1 MEMORANDUM

Date: January 31, 2013

Subject: Estimated Cost Impact for Mineral Wool Productio n Industry to Comply with

Proposed Residual Risk and Technology Review (RTR) Amendm ents

Mineral Wool Production RTR

RTI Project No. 0213199.001.007

From: Dave Reeves, RTI International

To: Susan Fairchild

OAQPS/SPPD/NRG (D243-02)

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

The purpose of this memorandum is to present the estimated costs related to the mineral wool

production source category for their processes and faciliti es to comply with the final RTR

amendments and associated emission limits.

I. BACKGROUND

Based on the information provided by the mineral wool productio n industry and their primary

trade association, North American Insulation Manufactur ers Association (NAIMA), there are

currently 7 facilities in the U.S. producing mineral wool. We are now also aware of a new

production facility planned for Byhalia, MS that is in t he construction permit review stage and we

have included it as part of the estimated cost impacts. B ased on the emissions test data provided

by the industry, none of the existing facilities will have install additional control equipment to

comply with the final rule requirements.

We estimate that all 8 of the mineral wool production fa cilities will incur additional testing costs

to demonstrate compliance with the new carbonyl sulfide ( COS), hydrochloric acid (HCl), and

hydrofluoric acid (HF) emission limits for cupolas. We also estimate that the 3 existing facilities

with bonded product lines will incur additional testing costs to demonstrate compliance with the

revised formaldehyde and new phenol and methanol emission lim its that will apply to collection

and curing operations combined. We only have general inform ation on the planned new facility

but to estimate costs conservatively, we assume in t his cost estimation that it would operate two

cupolas and two bonded product lines that would be subject to the f inal limits of the rule. All of

the new testing associated with the final rule requirem ents is based on a 5-year frequency.

Therefore, the initial (first year) testing costs wer e divided by 5 to come up with “annualized”

testing costs. Table 1 summarizes the above informatio n and the associated cost impacts.2

II. COMPLIANCE TESTING COSTS

Mr. Steffan Johnson of EPA’s Measurement Policy Group pr ovided the following estimates for

compliance testing based on the test methods included in the final RTR amendments:

Emission

Source HAP Test

Method Test Costs

(in 2011 $) Test

Frequency Annualized

Test Costs

(in 2011 $) Comment

Cupola COS 318 $14,000 Every

5 years $2,800 $12,000 for

each additional

test ($2,400

annualized)

HCl and HF 320

(add-on

to M318

FTIR) $4,000 Every

5 years $800 In addition to

COS testing

cost

Collection/

Curing

(combined) Phenol and

Methanol

(already testing

formaldehyde) 318 $15,000

(combined

phenol &

methanol) Every

5 years $3,000 $12,000 for

each additional

test ($2,400

annualized)3Table 1. Summary of Mineral Wool Production Facilities Costs to Comply with RTR AmendmentsCupolasaCombined Collection/Curing#CupolasAnnualized(New) COSTesting Costb# BondedLinesAnnualized(New) TestingCostcFacility LocationAnnualized(New) HCl/HFTesting CostbTotal Facility IncrementalAnnualized (New) CostsIndustrialInsulationGroup (IIG)Phenix City, AL1 2,800800 1 3,000 $6,600ThermafiberWabash IN25,200 1,600 1 3,000 $9,800USGInteriorsRed Wing, MN25,200 1,600 0 0 $6,800USGInteriorsWalworth, WI12,800 800 0 0 $3,600AmerrockProductsNolanville, TX25,200 1,600 0 0 $6,800Isolatek Int’lHuntington,IN25,200 1,600 0 0 $6,800Rock WoolMfgLeeds, AL1 2,800 800 1 3,000 $6,600Roxul USAByhalia, MS2 5,200 1,600 2 5,400 $12,200SubTotal13$34,400 $10,400 5 $14,400$59,200a – 8 of the 13 cupolas currently have (or will have) incineration/afterburner controls. None of the facilities are expected to have any additionalequipment or material cost impacts to meet the proposed emission limits.b–Cupola testing costs reflect incremental(new)costs for COS, HF, and HCltesting; current test requirements for PM not included.c – Collection/curing costs reflect incremental costs for phenol and methanol testing; current test requirements for formaldehyde not included.