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 expanded data collection and testing plan for the 

wool fiber glass and mineral wool insulation manufacturing industries to provide both existing 

test data and new test data in response to the draft Information Collection Requests (“ICRs”). In 

response to the Environmental 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 testing, 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) 684-0427 
Messrs. 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: 

PM2.5, 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: 

PM2.5, 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:

PM2.5, Total PM, Metal 

HAPs, Mercury, Hex 

Chrome, Hydrogen 

Fluoride, Hydrochloric 

Acid, Formaldehyde, 

Phenol, Methanol

Unbonded – No Testing of Collection, 

Curing, and Cooling Operations

 
Messrs. 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 subsequently 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 collected from the many production lines 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 scheduled 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 

PM2.5 (Filterable) Without 

Water Droplets 

EPA OTM 27 

PM2.5 (Filterable) With Water 

Droplets 

EPA Method 5 

PM2.5 (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 Insulation Manufacturers Association (“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 responsive to both draft ICRs. 

 
Messrs. Jeffrey A. Telander and William Neuffer

May 5, 2010

Page 4

DESCRIPTION OF GLASS AND MINERAL 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 first 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 required 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: PM2.5 (Filterable and Condensable), Total PM (Filterable and 

Condensable), Metals, Mercury, 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 PM2.5, total PM, metals, 

mercury, hex chrome, hydrogen fluoride, 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, Georgia 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 existing data – Delmar, 

New York; and Cleburne, Texas. As described below, the data 

collected at these plants is representative of the two facilities 

for which data will not be provided. 

Location/Lines Represented: Knauf – Lanett, Alabama (621 Furnace (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 Boost and DEP) and K5 Furnace 

(with DEP)); Waxahachie, Texas (V1 Furnace (with DEP)) 

Bases For Representativeness: The data collected is representative based on the following: all 

of the oxy fuel furnaces are powered by natural gas; all of the 

oxy fuel furnaces use a dry electrostatic 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 refractories4

 and 

operate at temperatures in excess of 2000°F; all the facilities 

use the same fiber glass manufacturing 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 operating 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 temperatures in excess of 2000°F 

and not the batch materials. 

Process Unit: Air Gas 

Pollutants To Be Tested: PM2.5 (Filterable and Condensable), Total PM (Filterable and 

Condensable), Metals, Mercury, 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 PM2.5, total PM, metals, 

mercury, hex chrome, hydrogen fluoride, and hydrochloric acid 

data will be collected from Johns Manville’s Defiance, Ohio 

facility (2603 Furnace) and Owens Corning’s Newark, Ohio 

facility (F6 Furnace). Existing data from both of CertainTeed’s 

Mountain Top, Pennsylvania facility furnaces will also be 

provided. The basis for selecting 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 based 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 refractories5

 and 

operate at temperatures in excess of 2000°F; and all the 

4

 Some raw materials contain trace elements of chromium; however, hex chrome emissions from raw materials 

would be insignificant compared to those contributed from the refractory. 5

 Some raw materials contain trace elements of chromium; however, hex chrome emissions from raw materials 

would be insignificant compared to those contributed from the refractory. 

 
Messrs. Jeffrey A. Telander and William Neuffer

May 5, 2010

Page 7

 

facilities use the same fiber glass 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: PM2.5 (Filterable and Condensable), Total PM (Filterable and 

Condensable), Metals, Mercury, Hex Chrome, Hydrogen 

Fluoride, Hydrochloric Acid 

Data To Be Supplied: There are eight cold top electric furnaces permitted in the 

industry. One of those furnaces is idle. New PM2.5, total PM, 

metals, mercury, hex chrome, hydrogen fluoride, and 

hydrochloric acid data will be collected from Johns Manville’s 

Richmond, Indiana facility (Melter) and Johns Manville’s 

Defiance, Ohio facility (three 800 Series Melters). Additional 

new metals, mercury, hex chrome, hydrogen fluoride, and 

hydrochloric acid data will be collected from Knauf’s Shasta 

Lake, California facility. Existing PM2.5 will be provided from 

Knauf’s Shasta Lake, California facility. Existing PM2.5, total 

PM, and metals data will be provided from CertainTeed’s 

Athens, Georgia facility. Existing PM2.5, 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 (Melter); 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 based on the following: all 

of the furnaces are operated with electricity and no natural gas; 

all of the furnaces use chrome refractories6

 and operate at 

temperatures in excess of 2000°F; all of the furnaces are either 

being tested or are the same design as the ones being tested; all 

of the furnaces make borosilicate 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 chromium; however, hex chrome emissions from raw materials 

would be insignificant compared to those contributed from the refractory. 

 
Messrs. Jeffrey A. Telander and William Neuffer

May 5, 2010

Page 8

 

and all of the facilities use the same fiber glass 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 Batch Wetting 

Pollutants To Be Tested: PM2.5 (Filterable and Condensable), Total PM (Filterable and 

Condensable), Metals, Mercury, 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 PM2.5, 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 based on the following: all 

of the facilities are operated by a single company and use the 

same fiber glass manufacturing process (as described on page 4 

above); all of the furnaces are operated with electricity and no 

natural gas; all of the furnaces use chrome refractories7

 and 

operate at temperatures in excess 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 company 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 excess of 2000°F and not the batch 

materials. 

7

 Some raw materials contain trace elements of chromium; however, hex chrome emissions from raw materials 

would be insignificant compared to those 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: PM2.5 (Filterable and Condensable), Total PM (Filterable and 

Condensable), Metals, Mercury, Hex Chrome, Hydrogen 

Fluoride, Hydrochloric Acid 

Data To Be Supplied: There are 30 electric steel shell melters with baghouses 

permitted in the industry. 14 of those furnaces are currently 

idled. New PM2.5, total PM, metals, mercury, hex chrome, 

hydrogen fluoride, and hydrochloric acid data will be collected 

from FiberTEK’s Lakeland, Florida facility (Middle and West 

Melters); Guardian’s Albion, Michigan 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 Cleburne, Texas facility (Line 91 

Melter); Johns Manville’s Willows, California facility (Line 

133); and Owens Corning’s Mount Vernon, Ohio facility 

(Furnace 1). Existing PM2.5, 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 facilities will be provided. 

Location/Lines Represented: FiberTEK – Lakeland, Florida (Middle Melter and West 

Melter); Nephi, Utah (Middle 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 Virginia (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 Melters); 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 based on the following: all 

of the melters are operated with electricity and no natural gas; 

all of the furnaces use chrome refractories8

 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 chromium; however, hex chrome emissions from raw materials 

would be insignificant compared to those 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 fabric; 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 glass 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: PM2.5, Total PM, Metals, Mercury, Hex Chrome, Hydrogen 

Fluoride, Hydrochloric Acid 

Data To Be Supplied: There are six electric steel shell melter with gas assist and 

marble feed – no batch melters permitted in the industry. 

Three of those melters are currently idle. New PM2.5, total PM, 

metals, mercury, hex chrome, hydrogen fluoride, and 

hydrochloric acid data will be collected from one of Johns 

Manville’s Waterville, Ohio facility’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 are four such lines that total six 

melters. These are unbonded lines 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 Plant 07 300X Lines (four 

lines) 

Bases For Representativeness: The Waterville, Ohio 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 electric 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, and cooling sources together into one source. 

These three sources are more often than not exhausted through one stack 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 forming, 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, and 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 Defiance, 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, Pennsylvania (M1 and M2 Lines) 

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

Line) 

 Guardian – Albion, Michigan (Line 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, FG3 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, Arizona (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 operations 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, California facility (Line 133); and 

Knauf’s Lanett, Alabama facility (621). Due to a scheduled 

 
Messrs. 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, California (100% Non-P/F); Lanett, 

Alabama (100% Non-P/F); Shelbyville, Indiana 

(Approximately 75% Non-P/F) 

Bases For Representativeness: The data collected 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, Georgia Line 106 has different control 

and thus is also being proposed for testing. 

The following company facilities do not use binders (they produce unbonded blowing wool). As 

such, no formaldehyde, phenol, and methanol test data will be provided. 

CertainTeed – Athens, Georgia (A12 and A23 Lines); 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: PM2.5 (Filterable and Condensable), Total PM (Filterable), 

Metals, Mercury, Hex Chrome, Hydrogen Fluoride, 

Hydrochloric Acid, Formaldehyde, 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 very 

 
Messrs. 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 

PM2.5, total PM, metals, mercury, hex chrome, hydrogen 

fluoride, and hydrochloric acid will be collected from Johns 

Manville’s Waterville, Ohio Plant 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 marble units (no binder)). 

Bases For Representativeness: The data collected is representative based on the following: all 

re-melt borosilicate glass marbles; all are pot & marble flame 

attenuation; and all are operated 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 sulfide and carbon monoxide data will be 

collected from Industrial Insulation Group’s Phenix City, 

Alabama facility; USG Interiors’ Walworth, Wisconsin 

facility; and Thermafiber’s Wabash, Indiana facility. Existing 

carbonyl sulfide data will be supplied 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, Wisconsin carbonyl sulfide data are 

representative for USG Interiors’ Red Wing, Minnesota 

facility; and USG Interiors’ cupolas 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 monoxide and carbonyl sulfide data will be 

collected from Isolatek’s Huntington, Indiana facility. Existing 

carbonyl sulfide and carbon monoxide 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 provided from each point source so no case for 

representativeness is made. 

Process Unit: Cupola 

Pollutants To Be Tested: PM2.5 (Filterable and Condensable), Total PM (Filterable and 

Condensable), Metals, Mercury, Hex Chrome, Hydrogen 

Fluoride, Hydrochloric Acid 

Data To Be Supplied: New PM2.5, total PM, metals, mercury, hex chrome, hydrogen 

fluoride, and hydrochloric acid data will be collected from 

Industrial Insulation Group’s Phenix City, Alabama facility (1 

Cupola); Thermafiber’s Wabash, Indiana facility (Cupola 2); 

USG Interiors’ Walworth, Wisconsin facility (1 Cupola); 

Isolatek’s Huntington, Indiana facility (Cupolas 1 and 2 – 

Common Baghouse/Combined Point Source); and Rock Wool 

Manufacturing’s Leeds, Alabama facility. New PM2.5, total 

PM, mercury, hex chrome, hydrogen 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 producing 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 Interiors, 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 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: All companies are 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 Interiors, Amerrock 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: All companies are 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 collected 

 
Messrs. Jeffrey A. Telander and William Neuffer

May 5, 2010

Page 16

 

from Thermafiber. New phenol and methanol data will be 

collected from Industrial Insulation Group. The remaining 

companies, USG Interiors, Amerrock 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 existing 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 wool fiberglass and mineral wool insulation 

manufacturing industries, requests EPA’s approval and acceptance of the proposed data 

collection plan set forth above and summarized in the enclosed tables as representative industry 

data so that we can develop a final plan and schedule for the collection of the data and other 

information responsive to the draft ICRs. 

Sincerely, 

Angus E. Crane 

Angus E. Crane 

Executive Vice President, General Counsel 

Enclosures