
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


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 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

