44 Canal Center Plaza ▪ Suite 310 ▪ Alexandria, Virginia 22314 ▪ Tel: (703) 684-0084 ▪ Fax: (703) 684-0427

VIA E-MAIL

April 13, 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: Representativeness of Wool Fiberglass and Mineral Wool Data

Dear Messrs. Telander and Neuffer:

INTRODUCTION

In the draft Information Collection Requests (“ICRs”) for both the wool fiberglass and mineral 

wool insulation manufacturing industries’ residual risk review, the Environmental Protection 

Agency (“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.

This letter sets forth the wool fiberglass and mineral wool insulation manufacturing industries’ 

proposal to provide both existing test data and new test data to respond to the draft ICR. 

Specifically this letter provides the details of the existing data that will be used to respond to the 

ICR and the bases for our position that such test data should constitute representative industry 

data. This letter also identifies where we propose that new testing be conducted and the bases for 

our position that such test data for the selected point sources should constitute representative 

industry data.
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 2

As we stated in our March 27, 2010 letter concerning the use of alternative test methods for 

responding to the draft ICRs, EPA’s acceptance of such alternative test methods will enable us to 

provide EPA the emissions data it needs while both expediting the information collection process 

and leveraging the use of existing emissions data. The industry recommended these alternative 

test methods not only because it has extensive data collected by these alternative methods that 

are relevant to EPA’s requests, but also because every company is operating at reduced 

production due to the significant economic downturn in the building industry. New data could 

not be collected from the many production lines that are not in operation, even though they are 

currently permitted. Use of existing data will be essential for providing EPA with the requisite 

data for all point sources.

Moreover, we appreciate EPA’s willingness to accept as responsive the test data generated by

many of the alternative test methods we identified. However, the use of such data necessarily 

requires EPA’s acceptance of at least some, if not all, such data that was generated pursuant to 

tests run for the length of time prescribed by the applicable test methods, not for some longer 

period of time. For example, one hour should be more than sufficient for all the organics to be 

measured. The majority of these test methods have a one-hour length; detection limits are set to 

work within the designated timeframes. If the detected amount of the pollutant is one or two 

orders of magnitude above the detection limit, extending the time and reducing the detection 

limit does not provide any additional substantive or meaningful information because the 

pollutant in question has already been detected and measured. We understand that it is our 

responsibility to make sure sampling times are long enough to obtain results that are greater than 

minimum detection limits (unless the EPA-recommended sampling times and volumes are 

implemented where no-detect results will be accepted).

By this letter, the North American Insulation Manufacturers Association (“NAIMA”) requests 

EPA’s approval of the selection of data below as representative industry data so that we can 

prepare a plan and schedule for the collection of the data and other information responsive to 

both draft ICRs.
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 3

DESCRIPTION OF GLASS AND MINERAL WOOL MANUFACTURING PROCESSES

Fiber glass insulation starts with raw materials such as sand, soda, and lime. 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 refractorylined furnaces, or in some cases, special large pots. The heat from the furnace converts these raw 

materials into a homogenous molten liquid.1 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 with many bubbles. 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.

EXISTING AND REPRESENTATIVE DATA

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.

 

1

F.J. Terence Maloney, Glass in the Modern World, at 74 (New York: Doubleday, 1968).
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 4

Wool Fiberglass

Furnaces

Process Unit: Oxy Fuel

Pollutants Testing Requested: PM2.5 (Filterable and Condensable), Total PM (Filterable), 

Metal HAPs, Hex Chrome, HF, HC1

Data To Be Supplied: There are 12 oxy fuel furnaces permitted in the industry. 

PM2.5, total PM, metal HAPs, hex chrome, and hydrogen 

fluoride data will be collected from Owens Corning’s Kansas 

City, Kansas, facility (K5 Line). As described below, the data 

collected at this plant will be representative of all 12 oxy fuel 

furnaces. It is critical that newly-collected data be accepted as 

representative data because at least 6 of the 12 oxy fuel 

furnaces are idle. A survey of fiber glass companies indicates 

that there would be no possible source for HC1.

Location/Lines Represented: Knauf – Lanett, Alabama (621 Furnace (with DEP) and 622 

Furnace (with DEP))

CertainTeed – Athens, Georgia (A2 Furnace); Chowchilla, 

California (A1 Furnace); Kansas City, Kansas (K1 Furnace and 

K2 Furnace); Mountain Top, Pennsylvania (M1 Furnace and 

M2 Furnace)

Johns Manville – Cleburne, Texas (1902 Marble Furnace (has 

Scrubber and ESP)); Defiance, Ohio (2601 & 2603 Marble 

Furnaces (have common ESP and Baghouse in series and do 

not have oxy firing))

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 (VI Furnace (with DEP)); 

Newark, Ohio (F6 Furnace (with Electric Boost and 

Baghouse), A3 Furnace (with DEP))

Bases For Representativeness: The data collected would be representative to the extent the 

method of operation is the same, all oxy fuel furnaces are 

powered by natural gas, all of the oxy fuel furnaces use a dry 

electrostatic precipitator or similar control, all of the oxy fuel 

furnaces are making borosilicate glass using essentially the 

same raw materials, all of the oxy fuel furnaces are the same 

class size of furnaces, and the Kansas City plant is at the 

midpoint of the range.
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 5

Process Unit: Cold Top Electric – With Baghouse

Pollutants Testing Requested: PM2.5 (Filterable and Condensable), Total PM (Filterable), 

Metal HAPs, Hex Chrome, HF, HC1

Data To Be Supplied: Heavy metal and hex chrome data will be collected from 

Knauf’s Shasta Lake, California facility using EPA Method 29 

and the accepted test method for hex chrome, and this data will 

be representative of all cold top furnaces with baghouses. 

PM2.5 and Total PM will be provided from Knauf’s Shasta 

Lake, California, facility’s existing data. This data will be 

representative of all cold top furnaces with baghouses, as 

described below. A survey of fiber glass companies indicates 

that there appears to be no possible source for HF or HC1 from 

this group of facilities.

Location/Lines Represented: Knauf – Shelbyville, Indiana (611 Furnace and 602 Furnace); 

Shasta Lake, California (641 Furnace)

CertainTeed – Athens, Georgia (A1 Furnace)

FiberTEK – Lakeland, Florida (Middle Melter and West 

Melter); Nephi, Utah (Middle Melter and West Melter)

Johns Manville – Richmond, Indiana (Melter); Defiance, Ohio 

(3 Melters, Lines 801-806)

Bases For Representativeness: The data collected would be representative to the extent the 

method of operation is the same, all of the furnaces are 

operated with electricity, all of the furnaces are the same brand, 

all of the furnaces are making borosilicate glass using 

essentially the same material, and all of the furnaces have a 

baghouse.

Process Unit: Cold Top Electric – Without Baghouse

Pollutants Testing Requested: PM2.5 (Filterable and Condensable), Total PM (Filterable), 

Metal HAPs, Hex Chrome, HF, HC1

Data To Be Supplied: Heavy metal, hex chrome, and hydrogen fluoride data will be 

collected from Owens Corning’s Kansas City, Kansas, facility

(70 furnace) using EPA Method 29 and the accepted test 

method for hex chrome, and that data will be representative of 

all cold top furnaces without baghouses. New emissions tests

for PM2.5 and Total PM will also be conducted. This data will 

be representative of all cold top furnaces without baghouses, as 

described below. A survey of fiber glass companies indicates 

that there appears to be no possible source for HC1.

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 
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 6

Furnace, V3 Furnace (With Batch Wetting)); Santa Clara,

California (M and O Furnaces (With Batch Wetting))

Bases For Representativeness: The data collected would be representative to the extent the 

method of operation is the same, all of the furnaces are 

operated with electricity, all of the furnaces are the same basic 

design, all of the furnaces are making borosilicate glass using 

essentially the same material, all furnaces are operated without 

a baghouse, and the capacity is at the midpoint of the range.

Process Unit: Electric Steel Shell Melter – With Baghouse

Pollutants Testing Requested: PM2.5 (Filterable and Condensable), Total PM (Filterable), 

Metal HAPs, Hex Chrome, HF, HC1

Data To Be Supplied: Existing PM2.5, total PM, and heavy metal data from Johns 

Manville’s Willows, California, facility will be used as 

representative data for all electric steel shell melters in the 

industry. Data for hex chrome will be collected at Johns 

Manville’s Willows, California, facility and will be used 

representative data for all electric steel shell melters in the 

industry.

Location/Lines Represented: 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 (Two Furnaces); Salt Lake 

City, Utah (Two Furnaces); Mount Vernon, Ohio (Three 

Furnaces)

Bases For Representativeness: The data collected would be representative to the extent the 

method of operation is the same, all of the furnaces are 

operated with electricity, all of the furnaces are steel shell pottype containers with refractory liners, all of the furnaces use a 

baghouse, and all of the furnaces are making borosilicate glass 

using essentially the same raw materials.
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 7

Process Unit: Pot & Marble Flame Attenuated

Pollutants Testing Requested: PM2.5 (Filterable and Condensable), Total PM (Filterable), 

Metal HAPs, Hex Chrome, HF, HC1

Data To Be Supplied: Johns Manville is the only member in NAIMA with a Pot & 

Marble melting process. They melt glass marbles in very small 

pots using small gas burners (not electric). It is a completely 

different process than rotary and was subcategorized in the 

original MACT standard. Johns Manville will provide heavy 

metal, hex chrome, PM2.5 and Total PM data from existing 

data. A survey of fiber glass companies indicates that there 

would be no possible source for HF or HC1 from this group of 

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 (pot and marble lines (no binder)). 

Bases For Representativeness: The data collected would be representative to the extent the 

method of operation is the same, all furnaces are making 

borosilicate glass using essentially the same material, and all 

are pot & marble flame attenuation. 

Forming, Curing, and Cooling

For purposes of identifying representative data responsive to EPA’s request, NAIMA has 

combined the forming, curing, and cooling sources together into one source. These three sources 

are more often than not exhausted through one stack or 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.

Process Unit: Forming, Curing, and Cooling

Pollutants Testing Requested: Formaldehyde, Phenol, Methanol

Data To Be Supplied: All plants with bonded lines using formaldehyde will use 

existing data from Owens Corning’s Kansas City, Kansas, 

facility for formaldehyde, phenol, and methanol with 

appropriate factors to account for different control devices, 

LOI, and/or pounds per ton of melt, as applicable, because this 

facility’s forming, curing and cooling sources have no voc 

controls. Formaldehyde, phenol, and methanol data are from 

testing done in accordance with Method 316 for formaldehyde, 

Method 308 for methanol, and Lab 8, BAAQMD Method ST16 for phenol. No formaldehyde, phenol, or methanol data will 
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 8

be supplied for plants with bonded lines using a nonPhenol/Formaldehyde (“P/F”) binder. 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 by EPA.

Location/Lines Represented: The following company facilities that use phenolic/

formaldehyde binders for which data from Owens Corning’s 

Kansas City facility will serve as representative data on 

formaldehyde, phenol, and methanol are:

CertainTeed – Athens, Georgia (All 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, L92, L93 Lines); 

Defiance, Ohio (Lines 89, 801-806, 807, 81-88, 21-25)

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)

The following member company facilities that do not use 

phenolic/formaldehyde binders or use no binders (unbonded 

lines) for which no such test data will be provided are:

CertainTeed – Athens, Georgia (A12 and A23 Lines); 

Chowchilla, California (C12 Line); Kansas City, Kansas (K11 

and K21 Lines)

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

Line)

Guardian – Albion, Michigan (Lines 2 and 4); Mineral Wells, 

Mississippi (Line 2)

Johns Manville – Penbryn, New Jersey (Line 58); Richmond, 

Indiana (Lines 2 and 3); Waterville, Ohio (Pot/Marble 

Production); Winder, Georgia (Lines 105 and 106); 

McPherson, Kansas (Lines 122 and 123); Willows, California 

(Lines 132 and 133)
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 9

Knauf – Shasta Lake, California (100% Non-P/F); Lanett, 

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

(Approximately 75% Non-P/F)

Owens Corning – Kansas City, Kansas (U3 Line); Salt Lake 

City, Utah (SL2 Line); Mount Vernon, Ohio (3 Unbonded 

Lines)

Bases For Representativeness: The data collected being provided would be representative of 

forming, curing, and cooling sources at facilities suing 

formaldehyde/phenolic binder because the method of 

manufacture is the same, of the all products are being formed 

from borosilicate glass using essentially the same raw 

materials, all of the products are bonded, all of the binders are 

phenolic, and essentially the same process controls are used.

Mineral Wool

Process Unit: Cupola – With Baghouse and Incinerator

Pollutants Testing Requested: Carbon Monoxide, Carbonyl Sulfide

Data To Be Supplied: Existing carbonyl sulfide and carbon monoxide data from a 

USG Interiors facility will be used as representative data for all 

mineral wool cupolas with baghouses and incinerators as 

described below. The carbonyl sulfide data has been collected 

with EPA Method 10, and the carbon monoxide data has been 

collected with EPA Method 320.

Location/Lines Represented: Based on the bases/assumptions identified below, this data is 

representative of all lines at the following plants and locations:

Industrial Insulation Group – Phenix City, Alabama

Thermafiber – Wabash, Indiana (Bonded #2, Granulated #4)

USG Interiors – Red Wing, Minnesota; Walworth, Wisconsin

Bases For Representativeness: This data is representative to the extent each cupola is cokefired, melting almost identical raw material mix, producing 

rock and slag wool products, and using controls of an 

incinerator or baghouse.

Process Unit: Cupola – With Baghouse Only

Pollutants Testing Requested: Carbon Monoxide, Carbonyl Sulfide

Data To Be Supplied: Existing carbonyl sulfide and carbon monoxide data from the 

Amerrock Products, Nolanville, Texas facility will be used as 

representative data for all mineral wool cupolas with baghouses 

and no incinerators. The carbonyl sulfide data has been 

collected with EPA Method 15, and the carbon monoxide data 

has been collected with EPA Method 10. 
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 10

Location/Lines Represented: Based on the bases/assumptions identified below, this data is 

representative of all lines at the following plants and locations:

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: This data is representative to the extent each cupola is cokefired, melting almost identical raw material mix, producing 

rock and slag wool products, and using controls of a baghouse.

Process Unit: Cupola

Pollutants Testing Requested: PM 2.5 (Filterable and Condensable), Total PM (Filterable), 

Metal HAPs, Hex Chrome, HF, HC1

Data To Be Supplied: Existing metal HAPs data from a USG Interiors facility will be 

used as representative data for the entire industry, as described 

below. The data has been collected pursuant to EPA Method 

29. Specific data on hexavalent chromium, mercury, and HF 

and HC1 need not be provided to EPA. Hex Chrome is 

identified in the wool fiber glass industry because glass 

furnaces are lined with chrome refractories that contain 

hexavalent chromium. Mineral wool companies do not use 

chrome refractories to line their cupolas. To the extent that hex 

chrome may appear in raw materials, NAIMA will provide data 

for the industry. A survey of mineral wool companies 

indicates that there would be only a limited possibility for a 

source for HF emissions and apparently no possible basis for 

HC1 emissions. PM2.5 (filterable and condensable) and Total 

PM filterable will have to be collected from new emissions 

testing. This data will be collected pursuant to EPA Method 27 

or 28 at one of the USG Interiors facilities. The data collected 

from USG Interiors will be used as representative data for the 

entire mineral wool industry.

Location/Lines Represented: Based on the bases/assumptions identified below, this data is 

representative of all lines at the following plants and locations:

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: This data is representative to the extent that all of the cupolas

are coke-fired, melting almost identical raw material mix, 
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 11

producing rock and slag wool products, and using controls of 

an incinerator or baghouse.

Process Unit: Collection Operation

Pollutants Testing Requested: Formaldehyde, Phenol, Methanol

Data To Be Supplied: Existing formaldehyde data will be supplied from Thermafiber, 

Industrial Insulation Group, and Rock Wool Manufacturing. 

New methanol and phenol data will be collected from 

Thermafiber pursuant to one the EPA approved methods (EPA 

Method 318 or 308 for methanol and EPA Method 318 or 

Method 8270D for phenol) and be used as representative for all 

three companies as described below. The remaining 

companies, USG Interiors, Amerrock Products, and Isolatek 

International, operate unbonded lines, and, therefore, use no 

binder is applied 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: As noted above, the data supplied will be for existing or 

representative data for:

Industrial Insulation Group – Phenix City, Alabama

Thermafiber (Bonded #2) – Wabash, Indiana

Rock Wool Manufacturing (Bonded Line #2) – Leeds, 

Alabama

Bases For Representativeness: This data is representative to the extent that all of the cupolas 

are coke-fired, melting almost identical raw material mix, 

producing rock and slag wool products, and using controls of 

an incinerator or baghouse.

Process Unit: Curing Oven

Pollutants Testing Requested: Formaldehyde, Phenol, Methanol

Data To Be Supplied: Existing formaldehyde data will be supplied from Thermafiber, 

Industrial Insulation Group, and Rock Wool Manufacturing. 

New methanol and phenol data will be collected from 

Thermafiber pursuant to one the EPA approved methods (EPA 

Method 318 or 308 for methanol and EPA Method 318 or 

Method 8270D for phenol) and be used as representative for all 

three companies as described below. The remaining 

companies, USG Interiors, Amerrock Products, and Isolatek 

International, operate unbonded lines, and, therefore, no binder 

is applied during the manufacturing of mineral wool. In
Messrs. Jeffrey A. Telander and William Neuffer

April 13, 2010

Page 12

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: As noted above, the data supplied will be for existing or 

representative data for:

Industrial Insulation Group – Phenix City, Alabama

Thermafiber (Bonded #2) – Wabash, Indiana

Rock Wool Manufacturing (Bonded Line #2) – Leeds, 

Alabama

Bases For Representativeness: This data is representative to the extent that each cupola is 

coke-fired, melting almost identical raw material mix, 

producing rock and slag wool products, and using controls of 

an incinerator or baghouse.

Process Unit: Cooling Operation

Pollutants Testing Requested: Formaldehyde, Phenol, Methanol

Data To Be Supplied: New formaldehyde, methanol, and phenol data will be 

collected from Thermafiber pursuant to one of the EPA 

approved methods (EPA Method 318 or 308 for methanol and 

EPA Method 318 or Method 8270D for phenol) and be used as 

representative for all three companies as described below. The 

remaining companies, USG Interiors, Amerrock Products, and 

Isolatek International, operate unbonded lines, and, therefore, 

no binder is applied 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: As noted above, the data supplied will be for existing or 

representative data for:

Industrial Insulation Group – Phenix City, Alabama

Thermafiber (Bonded #2) – Wabash, Indiana

Rock Wool Manufacturing (Bonded Line #2) – Leeds, 

Alabama

Bases For Representativeness: This data is representative to the extent that all of the cupolas 

are coke-fired, melting almost identical raw material mix, 

producing rock and slag wool products, and using controls of 

an incinerator or baghouse.

Sincerely,

Angus E. Crane

Angus E. Crane, Executive Vice President, General Counsel