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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 wool fiberglass manufacturing industry to 

comply with the final area source rule requirements. Major 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 manufacturing industry and their 

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

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

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

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

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

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

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

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

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

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

compound emissions. 

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

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

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

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

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

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

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

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

area source rule requirements. 
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II. GAS-FIRED GLASS-MELTING FURNACES 

 

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

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

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

pulled). Therefore, none of the gas-fired glass-melting furnaces 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 annualized cost of $80,000). 

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

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

Emission 

Source HAP 

EPA Test 

Method 

Test 

Costs1 

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 will need to be rebuilt to comply with the 

chromium emission limit in subpart NN, the EPA did not estimate reductions in chromium 

emissions attributable to the final rule. 

Table 2 summarizes the above information and associated cost impacts. 

 

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Personal communication with Mr. Steffan Johnson, US EPA Measurement Policy Group, March 2014. 
Table 2. Summary of Costs for Wool Fiberglass Manufacturing Facilities to Comply with Final Area Source Rule 

Glass-Melting Furnaces Total 

Annual 

O&M 

Costs 

Te

C

Company 

Facility 

Location 

Source 

Type* 

Electric Gas-Fired Total 

# 

# 

subject 

to area 

rule 

Annualized 

Capital 

Cost* 

Steel Shell 

Cold 

Top 

Air 

Gas 

Oxy 

Fuel 

1 CertainTeed Athens, GA Area 1 1 2 1 0 0 12 CertainTeed Chowchilla, CA Area 1 1 1 0 0 13 Guardian Kingman, AZ SynMnr 1 1 0 0 0 4 Johns Manville McPherson, KS Area 5 5 0 0 0 5 Johns Manville Penbryn, NJ Area 3 3 0 0 0 6 Johns Manville Richmond, IN Area 1 1 0 0 0 7 Johns Manville Waterville, OH Area 6 6 0 0 0 8 Johns Manville Willows, CA Area 6 6 0 0 0 9 Johns Manville Winder, GA Area 5 5 0 0 0 

10 Knauf Lanett, AL Area 2 2 2 0 0 211 Knauf Shasta Lake, CA Area 1 1 0 0 0 12 Owens-Corning Delmar, NY Area 2 2 2 0 0 213 Owens-Corning Eloy, AZ Area 2 2 0 0 0 14 Owens-Corning Fairburn, GA Area 3 3 0 0 0 15 Owens-Corning Kansas City, KS Area 1 2 3 2 0 0 216 Owens-Corning Mount Vernon, OH Area 3 3 0 0 0 17 Owens-Corning Salt Lake City, UT SynMnr 2 2 0 0 0 18 Owens-Corning Santa Clara, CA Area 2 2 0 0 0 19 Owens-Corning Nephi, UT SynMnr 2 2 0 0 0 20 Owens-Corning Lakeland, FL Area 2 2 0 0 0 

Totals 31 15 0 8 54 8 $0 $0 $8

Table 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 on 7% interest rate and a reduced equipment (furna