
VIA E-MAIL

October 3, 2014


Mr. David Reeves
RTI International
3040 East Cornwallis Road
Research Triangle Park, NC  27709-2194

      RE:	Refractory Recycling and Disposal Cost Data

Dear Mr. Reeves:

In response to the Environmental Protection Agency's ("EPA") request, the North American Insulation Manufacturers Association ("NAIMA") is pleased to provide EPA estimated cost data associated with sorting, recycling, and disposal of refractory brick.  NAIMA also provides additional information pertinent to refractory bricks.  The data and information set forth herein have been collected from NAIMA's fiber glass members.  The numbers provided herein are an aggregated average.  Since the data have been aggregated and no specific company data is identified, NAIMA is not claiming confidential business information on any data used to answer questions 1-3.

The data and information are presented here by restating the questions that were sent to NAIMA's members and then giving the answer.

Question 1:	Do you recycle the refractory bricks or dispose of them? Or both?

Answer:	NAIMA's member companies recycle used refractories that can be recycled.  Spent refractory bricks that are not recycled are disposed of properly.  The vast majority of spent refractory bricks are recycled.


Question 2:	What is the estimated cost to sort, recycle, and dispose of refractory bricks?  Please calculate the estimate based on a dollar per ton.

Answer:	Most of this data represent costs from actual furnace rebuilds or cost projections from third parties for ongoing rebuilds.  The data below are averaged:

            * Recycling  -  $143/ton
            * Hazardous Disposal  -  $343/ton
            * Non-Hazardous Disposal  -  $129/ton
            * Sorting  -  $199/ton

            * Average Cost For Sorting, Recycling, and Disposal Per Rebuild  -  $204/ton

Question 2A:	How many tons of refractory brick would be disposed or recycled in a typical furnace rebuild?

Answer:	There are many different types of furnaces with different amounts of refractory brick.  There are also different sizes of furnaces that would cause an obvious variation in the amount of spent refractory brick to be recycled or disposed.  Based on the data collected by NAIMA, the average total for tons of brick refractory sorted, recycled and disposed of is 295 tons.

Question 3:	Do you regard this cost as significant?

Answer:	It is a significant cost, but it is greatly outweighed by the cost of rebuilding the furnace.  An even far more significant cost would be cutting the life of a furnace, due to the more frequent business interruptions, more frequent capital cost incurred in rebuilds (with associated increase in depreciation), overall decrease in asset utilization, etc.


The underlying premise of this data request, as NAIMA understands it, is the notion that as refractories age there is a greater likelihood that chromium emissions will increase.  NAIMA and its members disagree with that assumption.  Emissions data is available that show chromium emissions levels lower at the end of an oxy-fuel furnace's life than at specific test times during the mid-life of that same oxy-fuel furnace.  When that same furnace was rebuilt, the chromium emissions from the new furnace were essentially the same or higher than the emission levels at the end of the furnace's life.  These results are significant because the same test methods were used for each of the testing periods.  To summarize, this data does not support the premise that there is an increase of emissions at the end of the furnace's life.

Similarly, data from another oxy-fuel furnace shows chromium emissions being variable throughout the life of the furnace, but some of the lower emissions were at the end of the furnace life.  Again, this data challenges the soundness of EPA's premise that aging refractories emit higher chromium levels.  While the oxy-fuel furnace data cited above may demonstrate that there is not a predictable curve, it certainly does not support EPA's premise that aging refractories produce increased chromium emissions.  NAIMA can provide this data to EPA as confidential business information.

Since this company data creates a different scenario than the one envisioned by EPA, NAIMA requests the opportunity to review the data that EPA may have relied upon to come to the conclusion that chromium emissions increase as the refractories age.  If EPA's conclusion was not data-based, NAIMA requests the basis upon which EPA did reach this conclusion.

NAIMA is also disturbed by EPA's assumption that cutting the life of fiber glass furnaces by one, two, or three years is a viable option.  Since the advent of chrome-based refractory, insulation manufacturers have been able to extend furnace life up to 50 percent.  The life span of a furnace is one of the most critical economic factors for a successful and economically solvent manufacturing operation and is highly dependent on the use of chrome refractories.  Losing the ability to maximize the life-time of a furnace renders wool fiber glass manufacturers non-competitive in the global market.

The cost of accelerated furnace rebuilds would be in the millions of dollars for each year lost in furnace use and the costs of accelerating rebuilds on business planning and logistics.  This would not only be economically devastating to the fiber glass insulation industry, but it would not be cost-effective for reducing hazardous air pollutants.  EPA has previously found that requiring costs over a specified dollar amount per ton of pollutant reduced to be unreasonable.  The cost of conducting a furnace rebuild before its time would be far in excess of the cost-effectiveness value EPA has found acceptable in prior Section 112 cost-effectiveness analyses and do not represent a reasonable investment for the amount of emissions reduction achieved.

This contemplated option is financially catastrophic and it is not even justified since NAIMA and its members know of no data that supports the idea that aging refractories increase chromium emissions.  In fact, NAIMA has offered data that demonstrates the converse  -  no relationship between age of refractory and chromium emissions.

This issue will be more fully challenged in NAIMA's comments on the Supplemental Proposal.

Sincerely,

Angus E. Crane
Executive Vice President, General Counsel

cc:	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

      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
