PRODUCING PRODUCTS WITH THE ENVIRONMENT IN MIND...



### June 30,2011 Sent Via Email

Ms Madeline

Barch Officeof Policy Regulatory

Management

Division U.S. Environmental

Protection

Asencv Washington,

D.C .20460 Re: Mineral

Wool SBAR Panel

- Proposed

Environmental

Regulation

Changes DearMs. 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 theAmerrock

plant located

in Nolanville,

Texas. I am also

doing this to provide some of the history and additional information

regarding

the plant andthe plant operations and the severe

economic

conditions

we have been andare currently

facing. I have been

involvedwith the mineralwool 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

hadtwo mineralwool plants. both of which are now shutdown 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 waswith Thermafiber

the company

shut down two of the plants. With flnancing

help from Thermafiber, some personal funds,and some

significant

bank financingI was able to acquire

the otherplant located in Nolanville,

Texas tn2006, which now operates as AmerrockProducts,

LP. One of the main reasons I wanted to acquire

the plant in Texas

was the fact that I know from many years

in the industry

that mineralwool 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 thatthe industry

sponsored

throughNAIMA 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) 5t6-9164 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 plantproduces only loose

fiber so there

areno 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 Amerrockplant is the only plant in the United States producing

looserock wool for the residential

insulation

market. When I acquired

the plant in January

2006 the home construction market was robust

andthe plant operated

5-6 daysper week.At the time I acquired the plant I anticipated

that there

would be a downturnin housing starts dueto the long upward cyclethe market had experienced.

I factored

in a 20% downturn

where in actuality

we haveexperienced 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 andthe company credit line hasbeen

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 merelyacademic because if new regulations

require a capital investment

of any magnitude

the company

will have

to closeresulting

in the lossof 33 jobs and

the possibility

thatthere

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 haveon the mineral wool industry

andthis company

in particular. Sincerelv: ,(-- Lee Hou Additional

copies sent Cristofaro;

Ms. Susanvia 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