VIA E

- MAIL

June 18, 2010

Mr. Peter Tsirigotis

Director, Sector Policies and Programs Division

Office of Air Quality Planning and Standards

Mail Drop D205

- 01

U.S. Environmental Protection Agency

109 TW Alexander Drive

Research Triangle Park, NC 27711

R E : USG Interiors Inc. Testing and ICR Response Schedule

Dea r Mr. Tsirigotis :

USG Interiors Inc. (“ USG Interiors ”) is providing this letter in response to EPA’s request for a

formal commitment from USG Interiors to provide data, perform testing to collec t new data, and

collect and submit existing test data for the purposes of quantifying emissions of hazardous air

pollutants and for assessing potential impacts to public health due to these emissions. Consistent

with the North American Insulation Manufact urers Association (“NAIMA”) and its members’

discussion with EPA staff and their specific requests, USG Interiors , in conjunction with

NAIMA and other industry companies, plans to conduct the following testing and collect the

following existing data:

Mine ral 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 at USG Interiors’ Walworth, Wisconsin facility.

Existing carbonyl sulfide and carbon monoxide data will be

provided from USG Interiors’ Red Wing, Minnesota facility.

Location/Lines Represented: USG Interiors

– Red Wing, Minnesota; Walworth, Wisconsin

Process Unit: Cupola

Pollutants To Be Tested: PM 2.5 (Filterable and Condensable), Total PM (Filterable and

Condensable), Metals, Mercury, 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 data wil l be collected at USG

Interiors’ Walworth, Wisconsin and Red Wing, Minnesota

facilities (3 Cupolas). Existing metals ( antimony, arsenic,

beryllium, cadmium, lead, manganese, nickel and selenium )

data will be provided from USG Interiors’ Red Wing,

Minnesot a facility.Mr

. Peter Tsirigotis

June 18 , 2010

Page 2

Location/Lines Represented: USG Interiors

– Red Wing, Minnesota; Walworth, Wisconsin

Process Unit: Collection Operation

Pollutants To Be Tested: Formaldehyde, Phenol, Methanol

Data To Be Supplied: USG Interiors operate s unbonded lines and, th erefore, use s no

binder during the manufacturing of mineral wool. N o data will

be collected for unbonded lines as agreed upon with EPA.

Process Unit: Curing Oven

Pollutants To Be Tested: Formaldehyde, Phenol, Methanol

Data To Be Supplied: USG Interiors operate s unbonded lines and, therefore, use s no

binder during the manufacturing of mineral wool. N o data will

be collected for unbonded lines as agreed upon with EPA.

Process Unit: Cooling Operation

Pollutants To Be Tested: Formaldehyde, Phenol, Metha nol

Data To Be Supplied: USG Interiors operate s unbonded lines and, therefore, use s no

binder during the manufacturing of mineral wool. N o data will

be collected for unbonded lines as agreed upon with EPA.

TESTING SCHEDULE

Pace Analytical Services, I nc. (“ Pace ”) , an environmental consulting and testing firm, will

supervise the collection of new emissions data as described above on behalf of USG Interiors

, Inc. at the Red Wing Minnesota and Walworth Wisconsin Plan ts

.

Pace will commence testing in Aug ust 2010, and testing will be completed by November 2010.

BT Environmental Consulting, Inc. (“BTEC”) will submit this new test data on behalf of USG

Interiors through the EPA Electronic Reporting Tool on a rolling basis within 60

- 90 days of

completing fiel d work and expects to complete the input of all data by January 2011. Please find

attached BTEC’s Emissions Test Program Summary, Scope of Work, and a description of

Quality Assurances. It should be noted that USG plans to test CO using EPA Method 10 and

COS using EPA Method 320, both approved alternatives which have been successfully utilized

at USG Interiors in the past.

NAIMA on behalf of USG will submit to EPA all existing data described above in June and July

2010. USG will submit completed Informa tion Collection Requests for its two facilities by the

end of August 2010.Mr

. Peter Tsirigotis

June 18 , 2010

Page 3

This letter outlines USG Interiors’ good faith attempt to accommodate its understanding of

EPA’s data and timing needs. USG Interiors Inc. commit s to complete the testing and ende avor s

to do so on the schedule outlined above.

Should you have any questions or require additional information, please contact me at 312

- 436

-

5587.

Sincerely,

John Bolden

Environmental Services Manager, USG

Enclosures

cc: Mr. Jeffrey A. Telander

Sect or 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 Progra ms 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