VIA E

- MAIL

June 15 , 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

R E : FiberTEK Insulation , LLC Testing and ICR Response Schedule

Dea r Mr. Tsirigotis :

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

a formal commitment from FiberTEK to provide data, perform testing to coll ect 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 Manufa cturers Association (“NAIMA”) and its members’

discussion with EPA staff and their specific requests, FiberTEK , in conjunction with NAIMA

and other industry companies, plans to conduct the following testing and collect the following

existing data:

Wool F iberglass

Furnaces

Process Unit: Electric Steel Shell Melter

– With Baghouse

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

FiberTEK’s Lakeland, Florida facility (Middle or West

Melters)

. Location/Lines Represented: FiberTEK

– Lakeland, Florida (Middle Melter and West

Melter); Nephi, Utah (Middle Melter and West Melter)

Forming, Curing, and Cooling

Process Unit: Forming, Curing, and Cooling

– Formaldehyde Binder

Pollutants To Be Tested: Formaldehyde, Phenol, Methanol

Data To Be Supplied: For bonded line using formaldehyde

, e xisting data for

formaldehyde, phenol, and methanol will be provided

. Location/Lines Represented: FiberTEK

– Lakeland, Florida (BL Line); Nephi, Utah (BL

Line)Mr

. Peter Tsirigotis

June 15 , 201 0

Page 2

TESTING SCHEDULE

BT Environmental Consulting, Inc. (“ BTEC ”) , an e nvironmental consulting and testing firm,

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

Insulation, LLC and other NAIMA companies . On

- site fieldwork support for this project will be

provided on a primarily g eography

- 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 Environ mental 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 Ma x x a m Analytics Limited of Mississauga, Ontario. Method 30B

analytica l 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 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 b eing 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 FiberTEK Insulation , LLC ’s good faith attempt to accommodate its

understanding of EPA’s data and timing needs. FiberTEK Insulation, LLC commit s to complete

the testing and endeavor s to do so on the schedule outlined above.

Should yo u have any questions or require additional information, please contact me at 863

- 682

- 4448 or by email at tom.osborn@fibertekinsulation.com

Sincerely,



## Thomas R. Osborn

Thomas R. Osborn

Lakeland Plant Manager

FiberTEK InsulationMr

. Peter Tsirigotis

June 15 , 201 0

Page 3

Enclosures

cc: Mr. Jeff rey 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