VIA E-MAIL

June 16,2010
Mr. Peter

Tsirigotis Director,

Sector Policies and Programs

Division Office of Air Quality Planningand Standards Mail DropD205-01 U.S. Environmental

Protection

Agency 109 TW Alexander

Drive Research

Triangle

Park, NC 27711 RE: Amerrock

Products

LP Testing

and ICR Response

Schedule DearMr. Tsirigotis: Amerrock Products

LP ("Amerrock") is providing this letter in response to EPA's request

for a formal commitment from Amerrock 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

andfor assessing

potential

impacts to public health

dueto these

emissions.

Consistent with the North American Insulation Manufacturers

Association

("NAIMA") and its members' discussion

with EPA staff and their specific requests,

Amerrock,in conjunction with NAIMA and other industry

companies,

plans to conduct

the following testing

and collectthe following existing data: Mineral Wool Process Unit: Cupola - With Baghouse

Only Pollutants

To Be Tested: Carbon Monoxide,

Carbonyl

Sulfide Data To Be Supplied: Existing carbonyl sulfide and carbon monoxide data will be provided

from Amenock's Nolanville, Texas facility. LocationJLinesRepresented: Amerrock-Nolanville,Texas
Process Unit: Cupola Pollutants

To Be Tested: PMz s (Filterable

and Condensable),

Total PM (Filterable

and Condensable),

Metals, Mercury, Hex Chrome, Hydrogen Fluoride,

Hydrochloric

Acid Data To Be Supplied: Amerrock will rely upon representative data from other sources. LocationlLinesRepresented: Amerrock-Nolanville,Texas
Process Unit: Collection Operation Pollutants

To Be Tested: Formaldehyde, Phenol, MethanolMr. Peter Tsirigotis J:une i6r2010 Page2
Data To Be Supplied:

Process Unit: Pollutants

To Be Tested: Data To Be Supplied:

Process Unit: Pollutants

To Be Tested: Data To Be Supplied: Amerrock operates unbonded lines and, therefore, uses no binder during the manufacturing of mineral wool. No data will be collected

for unbonded

lines as asreed

uoon with EPA. CuringOven Formaldehyde,

Phenol, Methanol Amerrock operates

unbonded lines and, therefore, uses no binder during the manufacturing of mineralwool. No data will be collected

for unbonded

lines asagreed

upon with EPA. Cooling Operation Formaldehyde,

Phenol, Methanol Amerrock 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.
TESTINGSCHEDULE BT Environmental

Consulting,

Inc. ("BTEC"), an environmental consulting

and testing

firm, will supervise

the collection

of new emissions

dataas described

above on behalf

of Amerrock Products

LP and other NAIMA companies.On-site fieldwork support

for this project

will be provided

on a primarilygeography-based basis by the followingcompanies: l. Prism

Analytical

Technologies,

Inc. of Mount Pleasant, Michigan; 2. Lehder

Environmental

Services,

Inc. of PointEdward,

Ontario; 3. Metco Environmental of Carrollton.

Texas; 4. Delta

Air Quality Services

of Orange,

California;

and 5. Environ

Corooration

of Irvine.California. Otherthan the mercury analyticalservices required by Method 30B, laboratory services for this project will be provided

by Maxxam AnalyticsLimited of Mississauga, Ontario. Method 30B analytical

services will be provided by Ohio Lumex Company of Twinsburg,Ohio. BTEC will commence testingin July 2010,and testing will be completed

in November

2010. BTEC will begin submitting new test data through the EPA Electronic Reporting Tool on a rolling basis

within 60-90days

of completing

field work andexpects to complete

the inputof all data by January

2011. Please

find attached

BTEC's Emissions

TestProgram

Summary,

Scope of Work, and a description of Quality Assurances. The ProjectSchedule is being developed

by BTEC andwill be forwarded to you at a laterdate. NAIMA will submit

to EPA all existing

data described

above in June andJuly 2010. Individual facilities will submit completed InformationCollection Requests by the end of August 2010.

### Mr. Peter

Tsirigotis Iune y52010 Page 3

This letter outlines Amerrock Products LP's good faith attempt to accommodate its understanding

of EPA's dataand timing needs. Amerrock Products LP commits to complete the testing andendeavors

to do so on the schedule outlinedabove. Should you have any questions or requireadditionalinformation,please contactme at 205-516- 9164. Sincerely, 

# ,4ril&

Enclosures
cc: Mr. Jeffrey

A. Telander Sector Policies and Programs

Division Metals andMinerals

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 Metalsand 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