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

- 0084 ▪ Fax: (703) 684

- 0427

**VIA E**
**- MAIL**  April 13 , 2010

Mr. Jeff rey 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 P ark, 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: IN TRODUCTION
Inthe 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 th e “Summary o f 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 IC R. Specificall y 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

b ecause it has extensive data collected by these alternative methods that are relevant to EPA’s requests, but also because every c ompany is operating at reduced production due to the signifi cant economic downturn in the building industry

. N ew data could not be collected from the many production lines that are not in operation, even though they are currentl y permitted. U se 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 o f the alternative test methods we identified. H owever, the use of such data necessaril y requires EPA’s acceptance of at leas t 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. F or example, one hour should be more than sufficient for all the organics to be me asured. The majority of these test methods have a one - hour length; detection limits are set to work within the designated timeframes. I f 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 Associ ation (“NA IMA”) 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 MI NERAL WOOLMANUFACTURI NG PROCESSES

Fiber glass insulation starts with raw materials such as sand, soda, and lime. B roken or recycled glass, known as cullet, is added to the mixture of raw materials to accelerate the melting process. These ingredi ents are mixed in the batch house and then transferred to and melted in refractory

lined 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 gl ass and for ming it into a fiber consists of two distinct stages. The first involves the chemical reaction between the ingredients and results in a sticky

m olten mass with many

bubbles. Inthe second stage, the glass is cooled until it has the required viscosity f or 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.
EXI STI NG 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 newl y 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: PM 2.5 (Filterable and Condensable), Total PM (Filterable), Metal HAPs, Hex Chrome, HF, HC1 Data To Be Supplied: There are 1 2 oxy f uel furnaces permitted in the industry

. PM 2.5 , total PM, m etal 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 1 2 oxy f uel furnaces. Iti s critical that newly

- collected data be accepted as representative data because at least 6 of the 12 oxy f uel furnaces are idle. A survey o f fiber glass companies indicates that there would be no possible source for HC1. Location/Lines Represented: **Knauf**

– Lan ett, 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 (h as Scrubber and ESP)); Defiance, Ohio (2601 & 2603 Marble Furnace s (h ave 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 f uel furnaces are powered by

natural gas, al l of the oxy f uel furnaces use a dry electrostatic precipitator or similar control , all of the oxy f uel furnaces are making borosilicate glass using essentially the same raw materials, all of the oxy f uel furnaces are the same class size of furnaces, and the Kansas City p lant 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: PM 2.5 (Filterable and Condensable), Total PM (Filterable), Metal HAPs, Hex Chrome, HF, HC1 Data To Be Supplied: Heavy met al and hex chrome data will be collected from Knauf’s Shasta Lake, California facility u sing EPA Method 29 and the accepted test method for hex chrome, and this data will be representative of all cold top furnaces with baghouses. PM 2.5 and Total PM will b e 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. Asurvey o f 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**

– Shelby ville, In diana (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 o f 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: PM 2.5 (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 fro m 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 test s for PM 2.5 and Total PM will also be conducted. This data will be representative of all cold top furnaces without baghouses, as described below. Asurvey o f 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 (V2Messrs . 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: PM 2.5 (Filterable and Condensable), Total PM (Filterable), Metal HAPs, Hex Chrome, HF, HC1 Data To Be Supplied: Existing PM 2.5 , total PM , and heavy metal data from Johns Manville’s Willows, California, facility will be u sed as representative data for all electric steel shell melters in the industry

. D ata 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 indus try

. 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 (L ine 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 Furnace s ); Salt Lake City, Utah ( Two Furnace s ); Mount Vernon, Ohio ( Three Furnace s ) 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 pot

ty pe containers with refractory l iners , all of the furnaces use a baghouse, and all of the furnaces are making borosilicate glass using essentiall y 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: PM 2.5 (Filterable and Condensable), Total PM (Filterable), Metal HAPs, Hex Chrome, HF, HC1 Data To Be Supplied: J ohns 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 completel y 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. Asurvey

o f fiber gl ass 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 respon sive 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 separatel y 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 anal ys is for each source.

Process Unit: Forming , Curing, and Cooling Pollutants Testing Requested: Formaldehyd e, 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 f or formaldehyde, phenol, and methanol with appropriate factors to account for different control devices , LO I, and/or pounds per ton of melt, as applicable, because this facility ’s forming, curing and cooling sources have no voc controls. Formaldehyd e, phenol, and m ethanol data are from testing done in accordance with Method 316 for formaldehyde, Method 308 for methanol, and Lab 8, BAAQMD Method ST

16 for phenol. No formaldehyde, phenol, or methanol data willMessrs . Jeffrey A. Telander and William Neuffer April 13, 2010 Page 8

be supplied for plants with bonded lines using a non Phenol/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 f acilities that use phenolic/ formaldehyde binders for which data from Owens Corning’s Kansas City

f acility w ill serve as representative data on formaldehyde, phenol, and methanol are: **Cer tainTeed** 

– 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, L 93 Lines); Defiance, Ohio (Lines 89, 801

- 806, 807 , 81

- 88, 21

- 25) **Knauf**

– Shelby

ville, 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/formaldehyd e 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 (U L Line); Nephi, Utah (UL Line) **Guardian**

– Albion, Michi gan (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); Shelby ville, 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) Base s F or 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 essentiall y 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 carbonylsulfide 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 1 0 , and the carbon monoxide data has been collected with EPA Method 3 20

. Location/Lines Represented: Based on the bases/assumpti ons 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 coke

fired, 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 carbonylsulfide 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 carbonylsulfide data has been collected with EPA Method 15 , and the carbon monoxide data has been collected with EPA Method 1 0

.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: **Am errock Products** 

– Nolanville, Texas **Isolatek International** 

– Huntington, Indiana (Cupola #1, Cupola #2

– common baghouse/combined point source) **R ock**  **Wool Manufacturing** 

– Leeds, Alabama (1 Cupola, Line #2) Bases For Representativeness: This data is representative to the extent each cupola is coke

fired, 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 b ecause glass furnaces are lined with chrome refractories that contain hexavalent chromium. M ineral 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 o f mineral wool companies indicates that there would be only a limited possib i l ity for a source for HF emissions and apparentl y no possible basis f or 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. Th e data colle cted 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: **Am errock 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 cupola s 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: Formaldehyd e, Phenol, Methanol Data To Be Supplied: Existing formaldehyde d ata will be supplied f rom 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 f

or methanol and EPA M ethod 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 Is olatek 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 **Thermafi ber**  (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 cupola s are coke

- fired, melting almost identical raw material mix, producin g rock and slag wool products, and using controls of an incinerator or baghouse.

Process Unit: Curing Oven Pollutants Testing Requested: Formaldehyd e, Phenol, Methanol Data To Be Supplied: Existing formaldehyde data will be supplied from Thermafiber, Ind ustrial 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 f

or methanol and EPA M ethod 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 Is olatek International, operate unbonded lines, and, therefore, no binder is applied during the manufacturing of mineral wool. InMessrs . 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: C ooling Operation Pollutants Testing Requested: Formaldehyd e, Phenol, Methanol Data To Be Supplied: New formaldehyd e, 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 cupola s are coke

- fired, melting almost identical raw material mix, producing rock and slag wool products, and using controls of an incinerator or baghou se. Sincerel y, **Angus E. Crane** Angus E. Crane , Executive Vice President, General Counsel