
VIA E-MAIL AND OVERNIGHT MAIL

August 20, 2013



Ms. Susan Fairchild
Sector Policies and Programs Division
Metals and Minerals Group (D243-02)
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
4930 Old Page Road
Durham, NC  27703

      RE:	EPA's Request For Cullet and Batch Cost Data

Dear Ms. Fairchild:

In response to the Environmental Protection Agency's ("EPA") request for cullet and batch costs, the North American Insulation Manufacturers Association ("NAIMA") created the following questionnaire:

1. What was the cost per ton of purchased cullet for:
   2010:  ____________________
   2011:  ____________________

2. What was the cost per ton of glass for batch raw materials excluding cullet for:
   2010:  ____________________
   2011:  ____________________

3. What was your overall batch cost per ton of glass for:
   2010:  ____________________
   2011:  ____________________

4. What would your cost per ton of glass batch have been if no purchased cullet was used for:
   2010:  ____________________
   2011:  ____________________

The questionnaire was sent out to all five fiber glass companies.  The companies submitted data to Kirkland & Ellis, to protect and preserve the confidentiality of the data, and Kirkland & Ellis aggregated the data and calculated industry average values weighted by the most recent year's sales data.

While the data was requested from five companies, some responsive data from one company was incomplete.  Therefore the summary of data set forth below represents four companies that comprise approximately 90 percent of the industry:



                               Weighted Average
1.
What was the cost per ton of purchased cullet for:


2010
                                                             $            88.82

2011
                                                             $            94.20



2.
What was the cost per ton of glass for batch raw materials excluding cullet for:


2010
                                                              $          171.96

2011
                                                              $          177.15



3.
What was your overall batch cost per ton of glass for:


2010
                                                              $          145.59

2011
                                                              $          151.52



4.
What would your cost per ton of glass batch have been if no purchased cullet was used for:


2010
                                                              $          151.92

2011
                                                              $          158.81

These numbers illustrate the aggregated costs of purchased cullet and batch materials for the years indicated for NAIMA member companies.  While the data show that cullet is less expensive than other batch materials, it is not significant enough so as to prevent individual companies from cutting out or reducing chrome-containing cullet to avoid surpassing a stringent chromium emission limit, especially given the costly and unproven alternatives for reducing chromium emissions at facilities that may need to do so.  In fact, individual company cost data in some instances showed a much narrower difference between cullet and virgin batch, including, in at least one case, a higher total cost of using cullet than if all batch were utilized.

Please do not hesitate to contact the undersigned if you have any questions.

Sincerely,

Angus E. Crane
Executive Vice President, General Counsel

cc:	Mr. Keith W. Barnett
	Group Leader, Office of Air Quality and Planning Standards
	Sector Policies and Programs Division, Mineral and Manufacturing Group
      U.S. Environmental Protection Agency
      4930 Old Page Road
      Durham, NC  27703
