“Insert” then choose “Picture” – select your picture.Right click your picture and “Send to back”.The world’s leading sustainability consultancyRoxul, Inc. - EPA MeetingProposed Mineral Wool MACTJuly 25, 2013The world’s leading sustainability consultancyRoermondStartup COS Emissions – July 3, 20132•All samples belowdetetction limit•Tedlar bag samples,analyzed by GC-MS•1 ppm COS = 0.006lb/ton melt or 0.06 lb/hr•Representative sulfurcontent of chargeThe world’s leading sustainability consultancyProposed Mineral Wool MACT - Definitions3New design meets current cupola definitionCupolameans a large, water-cooled metal vessel to which ischarged a mixture of fuel, rock and/or slag, and additives. As thefuel is burned, the charged mixture is heated to amolten state forlater processing to form mineral wool.New design is an open-top cupola [as proposed]Open-top cupolameans a cupola that is open to the outside airand operates with an air flow rate that is unrestricted and at lowpressure. [Proposed]NAIMA Comment: Deleted the phrase “and at low pressure.”Closed-top cupolameans a cupola that operates as a closed (process)systemand has a restricted air flow rate. [Proposed]NAIMA Comment: Replaced the word restricted with controlled.Slag is typically used as a raw material in the processThe world’s leading sustainability consultancyProposed Mineral Wool MACT - Definitions4Proposed Definition of Startup“Startup begins when the coke interspersed with layers ofrock and/or slag and other mineral products are ignited.Startup ends when molten mineral wool begins to flow fromthe cupola.” [Proposed §63.1197(c)]NAIMA Comment: “Startup begins when combustion airisturned on to the cupola. Startup ends when the cupola isoperating within normal parameters, not to exceed four hoursfrom the start of feed of raw materials, and usefulmeltbegins to flow from the cupola.”New Melting TechnologyStartup Begins (Start of NG/Oxy-Fuel Burners)Startup Ends (Thermal Stable Production achieved)The world’s leading sustainability consultancyProposed Mineral Wool MACT - Definitions5Proposed Definition of Shutdown”Shutdown begins when the cupola has reached the end ofthe melting campaign and is empty. No mineral woolglasscontinues to flow from the cupola during shutdown.”[Proposed §63.1197(d)]NAIMA Comment: “Shutdown begins when the feed of rawmaterials is stopped and the combustion air is shutoff.Shutdown ends when the cupola is empty and melt nolonger flows from the cupola spout.”New Melting TechnologyShutdown Begins (Raw Material/Fuel Feed stopped)Combustion air is still required for natural gas/oxy-burners to maintain moltenstate of meltStartup Ends (When Melter is Empty)The world’s leading sustainability consultancyProposed Mineral Wool MACT – SU/SD6■Demonstrating Compliance w/ SU & SD Provisions■Proposed §63.1197(e), “During periods of startups andshutdowns you may demonstrate compliance with the emissionlimits in §63.1178 by keeping records showing thatyouremissions were controlled using air pollution control devicesoperated at the parameters established by the mostrecentperformance test that showed compliance with the standard.”■New Melting Technology “air pollution control device” records■Baghouse (PM) – Bag Leak Detection Alarms■Secondary Combustion Chamber (COS) – Outlet Temperature■Dry Sorbent Injection (HCl, HF) – Outlet Temperature?■Proposed rule indicates incinerator (RTO) firebox temperaturemonitoring for HF and HCl [Proposed 11/25/2011 §63.1182(a),(b)]The world’s leading sustainability consultancyOptions for Compliance Standard - Startup7Work PracticesPropose: Operate furnace in an oxidizingatmosphere or with an oxygen content >21%.Demonstration of Compliance: Calculatedoxygen content based on oxygen andcombustion air flow monitoring.The world’s leading sustainability consultancyOptions for Compliance Standard - Shutdown8Work PracticesPropose: Operate furnace in an oxidizingatmosphere or with an oxygen content >21%.Demonstration of Compliance: Calculatedoxygen content based on oxygen andcombustion air flow monitoring.Alternatively: Use only natural gas fuel duringshutdown.