# 1 MEMORANDUM

Date: June 15, 2015

Subject: Costs and Emission Reductions for the Final Wool Fiberglass Manufacturing

NESHAP - Area Sources

From: Susan Fairchild

OAQPS/SPPD/NRG (D243-02)

U.S. Environmental Protection Agency

To: Docket EPA-HQ-OAR-2010-1042

This memorandum presents the estimated costs for the woo l fiberglass manufacturing industry to

comply with the final area source rule requirements. Ma jor sources are regulated under Part 63

Subpart NNN; area sources will be regulated under Part 63, Subpart NN.

I. BACKGROUND

Based on the information provided by the wool fiberglass m anufacturing industry and their

primary trade association, North American Insulation Manufacturers Association (NAIMA), there

are currently 30 facilities in the U.S. producing wool fiber glass. A letter from NAIMA dated June

8, 2011, stated “non-formaldehyde binder products represent the v ast majority of the industry” and

“all major sources have already converted or have announc ed plans to convert to non-phenol

formaldehyde binders.” Based on a review of the current per mit status of all sources and recent

information provided by industry, 10 facilities are major so urces (subject to the existing MACT

rule, subpart NNN) and 20 facilities are area source faci lities. These 30 facilities operate a total of

54 glass-melting furnaces. Five of the area source faciliti es operate 8 furnaces which meet the

applicability requirements in the final area source NESH AP (subpart NN). Based on our current

emissions data, none of the area source facilities w ill be required by the rule to reduce chromium

compound emissions.

Industry comments on the proposed major source rule amen dments (76 FR 72770) stated that

some of the major source facilities have already swit ched some or most of their lines to non-HAP

binders and would no longer be subject to subpart NNN. With t he phase-out of phenolformaldehyde binders, these sources will also be redesigna ted as area sources. While industry

sources also predicted before proposal of the RTR amendm ents to NNN that no major sources

would exist by the end of 2012, we now believe this to be inac curate. Table 2 provides further

information on wool fiberglass furnaces by furnace type a nd whether furnaces would currently be

subject to the area source rule under subpart NN. The foll owing cost impacts are based on the

estimated five facilities and 8 gas-fired glass-melting fur naces that would be subject to the final

area source rule requirements.

# 2

II. GAS-FIRED GLASS-MELTING FURNACES

We estimate that there are currently 8 gas-fired furnace s located at five facilities designated as

area sources. We also estimate that none of the gas-f ired furnaces located at area source facilities

emit chromium compounds above the final chromium emiss ion limit (2.5E-04 lb/ton of glass

pulled). Therefore, none of the gas-fired glass-melting f urnaces at area sources must be rebuilt to

comply with subpart NN. However, the facilities must conduct compliance testing for each

furnace (annualized cost of $10,000 per furnace for a total annua lized cost of $80,000).

The annual cost for compliance testing is estimated be low in Table 1.

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

Emission

Source HAP EPA Test

Method Test

Costs 1 

# Test

Frequency Annualized

Test Costs

Gas-Fired

Glass- Melting

Furnace Chromium

Compounds 29 $10,000 Annual $10,000

Because none of the furnaces at area source standards wi ll need to be rebuilt to comply with the

chromium emission limit in subpart NN, the EPA did no t estimate reductions in chromium

emissions attributable to the final rule.

Table 2 summarizes the above information and associated cost impacts.

1 

# Personal communication with Mr. Steffan Johnson, US EPA Measurement Policy Group, March 2014.3Table 2. Summary of Costs for Wool Fiberglass Manufacturing Facilities to Comply with Final Area Source RuleGlass-Melting FurnacesTotal Facility CostAnnualO&MCostsCrTestingCostCostEffectiveness($ / lb Crreduced)CompanyFacilityLocationSourceType*ElectricGas-FiredTotal##subjectto arearuleAnnualizedCapitalCost*TotalAnnualFacilityCostSteelShellColdTopAirGasOxyFuel1 CertainTeed Athens, GAArea11210010,00010,000NA2 CertainTeed Chowchilla, CAArea1110010,00010,000NA3 Guardian Kingman, AZSynMnr1100000-4 Johns Manville McPherson, KSArea5500000-5 Johns Manville Penbryn, NJArea3300000-6 Johns Manville Richmond, INArea1100000-7 Johns Manville Waterville, OHArea6600000-8 Johns Manville Willows, CAArea6600000-9 Johns Manville Winder, GAArea5500000-10 Knauf Lanett, ALArea2220020,00020,000NA11 Knauf Shasta Lake, CAArea1100000-12 Owens-Corning Delmar, NYArea2220020,00020,000NA13 Owens-Corning Eloy, AZArea2200000-14 Owens-Corning Fairburn, GAArea3300000-15 Owens-Corning Kansas City, KSArea12320020,00020,000NA16 Owens-Corning Mount Vernon, OHArea3300000-17 Owens-Corning Salt Lake City, UTSynMnr2200000-18 Owens-Corning Santa Clara, CAArea2200000-19 Owens-Corning Nephi, UTSynMnr2200000-20 Owens-Corning Lakeland, FLArea2200000-Totals311508548$0$0$80,000$80,000NATable 2 notes:- Major sources will not be subject to the area source rule requirements and any associated control/compliance costs are not included.- JM Waterville, OH facility also has 40 pot & marble furnaces which are not included in this analysis.- Capital cost = $10.7M per furnace (using replacement cost method); annualized capital cost based on7% interest rate and a reduced equipment (furnace) life from 10 to 7 years.