VIA E-MAIL

June 18, 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: Industrial Insulation Group, LLC Testing and ICR Response Schedule

Dear Mr. Tsirigotis:

Industrial Insulation Group, LLC (“IIG”) is providing this letter in response to EPA’s request for 

a formal commitment from IIG 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, IIG, 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 and Incinerator

Pollutants To Be Tested: Carbon Monoxide, Carbonyl Sulfide

Data To Be Supplied: New carbonyl sulfide and carbon monoxide data will be 

collected at Industrial Insulation Group’s Phenix City, 

Alabama facility.

Location/Lines Represented: Industrial Insulation Group – Phenix City, Alabama

Process Unit: Cupola

Pollutants To Be Tested: PM2.5 (Filterable and Condensable), Total PM (Filterable and 

Condensable), Metals, Mercury, Hex Chrome, Hydrogen 

Fluoride, Hydrochloric Acid

Data To Be Supplied: New PM2.5, total PM, metals, mercury, hex chrome, hydrogen 

fluoride, and hydrochloric acid data will be collected at

Industrial Insulation Group’s Phenix City, Alabama facility (1 

Cupola).

Location/Lines Represented: Industrial Insulation Group – Phenix City, Alabama
Mr. Peter Tsirigotis

June 18, 2010

Page 2

Process Unit: Collection Operation

Pollutants To Be Tested: Formaldehyde, Phenol, Methanol

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

Insulation Group. New formaldehyde, phenol and methanol 

data will be collected from Industrial Insulation Group.

Location/Lines Represented: Industrial Insulation Group – Phenix City, Alabama

Process Unit: Curing Oven

Pollutants To Be Tested: Formaldehyde, Phenol, Methanol

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

Insulation Group. New formaldehyde, phenol and methanol 

data will be collected from Industrial Insulation Group.

Location/Lines Represented: Industrial Insulation Group – Phenix City, Alabama

Process Unit: Cooling Operation

Pollutants To Be Tested: Formaldehyde, Phenol, Methanol

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

Insulation Group. New formaldehyde, phenol and methanol 

data will be collected from Industrial Insulation Group. 

Location/Lines Represented: Industrial Insulation Group – Phenix City, Alabama

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 Industrial 

Insulation Group, LLC and other NAIMA companies. On-site fieldwork support for this project 

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

1. 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 Corporation 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 
Mr. Peter Tsirigotis

June 18, 2010

Page 3

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.

This letter outlines Industrial Insulation Group, LLC’s good faith attempt to accommodate its 

understanding of EPA’s data and timing needs. Industrial Insulation Group, LLC 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 281-605-

4630.

Sincerely,

Jessie C. Payne

Corporate EHS Manager

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