### 1 **MEMORANDUM** Date: J anuary 31 , 201 3 Subject: Estimated Cost Impact for Mineral Wool Production Industry to Comply with Proposed Residual Risk and Technology Review (RTR) Amendments Mineral Wool Production RTR RTIProject No. 021 3199

. 00 1

. 0 0 7 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 limit s . **I. BACKGROUND**  Based on the information provided b y the mineral wool production industry and their primary trade association, North American Insulation Manufacturers Association (NAIMA), there are currentl y 7 facilities in the U.S. producing mineral wool. We are now also aware of a new production facility planned for By halia, 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 faci lities 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 carbonylsulfide (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 line s 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 c ompliance testing based on the test methods included in the final RTR amendments: **Emission Source**  **HAP Test**  **Method Test Cost**  **s**

**(in 201 1**  **$) Test** 

**Fre q**  **** **uency Annualized**  **Test Costs (in 201**  **1 $)**  **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 $1 5 ,000 (combined p henol & methanol) 

### Every

5 years $ 3 , 0 00 $12,000 for

each additional test ($2,400 annualized)

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## Table 1. **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 3 , 0 00 $ 6 ,600
Thermafiber Wabash IN 2 5 , 20 0 1,6 00 1 3,0 00 $ 9 , 8 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 3,0 00 $ 6 ,600 Roxul USA Byhalia, MS 2 5 , 2 00 1,600 2 5,400 $ 12 ,200

SubTotal 1 3 $ 34, 4 00 $ 10 , 4 00 5 $ 14 , 4 00 **$ 59**  **, 2**  **00**

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.