1

MEMORANDUM

TO: Anne Pope, EPA

FROM: Susan Fairchild, Project Lead

DATE: October 10, 2014

SUBJECT: Emissions Data Used in Residual Risk Modeling for Mineral Wool

Production

The purpose of this memorandum is to provide information on the RTR dat abase used in estimating residual risk for the Mineral Wool Production Maximum Achievable Control Technology ( MACT ) source category.

BACKGROUND

Section 112 of the Clean Air Act (CAA) establishes a two

- stage regulatory process to

address emissions of h azardous air pollutants (HAPs) from stationary sources. In the first stage, section 112(d) requires the Environmental Protection Agency (EPA) to develop technology

- based standards for categories of industrial sources. In the second sta g e, known as the res idual risk stage, section 112(f)(2) requires EPA to assess the hea l th and environmental risks that remain after sources come into compliance with MACT. If additional risk reductions are necessary to protect public health with an ample margin of safety or t o prevent adverse environmental effects, EPA must develop standards to address these remaining (“residual”) risks. As part of this second stage, data w ere gathered to assess the residual risks from the Mineral Wool Production MACT source

category.

EMISSI ONS DATA USED IN RESIDUAL RISK MODELING

I. Information Collection Request (ICR)

A voluntary ICR was sent out in March 2010 to th e seven mineral wool production

facilitie s currently operating in the U S. ICR responses from all the facilities were compiled in the project databa se and included information on facility process es, equipment, control devices , costs, and HAP emissions. Facility

- specific production rate

information was also included and was claimed as confidential business information (CBI), which r esulted in much of the project database being treated as CBI.

II. Emissions Testing

Mineral wool facilities were asked to supply test data on cupolas, curing ovens, and collection operations. All facilities supplied existing test data, new test data conducte d in 2010, or a combination of these for one or more emission unit(s). Six of the mineral wool production facilities conducted “new” emissions testing in 2010. The one facility that did2

not conduct any recent (2010) emissions testing was Amerrock Products LP (Amerrock) located in Nolanville, TX. The test results were typically presented as an average of three test runs and provided in units of mass of pollutant per mass of production (e.g., lbs of HAP/ton of melt).

Both new and existing test results were used to calculate average emission rates for

emission sources . The number of data sets varied depending on the pollutant, emission source, and the type of product being produced at the facility (one to four datasets were used for a pollutant at a specific source).

After the 201 3 supplemental proposal, two facilities , Thermafiber and Rockwool provided additional emissions test data and information on their bonded lines.

III. Source

- Specific Emissions

Using the production rates that each facility provided i n their ICR response and the emission rates from the emission testing, annual emissions (tpy) for each pollutant were

calculated for each emission source. The sources modeled in the risk analysis are listed as

follows.

o Facilities making loose mineral wool : Cupolas

o Facilities making bonded products : Cupolas, Curing Ovens, Collection, and Cooling.

As previously mentioned, the p ollutants and emission sources tested by facilities varied. For facilities that did not perform testing on a particular pollutant a t a specified source, an emission rate (lb/ton melt) for each missing pollutant was calculated from a similar

source at another facility. If there was more than one similar source that had emission rate data, the average emission rate of all the similar so urce s was used. This emission rate was then multiplied by the production rate of the facility with the missing data

. T esting parameters (velocity, temperature, etc.) of the similar source were also used (or the average if there was more than one similar so urce) to populate the data set for each facility

. The s tack parameters (height, diameter, etc.) were all taken from facility ICR

responses

– none of them were estimated or based off similar sources

.

a. Cupola Emissions

Pollutants estimate d for cupolas incl ude: HAP Metals, Hydrogen Chloride (HCl)

, Hydrogen Fluoride (HF) , Hexavalent Chromium (Cr+6), Carbonyl Sulfide (COS), and Mercury ( Hg ).

In order to cal culate an average emission rate (lb/ton melt) from cupolas for each pollutant, the control device had t o be taken in acco unt. Cupolas were divided into two categories:

 Cupolas with baghouse control3  Cupolas with baghouse and incinerator control

Therefore, if a cupola that only has baghouse control was not tested for a certain pollutant, an average emission rate (lb/ton melt) for that pollutant was calculated using test results from other cupolas that also only have baghouse control.

 Amerrock

- The Amerrock facility did submit recent emissions testing for

their two cupolas which are routed to one stack an d controlled by a scrubber

and a baghouse (fabric filter) . Since they are the only facility with that configuration and we did not have enough test data to estimate the control efficiency of the scrubber for all the pollutants, the average emi ssion rate ( l b/ton melt) of cupolas with just a baghouse control were conservatively used and multiplied by Amerrock’s total plant production capacity (tons melt) to account for emissions from both cupolas.

 Thermafiber

- The Thermafiber facility has two cupolas tha t are not routed together; they tested each cupola separately for almost all pollutants. A few pollutants were tested at one cupola but not the other. When this was the case, the emission rate (lb/ton melt) of the cupola tested was used along with the prod uction capacity of the cupola with the missing pollutant to get annual

emissions.

b. Curing Oven, Cooling, and Collection Emissions

Pollutants estimated for Curing/Collection: Formaldehyde, Phenol, Methanol.

There are three mineral wool facilities that pr oduce a bonded mineral product and therefore operate c uring, cooling, and collection operations. All three facilities submitted formaldehyde, phenol, and methanol emissions testing for their bonded line processes.

These data underwent QA/QC procedure and risks associated with facilities covered by

the Mineral Wool Production MACT standa rd were modeled in April 2011. After modeling, it was discovered that one test run submitted by a facility was not performed during normal operating conditions and that the production rate for another facility was interpreted incorrectly and did not capture production for the facility as a whole

. T he file

was corrected and risks associated with the source category were remodeled in May

2011.

IV. Chromium and Mercury Speciat ion

Consistent with the HAP list in the Clean Air Act, metals such as chromium and mercury may be reported in the ICR under different names, including chromium, chromium compounds, mercury, and mercury compounds. Facilities that submitted chromium

emissio ns data reported it as total chromium and hexavalent chromium emissions. Hexavalent chromium emissions were not speciated further and were modeled as chromium VI. Total chromium was speciated to Chromium III by subtracting chromium4

VI emissions from total chromium. In some cases chromium VI emissions were larger

than total chromium. For these circumstances it was assumed that all chromium

emissions were hexavalent chromium and chromium III emissions were “0”. Facilities that submitted mercury data provided it as total mercury; the following table summarizes the speciation factors that were applied to mercury emissions.

POLLUTANT_CODE POLLUTANT_DESCRIPTION HAP_CATEGORY_NAME % of total

200 Elemental Gaseous Mercury Mercury Compounds 80%

202 Particulate Diva lent Mercury Mercury Compounds 10%

201 Gaseous Divalent Mercury Mercury Compounds 10%

V. Emission Process Group Assignment

In order to assign risk results to specific operations within mineral wool facilities, Emission Process Groups are assigned to SCCs. There are only three types of emission process groups for mineral wool production: 1) cupolas, 2) collection, and 3) curing operations. Combinations of these processes were used as emission process groups when one or more of these processes shared a commo n stack.

VI. QA/QC

Companies were sent aerial views of each plant and asked to label and provide coordinates for each stack. They were also asked to review their stack configurations for each emission unit. All wool fiberglass facilities answered the reques t and provided labeled aerial views along with coordinates. EPA also conducted an extensive review of the locational coordinates for all facilities in the wool fiberglass source category. Locations were visually reviewed using Google Earth or ArcExplorer. Adjustments were made for coordinates based on these visual evaluations if necessary.

Emissions data, stack parameters, and facility information was also reviewed for each unit and pollutant at a given plant. Production rates for each unit were checked w ith the responses provided in the ICR.

After risk modeling was conducted, it was discovered that one test run submitted by a facility was not performed during normal operating conditions and that the production rate for another facility was interpreted i ncorrectly and did not capture production for the facility as a whole. The data set file was corrected and risks associated with the changed

sources were remodeled.

VII. Allowable Emissions

In order to evaluate the risk associated with the highest allowable emissions for all air pollutants from the Mineral Wool Production source category, we estimated the allowable emissions based on formaldehyde. Formaldehyde was considered the most important HAP emitted from this source category based on our screening level risk assessment and the HAP

for which we had the most data. To estimate emissions at the MACT

- allowable level from5

stacks, we estimated the actual formaldehyde emission rates at curing and collection sources for facilities that operate bonded lines. These emission rates were compared to the maximum allowed by the existing MACT standard (i.e., 0.06 pounds of formaldehyde per ton of melt) from all curing ovens. Based on this analysis, we concluded that all facilities are emitting formaldehyde at emission rat es lower than allowable. The estimated actual formaldehyde emission rates were approximately 2 times lower than allowable emissions. The other facilities producing nonbonded product (i.e., loose mineral wool) did not report any formaldehyde, phenol, or met hanol emissions.

MACT

- allowable emissions were conservatively estimated to be 3 times the actual emissions for all pollutants in the Mineral Wool Production category to account for control device efficiencies at the different facilities. Therefore, to de velop the MACT

- allowable emissions the actual stack emissions were multiplied by 3 for each Mineral Wool Production facility.