----

Roermond Startup COS Emissions - July 3, 2013 


Sampling time COS emission Sampling [h:min] (ppm]

1 16:20-16:30 h <1 

2 16:30-16:40 h <1 

3 16:40 -16:50 h <1 

4 16:50-17:00 h <1 

5 17:00-17:10 h <1 

6 17:10-17:20 h <1 

7 17:20 -17:30 h <1 

8 17:30 - 17:40 h <1

9 17:40 -17:50 h <1

Average <1

• 	 All samples below 

detetction limit 

• 	 Tedlar bag samples, 

analyzed by GC-MS 

• 	 1 ppm COS =0.006 

Ib/ton melt or 0.06 Ib/hr 

• 	 Representative sulfur 

content of charge 

The world's leading sustainability consultancy 	 ERM 

2 
Proposed Mineral Wool MACT - Definitions 

• New design meets current cupola definition 

• 	 Cupola means a large, water-cooled metal vessel to which is 

charged a mixture of fuel, rock and/or slag, and additives. As the 

fuel is burned, the charged mixture is heated to a molten state for 

later processing to form mineral wool. 

• New design is an open-top cupola [as proposed] 

• 	 Open-top cupola means a cupola that is open to the outside air 

and operates with an ai r flow rate that is unrestricted and at low 

pressure. [Proposed] S.--h.-tj--' 

• NAIMA Comment: Deleted the phrase "and at low pressure.~ 

• 	 Closed-top cupola means a cupola that operates as a closed (process) system 

and has a restricted air flow rate. [Proposed] 

• 	 NAIMA Comment: Replaced the word restricted ~ 

• Slag is typically used as a raw material in the process 

The wor/d's leading sustainability consultancy 	 ERM 

3 
Proposed Mineral Wool MACT - Definitions 

• 	 Proposed Definition of Startup 

• 	 "Startup begins when the coke interspersed with layers of 

rock and/or slag and other mineral products are ignited. 

Startup ends when molten mineral wool begins to flow from 

the cupola." [Proposed §63.1197(c)] 

NAIMA Comment: "Startup begins when combustion air is 

turned on to the cupola. Startup ends when the cupola is 

operating within normal parameters, not to exceed four hours 

~ 

. from the start of feed .. of raw materials,;'and useful melt 


e . s to flow from the 

~ 

cupola." 


• 	 New Melting Technology 

• 	 Startup Begins (Start of NG/Oxy-Fuel Burners) 

• 	 Startup Ends (Thermal Stable Production achieved) 

~ 

~ 

The world's leading SllsramaOlllfV COT/SUI/ii' 	 ERM 

4 
Proposed Mineral Wool MACT - Definitions 

• 	 Proposed Definition of Shutdown 

• 	 "Shutdown begins when the cupola has reached the end of 

the melting campaign and is empty. No mineral wool glass 

continues to flow from the cupola during shutdown." 

[Proposed §63.1197(d)] 

• 	 NAIMA COrTlment: "Shutdown begins when the feed of raw 

materials is stopped and the combustion air is shut off. 

~\ Shutdown ends when the cupola is empty and melt no 

longer flows from the cupola spout." 

• 	 New Melting Technology 

• Shutdown Begins (Raw Material/Fuel Feed stopped) 

• 	 Combustion air is still required for natural gas/oxy-burners to maintain molten 

state of melt 

• Startup Ends (When Melter is Empty) 

The world's leading sustainability consultancy 	 ERM 

5 
Options for COll1pliance Standard - Startup 


• Work Practices 

• Propose: Operate furnace in an oxidizing 

atmosphere or with an oxygen content >21 0/0. 

• Demonstration of Compliance: Calculated 

oxygen content based on oxygen and 

combustion air flow monitoring. 

........... .,. 
 ····t····· ..·· 

. .... -". --i­ • +- -'-"'­

The war/d's leading sustainability consultancy ERM 

7 
Options for COll1pliance Standard - Shutdown 

• Work Practices 

• Propose: Operate furnace in an oxidizing 

atmosphere or with an oxygen content >21 0/0. 

• Demonstration of Compliance: Calculated 

oxygen content based on oxygen and 

combustion air flow monitoring. 

• Alternatively: Use only natural gas fuel during 

shutdown. 

';,. 

-f +--: ...j. 

•t-- -.I. •

The world's leading sustainability consultancy ERM 

8