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

RE: USG Interiors Inc. Testing and ICR Response Schedule

Dear 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 collect 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 Manufacturers 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:

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 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: 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 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, 

Minnesota 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 operates unbonded lines and, therefore, uses no 

binder during the manufacturing of mineral wool. No 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 operates unbonded lines and, therefore, uses no 

binder during the manufacturing of mineral wool. No data will 

be collected for unbonded lines as agreed upon with EPA. 

Process Unit: Cooling Operation

Pollutants To Be Tested: Formaldehyde, Phenol, Methanol

Data To Be Supplied: USG Interiors operates unbonded lines and, therefore, uses no 

binder during the manufacturing of mineral wool. No data will 

be collected for unbonded lines as agreed upon with EPA. 

TESTING SCHEDULE

Pace Analytical Services, Inc. (“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 Plants. 

Pace will commence testing in August 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 field 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 Information 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. commits to complete the testing and endeavors

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

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