MEMORANDUM

	

Date:	August 9, 2011

	

Subject:	Estimated Cost Impact for Mineral Wool Production Industry to
Comply with Proposed Residual Risk and Technology Review (RTR)
Amendments 

Mineral Wool Production  RTR

RTI Project No. 0210426.010

From:	Dave Reeves, RTI International



To:	Susan Fairchild

OAQPS/SPPD/NRG (D243-02)

U.S. Environmental Protection Agency

The purpose of this memorandum is to present the estimated costs related
to the mineral wool production source category for their processes and
facilities to comply with the proposed RTR amendments and associated
emission limits.

BACKGROUND 

Based on the information provided by the mineral wool production
industry and their primary trade association, North American Insulation
Manufacturers Association (NAIMA), there are currently 7 facilities in
the U.S. producing mineral wool. We estimate that all 7 of those
facilities will incur additional testing cost to demonstrate compliance
with the new (proposed) carbonyl sulfide (COS), hydrogen fluoride (HF),
and hydrogen chloride (HCl) emission limits for cupolas.  One facility
will also incur additional annual costs to purchase low-sulfur raw
materials in order to comply with the proposed COS emission limit for
cupolas.  We also estimate that the 3 facilities with bonded product
lines will incur additional testing cost to demonstrate compliance with
the revised formaldehyde and new (proposed) phenol and methanol emission
limits that will apply to collection and curing operations combined. 
Table 1 summarizes the above information and the associated cost
impacts.

Table 1.  Summary of Mineral Wool Production Facilities Costs to Comply
with RTR Amendments 













	Cupolasa



Total  Facility Costs



Low-Sulfur Mat'ls	#	Testing	Collection/Curing



Facility	Location	Incremental Cost	Cupolas	Costb	# Bonded Lines	Test
Costc



Industrial Insulation Group (IIG)	Phenix City, AL	

0	1	18,000	1	14,000

32,000

Thermafiber	Wabash IN	

0	2	34,000	1	14,000

48,000

USG Interiors	Red Wing, MN	

0	2	34,000	0	0

34,000

USG Interiors	Walworth, WI	

0	1	18,000	0	0

18,000

Amerrock Products	Nolanville, TX	

0	2	34,000	0	0

34,000

Isolatek Int’l	Huntington, IN	

0	2	34,000	0	0

34,000

Rock Wool Mfg	Leeds, AL	

360,000	1	18,000	1	14,000

392,000

	SubTotal  	$360,000	11	$190,000	3	$42,000

$592,000











a – 6 of the 11 cupolas currently have incineration control (RTOs);
Rock Wool is the only facility that is not currently meeting the
proposed COS limit based on emission testing results provided by
industry.  Low-sulfur material incremental cost based on an estimated
50% increase (per ton) of slag costs.  No other facility is expected to
have any additional equipment or material cost impacts.

b – Cupola testing costs reflect incremental costs for COS, HF, and
HCl testing; current test requirements for PM not included.

c – Collection/curing costs reflect incremental costs for phenol and
methanol testing; current test requirements for formaldehyde not
included.

COMPLIANCE TESTING COSTS  

Mr. Stef Johnson of EPA’s Measurement Policy Group provided the
following estimates for compliance testing based on the test methods
being proposed in the RTR amendments:

Emission Source	HAP	Test Method	Test Cost	Comment



Cupola	COS	318	$14,000	$12,000 for each additional test

	HF and HCl	320 

(add-on to M318 FTIR)	$4,000 (combined HF/HCl)	In addition to COS 

testing cost

Collection/ Curing  (combined)	Phenol and Methanol (already testing for
formaldehyde)	318	$14,000 (combined Phenol & Methanol)	$12,000 for each
additional test



III.	LOW- SULFUR RAW MATERIAL COSTS 

Based on the emission test data provided in the ICR responses, we
estimate that only one facility (Rock Wool Manufacturing) is not
currently meeting the proposed COS emission limit for cupolas.  We
assumed that the least costly compliance option would be for the
facility to switch to low-sulfur raw materials to reduce the amount of
COS generated in the cupolas.  

Rock Wool reported that slag comprises approximately 90% of the raw
material going into their cupola.  Since there is no readily available
source of low-sulfur slag, we estimated an incremental cost of 50% more
(per ton) for switching to other low-sulfur raw materials.  No raw
material cost information was provided by any of the companies, so we
assumed a 50% cost increase per ton and then used Rock Wool’s reported
annual slag usage to calculate an annual raw material cost increase of
$360,000. (Production data and raw material usage and costs are
considered confidential business information). 







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