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MEMORANDUM

Date: August 29, 2014

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. 0213199.002.009

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 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 installed additional control equipment to 

comply with the proposed 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 proposed limits of the rule. All 

of 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 summarizes 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 

Costs

1

(in 

2013 $)

Test 

Frequency

Annualized 

Test Costs

(in 2013 $)

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 

phenol & 

methanol)

Every 

5 years $800

In addition to 

formaldehyde 

testing cost

 

1 Personal communication 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

Cupolasa Combined Collection/Curing

#

Cupolas

Annualized 

(New) COS 

Testing Costb

# Bonded 

Lines

Annualized 

(New) Testing

Costc

Facility Location

Annualized 

(New) HCl/HF 

Testing Costb

Total Facility Incremental 

Annualized (New) Costs

Industrial 

Insulation 

Group (IIG)

Phenix City, AL 1 2,800 800 1 800 $4,400

Thermafiber Wabash IN 2

5,200 1,600 1 800 $7,600

USG 

Interiors

Red Wing, MN 2

5,200 1,600 0 0 $6,800

USG 

Interiors

Walworth, WI 1

2,800 800 0 0 $3,600

Amerrock 

Products

Nolanville, TX 2

5,200 1,600 0 0 $6,800

Isolatek Int’l Huntington, 

IN

2

5,200 1,600 0 0 $6,800

Rock Wool 

Mfg

Leeds, AL 1 2,800 800 1 800 $4,400

Roxul USA Byhalia, MS 2 5,200 1,600 2 1,600 $8,400

SubTotal 13 $34,400 $10,400 5 $4,000 $48,800

a – 8 of the 13 cupolas currently have (or will have) incineration/afterburner controls. 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.