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MEMORANDUM

Date: August 9, 2011

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. 0210426.010

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 proposed 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 estimate that all 7 of those facilities 

will incur additional testing cost to demonstrate compliance with the new (proposed) carbonyl

sulfide (COS), hydrogen fluoride (HF), and hydrogen chloride (HCl) emission limits for cupolas. 

One facility will also incur additional annual costs to purchase low-sulfur raw materials in order to 

comply with the proposed COS emission limit for cupolas. We also estimate that the 3 facilities 

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

revised formaldehyde and new (proposed) phenol and methanol emission limits that will apply to 

collection and curing operations combined. Table 1 summarizes the above information and the 

associated cost impacts.
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Table 1. Summary of Mineral Wool Production Facilities Costs to Comply with RTR Amendments 

Cupolasa

Total Facility 

Costs

Low-Sulfur Mat'ls # Testing Collection/Curing

Facility Location Incremental Cost Cupolas Costb# Bonded Lines Test Costc

Industrial Insulation 

Group (IIG)

Phenix City, AL

0 1 18,000 1 14,000 32,000

Thermafiber Wabash IN

0 2 34,000 1 14,000 48,000

USG Interiors Red Wing, MN

0 2 34,000 0 0 34,000

USG Interiors Walworth, WI

0 1 18,000 0 0 18,000

Amerrock Products Nolanville, TX

0 2 34,000 0 0 34,000

Isolatek Int’l Huntington, IN

0 2 34,000 0 0 34,000

Rock Wool Mfg Leeds, AL

360,000 1 18,000 1 14,000 392,000

SubTotal $360,000 11 $190,000 3 $42,000 $592,000

a – 6 of the 11 cupolas currently have incineration control (RTOs); Rock Wool is the only facility that is not currently meeting the proposed COS limit

based on emission testing results provided by industry. Low-sulfur material incremental cost based on an estimated 50% increase (per ton) of slag 

costs. No other facility is expected to have any additional equipment or material cost impacts.

b – Cupola testing costs reflect incremental costs for COS, HF, and HCl testing; 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.
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II. COMPLIANCE TESTING COSTS

Mr. Stef Johnson of EPA’s Measurement Policy Group provided the following estimates for 

compliance testing based on the test methods being proposed in the RTR amendments:

Emission 

Source

HAP Test Method Test Cost Comment

Cupola

COS 318 $14,000 $12,000 for each 

additional test

HF and HCl 320 

(add-on to 

M318 FTIR)

$4,000

(combined 

HF/HCl)

In addition to COS 

testing cost

Collection/ 

Curing 

(combined)

Phenol and Methanol 

(already testing for 

formaldehyde)

318 $14,000

(combined 

Phenol & 

Methanol)

$12,000 for each 

additional test

III. LOW- SULFUR RAW MATERIAL COSTS

Based on the emission test data provided in the ICR responses, we estimate that only one facility

(Rock Wool Manufacturing) is not currently meeting the proposed COS emission limit for 

cupolas. We assumed that the least costly compliance option would be for the facility to switch to 

low-sulfur raw materials to reduce the amount of COS generated in the cupolas. 

Rock Wool reported that slag comprises approximately 90% of the raw material going into their 

cupola. Since there is no readily available source of low-sulfur slag, we estimated an incremental 

cost of 50% more (per ton) for switching to other low-sulfur raw materials. No raw material cost 

information was provided by any of the companies, so we assumed a 50% cost increase per ton 

and then used Rock Wool’s reported annual slag usage to calculate an annual raw material cost 

increase of $360,000. (Production data and raw material usage and costs are considered 

confidential business information).