MEMORANDUM

Date:
January 31, 2013
	
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. 0213199.001.007
From:
Dave Reeves, RTI International

To:
Susan Fairchild
OAQPS/SPPD/NRG (D243-02)
U.S. Environmental Protection Agency
Research Triangle Park, NC  27711

      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 final RTR amendments and associated emission limits.

      I. 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 are now also aware of a new production facility planned for Byhalia, MS that is in the construction permit review stage and we have included it as part of the estimated cost impacts.  Based on the emissions test data provided by the industry, none of the existing facilities will have install additional control equipment to comply with the final rule requirements.  

We estimate that all 8 of the mineral wool production facilities will incur additional testing costs to demonstrate compliance with the new carbonyl sulfide (COS), hydrochloric acid (HCl), and hydrofluoric acid (HF) emission limits for cupolas.   We also estimate that the 3 existing facilities with bonded product lines will incur additional testing costs to demonstrate compliance with the revised formaldehyde and new phenol and methanol emission limits that will apply to collection and curing operations combined.  We only have general information on the planned new facility but to estimate costs conservatively, we assume in this cost estimation that it would operate two cupolas and two bonded product lines that would be subject to the final limits of the rule. All of the new testing associated with the final rule requirements is based on a 5-year frequency.  Therefore, the initial (first year) testing costs were divided by 5 to come up with "annualized" testing costs.  Table 1 summarizes the above information and the associated cost impacts.


      II. COMPLIANCE TESTING COSTS  
      Mr. Steffan Johnson of EPA's Measurement Policy Group provided the following estimates for compliance testing based on the test methods included in the final RTR amendments:
      
                                Emission Source
                                      HAP
                                     Test 
                                    Method
                            Test Costs (in 2011 $)
                                  Test Freq-
                                     uency
                       Annualized Test Costs (in 2011 $)
                                    Comment




Cupola

COS

                                       
                                      318
                                       
                                    $14,000
                                       
                                 Every 5 years
                                       
                                    $2,800
             $12,000 for each additional test ($2,400 annualized)


HCl and HF
                           320 (add-on to M318 FTIR)
                                       
                                    $4,000
                                       
                                 Every 5 years
                                       
                                     $800
                                       
                        In addition to COS testing cost

Collection/ Curing  (combined)
Phenol and Methanol (already testing formaldehyde)
                                       
                                       
                                      318
                                       
                   $15,000 (combined phenol & methanol)
                                       
                                 Every 5 years
                                       
                                       
                                    $3,000
             $12,000 for each additional test  ($2,400 annualized)
      










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



                                  Cupolas[a]
                          Combined Collection/Curing
                                       

                                       


                                       #
                                    Cupolas
                     Annualized (New) COS Testing Cost[b]
                                       
                                       
                                # Bonded Lines
                                  Annualized 
                             (New) Testing Cost[c]
                                       
                                   Facility
                                   Location
                                       
                                       
                    Annualized (New) HCl/HF Testing Cost[b]
                                       
                                       
Total  Facility  Incremental Annualized (New) Costs
Industrial Insulation Group (IIG)

Phenix City, AL
                                       
                                       1
                                     2,800
                                       
                                      800
                                       1
                                     3,000
                                    $6,600
Thermafiber
Wabash IN

                                       2
                                     5,200
                                     1,600
                                       1
                                     3,000
                                    $9,800
USG Interiors
Red Wing, MN
                                       2
                                     5,200
                                     1,600
                                       0
                                       0
                                    $6,800
USG Interiors
Walworth, WI
                                       1
                                     2,800
                                      800
                                       0
                                       0
                                    $3,600
Amerrock Products
Nolanville, TX
                                       2
                                     5,200
                                     1,600
                                       0
                                       0
                                    $6,800
Isolatek Int'l
Huntington, IN
                                       2
                                     5,200
                                     1,600
                                       0
                                       0
                                    $6,800
Rock Wool Mfg
Leeds, AL
                                       1
                                     2,800
                                      800
                                       1
                                     3,000
                                    $6,600
Roxul USA

Byhalia, MS
                                       2
                                     5,200
                                     1,600
                                       2
                                     5,400
                                    $12,200

                                                                     SubTotal  
                                      13
                                    $34,400
                                    $10,400
                                       5
                                    $14,400
                                    $59,200
a  -  8 of the 13 cupolas currently have (or will have) incineration/afterburner controls. None of the facilities are expected to have any additional equipment or material cost impacts to meet the proposed emission limits. 
b  -  Cupola testing costs reflect incremental (new) 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.

