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MEMORANDUM 

Date: January 31, 2013 

 

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

Proposed Residual Risk and Technology Review (RTR) Amendments 

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 facilities to comply with the final RTR 

amendments and associated emission limits. 

I. BACKGROUND 

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

trade association, North American Insulation Manufacturers 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 the construction permit review stage and we 

have included it as part of the estimated cost impacts. Based 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 facilities 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 limits that will apply to collection 

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

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

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

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

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

testing costs. Table 1 summarizes the above information and the associated cost impacts. 
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II. COMPLIANCE TESTING COSTS 

Mr. Steffan Johnson of EPA’s Measurement Policy Group provided 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) 
Table 1. Summary of Mineral Wool Production Facilities Costs to Comply with RTR Amendm

Cupolas

a Combined Collection/Curing

# 

Cupolas 

Annualized 

(New) COS 

Testing Cost

b

# Bonded 

Lines 

Annualized 

(New) Testing 

Cost

c

Facility Location 

Annualized 

(New) HCl/HF 

Testing Cost

b

Total FAnnual

Industrial Insulation Group (IIG) 

Phenix City, AL 1 2,800 800 1 3,000 

Thermafiber Wabash IN 2 5,200 1,600 1 3,000 USG Interiors 

Red Wing, MN 2 5,200 1,600 0 0 

USG Interiors 

Walworth, WI 1 2,800 800 0 0 

Amerrock Products 

Nolanville, TX 2 5,200 1,600 0 0 

Isolatek Int’l Huntington, 

IN 

2 5,200 1,600 0 0 

Rock Wool Mfg 

Leeds, AL 1 2,800 800 1 3,000 

Roxul USA Byhalia, MS 2 5,200 1,600 2 5,400 

SubTotal 13 $34,400 $10,400 5 $14,400 

a – 8 of the 13 cupolas currently have (or will have) incineration/afterburner controls. None of the facilities are expected 

equipment or material cost impacts to meet the proposed emission limits. 

b 

– Cupola testing costs reflect incremental (new) costs for COS, HF, and HCl testing; current test requirements for PM n

c – Collection/curing costs reflect incremental costs for phenol and methanol testing; current test requirements for form