1 From: Fairchild.Susan@epamail.epa.gov Sent: Monday, June 20, 2011 10:52 AM To: Hancy, Cindy Wang; Reeves, David Subject: Fw: NAIMA Presentation - SBAR Panel Meeting - 6/16/11 Attachments: SBARMineralWoolPresentation061611.pptx Categories: Blue Category This was NAIMA's presentation, which t hey sent the morning of the meeting ----- Forwarded by Susan Fairchild/RTP/USEPA/US on 06/20/2011 10:52 AM ----- From: Denise Radinovic < dradinov@naima.org > To: Susan Fairchild/RTP/USEPA/US@EPA, " chiggins@omb.epa.gov " < chiggins@omb.epa.gov > Cc: Angus Crane < acrane@naima.org > Date: 06/16/2011 10:29 AM Subject: NAIMA Presentation - SBAR Panel Meeting - 6/16/11

Ms. Fairchild, Angus Crane requested I forward NAIMA’s presentation to you. Denise Radinovic Coordinator, Legal and Regulatory Affairs North American Insulation Manufacturers Association Ph: (703) 684 ‐ 0084 ext. 125 Fax: (703) 684 ‐ 0427 Visit NAIMA online at: www.naima.org www.PipeInsulation.org

# The North American Insulation Manufacturers Association (“NAIMA”) 

# Mineral Wool Presentation at the SBAR Panel Meeting Thursday , June 16, 2011

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# Objective NAIMA and its members are deeply concerned that the proposed additions and revisions set forth in the Mineral 

# Wool Information Update will result in the closure of the majority of the remaining mineral wool operations in the United States. This presentation captures the vulnerability of the 5 small businesses that make up the U.S. mineral 

# wool industry. Most importantly, this presentation identifies alternatives that will enable EPA to address the risk and Brick MACT issues without threatening the viability of the 

# U.S. mineral wool industry. 2

# U.S. Mineral Wool Production 

# Facilities Have Significantly Declined Mineral Wool Production Lines – 1999 Company Location Bonded - Product Production Lines Nonbonded - Product Production Lines Date of Installation American Rockwool Spring Hope, NC 0 2 1978 American Rockwool Nolanville, TX 0 2 1986 Celotex Pittston, PA 0 1 1957 Celotex Lagro, IN 0 2 1946 Fibrex Alexandria, IN 0 2 1970 Isolatek Huntington, IN 0 2 1929 MFS Inc . Bethlehem, PA 0 2 1970 Owens Corning Phenix City, AL 1 1 1990 Rock Wool Mfring . Leeds, AL 1 1 1970 Sloss Birmingham, AL 0 5 1947 Thermafiber Wabash, IN 1 1 1935 Thermafiber Tacoma, WA 1 1 1946 Thermafiber Birmingham, AL 1 1 1959 USG Walworth, WI 0 1 1969 USG Red Wing, MN 0 2 1973 1979 TOTAL 5 26 3

# U.S. Mineral Wool Production 

# Facilities Have Significantly Declined Mineral Wool Production – 2011

1 Amerrock has two operational lines, but due to a consent order with the Texas Commission on Environmental Quality, Amerrock is only permitted to operate one line at a time. 2 IIG continues to operate both an unbonded and bonded line at the former Owens Corning facility in Phenix City, AL, but those lines are not operated simultaneously. In other words, only one cupola is in operation at IIG at any time. 3 Rock Wool Manufacturing has permits to operate both an unbonded and bonded line, but because the market for unbonded product used in manufactured housing has been largely taken over by cellulose insulation, only the bonded line currently is operating.

Company Location Bonded - Product Production Lines Nonbonded Product Production Lines Date of

Installation Amerrock Nolanville, TX 0 2 1 1986 Isolatek Huntington, IN 0 2 1929 IIG Phenix City, AL 1 2 1 1990 Rock Wool Mfring Leeds, AL 1 3 1 1970 Thermafiber Wabash, IN 1 1 1935 USG Walworth, WI 0 1 1969 USG Red Wing, MN 0 2 1973 1979 TOTAL 3 10

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# EPA’s Preliminary Amendments Are Cost - Prohibitive

 

# Amerrock

 Struggling to meet immediate financial needs

 Statement from Lee Houlditch, Chief Executive Officer  

# Rock Wool Manufacturing

 Statement from Gerald Miller, Chief Financial Officer  

# Isolatek International

 Owned by a Trust; any technology change with significant price 

# tag will place company survival in jeopardy

 Statement from Tom Lund, Operations Manager  

# Thermafiber

 Statement from Steve Edris, President & CEO 5

# Available Alternatives Curing Oven – Alternative #1  

## Formaldehyde – 0.06 lbs. per ton of melt  

## Phenol – 0.04 lbs. per ton of melt  

## Methanol 0.04 lbs. per ton of melt



#  This alternative recognizes:  

## The validity of EPA’s statement: “The risks due to the mineral wool industry are low, and do not compel us to amend the MACT.”  

# The ranges proposed by EPA essentially amend the Mineral Wool MACT  

## Testing via 318 – EPA’s recommended ranges are out of sync with formaldehyde  

## Suggested ranges would force a lower formaldehyde limit  

# Alternative #1 appropriately bases phenol and methanol limits on the ratio of formaldehyde  

## Allows three separate limits 6

# Available Alternatives Curing Oven – Alternative #2  

## Formaldehyde – 0.06 lbs. per ton of melt  

## Formaldehyde would serve as surrogate for phenol and methanol  

## A single emission limit  

## Does not amend the MACT Standard  

## Consistent with EPA’s statement: “The risks due to the mineral wool industry are low, and do not compel us to amend the MACT.”

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# Alternatives Collection

 Control technology on the collection chamber is cost prohibitive

 A Cost estimate for an incinerator:  

## Incinerator - $1.77 million  

## Pre - Filter - $0.3 million  

## Exhaust Stack - $0.1 million  

## Annual Operating and Maintenance - $1.043 to $1.084 million This is essentially an expenditure of $600,000 per ton of reduction



#  Contrast this expenditure to the settlement between Duke Energy and EPA  

# $85 million to cut 35,000 tons of SO 2 

## This is $2,286 per ton of reduction - BACT standards typically establish a $5,000 - $10,000 per ton range 8

# Available Alternatives Collection – Alternative #1  

## NAIMA recommends a 4 lbs. per ton of melt for formaldehyde and use formaldehyde as surrogate for phenol and methanol 

# Collection – Alternative #2  

## NAIMA recommends emission limits of 4 lbs. per ton of melt for formaldehyde, 2.7 lbs. per ton of melt for phenol, and 2.7 lbs. per ton of melt for methanol

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# Carbonyl Sulfide (COS)

 

# This is a new emission limit; NAIMA questions whether the Brick MACT decision requires imposition of these new requirements  

# Cost of incinerators

 Based on mineral wool experience, each incinerator system could cost between $3 to $6 million  

# EPA proposes 0.05 emission limit

 Concerns over accuracy of current performance data

 Not all companies with incinerators can meet this limit

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# Carbonyl Sulfide (COS)

 

# Lack of scientific support for risk associated with COS

 COS science  

## Limited data on risk arising from COS  

## 80 percent of atmospheric carbonyl sulfide results from natural sources  

## Mineral wool contributes a negligible share of COS  

## No adverse effects have ever been attributed to the relatively high concentrations of COS that occur naturally in the environment  

## COS is a by - product of the mineral wool manufacturing process  

## Incineration of COS increases SO 2 

###  

# These facts mandate consideration of the following alternatives:
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# Carbonyl Sulfide (COS) Alternative #1

 NAIMA recommends an emission limit for carbonyl sulfide of 5 lbs. per ton of melt 

# Alternative #2

 Pursuant to 42 U.S.C . § 112(b)(3)(c), either the EPA Administrator or NAIMA, as petitioner, “delete” carbonyl sulfide from “the list” 

# Alternative #3

 Subcategorization – Subcategorize industry based on melt rate:  

## Greater than 9 tons per hour  

## 6 to 9 tons per hour  

## Less than 6 tons per hour 12

# Carbonyl Sulfide (COS) Alternative #4

 Establish threshold limits that limit the scope of applicability

 The threshold should be 250 tons of COS per year 

# Alternative #5

 Pursuant to 42 U.S.C. § 7412(d)(4), consider a health threshold when establishing a COS emission limit 

# Alternative #6

 Subcategorization – Subcategorize industry to reflect the 

# diversity of the industry and the products it manufactures 13

# Carbonyl Sulfide (COS) Alternative #7

 Use the combined statistical - technical procedure in establishing the COS emission limit, which considers all the emissions data and eliminates outliers and questionable 

# data to come up with an industry average 

# Alternative #8

 Unit Exemption – Any unit not posing a greater than one in 

# a million maximum individual lifetime cancer risk from COS shall be exempted 

# Alternative #9

 Cupolas installed prior to the 1999 implementation of the Mineral Wool MACT Standard are not required to meet the newly proposed COS emission limits 14

# Carbonyl Sulfide (COS) Alternative #10

 Create a health - based risk standard for carbonyl sulfide using the World Health Organization (“WHO”) framework or other 

# alternative 

# Alternative #11

 Offset/Credit – EPA recognizes that improved energy efficiency reduces pollutants. Insulation products increase energy efficiency. Establish the COS emissions limit based on accurate data of the best performing 5 sources, but allow mineral wool companies to offset those emissions based on 

# pounds of product produced. 15

# Hydrogen Fluoride and Hydrochloric Acid

 

# This is a new addition to the Mineral Wool MACT; NAIMA questions whether the Brick MACT decision requires these new requirements  

# Even though these pollutants were identified as HAPs in 1999, the Mineral Wool MACT did not include these as pollutants

 Industry - wide emissions are low

 EPA’s proposed limits are so extremely low as to require installation of control, which is essentially dictating a technology

 Wet scrubbing is cost - prohibitive  

# Specifically, EPA states that Packed Bed Tower Scrubbers are the best control device  

## Wet scrubber equipment costs are expected to exceed $1 to $4 million  

# Wet scrubber operating and maintenance costs are expected to exceed $0.5 to $2 million annually  

## Wet Scrubbers produces wastewater subject to regulations 16

# Hydrogen Fluoride and Hydrochloric Acid Alternative #1 Do not set HF and HCl limits for the Mineral Wool MACT

 Brick MACT decision does not require it 

# Alternative #2 Establish threshold limits that reduce the scope of applicability

 For example, 1,000 tons of HF per year

 For example, 1,000 tons of HCl per year

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# Hydrogen Fluoride and Hydrochloric Acid Alternative #3 Establish an HF or HCl limit based on actual mineral wool emissions data averages – establish a feasible and achievable 

# limit

 Mineral wool emission data is limited and based only on BTEC data collected last year 

# Alternative #4 Adopt the following emission limits for Mineral Wool MACT

 Hydrogen Chloride – 25 tons per year

 Hydrogen Fluoride – 25 tons per year
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# Other Issues

 

# Compliance deadline

 Given the expense and complexity of possible technology installation, NAIMA recommends a 7 year compliance deadline  

# EPA has indicated startup and shutdown is a Brick MACT issue

 NAIMA has addressed this in its May 16, 2011 letter



#  Can EPA give NAIMA any indication of its targets on this issue?

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