**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 IC R 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 he alth 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 c ompanies, plans to co nduct 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 carbonyls ulfide 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: PM 2.5 (Filterable and Condensable), Total PM (Filterable and Condensable), Metals, Mercury , Hex Chrome, Hydrogen Fluoride, Hydrochloric Acid Data To Be Supplied: New PM 2.5 , 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, AlabamaMr
. Peter Tsirigotis

June 18 , 2010 Page 2
Process Unit: Collection Operation Pollutants To Be Tested: Formaldehyd e, Phenol, Methanol Data To Be Supplied: Existing formaldehyd e data will be supplied from In dustrial Insulation Group. N ew formaldehyde, phenol and methanol data will be collected from Industrial Insulation Group. Location/Lines Represented: **Industrial Insulation Group**

– Phenix City, A labama
Process Unit: Curing Oven Pollutants To Be Tested: Formaldehyd e, Phenol, Methanol Data To Be Supplied: Existing formaldehyd e data will be supplied from In dustrial Insulation Group. N ew formaldehyde, phenol and methanol data will be collected from In dustrial Insulation Group. Location/Lines Represented: **Industrial Insulation Group**

– Phenix City, Alabama
Process Unit: Cooling Operation Pollutants To Be Tested: Formaldehyd e, Phenol, Methanol Data To Be Supplied: Existing formaldehyd e data will be supplied from In dustrial Insulation Group. N ew formaldehyde, phenol and methanol data will be collected from Industrial Insulation Group. Location/Lines Represented: **Industrial Insulation Group**

– Phenix City, Alabama
TESTI NG 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
. O n - site fieldwork support for this project will be provided on a primarily geograph y- based basis by the following companies: 1. Prism Analy

tical 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

anal ytical services required by M ethod 30B, laboratory s ervices for this project will be provided b y Max x am Analy tics Limited of Mississauga, Ontario. M ethod 30B anal ytical services will be provided by Ohio Lumex Company

of Twinsburg, Ohio. BTEC will commence testing i n July 2010 , and testing will be completed in November 2010. BTEC will begin submitting new test data through the EPA Electronic Reporting Tool o n a rolling basis within 60

- 90 day s of completing field work and expects to complete the input of all data b y January

2011
. Please find attached BTEC’s Emissions Test Program Summary , Scope ofMr
. Peter Tsirigotis

June 18 , 2010 Page 3 Work, and a description of Quality A ssurances. 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 sub mit completed Information Collection Requests by the end of August 2010. This letter outlines In dustrial In sulation Group, LLC’s good faith attempt to accommodate its understanding of EPA’s data and timing needs. In dustrial Insulation Group, LLC commit s to complete the testing and endeavor s to do so on the schedule outlined above. Should you have any questions or require additional information, please contact me at 281
- 605
- 4630
. Sincerel y, Jessie C. Pay

ne Corporate EHS Manager
Enclosures
cc: Mr. Je ffrey

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 Sect or 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