VIA E-MAIL

June 16,2010

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: Amerrock Products LP Testing and ICR Response Schedule

Dear Mr. 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 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, Amerrock, 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 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, Methanol
Mr. 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.

Curing Oven

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.

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.

TESTING SCHEDULE

BT Environmental Consulting, Inc. ("BTEC"), an environmental consulting and testing firm,

will supervise the collection of new emissions data as described above on behalf of Amerrock

Products LP and other NAIMA companies. On-site fieldwork support for this project will be

provided on a primarily geography-based basis by the following companies:

l. Prism Analytical Technologies, Inc. of Mount Pleasant, Michigan;

2. Lehder Environmental Services, Inc. of Point Edward, Ontario;

3. Metco Environmental of Carrollton. Texas;

4. Delta Air Quality Services of Orange, California; and

5. Environ Corooration of Irvine. California.

Other than the mercury analytical services required by Method 30B, laboratory services for this

project will be provided by Maxxam Analytics Limited of Mississauga, Ontario. Method 30B

analytical services will be provided by Ohio Lumex Company of Twinsburg, Ohio.

BTEC will commence testing in 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 60-90 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. The Project Schedule is being developed by

BTEC and will be forwarded to you at a later date.

NAIMA will submit to EPA all existing data described above in June and July 2010. Individual

facilities will submit completed Information Collection 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 data and timing needs. Amerrock Products LP 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 205-516-

9164.

Sincerely,

,4ril&

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