### 1 MEMORANDUM

Date: August 29

, 201 4

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. 021 3199

. 00 2

. 0 0 9

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 limit s

.

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

h ave 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 ed additional control equipment to
comply with the proposed rule requirements.

We estimat e 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 tha t 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 line s that would be subject to the proposed limits of the rule. All

o f the new testing associated with the proposed 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 2 at the end of this memorandum summari zes the above information and the
associated cost impacts.

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II. COMPLIANCE TESTING COSTS

The annual cost estimates for compliance testing is estimated below in Table 1:

Table 1. Summary of Compliance Testing Costs (2013 Dollars)

Emission

Source HAP Test

Method Test

Cost s 1 

### (in

201 3 $) Test

Fre q

uency Annualized

Test Costs (in 201 3 $) 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

(part of

M318 FTIR) $ 4 ,000

(combined

p henol &

m ethanol) 

### Every

5 years $ 8 00 In addition to formaldehyde testing cost

1 Personal commun ication with Mr. Steffan Johnson, US EPA, Measurement Policy Group, March 2014.

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## Table 2 . Summary of Mineral Wool Production Facilities Costs to Comply with RTR Amendments

Cupolas a Combined Collection/ Curing

# Cupolas Annualized

(New) COS
Testing Cost b # Bonded

Lines Annualized

(New) Test ing

Cost c
Facility Location Annualized (New) HCl/HF
Testing Cost b Total Facility Incremental Annualized (New) Costs

Industrial

Insulation

Group (IIG) Phenix City, AL 1 2,800 800 1 8 00 $ 4,4 00

Thermafiber Wabash IN 2 5

, 20 0 1,6 00 1 8 00 $ 7,6 00

USG

Interiors Red Wing, MN 2 5

, 2 00 1,6 00 0 0 $ 6

, 8 00

USG

Interiors Walworth, WI 1 2,8 00 8 00 0 0 $ 3

, 6 00

Amerrock

Products Nolanville, TX 2 5

, 2 00 1,6 00 0 0 $ 6

, 8 00

Isolatek Int ’l Huntington,

IN 2 5

, 2 00 1,6 00 0 0 $ 6

, 8 00

Rock Wool

M fg Leeds, AL 1 2,8 00 8 00 1 8 00 $ 4

, 4 00

Roxul USA Byhalia, MS 2 5

, 2 00 1,600 2 1,600 $ 8,4 00

SubTotal 1 3 $ 34, 4 00 $ 10

, 4 00 5 $ 4,0 00 $ 48,800

a

– 8 of the 1 3 cupolas currently have (or will have) incineration /afterburner control s. None of the facilities are expected to have any additional
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 not included.

c

– Collection/curing costs reflect incremental costs for phenol and methanol testing; current test requirements for formaldehyde not included.