11 Canal Center Plaza ▪ Suite 103 ▪ Alexandria, Virginia 22314 ▪ Tel: (703) 684-0084 ▪ Fax: (703) 684-0427

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
Mr. David Reeves

October 3, 2014

Page 2

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 
Mr. David Reeves

October 3, 2014

Page 3

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 noncompetitive 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.1 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

 

1 59 Fed. Reg. 25,387, 25,391 (May 16, 1994).