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I~IMA NC)RTH AME1'I1c:.AN INSUL.ATION 


MI\NUP'Ac:.TU IUUt!S A.5SQc:.IATION 


VIA E-MAIL AND OVERNIGHT MAIL 

August 20,2013 

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 the 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 cullet was used for: 

2010: ________ 


2011: 


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 90 percent ofthe industry: 

. 44 Canal Center Plaza • Suite 310 • Alexandria, Virginia 22314 • Tel: (703) 684-0084 • Fax: (703) 684-0427 
Ms. Susan Fairchild 


August 20, 2013 


N Page 2 

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Weighted 

Average 

What was the cost per ton of purchased Sfullet for: - 2010 / crt" ·Q1 $ 

2011 I 0 I . Ilj 88. $ 94.20 

~·I\.c.w it.u ,.fk~ I b....v,; k-:J. £.H . ~J..(.rfllt+~ 

2. What was the cost per ton of glass for batch raw materials excluding cullet for: 'I~~ 2010 '1L'oO $ 171.96 

2011 i~· 00 $ 177.15 

3. What was your overall batch cost per ton of glass for: ;""\ . ~\\.l \ 

, $ 145.59 

2011 I ~<.K .11CO 

2010 	 J 14-1.Va 

$ 	 151.52 ~ 

\ 	 '(A:l ""'flll.n 

4. What would your cost per ton of glass batch have been if no purchased cullet was V 'S. Zused for: ,Jt 

2010 \ 3~ ¥;}"z.. $ 151.921 ) 

1. 2011 ( 45"' '11 $ 158.81, ",fa, 

~------------------------------------~--~----~------~ 5~~~ . These numbers illustrate the aggregated costs of purchased cullet and batch materials for the t; I ,,:; if, 

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

expensive than other batch materials, it is not significant enough so as to prevent individual ~~"7f c· 

companies from cutting out or reducing chrome-containing cullet to avoid surpassing a stringent • \ ..:.. ~ 

chromium emission limit, especially given the costly and unproven alternatives for reducing 5D a "'f F1 

chromium emissions at facilities. that may need to do so. In fact, individual company cost data il '1.12-. J. r ~ome instances showed a much narrower difference between cullet and virgin batch, including, 6~ 

i2.n at least one case: a higher total cost of using cullet than if all batch were utilized. . C!A.\.\L.t 

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

Sincerely, 

f+v~Z;.~

Angus E. Crane 


Executive Vice P:t;esident, General Counsel 


cc: 	 Mr. 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 --W' \~. (...A:;..l..l _)-"" I.'" -L~ !?~J.d 4930 Old Page Road I ~ (J U V ft ," i 

Durham, NC 27703 vvJ-~ ,I ~-h> &"lv+C[ fl.. ( e <2-{....... C,· , 

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