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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 they 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

1
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

NonbondedProduct 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

4
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.”

7
Alternatives

Collection

 Control technology on the collection chamber is costprohibitive

 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 SO2

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

9
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

10
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 SO2

 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

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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

18
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?

19