----- Original Message ----- 

From: French.Chuck@epamail.epa.gov <French.Chuck@epamail.epa.gov> 

To: Steinwurtzel, Robert N. 

Cc: Danny Greene <Danny.Greene@erg.com>; 'Russell Kemp' <rkemp@environcorp.com> 

Sent: Thu May 27 17:25:27 2010 

Subject: RE: Draft ICR and Test Plan 

Hi Robert, 

We agree with most of your comments and are making the changes accordingly. However, there may be 

1 (or possibly more) comments that we may not be able to incorporate. Anyway, we are working on it..... 

In the meantime, we are also compiling the contact names and addresses for the companies to receive 

the cover letters and questionnaire survey (enclosure #1). Could you please review the attached draft list 

and let me know the appropriate contact names and addresses for these ICRs for each company by 

Tuesday (6/1/2010). 

 Thanks. 

Chuck 

(See attached file: Addresses-Secondary-Lead-corp-contacts.doc) 

 

From: "Steinwurtzel, Robert N." <Robert.Steinwurtzel@bingham.com> 

To: Chuck French/RTP/USEPA/US@EPA 

Cc: "'Russell Kemp'" <rkemp@environcorp.com>, "Danny Greene" <Danny.Greene@erg.com>, Susan 

Fairchild/RTP/USEPA/US@EPA 

Date: 05/26/2010 02:22 PM 

Subject: RE: Draft ICR and Test Plan 

Thanks, Chuck. I will transmit your response to my client and let you know if we have any comments 

thereto. We also would appreciate receiving your response to our comments on the survey 

questionnaire. 

Regards, Rob. 

Robert N. Steinwurtzel 

Attorney 

T 202.373.6030 

F 202.373.6001 

robert.steinwurtzel@bingham.com 

B I N G H A M 

Bingham McCutchen LLP 

2020 K Street NW 

Washington, DC 20006-1806 
-----Original Message----- 

From: French.Chuck@epamail.epa.gov [mailto:French.Chuck@epamail.epa.gov] 

Sent: Wednesday, May 26, 2010 2:18 PM 

To: Steinwurtzel, Robert N. 

Cc: 'Russell Kemp'; Danny Greene; Fairchild.Susan@epamail.epa.gov 

Subject: Re: Draft ICR and Test Plan 

Hi Rob, 

Thank you for the comments, we are now reviewing them, and we plan to revise the survey after 

considering your comments. With regard to our discussions on the Test Plan and schedule for testing, 

submitting data, etc... here is our response: 

1. We are agreeable with you and your colleagues developing a draft Test Plan, but please make sure the 

draft Test Plan generally reflects the approaches, methods and pollutants that we provided in the draft 

Enclosure #2 that we sent you on 4/26/2010 (which is attached to this email), and that it covers about 

50% of the industry, or more. 

2. With regard to schedule for the test plan, we conclude that waiting another 30 days to complete the 

draft test plan is too much time. Please submit the draft Test Plan within 15 days (by 6/10/2010). After we 

receive the draft Test Plan, we will then review it quickly and respond back to you ASAP (e.g., within a 

few days), hopefully with an approval letter and/or comments, as needed, depending on our review, 

etc... 

3. With regard to the overall schedule, I recall that you proposed 120 days would be needed to complete 

the overall work (i.e., do all the testing, QA/QC data, finish test reports, submit data, etc....). As you know, 

we initially requested that it be done in 90 days. We are concerned about waiting 120 days to receive all 

the materials. We might be able to accept 120 days for the final deliverable. However, we will need some 

deliverables in the interim (such as preliminary test data and draft test results), as soon as possible. 

Therefore, we request the following schedule: 

- submit the "preliminary" emissions test data and draft test results (e.g., in the form of draft test reports 

and tables, spreadsheets) within 90 days of the day we approve the Test Plan (e.g.,by 9/14/2010), with 

appropriate caveats, as needed. 

- submit "final" test reports within 108 days, by email and/or by express overnight mail (e.g., by 

10/2/2010) 

- upload all the data to the ERT within 120 days (e.g., by 10/14/2010) 

 I hope this plan and schedule works for you. Please let me know if you have questions. 

 Thanks. 

Chuck 

(See attached file: draft 2nd Pb Enclosure 2 (test plan) 042610.doc)