scrubbers with three parallel stacks. Location/Lines Represented: Johns Manville – Waterville, Ohio Pl ant 07 300X Lines (four lines) Bases For Representativeness: The Waterville, Oh io lines are the only such lines operated by NAIMA members. The data collected is representative based on the following: Johns Manville uses the identical process for all melters; all melters are elect ric steel shell; all melters use gas assist for power; all melters use marble feed; no batch is used; and all melters are operated by the same company at the same plant location.

Forming, Curing, and Cooling

For purposes of identifying representative data responsive to EPA’s request, NAIMA has combined the wool fiberglass forming, curing, a nd cooling sources together into one source.

These three sources are more often than not ex hausted through one stac k or a common exhaust system, not separately and individually. Where a common stack or exhaust is not used, NAIMA

will combine the emissions data from the three sources into one data set. This is consistent with prior practices and eliminates a lot of confusion in treating fo rming, curing, and cooling in separate categories that ultimately undertake the same discussion and analysis for each source.Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 11

Process Unit: Forming, Curing, a nd Cooling – Formaldehyde Binder Pollutants To Be Tested: Formaldehyde, Phenol, Methanol Data To Be Supplied: All plants with bonded lines using formaldehyde will provide existing data for formaldehyde, phenol, and methanol. This primarily is MACT compliance test data, which significantly overstates formaldehyde emissions during normal operations because the testing was used to set the MACT compliance limits and, as such, involved the artificial increase of formaldehyde levels. Normal operational test data will be provided, too. New formaldehyde , phenol, and methanol data will be collected at Johns Manville’s Cleburne, Texas facility (L91) and Johns Manville’s Defi ance, Ohio facility (89 and 804). Location/Lines Represented: CertainTeed – Athens, Georgia (A11 Lines); Chowchilla, California (C11 Line); Kansas City, Kansas (K11 Line, K21 Line); Mountain Top, Pennsyl vania (M1 and M2 Lines)

FiberTEK – Lakeland, Florida (BL Line); Nephi, Utah (BL Line)

Guardian – Albion, Michigan (Lin e 1, Line 3); Kingman, Arizona (Line 1); Inwood, West Virginia (Lines 1 and 2); Winnsboro, South Carolina (Line 1); Mineral Wells, Mississippi (Line 1)

Johns Manville – Cleburne, Texas (Lines 91, 92, and 93); Defiance, Ohio (Lines 89, 801-806, 807)

Knauf – Shelbyville, Indiana (Bonded Line)

Owens Corning – Delmar, New York (DM1 and DM2 Lines); Fairburn, Georgia (FG1, FG2, FG 3 Lines); Newark, Ohio (C4, F6, B4, A4, A5 Lines); Kansas City, Kansas (70, J6, K5 Lines); Waxahachie, Texas (V1, V2, V3 Lines); Santa Clara, California (M, O Lines); Eloy, Ar izona (1 Bonded Line); Salt Lake City, Utah (1 Bonded Line) Bases For Representativeness: Because data is being provided from every company, there is no assertion of cross-company representativeness; however, within each company, these opera tions are identical from line

to line.

Process Unit: Forming, Curing, and Cooling – Non-Formaldehyde Binder Pollutants To Be Tested: Formaldehyde, Phenol, Methanol Data To Be Supplied: New formaldehyde, phenol, and methanol data will be

collected at Johns Manville’s Winder, Georgia facility (106); Johns Manville’s Willows, Califor nia facility (Line 133); and Knauf’s Lanett, Alabama facility (621). Due to a scheduledMessrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 12

furnace reconstruction/rebuild, the CertainTeed C11 line is unavailable for testing until Fall 2010, at the earliest. Location/Lines Represented: CertainTeed – Chowchilla, California (C11 Line, approximately 50% Non-P/F)

Johns Manville – Penbryn, New Jersey (Line 58); Winder, Georgia (Lines 105 and 106); McPherson, Kansas (Lines 122 and 123); Willows, California (Lines 132 and 133)

Knauf – Shasta Lake, Californi a (100% Non-P/F); Lanett, Alabama (100% Non-P/F); Shelbyville, Indiana (Approximately 75% Non-P/F) Bases For Representativeness: The data colle cted is representative of forming, curing, and cooling sources at facilities using non-formaldehyde/phenolic binder based on the following: all of the facilities make borosilicate glass using the same raw materials (soda ash 9%; borax 12%; cullet 34%; limestone 9%; sand 31%); all of the products are bonded; all of the binders are non-phenolic; and

all of the facilities use the same fiber glass manufacturing process (as described on page 4 above). The Knauf Lanett, Alabama data is representative of all Knauf’s facilities because

the binder used is identical and control methods are identical. The Johns Manville Willows, California data is representative

of all John Manville’s facilities except Winder, Georgia Line

106 because the binder used is identical and control methods are identical. Winder, Georgi a Line 106 has different control and thus is also being proposed for testing.

The following company facilities do not use bind ers (they produce unbonded blowing wool). As such, no formaldehyde, phenol, and metha nol test data will be provided.

CertainTeed – Athens, Georgia (A12 and A23 Line s); Kansas City, Kansas (K12 and K21 Lines); Chowchilla, California (C12 Line);

FiberTEK – Lakeland, Florida (UL Line); Nephi, Utah (UL Line);

Guardian – Albion, Michigan (Lines 2 and 4); Mineral Wells, Mississippi (Line 2);

Johns Manville – Richmond, Indiana (Lines 2 and 3); Waterville, Ohio Plant 07 (300X Lines); and Owens Corning – Kansas City, Kansas (U3 Line); Salt Lake City, Utah (SL2 Line); Mount Vernon, Ohio (3 Unbonded Lines).

Process Unit: Pot & Marble Flame Attenuated Pollutants Testing Requested: PM 2.5 (Filterable and Condensable ), Total PM (Filterable), Metals, Mercury, Hex Chrome, Hydrogen Fluoride, Hydrochloric Acid, Formal dehyde, Phenol, Methanol Data To Be Supplied: Johns Manville is the only member in NAIMA with a Pot & Marble melting process. They re-melt glass marbles in veryMessrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 13

small pots using small gas burners (not electric). It is a completely different process than rotary and was subcategorized in the original MACT standard. New data for

PM 2.5 , total PM, metals, mercury, hex chrome, hydrogen fluoride, and hydrochloric acid will be collected from Johns Manville’s Waterville, Ohio Pl ant 07 (Unit 29- 30). Existing data on formaldehyde, phenol, and methanol will be provided for each line in Johns Manville’s Defiance, Ohio and Cleburne,

Texas facilities. Location/Lines Represented: Johns Manville – Defiance, Ohio (Lines 81, 82, 84, 85, 86, 87, 88, 21, 23, 24, 25); Cleburne, Texas (L92, 93); Waterville, Ohio Plant 07 (pot and ma rble units (no binder)). Bases For Representativeness: The data collected is representative base d on the following: all re-melt borosilicate glass marbles; all are pot & marble flame attenuation; and all are op erated by Johns Manville.

Mineral Wool

Process Unit: Cupola – With Baghouse and Incinerator Pollutants To Be Tested: Carbon Monoxide, Carbonyl Sulfide Data To Be Supplied: New carbonyl sulf ide and carbon monoxide data will be collected from Industrial Insulation Group’s Phenix City, Alabama facility; USG Interiors’ Walworth, Wisconsin facility; and Thermafiber’s Wabas h, Indiana facility. Existing carbonyl sulfide data will be s upplied for USG Interiors’ Red Wing, Minnesota facility. Location/Lines Represented: Industrial Insulation Group – Phenix City, Alabama

Thermafiber – Wabash, Indiana (Bonded #2, Granulated #4)

USG Interiors – Red Wing, Minnesota; Walworth, Wisconsin Bases For Representativeness: Each company is providing data. The data is representative based on the following: when based on fuel used, USG Interiors’ Walworth, Wiscons in carbonyl sulfide data are representative for USG Interiors’ Red Wing, Minnesota facility; and USG Interiors’ c upolas are coke-fired, melting a slag plus additive charge, and producing slag wool using controls of an incinerator and baghouse.

Process Unit: Cupola – With Baghouse Only Pollutants To Be Tested: Carbon Monoxide, Carbonyl Sulfide Data To Be Supplied: New carbon monoxi de and carbonyl sulf ide data will be collected from Isolatek’s Huntington, Indiana facility. Existing carbonyl sulfide and carbon mono xide data from Amerrock Products’ Nolanville, Texas facility and Rock Wool Manufacturing’s Leeds, Alabama facility will be provided.Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 14

Location/Lines Represented: Amerrock Products – Nolanville, Texas

Isolatek International – Huntington, Indiana (Cupola #1, Cupola #2 – common baghouse/combined point source) Rock Wool Manufacturing – Leeds, Alabama (1 Cupola, Line #2) Bases For Representativeness: Data is pr ovided from each point source so no case for representativeness is made.

Process Unit: Cupola

Pollutants To Be Tested: PM 2.5 (Filterable and Condensable ), Total PM (Filterable and Condensable), Metals, Merc ury, Hex Chrome, Hydrogen Fluoride, Hydrochloric Acid Data To Be Supplied: New PM 2.5 , total PM, metals, mercury, hex chrome, hydrogen fluoride, and hydrochloric acid da ta will be collected from Industrial Insulation Group’s Phen ix City, Alabama facility (1 Cupola); Thermafiber’s Wabash, Indiana facility (Cupola 2); USG Interiors’ Walworth, Wisconsin facility (1 Cupola); Isolatek’s Huntington, Indian a facility (Cupolas 1 and 2 – Common Baghouse/Combined Poin t Source); and Rock Wool Manufacturing’s Leeds, Alabama facility. New PM 2.5 , total PM, mercury, hex chrome, hydroge n fluoride, and hydrochloric

acid will be collected at USG Interiors’ Red Wing, Minnesota facility. Existing metals data from USG Interiors’ Red Wing, Minnesota facility will be provided. Location/Lines Represented: Amerrock Products – Nolanville, Texas Industrial Insulation Group – Phenix City, Alabama

Isolatek International – Huntington, Indiana Rock Wool Manufacturing – Leeds, Alabama

Thermafiber – Wabash, Indiana

USG Interiors – Red Wing, Minnesota; Walworth, Wisconsin Bases For Representativeness: Five of the six companies are collecting new data. The Thermafiber data is representative of Amerrock Products based on the following: all of the cupolas are coke-fired, melting blast furnace slag, and pr oducing slag wool products.

Process Unit: Collection Operation Pollutants To Be Tested: Formaldehyde, Phenol, Methanol Data To Be Supplied: Existing formaldehyde data will be supplied from Thermafiber, Industrial Insulation Group, and Rock Wool Manufacturing. New formaldehyde, methanol, and phenol data will be collected from Thermafiber. New phenol and methanol data will be collected from Industrial Insulation Group. The remaining companies, USG Inte riors, Amerrock Products, and Isolatek International, operate unbonded lines, and, therefore,Messrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 15

use no binder during the manufact uring of mineral wool. In addition, Thermafiber line – Granulated #4 – is unbonded. The data that will be provided to EP A is not represen tative of these unbonded lines, and no data has been collected for these unbonded lines as agreed upon with EPA. Location/Lines Represented: Industrial Insulation Group – Phenix City, Alabama

Thermafiber (Bonded #2) – Wabash, Indiana Rock Wool Manufacturing (Bonded Line #2) – Leeds,

Alabama Bases For Representativeness: All companies ar e providing existing formaldehyde data. This phenol and methanol data is representative based on the following: all of the cupolas are coke-fired, melting similar raw material mix, producing rock and slag wool products, using the same binder products, and using controls of mechanical filters.

Process Unit: Curing Oven Pollutants To Be Tested: Formaldehyde, Phenol, Methanol Data To Be Supplied: Existing formaldehyde data will be supplied from Thermafiber, Industrial Insulation Group, and Rock Wool Manufacturing. New formaldehyde, methanol, and phenol data will be collected from Thermafiber. New phenol and methanol data will be collected from Industrial Insulation Group. The remaining companies, USG Inte riors, Amerrock Products, and Isolatek International, operate unbonded lines, and, therefore, use no binder during the manufact uring of mineral wool. In addition, Thermafiber line – Granulated #4 – is unbonded. The data that will be provided to EP A is not representative of these unbonded lines, and no data has been collected for these unbonded lines as agreed upon with EPA. Location/Lines Represented: Industrial Insulation Group – Phenix City, Alabama

Thermafiber (Bonded #2) – Wabash, Indiana Rock Wool Manufacturing (Bonded Line #2) – Leeds,

Alabama Bases For Representativeness: All companies ar e providing existing formaldehyde data. This phenol and methanol data is representative based on the following: each cupola is coke-fired, melting similar raw material mix, producing rock and slag wool products, using the same binder products, and using controls of mechanical filters.

Process Unit: Cooling Operation Pollutants To Be Tested: Formaldehyde, Phenol, Methanol Data To Be Supplied: Existing formaldehyde data will be supplied from Industrial Insulation Group and Rock Wool Manufacturing. New formaldehyde, methanol, and phenol data will be collectedMessrs. Jeffrey A. Telander and William Neuffer May 5, 2010 Page 16

from Thermafiber. New phenol and methanol data will be

collected from Industrial In sulation Group. The remaining companies, USG Interiors, Am errock Products, and Isolatek International, operate unbonded lines, and, therefore, use no binder during the manufacturing of mineral wool. In addition,

Thermafiber line – Granulated #4 – is unbonded. The data that will be provided to EPA is not representative of these unbonded lines, and no data has been collected for these unbonded lines as agreed upon with EPA. Location/Lines Represented: Industrial Insulation Group – Phenix City, Alabama

Thermafiber (Bonded #2) – Wabash, Indiana Rock Wool Manufacturing (Bonded Line #2) – Leeds,

Alabama Bases For Representativeness: The new and ex isting formaldehyde, phenol, and methanol data is representative of all based on the following: all of the cupolas are coke-fired, melting similar raw material mix, producing rock and slag wool products, and using the same binder products from the same binder manufacturer.

By this letter, NAIMA, on behalf of the w ool fiberglass and mineral wool insulation manufacturing industries, requests EPA’s approval and acceptance of the proposed data collection plan set forth above a nd summarized in the enclosed ta bles as representative industry data so that we can develop a final plan and schedule for the co llection of the data and other information responsive to the draft ICRs.

Sincerely,

Angus E. Crane

Angus E. Crane

Executive Vice Presiden t, General Counsel

Enclosures