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- MAIL AND OVERNIGHT MAIL

August 20 , 201 3

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

RE: EPA’s Request For Cullet and Batch Cost Data

Dear Ms. Fairchild:

In response to t he Environmental Protection Agency ’s (“EPA”) request for cullet and batch

costs, the North American Insulation Manufacturers Association (“ NAIMA ”) created the

following questionnaire:

1. What was the cost per ton of purchased cullet for:

2010:

____________________ 2011:

____________________

2. What was the cost per ton of glass for batch raw materials excluding cullet for:

2010:

____________________ 2011:

____________________

3. What was your overall batch cost per ton of glass for:

2010:

____________________ 2011:

____________________

4. What would your cost per ton of glass batch have been if no purchased culle t was used for:

2010:

____________________ 201 1:

____________________

The questionnaire was sent out to all five fiber glass companies. The companies submitted data

to Kirkland & Ellis, to protect and preserve the confidentiality of the data, and Kirkland & Ellis

aggregated the data and calculated industry average values weighted by the most recent year ’ s

sales data.

While the data was requested from five companies, some responsive data from one company was

incomplete

. Therefore the summary of data set forth below represents four companies that

comprise approximately 9 0 percent of the industry:Ms . Susan Fairchild

August 20 , 2013

Page 2

Weighted

Average

1. What was the cost per ton of purchased cullet for:

2010 $ 88

. 82

2011 $ 9 4

. 20

2. What was the cost per ton of glass for batch raw materials excluding cullet

for:

2010 $ 171

. 9 6

2011 $ 177 .1 5

3. What was your overall batch cost per ton of glass for:

2010 $ 14 5

. 59

2011 $ 1 51

. 52

4. What would your cost per ton of glass batch have been if no purchased

cullet was used for :

2010 $ 1 51

. 92

2011 $ 15 8

. 81

These numbers illustrate the aggregated costs of purchased cullet and batch materials for the

years indicated for NAIMA member companies. While the data show that cullet is less

expensive than other batch materials, it is not significant enough so as to prevent individual

companies from cut ting out or reduc ing chrome

- containing cullet to avoid surpassing a stringent

chromium emission limit , especi ally given the costly and unproven alternatives for reducing

chromium emissions at facilities that may need to do so

. In fact, individual company cost data in

some instances showed a much narrower difference between cullet and virgin batch, including

, in at least one case

, a higher total cost of using cullet than if all batch were utilized.

Please do not hesitate to contact the undersigned if you have any questions.

Sincerely,

Angus E. Crane

Executive Vice President, General Counsel

cc: Mr. Keith W. B arnett

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