PRODUCING PRODUCTS WITH THE ENVIRONMENT IN MIND...

June 30,2011

Sent Via Email

Ms Madeline Barch

Office of Policy

Regulatory Management Division

U.S. Environmental Protection Asencv

Washington, D.C .20460

Re: Mineral Wool SBAR Panel - Proposed Environmental Regulation Changes

Dear Ms. Barch:

I am writing this letter to make additional comments to those I made in the June 15,201 1 SBAR

Panel meeting regarding the potential effects the proposed changes in environmental regulations

will have on the Amerrock plant located in Nolanville, Texas. I am also doing this to provide

some of the history and additional information regarding the plant and the plant operations and

the severe economic conditions we have been and are currently facing.

I have been involved with the mineral wool industry for over 30 years. During my career I have

worked for several of the mineral wool companies. While I was President of Sloss Industries,

the company had two mineral wool plants. both of which are now shut down and decommissioned. While President of Thermafiber, the company operated four mineral wool plants

and owned another that had been shut down before I joined the company.While I was with

Thermafiber the company shut down two of the plants. With flnancing help from Thermafiber,

some personal funds, and some significant bank financing I was able to acquire the other plant

located in Nolanville, Texas tn2006, which now operates as Amerrock Products, LP.

One of the main reasons Iwanted to acquire the plant in Texas was the fact that I know from

many years in the industry that mineral wool is a unique product with a combination of superior

thermal, acoustical, and fire proofing qualities that are not available from any other insulation

material. Also, having been involved in NAIMA I am very aware of the significant health studies

that the industry sponsored through NAIMA over many years to ensure that the product does not

impose adverse health effects for plant workers or those installing the products.

Amerrock Products

440 Jackrabbit Rd.

Nolanville. l'X 76559

(205) 5 t6-9164

lhou lditch(@amerrock. com

\\'ww. amerrock.com
Another rason r rert :::?:::#':::;:,::;{:{:'ffif#ii:W:ff#^Jffli; ,n. tsseMACr had

been promulgated and knowing that the plant operations are efficient, the plant performs stack

testing every year, the plant has an emission stack that is 195 feet high, and the plant produces

only loose fiber so there are no binders involved, I believed that the residual risk review would

result with a finding of minimal risk and no additional controls would be necessary.

The Amerrock plant is the only plant in the United States producing loose rock wool for the

residential insulation market. When I acquired the plant in January 2006 the home construction

market was robust and the plant operated 5-6 days per week. At the time I acquired the plant I

anticipated that there would be a downturn in housing starts due to the long upward cycle the

market had experienced. I factored in a 20% downturn where in actuality we have experienced

an almostT0% downturn. The plant has operated at a loss for 3 Yzyears with the loss in 2010

exceeding $ i million. The company has been placed in the special assets division of the bank

carrying the note and the company credit line has been frozen leaving the company with no

ability to borrow any funds.

And as I mentioned in my comments at the SBAR meeting, if an incinerator were required there

is not a natural gas line in the vicinity of the pant and I don't know that there are other viable

options for incineration. In actuality this is merely academic because if new regulations require a

capital investment of any magnitude the company will have to close resulting in the loss of 33

jobs and the possibility that there will no longer be an insulation product that brings to the

market the superior attributes of rock wool.

I respectfully plead that you consider the impact that new regulations will have on the mineral

wool industry and this company in particular.

Sincerelv:

,(--

Lee Hou

Additional copies sent

Cristofaro; Ms. Susan

via email

Fairchild

to: Mr. David Rostker; Ms. Cortney Higgins; Mr. Alex

Amerrock Products

440 .lackrabbit Rd.

Nolanville. l'X 76559

(20s) s t6-9t64

lhoulditch@amerrock. co m

www.amerrock.com