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Roxul, Inc. - EPA MeetiProposed Mineral Wool MACT

July 25, 2013
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Roermond Startup COS Emissions – Jul2

• All samples 

detetction li

• Tedlar bag s

analyzed by 

• 1 ppm COS 

lb/ton melt o

• Representa

content of c
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Proposed Mineral Wool MACT - Defini3

 New design meets current cupola definition

 Cupola means a large, water-cooled metal vessel to w

charged a mixture of fuel, rock and/or slag, and additivfuel is burned, the charged mixture is heated to a moltlater processing to form mineral wool. 

 New design is an open-top cupola [as propo

 Open-top cupola means a cupola that is open to the o

and operates with an air flow rate that is unrestricted apressure. [Proposed]

 NAIMA Comment: Deleted the phrase “and at low pres

 Closed-top cupola means a cupola that operates as a closed (pro

and 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 pro
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Proposed Mineral Wool MACT - Defini4

 Proposed Definition of Startup

 “Startup begins when the coke interspersed with la

rock and/or slag and other mineral products are igStartup ends when molten mineral wool begins to the cupola.” [Proposed §63.1197(c)] 

 NAIMA Comment: “Startup begins when combusti

turned on to the cupola. Startup ends when the cuoperating within normal parameters, not to exceed 

from the start of feed of raw materials, and useful begins to flow from the cupola.”

 New Melting Technology

 Startup Begins (Start of NG/Oxy-Fuel Burners) Startup Ends (Thermal Stable Production achieved
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Proposed Mineral Wool MACT - Defini5

 Proposed Definition of Shutdown

 ”Shutdown begins when the cupola has reached t

the melting campaign and is empty. No mineral wcontinues to flow from the cupola during shutdown[Proposed §63.1197(d)]

 NAIMA Comment: “Shutdown begins when the fe

materials is stopped and the combustion air is shuShutdown ends when the cupola is empty and melonger flows from the cupola spout.”

 New Melting Technology

 Shutdown Begins (Raw Material/Fuel Feed stopped

 Combustion air is still required for natural gas/oxy-burners to maint

state of melt

 Startup Ends (When Melter is Empty)
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Proposed Mineral Wool MACT – SU/SD 6

■ Demonstrating Compliance w/ SU & SD Provision

■ Proposed §63.1197(e), “During periods of startups a

shutdowns you may demonstrate compliance with thlimits in §63.1178 by keeping records showing that yemissions were controlled using air pollution control operated at the parameters established by the most performance test that showed compliance with the s

■ New Melting Technology “air pollution control device

■ Baghouse (PM) – Bag Leak Detection Alarms■ Secondary Combustion Chamber (COS) – Outlet Temp■ Dry Sorbent Injection (HCl, HF) – Outlet Temperature? 

■ Proposed rule indicates incinerator (RTO) firebox tem

monitoring for HF and HCl [Proposed 11/25/2011 §63
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Options for Compliance Standard - Star7

 Work Practices

 Propose: Operate furnace in an oxid

atmosphere or with an oxygen conte

 Demonstration of Compliance: Calc

oxygen content based on oxygen ancombustion air flow monitoring.
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Options for Compliance Standard - Shu8

 Work Practices

 Propose: Operate furnace in an oxid

atmosphere or with an oxygen conte

 Demonstration of Compliance: Calc

oxygen content based on oxygen ancombustion air flow monitoring. 

 Alternatively: Use only natural gas fu

shutdown.