From: Fairchild, Susan

To: Higgins, Cortney

Cc: Reeves, David
Subject: RE: Request for Documents cited in Mineral Wool Supplemental NPRM

Attachments: EIA SUPP PROP MW WF RTR report.docx Mineral Wool Cost Impacts_1-31-13.docx Wool Fiberglass Secondary Impacts Major 2.7.13.docx Wool Fiberglass RTR Cost Impacts 2-28-13.docx Wool Fiberglass Area Souce Cost Impacts.docx Wool Fiberglass Secondary Impacts Area.docx



### Dear Cortney:

I am attaching the documents you requested:

FOR BOTH MAJOR SOURCE RULES

The Economic Impact And Small Business Analysis –Mineral Wool and Wool Fiberglass RTR NESHAPs

SPECIFIC ONLY TO MINERAL WOOL (DDD)

Cost Impacts And Emission Reductions For Mineral Wool (DDD)

SPECIFIC ONLY TO WOOL FIBERGLASS (NNN)

Cost Impacts And Emission Reductions For Wool Fiberglass Major Sources (NNN)

Secondary Impacts for Wool Fiberglass Manufacturing NESHAP (NNN)

SPECIFIC ONLY TO THE WOOL FIBERGLASS AREA SOURCE RULE (NN)

Cost Impacts And Emission Reductions For Wool Fiberglass Area Sources(NN)

Secondary Impacts for Wool Fiberglass Manufacturing NESHAP (NN)

The document for the Development of Background Information on Proposed Area Source Emissions
Limits (p. 64) is still under legal review. I’ll send it to you as soon as that review is completed.

Susan Fairchild

Senior Environmental Scientist

(919) 541-5167

USPS Address:

OAQPS/SPPD/MMG

Mail Code D 243-04

Research Triangle Park, NC 27711

From: Higgins, Cortney [ mailto:Cortney_Higgins@omb.eop.gov ]

Sent: Thursday, February 28, 2013 10:53 AM

To: Barnett, Keith

Cc: Fairchild, Susan; VanLare, Paula Subject: RE: Request for Documents cited in Mineral Wool Supplemental NPRM

### Hi Keith,

Can you also send me the following:

The Reg Flex section of the preamble refers to “the economic impact and small business analysis that

is in the docket.

Regards,

Cortney

From: Higgins, Cortney

Sent: Thursday, February 28, 2013 10:40 AM

To: Barnett.Keith@epamail.epa.gov

Cc: Fairchild.Susan@epamail.epa.gov ; VanLare.Paula@epamail.epa.gov Subject: Request for Documents cited in Mineral Wool Supplemental NPRM



### Hi Keith,

Can you send me the following supporting documents cited in the Mineral Wool supplemental

proposal? If they are not yet ready, can you tell me when they will be?

- 

### Development of Background Information on Proposed Area Source Emissions Limits (p. 64)

- 

### Costs and Emission Reductions for the Proposed Wool Fiberglass Manufacturing NESHAP -
Area Sources (p. 69)

- 

### Secondary Impacts of the Proposed Wool Fiberglass Manufacturing NESHAP - Area Sources
(p.78)

- 

### Cost Impacts of the Proposed NESHAP RTR Amendments for the Wool Fiberglass
Manufacturing Source Category (p. 96)

Thanks,

CortneyDRAFT

– For Review by EPA Workgroup

1 U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

J anuar y 201 3

Economic Impact and Small Business Analysis

– Mineral Wool and Wool Fiberglass RTR NESHAP s

This report is the economic impact analysis for the proposed Mineral Wool Production

and Wool Fiberglass Manufacturing Risk and Technology Review (RTR) standard s . Th ese

standard s are to be pro posed on March 15 , 201 3

. Promulgation of these standards is scheduled

to occur on January 30, 2014. The report presents im pacts to firms affe cted by the

requirements in the proposed rule s and their consumers. Impacts to small firms are accounted

for in adherence to the Regulatory Flexibility Act as amended by the Small Business Regulatory

Enforcement Fairness Act (SBREFA). These industries are found in NAICS 327993

.

This action is a reproposal . On November 25, 2011 the EPA proposed revisions to the

Mineral Wool and th e Wool Fiberglass Manufacturing NESHAP, 40 CFR part 63, subparts DDD

and NNN, respectively, to address the results of the RTR that the EPA is required to conduct

under sections 112(d)(6) and 112(f)(2)(76 FR 72812). The limits in those proposed amendments

w ould apply only to major sources, that is, sources emitting at least 10 tons per year of a single

HAP or 25 tons per year of any combination of HAP; area sources emit less than this amount.

In the November 2011 proposal, the Agency noted that since promulg ation of the 1999

NESHAP, sources had modified certain processes by using HAP

- free binders instead of phenolic

formaldehyde binders (76 FR 72777). When a facility completely phases out its use of phenol

formaldehyde binders it generally becomes an area sou rce because it no longer has the

potential to emit at least 10 tons per year of a single HAP or 25 tons per year of any

combination of HAP. While 20 of the existing 30 wool fiberglass facilities have become area

sources through the phase

- out of phenol/form aldehyde in the binders, the furnaces at these

sources continue to emit chromium and other HAP metal compounds. This demonstrates that

emissions from furnaces are completely separate and independent from emissions on bonded

lines. Further, while replacemen t of phenol/formaldehyde binders with non

- HAP binders is an Formatted: Line spacing: 1.5 linesDRAFT

– For Review by EPA Workgroup

2 environmentally responsible, or ‘green’ choice within the wool fiberglass manufacturing

industry, furnaces at area sources may continue to emit chromium and other HAP metal

compounds which are not currently required to be reduced by any regulation.

While subpart NNN applies to wool fiberglass manufacturing facilities that are major

sources, today’s proposed rule making would also apply to gas

- fired furnace operations at wool

fiberglass manufacturi ng facilities that are area sources. Sources in the wool fiberglass

manufacturing category that have reduced their HAP emissions below major source levels (10

tons per year of a single HAP or 25 tons per year of any combination of HAP) are not subject to

t he major source rule (subpart NNN). When those sources also operate gas

- fired furnaces, they

would be subject to this proposed area source rule (subpart NN). The economic impact analysis

for this proposed area source wool fiberglass rule is in a separate report that is part of this

rulemaking package. 1

The Mineral Wool Production amendments include emissions limits for carbonyl sulfide,

formaldehyde, phenol and methanol and the addition of combined collection and curing

processes as new regulated source s.

The amendments for Wool Fiberglass Manufacturing include emissions limits for phenol,

methanol, chromium compounds, and particulate matter, revised emissions limits for

formaldehyde, and work practice standards for hydrogen fluoride and hydrochloric acid. For

more information on this regulatory action, please refer to the preamble for this action.

Background on Mineral Wool Industry

Mineral wood often is defined as any fibrous glassy substance made from minerals or

mineral products s uch as slag and glass. The chemical composition of mineral wool can vary

1 U.S. EPA, Office of Air Quality Planning and Standards. Economic Impact and Small Business Analysis

– Proposed

W ool Fiberglass Area Source NESHAP. January 2013. Formatted: Line spacing: 1.5 lines, Tab stops: 3", Left + 3.5", Left

Formatted: Line spacing: 1.5 lines, Tab stops: 3", Left + 3.5", LeftDRAFT

– For Review by EPA Workgroup

3 widely. The basic materials for glass wool manufacture include sand, soda ash, dolomite,

limestone, sodium sulfate, sodium nitrate, and minerals containing boron and alumina.

Tradi tional stone wool production involves melting a combination of alumino

- silicate rock

(usually basalt), blast furnace slag, and limestone or dolomite. In addition, for both glass and

stone wool the batch may contain recycled process or product waste. For glass wool, other

forms of waste glass (cullet) are also used as feedstock.

These materials are processed into insulation and other fibrous building materials that

are used for structural strength and fire resistance. Generally, these products take one of four

forms: “blowing” wool or “pouring” wool, which is put into the structural spaces of buildings;

batts, which may be covered with a vapor barrier of paper or foil and are shaped to fit between

the structural members of buildings; industrial and com mercial products such as high

- density

fiber felts and blankets, which are used for insulating boilers, ovens, pipes, refrigerators, and

other process equipment; and bulk fiber, which is used as a raw material in manufacturing

other products, such as ceilin g tile, wall board, spray

- on insulation, cement, and mortar.

Glass wool and stone wool production make use of different proprietary technologies,

including melting, fiberi z ing and curing. Production of mineral wool is a high temperature,

energy intens ive process. Mineral wool plants use a mix of technologies and fuels: a total of 11

propri etary fiberizing technologies are employed worldwide. Glass wool furnaces are

predominantly gas fired, but there are a substantial number of furnaces that are elec trically

heated.

In the production of mineral wool products that do not require high rigidity, oil is

typically applied to suppress dust and add some strength to the fiber; the fiber is then sized and

bagged or baled. This is known as a “nonbonded” prod uct which is manufactured on a

“nonbonded” production line.

For mineral wool products requiring a higher structural rigidity, a HAP

- based

(phenol/formaldehyde) binder may be applied to the fiber. This is known as a “bonded”

product made on a bonded production line. The binder

- laden fiber mat is then thermoset in aDRAFT

– For Review by EPA Workgroup

4 curing oven and cooled. The major differences between the “nonbonded” and bonded

production lines are the application of binder during the collection process followed by the

curing oven. Four facilities only manufacture nonbonded products, while the other 3 facilities

operate both bonded and nonbonded production lines. A total of 11 cupolas and 3 curing ovens

are operated by the facilities in this source category.

As mentioned previously, m ineral wool manufacturing facilities are included in NAICS

327993. The industry’s revenue for 201 1 was $5.1 billion, and the estimated gross profit was

40.15%. Exports from US mineral wool firms exceeded imports by about $330 million in 201 1

. 2

According to the size definition applied to this industry by the U.S. Sm all Business

Administration ( 750 company emplo yees or less) 3 , five of the seven parent firms in this industry

affected by this proposed rule are classified as small businesses. Of the five small firms, their

average number of employees is 108. All of these firms are U.S. owned except for Roxul USA.

Roxul USA is a subsidiary of a Danish company, Rockwool International, which is the world’s

largest producer of mineral wool insulation

. Roxul USA’s facility, which is located in Mississippi,

is slated to begin mineral wool production in 2014.

This analysis identified the businesses that will be affected by this rule and provides an

analysis at a screening level to assist in determining whether this rule is likely to impose a

significant economic impact on affected businesses. The analysis empl oyed here is a “sales

test” that computes the annualized compliance costs as a share of sales for each company. The

annualized cost per sales for a company represents the maximum price increase in affected

product needed for the company to completely recov er the annualized costs imposed by the

regulation.

The “sales test” is the impact methodology EPA employs in economic impact analysis

such as this one as opposed to a “profits test”, in which annualized compliance costs are

2 Mineral Wood Manufacturing Industry in the U.S. and its International Trade (2011 Edition). LLC Supplier
Relations US. Found on Amazon.com on August 2, 2011.

3 Found at the web site for the U.S. Sma ll Business Administration ( http://www.sba.gov/size ), with small business
size standards updated as of January 7, 2013.DRAFT

– For Review by EPA Workgroup

5 calculated as a share of profi ts. 4 This is because revenues or sales data are commonly available

data for entities normally impacted by EPA regulations and profits data normally made

available are often not the true profits earned by firms due to accounting and tax

considerations. Fi rms and entities often have ways legally available in the tax code to minimize

their reported profits; thus, using reported profits may lead to a less than accurate estimate of

the economic impact of a regulation to an affected firm or entity and their con sumers. While

screening level analyses are often employed to estimate impacts to small business or entities as

part an analysis in compliance with the Regulatory Flexibility Act (RFA) as amended by the Small

Business Regulatory Enforcement Fairness Act ( SBREFA), a screening level analysis can also be

employed in an economic impact analysis such as this one whose focus is on the regulated

companies.

For these firms, the impacts of the final rule range from 0.0 0 6 percent to 0

. 1 percent,

expressed as annual compliance costs as a percent of sales. 5 The price elasticity of demand for

the mineral wool industry is estimated at

- 0.8 6 , and the price elasticity of supply for the

industry is estimated at

- 0.7. 7 With the responsiveness of mineral wool demand and su pply to

be less in percentage terms than the change in product price as approximated by the cost to

revenue ratio, since this ratio is the maximum price change that producers may face, and with

this ratio at or below 1 percent for the majority of production from this industry, it is expected

that mineral wool price and output changes in response to this final rule will be less than 1

4 More information on sales and profit tests as used in analyses done by U.S. EPA can be found at http://www.epa.gov/sbrefa/documents/rfaguidance11

- 00

- 06.pdf , pp. 32

- 33.

5 Use of this metric for economic impacts when small businesses are prevalent in an industry affected by a
regulation is consistent with the EPA guidance on SBREFA compliance
( http: //www.epa.gov/sbrefa/documents/Guidance

- RegFlexAct.pdf ), chapters 2 and 3.

6 Ho, M. S, R. Morgenstern, and J. S. Shih. 2008. “Impact of Carbon Price Policies on US Industry.” RFF Discussion
Paper 08

- 37. Http://Www.Rff.Org/Publications/Pages/Publicationdetails.Aspx?. Publicationid=20680.
Accessed August 2009. Table 8.A.6.

7 Broda, C., N. Limao, and D. Weinstein. 2008b. “Export Supply Elasticities.” <http://faculty.
chicagobooth.edu/christian.broda/website/ research/unrestricted/TradeElasticities/

TradeElasticities.html.>DRAFT

– For Review by EPA Workgroup

6 percent. 8 The total annual compliance costs of the cu rrent proposed rule for this industry are

$ 592 ,000 ( 201 1 dollars). 9 Since confidential business information (CBI) provided by the subject

firms has been used to estimate these impacts, we will not provide the names of the affected

firms nor provide impact estimates by firm.

Background on the Wool Fiberglass Industry

Wool fiberglass is a thick, fluffy material made from discontinuous fibers, is used for

thermal insulation and sound absorption. It is commonly found in ship and submarine

bulkheads and hulls; automobile engine compartments and body panel liners; in furnaces and

air conditio ning units; acoustical wall and ceiling panels; and architectural partitions. Fiberglass

can be tailored for specific applications such as Type E (electrical), used as electrical insulation

tape, textiles and reinforcement; Type C (chemical), which has sup erior acid resistance, and

Type T, for thermal insulation.

The basic raw materials for fiberglass products are a variety of natural minerals and

manufactured chemicals. The major ingredients are silica sand, limestone, and soda ash. Other

ingredients ma y include calcined alumina, borax, feldspar, nepheline syenite, magnesite, and

kaolin clay, among others. Silica sand is used as the glass former, and soda ash and limestone

help primarily to lower the melting temperature. Other ingredients are used to imp rove certain

properties, such as bor ides for chemical resistance and ductability . Waste glass, also called

cullet, is also used as a raw material and may be ‘internal’ from the production of fiberglass or

may be ‘external’ from glass recycling . The raw mat erials must be carefully weighed in exact

quantities , their chemical compositions evaluated, and thoroughly mixed together (called

batching) before being melted into glass for the manufacture of fiberglass

.

8 This conclusion is consistent with perfect competition for this industry. This conclusion may change somewhat to
the extent that this industry is imperfectly competitive.

9 For more in formation on the costs of the rule, please refer to the cost memo prepared for this industry as part of this rule, which is RTI International to U.S. EPA/O AQPS/SPPD/NRG, “ Estimated Cost Impact for Mineral Wool
Production Industry to Comply with the Propose d Residual Risk and Technology Review (RTR) Amendments
Mineral Wool RTR,” January 31, 2013. Formatted: Line spacing: 1.5 linesDRAFT

– For Review by EPA Workgroup

7 The costs used as input to the economic impact a nalysis include the cost of emissions

control and the costs of monitoring, recordkeeping, reporting and testing. These are the full

cost of compliance estimated by EPA for this proposed rule. Based on emissions test data

received, we estimate that there a re currently two furnaces located at a single facility that

cannot meet the chromium compounds emission limit. We have estimated the cost impact for

that facility based on the installation of a sodium hydroxide (NaOH) scrubber to remove

chromium compounds from the furnace exhaust stream(s). The capital equipment cost was

estimated to be $250,000 for each unit (scrubber) with an annual operation cost of $100,000

per unit. The highest chromium compound emitting furnace was idled in December 2011 and

the comp any indicated that it may be re

- built prior to being brought back on

- line.

This economic impact analysis identified the businesses that will be affected by this rule

and provides an analysis at a screening level to assist in determining whether this rule i s likely

to impose a significant economic impact on affected businesses. The analysis employed here is

a “sales test” that computes the annualized compliance costs as a share of sales for each

company. The annualized cost per sales for a company represent s the maximum price increase

in affected product needed for the company to completely recover the annualized costs

imposed by the regulation. This is the same methodology employed for economic impact

analysis for the mineral wool industry, shown earlier i n this report.

The “sales test” is the impact methodology EPA employs in economic impact analysis

such as this one as opposed to a “profits test”, in which annualized compliance costs are

calculated as a share of profits. 10 This is because revenues or sale s data are commonly

available data for entities normally impacted by EPA regulations and profits data normally

made available are often not the true profits earned by firms due to accounting and tax

considerations. Firms and entities often have ways legally available in the tax code to minimize

their reported profits; thus, using reported profits may lead to a less than accurate est imate of

the economic impact of a regulation to an affected firm or entity and their consumers. While

screening level analyses are often employed to estimate impacts to small business or entities as

10 More information on sales and profit tests as used in analyses done by U.S. EPA can be found at http://www.epa.gov/sbrefa/documents/rfaguidance11

- 00

- 06.pdf , pp. 32

- 33.DRAFT

– For Review by EPA Workgroup

8 part an analysis in compliance with the Regulatory Flex ibility Act (RFA) as amended by the Small

Business Regulatory Enforcement Fairness Act (SBREFA), a screening level analysis can also be

employed in an economic impact analysis such as this one whose focus is on the regulated

companies.

As mentioned earlie r, w ool fiberglass facilities are also included in NAICS (North

American Industrial Classification System) 327993 along with mineral wool facilities . There are

five parent firms owning these faciliti es with major HAP sources affected by this proposal, an d

these firms are shown in Table 1. N one of these firms is a small business as defined by the SBA

( 75 0 employees or less for an ultimate parent company , as mentioned earlier for the relevant

NAICS code )

. Each of t hese firms ha s revenues in excess of $ 3 billion in 201 1 , as shown in

Table 1

. All of the firms are owned by parent companies based in the U.S

. except for

CertainTeed, which is owned by Sain t

- Gobain, a French conglomerate , and Knauf, Inc., which is

owned by Gebr. Knauf Verwaltungsgesellschaft ) KG, a German conglomerate

. Table 1 provides the

annualized costs and economic impacts to the affected firms from this proposed rule. EPA used

no CBI in generating economic impacts for this industry.

Table 1: Wool Fiberglass Firms t hat Are Affected b y the Proposed Rule , their Revenues and

Costs Incurred from the Proposed Rule , and Economic Impacts from this Rule

Wool Fiberglass Firm Annual Revenues

in 201 1 (billions) Total Annualized

Costs (201 1

dollars) f Annualized Costs as a

Percentage of Annual

Revenues in 201 1

Owens Corning

$5. 3 0 c $ 324

, 4 00 0.00 6 Formatted Table

Formatted: Centered, Space After: 0 pt, Line spacing: 1.5 linesDRAFT

– For Review by EPA Workgroup

9 Johns Manville (owned by

Berkshire

- Hathaway)

$1 43

. 69 d 386

, 0 00 0.0003

Certain Teed (owned by Saint

Gobain)

$5 6

. 31 b 2 2 3, 0 00 0.0004

Guardian, Inc.

$ 5

. 60 e 26 6

, 8 00 0.00 5

Knauf

, Inc. (owned by Gebr.

Knauf

Verwaltungsgesellschaft) KG

$ 3 .0 2 10

, 2 00 0.00000 3

a Taken from http://www.reuters.com/article/2011/07/22/idUS50641+22

- Jul

- 2011+BW20110722 . Conversion

from euros uses euro to U.S. dollar value as of August 15, 2011.

b Taken from 201 1 annual report for Saint

- Gobain, Inc., found at http://www.saint

gobain.com/files/Rapport_annuel_2011_EN.pdf , p. 6. Conversion from euros uses euro to U.S. dollar value as of

August 15, 2011.

c Taken from http://investor.owenscorning.com/phoenix.zhtml?c=71581&p=irol

- IRHome

.

d Taken from the 201 1 Berkshire

- Hathaway annual report

at http://www.berkshirehathaway.com/2011ar/2011ar.pdf , p. 2 4

.

e Revenues available at http://www.insideview.com/directory/guardian

- industries

- corp

.

f Costs are taken from RTI International to U.S. EPA/O AQPS/SPPD/NRG, “ Estimated Cost Impact for Wool Fiberglass

Manufacturing Industry to Comply with Proposed Residual Risk and Technology Review (RTR) Amendments Wool

Fiberglass Manufacturing RTR ,” Januar y 3 1 , 201 3

.

The economic impact on these wool fiberglass firms, measured in annual compl iance

costs as a percent of sales or revenue s, is less than 0.00 7 percent for each affected parent firm

based on using available revenue data for 2011 to be consistent with the year for the cost Formatted: Centered, Space After: 0 pt, Line spacing: 1.5 lines

Formatted: Centered, Space After: 0 pt, Line spacing: 1.5 lines

Formatted: Centered, Space After: 0 pt, Line spacing: 1.5 lines

Formatted: Centered, Space After: 0 pt, Line spacing: 1.5 lines

Formatted: Line spacing: 1.5 linesDRAFT

– For Review by EPA Workgroup

10 estimates

. The total annualized costs of the proposed rule to the wool fiberglass industry are

$ 1,210

, 00 0 (201 1 dollars). The price elasticity of demand for the wool fiberglass industry is

estimated at

- 0.8 11 , and the price elasticity of supply for the wool fiberglass industry is

estimated at

- 0.7. 12 With the responsiveness of wool fiberglass demand and supply at less than

1:1 compared to a price change of 1 percent , and with the change in product price as

approximated by the cost to revenue ratio at less than 0.1 percent, for this ratio is the

maximum price change that producers may face, it is expected that wool fiberglass price and

output changes will be less than 0.1 percent. 13 Hence, the overall economic impact of this

proposed rule should be low on the affected industry and its consumers.

The total annualized costs of the proposed RTR rule s for the mineral wool and wool

fiberglass manufacturing categories together are $ 1,2 6 0 ,000 (201 1 dollars). For more

information on the compliance costs (i.e., the costs of control + the costs of monitoring, testing,

and other administrative costs), please refer to the cost memos f or this rule for these

industries

.

For the proposed rule s , we find that we can certify that there is not a significant impact

on a substantial number of small entities (or SISNOSE). This is based on no small firm being

significantly impacted by this rule as shown in the impact results presented in this economic

impact and sma ll business impact analysis. We include all small firms affected by this rule in

the determination of this conclusion. Of the eleven firms affected by these two rule s
, five

mineral wool companies are small firms, and n one of the small firms is affected s ignificantly. All

of these small firms are mineral wool manufacturers ; no wool fiberglass manufacturer is a small

11 Ho, M. S, R. Morgenstern, and J. S. Shih. 2008. “Impact of Carbon Price Policies on US Industry.” RFF Discussion
Paper 08

- 37. Http://Www.Rff.Org/Publications/Pages/Public ationdetails.Aspx Publicationid=20680.
Accessed August 2009. Table 8.A.6.

12 Broda, C., N. Limao, and D. Weinstein. 2008b. “Export Supply Elasticities.” <http://faculty.
chicagobooth.edu/christian.broda/website/research/unrestricted/TradeElasticities/

Trade Elasticities.html.>

13 This conclusion is consistent with perfect competition for this industry. This conclusion may change somewhat
to the extent that this industry is imperfectly competitive.DRAFT

– For Review by EPA Workgroup

11 business

. Since the proposed area source rule for wool fiberglass manufacturing does not

impact small businesses, the Agency can provide a c ertification of no SISNOSE for the entire

rulemaking in today’s action.

Although these proposed rules would not have a significant economic impact on a

substantial number of small entities, the EPA nonetheless has tried to reduce the impact that

these rules would have on small entities. The actions we are proposing to take to reduce

impacts on small businesses include less frequent compliance testing for the entire mineral

wool industry and subcategorizing the Mineral Wool Production Source Category in developing

the proposed COS, HF and HCl emissions limits.

A Small Business Regulatory Enforcement Fairness Act (SBREFA) panel was convened for

th e propos ed rule s for the earlier 2011 RTR proposal based on anticipated significant impacts to

affected small b usinesses (all of these businesses are mineral wool producers)

. Details of the

findings and conclusions of this panel can be found in the report of the panel in the docket for

this rulemaking and are summarized in the preamble for the proposed rule

.

### 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 RTI Project 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 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 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 carbonyl sulfid e (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 formaldehyd e 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 we re divided by 5 to come up with “annualized”
testing costs. Table 1 summarizes the above information and the associated cost impacts.

### 2 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 &

m ethanol) 

### Every 5 years $ 3

, 0 00 $12,000 for

each additional

test ($2,400 annualized)

### 3 

## 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.

### 1 Date: February 7 , 2013

Subject: Environmental and Energy Impacts for Wool Fiberglass Manufacturing NESHAP

– Proposed RTR Amendments 40 CFR 63, Subpart NNN

– Supplemental Proposal

EPA Contract No. EP

- D

- 11

- 084 ; EPA Work Assignment No. 1

- 0 7

RTI Project No. 021 3199 .00 1 .00 7

From: Cindy Hancy

Dave Reeves

To: Susan Fairchild, EPA/OAQPS/SPPD/MMG

I. Introduction The purpose of this memorandum is to document the estimated environmental and energy impacts

associated with the proposed residual risk and technology review (RTR) amendments to 40 CFR 63, Subpart NNN

- Wool Fiberglass Manufacturing. Secondary impacts include the solid waste, water, wastewater generated and the electricity required to operate air pollution control devices , a s well as, the resultant greenhouse gas (GHG) emissions from controls or work practices required by the NESHAP.

II. Water, Wastewater , and Solid Waste Impacts

The EPA estimates that three gas

- fired glass

- melting furnaces at wool fiberglass manufacturing faci lities

will need to install a caustic scrubber to meet the proposed chromium compound emission limit for Subpart NNN. The water required to operate the scrubber and the solid and wastewater generated by the

effluent were calculated for the three units. The 2010 information collection request, sent to all wool fiberglass manufacturers, requested that facilities provide detailed information for each control device. For scrubbers, facilities were asked to provide gas and wate r flow rates, liquid to gas ratios, pressure drop, wastewater generation, and several other operating parameters for each of their existing scrubber s

. Append ix 1 contains a complete list of all the information EPA requested for scrubbers, however,

because the majority of facilities submitted this information as confidential business information (CBI), facility responses are not included in this memo. The EPA compiled these ICR responses, and using the operating parameters (also considered CBI) of the three furnaces estimated to need caustic scrubbers, estimated the amount of water needed to operate the scrubbers, as well as the wastewater and solid waste that would be generated. The calculated impact estimates are provided in Table 1.

Table 1. Estimated Wat er and Solid Waste Impacts for Caustic Scrubbers on Fur n aces Impacts per facility Total industry impacts Water flow rate into scrubber (gpm) 1 

### 194 582 Percent of scrubber water from recycled facility wastewater 1 

### 60 60

Total non

- recycled water necessary (gallons per year) 2 

### 41M 123 M

Total scrubber effluent rate (gpm) 1 

### 6.1 6.1 Percent scrubber wastewater recycled 1 

### 50 50 Total wastewater generated (gallons per year) 3 

### 1.6M 4.8M Total solid waste collected (lb/yr) 1 

### 468,000 1.4M

(1) Estimates from ICR responses

. (2) Calculation: 194 (gpm) x 60 (min/hr) x 8760 (hrs/yr) x (100%

- 60%)

. (3) Calculation: 6.1 (gpm) x 60 (min/hr) x 8760 (hrs/yr) x (100%

- 50%)

.

### 2 III. Energy Impacts and GHG Emissions from Electricity Usage

The amount of electricity required to operate a control device (i.e., caustic scrubber) was calculated using the information summarized in Table 1. The electricity costs associated with operating a scrubber derive from fan requirements to overcome the pres sure drop in the column, ductwork, and other parts of the control system, and pump requirements to re

- circulate the water. According to the EPA’s Air Pollution Control Cost Manual, fan and pump energy requirements can be calculated by using equation

3

- 1 an d 3

- 2, respectively.

Equation 3

- 1

Energy fan 

### = 1

. 17 x 10 − 4 

### x G i 

### x P

e Equation 3

- 2

Energy pump 

### = 0

. 746 x 2

. 52 x 10 − 4 

### x Li x P

e

Where Gi is the gas flow rate entering the scrubber, P is the total pressure drop, Li is the liquid flow rate entering the scrubber , P is the pressure of the pump which we assume to be 60 ft of

water and e is the efficiency of the device

.

The average gas flow rate entering the scrubber for the three furnaces is 26,000 acfm, the average estimated press ure drop for the scrubber is 9.8 inches of water, and the average estimated liquid flow is 194 gallons per minute. Using equation s 3

- 1 and 3

- 2 and an estimated efficiency of 0.7 for both the pump and the fan , we estimated the energy required to be 43kW h fo r the fan, and 3kW h for the pump

.

Energy fan 

### = ( 1

. 17 x 10 − 4 

### ) x ( 26

, 000 ) x ( 9

. 8 )

0

. 7 = 43 kW h

Energy pump 

### = ( 0

. 746 ) x ( 2

. 52 x 10 − 4 

### ) x ( 60 ) x ( 194 )

0

. 7 = 3 kW h

Assuming operating hours is 8,760 per year, the total annual energy required for each scrubber is:

46 kW

h r x 8

, 760 h rs

yr = 403

, 000 kW / yr

This results in 1.2 m illion kW h per year (1,200 m egawatts ) for all three scrubbers. We used the natural

gas emission factor (in kilograms [kg]/MMBtu) from the General Stationary Fuel Combustion Sources subpart (40 CFR part 98, subpart C) of the Greenhouse Gas Reporting Rule (listed in Table 2) to estimate the secondary emissions for CO 2 

### , CH 4 

### , and N 2 

### O.

### 3 Tabl e 2. Emission Factors from General Stationary Fuel Combustion Sources (40 CFR part 98, subpart C)

Fuel Default CH 4 

### emission factor (kg CH 4 

### /MM Btu) Default N 2 

### O

emission factor (kg N 2 

### O/MM Btu) Default CO 2 

### emission factor (kg C O 2 

### /MM Btu)

Natural Gas 1.0 × 10−03 1.0 × 10−04 53.02



### Global warming potentials of 1 for CO 2 

### , 21 for CH 4 

### , and 310 for N 2 

### O (from Table A

- 1 to subpart A of part 98) were used to estimate CO 2 

### equivalent emissions (CO 2 

### eq). First we converted kWh to MMB tu as
follows:

1

, 200

, 000 kW h x 0

. 0034 MMBtu

kW h = 4

, 100 MMBtu

Using the values in Table 2 we estimated CH 4 

### , N 2 

### 0, and CO 2 

### , emissions as 4.1 kg/yr (9 lb s/yr), 0.41 kg/yr (0.9 lbs/yr), and 217,000 kg/yr (478,000 lbs/yr) , respectively. We then calculated the CO 2 

### eq emissions based o n the global warming potentials above as follows:

CO 2 eq 

### lb

yr = 478

, 000 lb CO 2



### yr + � 21 x 9 lb CH 4



### yr � + ( 310 x 0

. 9 lb N 2 

### O

yr )

This results in 478, 5 00 lbs CO 2eq 

### per year for all three scrubbers.

### 1 MEMORANDUM

Date: February 28

, 201 3

Subject: Cost s and Emission Reductions for the Proposed Wool Fiberglass Manufacturing

NESHAP

- Residual Risk and Technology Review (RTR) Amendments

Wool Fiberglass Manufacturing RTR RTI Project No. 021 3199

. 00 1

. 0 07

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 for the wool fiberglass manufacturing industry to comply with the re

- proposed RTR amendments

.

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 prod ucts 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.” However, based on a review of the current permit status of all sources,

there are 1 0 ma jor source facilities with 8 gas

- fired glass

- melting furnaces and 3 1 manufactu r ing
lines that will have to comply with the RTR amendments to the NESHAP (subpart NNN)
requirements

. Industry comments on the proposed rule stated that several facilities have already

switched all or most of their lines to non

- HAP binders and submitted paperwork to be
redesignated as area sources and no longer subject to subpart NNN. Therefore, the following cost impacts are based on an estimated 10 facilities that were identified as major sources in the most
recent industry information provided in December 2012.

II. GLASS

- MELTING FURNACES

Based on emissions test data received, w e estimate that there are currently t hree gas

- fired furnaces

located at two facilit ies that cannot meet the proposed chromium compounds emission limit. We
have estimated the cost impact for th ose facilit ies based on the installation of a sodium hydroxide
(NaOH) scrubber to remove chromium compounds from the furnace exhaust stream(s). The i nitial capital equipment cost was estimated to be $250,000 for each unit (scrubber) with a calculated
annualized capital cost of $27,400 based on a 15

- year equipment life and 7% interest rate. The
annual operation and maintenance (O&M) costs were estimated to be $72,600 per unit. T he

### 2 high est chromium compound emitting furnace was idled in December 2011 and the company

indicated that it may be re

- built prior to being brought back on

- line.

III. ROTARY SPIN AND FLAME ATTENUATION MANUFACTURING LINES

As mentioned previously, several facilities have already switched all or most of their rotary spin
(RS) manufacturing lines to non

- PF binders . Based on the most recent information provided by
industry, w e estimate that the re will be 10 facilities subject to the final rule requirements with 1 8
RS manufacturing lines making bonded product. Two of those facilities also have 1 3 bonded
flame attenuation (FA) lines producing heavy density products and /or pipe insulation

. Based on
facility information co llected in the survey responses, most facilities currently have thermal

oxidizers and we assumed that the estimated 6 facilities currently not meeting the proposed

emission limits have thermal oxidizers (or scrubbers) on their bonded product lines. Theref ore,

there are no additional capital costs to comply with the new RS emission limits and we estimated
operation and maintenance (O & M) costs for a thermal oxidizer at each facility to be $125,000
annually. All 10 major source facilities with bonded lines will incur additional testing cost s to demonstrate compliance with the new phenol and methanol emission limits for forming and curing
operations

.

Table 1 summarizes the above informat ion and associated cost impacts.

IV. COMPLIANCE TESTING COSTS

Mr. Stef fan Johnson of EPA’s Measurement Policy Group provided the following cost estimates for compliance testing based on the test methods included in the final RTR amendments:

Emission

Source HAP Test

Method Test Cost s (in 201 1 $) Test Freq

uency Annualized

Test Costs (in 201 1 $) Comment

G as

- Fired

Furnace Chromium Compounds 29 $ 10 ,000 Every year* $ 10 ,000 *Reduced test frequency not

included in this

cost analysis.

Collection/ Curing (combined) Phenol and

Methanol (already testing formaldehyde) 318 $1 5 ,000
(combined

p henol &

m ethanol) 

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

each additional

test ($2,400 annualized)

* The final rule will allow owners/operators to reduce testing frequency for chromium compounds
from every year to once every three years if the initial and second compliance tests are each less
than 75% of the chromium compounds emission limit in the prop osed amendments

.

### 3 V. EMISSION REDUCTIONS

A. Gas

- Fired Glass

- Melting Furnaces

Based on the recent test data provided by the facilities, the eight gas

- fired furnaces emit
approximately 500 pounds of chromium compounds annually. We identified three gas

- fired
furnaces with emission rates above the proposed emission limit and their associated emissions
ranged from 13 to 442 pounds of chromium compounds. With the assumption that additional

cont rols on the three furnaces will reduce chromium compound emissions to a level that would
meet the proposed emission limit, approximately 455 pounds of chromium compounds would be
reduced annually at major sources

– which represents a 90 percent reduction c ompared to current

baseline emissions.

The annualized control costs for the gas

- fired furnaces ($380,000) divided by the emission
reduction (455 pounds of chromium compounds) results in a cost effectiveness of $835 per pound
of chromium compounds reduced.

B. Combined Collection/Curing Operations

Based on the recent test data provided by the facilities, the 31 manufacturing lines located at the
10 major source facilities emit approximately 6 00 tons of organic HAP (i.e., formaldehyde,
phenol, and methanol) annu ally. We identified eight manufacturing lines with emission rates
above the proposed emission limit s . With the assumption that additional controls on the eight
rotary spin (RS) manufacturing lines will reduce organic HAP emissions to a level that would

mee t the proposed emission limit s , approximately 123 tons of organic HAP would be reduced
annually at major sources

– which represents a 2 0 percent reduction compared to current baseline

emissions.

The annualized control costs for the RS manufacturing lines ($830,400) divided by the emission
reduction (123 tons of organic HAP) results in a cost effectiveness of $ 6,750 per ton of organic

HAP reduced.

### 4 Table 1. Summary of Costs for Wool Fiberglass Mfg Facilities to Comply with Proposed RTR Amendments

Gas

- Fired Furnaces

Rotary Spin (RS) Mfg

Bonded

Lines Addt’l RS

Control (O & M)

Costs F lame

Atten. (FA) Mfg

Bonded

Lines RS and FA Mfg

Line

Test ing

Cost Total Facility Cost Annual
O&M Cost # Gas

Fired

Furn

aces Cr Testing

Cost Company Facility

Location Source Type Annual

ized Capital

Cost

1 CertainTeed Athens, GA Area 0

2 CertainTeed Chowchilla, CA Area 0

3 CertainTeed Kansas City, KS Major 54,800 145,200 2 20,00 0 1 0 0 3,000 223,00 0

4 Guardian Albion, MI Major 0 0 0 0 2 0 0 5,400 5,400

5 Guardian Inwood, WV Major 0 0 0 0 2 125,000 0 5,400 130,400

6 Guardian Kingman, AZ SynMnr 0

7 Guardian Mineral Wells, MS Major 0 0 0 0 1 0 0 3,000 3,000

8 Guardian Winnsboro, SC Major 0 0 0 0 1 125

, 000 0 3,000 128,000

9 Johns Manville Cleburne, TX Major 0 0 1 10,000 1 125

, 000 2 7,800 142,800

10 Johns Manville Defiance, OH Major 0 0 2 20 ,000 4 125,00 0 1 1 36,600 181,600

11 Johns Manville McPherson, KS Area 0

12 Johns Manville Penbryn, NJ Area 0

13 Johns Manville Richmond, IN Area 0

14 Johns Manville Waterville, OH Area 0

15 Johns Manville Willows, CA Area 0

16 Johns Manville Winder, GA Area 0

17 Knauf Lanett, AL Area 0

18 Knauf Shasta Lake, CA A rea 0

19 Knauf Shelbyville, IN Major 0 0 0 0 4 0 0 10,200 10,200

20 Owens

- Corning Delmar, NY Area 0

21 Owens

- Corning Eloy, AZ Area 0

22 Owens

- Corning Fairburn, GA Area 0

23 Owens

- Corning Kansas City, KS Area 0

24 Owens

- Corning Mount Vernon, OH Area 0

25 Owens

- Corning Newark, OH Major 27,400 72,600* 2 20 ,000 1 125,000 0 3,000 248,0 00

26 Owens

- Corning Salt Lake City, UT SynMnr 0

27 Owens

- Corning Santa Clara, CA A rea 0

28 Owens

- Corning Waxahachie, TX Major 0 1 10 ,000 1 125,000 0 3,000 138,000

29 Owens

- Corning Nephi, UT SynMnr 0

30 Owens

- Corning Lakeland, FL Area 0
$ 82,200 $ 217,800 8 $ 80 ,000 18 $750,000 13 $ 80,400 $ 1,210,400

Table 1 notes: * One (high

- emitting) f urnace already scheduled for replacement. **The re are no HF/HCl testing costs since the final rule requires work practice standards

.

-Annualized capital cost is based on interest rate of 7% and 15 year equipment life

.

### 1 MEMORANDUM

Date: February 28, 2013

Subject: Cost s and Emission Reductions for the Proposed Wool Fiberglass Manufacturing

NESHAP

- Area Source s RTI Project No. 021 3199

. 00 1

. 0 07

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 for the wool fiberglass manufacturing industry to comply with the proposed area source rule requirements

. Major sources are regulated under Part 63 Subpart NNN; area sources will be proposed to 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 let ter 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.” B ased on a revie w of the current permit status of all sources and recent
information provided by industry

, there are 10 facilities that are major sources (subject to the
existing MACT rule, subpart NNN) and 2 0 area source facilities ( with a total of 5 4 glass

- melting

furna ces )

. However, only five of the area source facilities with a total of eight furnaces meet the
proposed applicability requirements in t he proposed area source NESHAP (subpart NN)

.

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

s ome of the major source facilities have already switched some or most of their lines to non

- HAP

binders and are working towards being redesignated as area sources and no longer subject to
subpart NNN. 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 find this to be an
overstatement. Table 1 provides further information on wool fiberglass furnaces by furnace type

and whether furnaces wou ld currently be subject to the proposed area source rule under subpart

NN. T he following cost impacts are based on the estimated five facilities and eight gas

- fired

furnaces that w ould be subject to the proposed area source rule requirements.

II. GAS

- FIRED GLASS

- MELTING FURNACES

### 2 Based on emissions test data received, w e estimate that there are currently eight gas

- fired furnaces

located at five facilit ies that do not meet the proposed chromium compounds emission limit. We

have estimated the add

- on control cost impact for th ose f acilit ies (three furnaces) based on the
installation of a sodium hydroxide (NaOH) scrubber to remove chromium compounds from the
furnace exhaust stream(s). The initial capital equipment cost was estimated to be $250,000 for
each unit (scrubber) with a calculated annualized capital cost of $27,400 based on a 15

- year equipment life and 7% interest rate. The annual operati on and maintenance (O&M) cost s were

estimated to be $ 72,600 per unit. Some of t he high est chromium compound emitting furnace s are located at major source facilit ies and those cost impacts will be attributed to subpart NNN

.

Table 1 summarizes the above informat ion and associated cost impacts.

III. COMPLIANCE T ESTING COSTS

Mr. Steffan Johnson of EPA’s Measurement Policy Group provided the following cost estimates for compliance testing based on the test methods included in the final RTR amendments:

Emission

Source HAP Test

Method Test

Cost s (201 1 $) Test Freq

uency Annualized

Test Costs

(201 1 $) Comment

Glass

Melting

Furnace PM (surrogate for HAP metals) 5

and

29 (combined) $10,000 Every year* $10,000 *Reduced test frequency not

included in this

cost analysis. Chromium Compounds

* The proposed rule allow s owners/operators to reduce testing frequency for PM and chromium
compounds from every year to once every three years if the initial and second compliance tests are

each less than 75% of the proposed PM and chromium compounds e mission limit s

.

IV. EMISSION REDUCTIONS

Based on the recent test data provided by the facilities, the eight gas

- fired furnaces emit
approximately 80 pounds of chromium compounds annually. We identified three gas

- fired
furnaces with emission rates above the p roposed emission limit and th eir associated emissions
ranged from 5 to 38 pounds of chromium compounds. With the assumption that additional
controls on the three furnaces will reduce chromium compound emissions to a level that would
meet the proposed emiss ion limit, approximately 50 pounds of chromium compounds would be
reduced annually at area sources

– which represents a 65 percent reduction compared to current

baseline emissions.

### 3 Table 1. Summary of Costs for Wool Fiberglass M anufacturing Facilities to Comply with Proposed Area Source Rule

Glass

- Melting Furnaces Total Facility Cost

Annual
O&M Costs Cr Testing

Cost Total

Annual Facility

Cost Company Facility

Location Source Type* Steel

Shell Electric

Cold Top Air

Gas Oxy

Fuel Total

# # subject

to area

rule Annual

i zed Capital

C ost *

1 CertainTeed Athens, GA Area 1 1 2 1 0 0 1 0 ,000 10,000

2 CertainTeed Chowchilla, CA Area 1 1 1 0 0 1 0 ,000 10,000

3 CertainTeed Kansas City, KS Major 2 2 0 0 0 0 0

4 Guardian Albion, MI Major 4 4 0 0 0 0 0

5 Guardian Inwood, WV Major 2 2 0 0 0 0 0

6 Guardian Kingman, AZ SynMnr 1 1 0 0 0 0 0

7 Guardian Mineral Wells, MS Major 2 2 0 0 0 0 0

8 Guardian Winnsboro, SC Major 1 1 0 0 0 0 0

9 Johns Manville Cleburne, TX Major 2 1 3 0 0 0 0 0

10 Johns Manville Defiance, OH Major 1 3 2 6 0 0 0 0 0

11 Johns Manville McPherson, KS Area 5 5 0 0 0 0 0

12 Johns Manville Penbryn, NJ Area 3 3 0 0 0 0 0

13 Johns Manville Richmond, IN Area 1 1 0 0 0 0 0

14 Johns Manville Waterville, OH Area 6 6 0 0 0 0 0

15 Johns Manville Willows, CA Area 6 6 0 0 0 0 0

16 Johns Manville Winder, GA Area 5 5 0 0 0 0 0

17 Knauf Lanett, AL Area 2 2 2 54,800 145,200 2 0,000 2 2 0,000

18 Knauf Shasta Lake, CA A rea 1 1 0 0 0 0 0

19 Knauf Shelbyville, IN Major 2 2 0 0 0 0 0

20 Owens

- Corning Delmar, NY Area 2 2 2 27,400 72,600 20 ,000 120

, 0 00

21 Owens

- Corning Eloy, AZ Area 2 2 0 0 0 0 0

22 Owens

- Corning Fairburn, GA Area 3 3 0 0 0 0 0

23 Owens

- Corning Kansas City, KS Area 1 2 3 2 0 0 2 0,000 2 0 ,000

24 Owens

- Corning Mount Vernon, OH Area 3 3 0 0 0 0 0

25 Owens

- Corning Newark, OH Major 2 2 4 0 0 0 0 0

26 Owens

- Corning Salt Lake City, UT SynMnr 2 2 0 0 0 0 0

27 Owens

- Corning Santa Clara, CA A rea 2 2 0 0 0 0 0

28 Owens

- Corning Waxahachie, TX Major 2 1 3 0 0 0 0 0

29 Owens

- Corning Nephi, UT SynMnr 2 2 0 0 0 0 0

30 Owens

- Corning Lakeland, FL Area 2 2 0 0 0 0 0

Totals 42 25 4 12 83 8 $82,200 $ 217,800 $ 80 ,000 $ 380

, 0 00

Table 1 notes:

- Major sources will not be subject to the area source rule requir e ments 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.

- A nnualized capital cost is based on interest rate of 7% and 15 year equipment life

.

### 1 Date: March 5 , 2013

Subject: Secondary ( Environmental and Energy ) Impacts for Wool Fiberglass Manufacturing

NESHAP

– Area Sources 40 CFR 63, Subpart NN

– Supplemental Proposal

EPA Contract No. EP

- D

- 11

- 084 ; EPA Work Assignment No. 1

- 0 7

RTI Project No. 021 3199 .00 1 .00 7

From: Cindy Hancy

Dave Reeves

To: Susan Fairchild, EPA/OAQPS/SPPD/MMG

I. Introduction

The purpose of this memorandum is to document the estimated environmental and energy impacts

associated with the proposed National Emission Standard for Hazardous Air Pollutants ( NESHAP ) 40 CFR 63, Subpart NN

- Wool Fiberglass Manufacturing for area sources

. Secondary impacts include the solid waste, water, wastewater generated and the electricity required to operate air pollution co ntrol

devices , as well as, the resultant greenhouse gas (GHG) emissions from controls or work practices required by the NESHAP.

II. Water, Wastewater , and Solid Waste Impacts

The EPA estimates that three gas

- fired glass

- melting furnaces at area source wool fiberglass manufacturing facilities will need to install a caustic scrubber to meet the proposed chromium compound emission limit for Subpart NN

. The water required to operate the scrubber and the solid and wastewater generated by the effluent were ca lculated for the three units. The 2010 information collection request, sent to all wool fiberglass manufacturers, requested that facilities provide detailed

information for each control device. For scrubbers, facilities were asked to provide gas and water flow rates, liquid to gas ratios, pressure drop, wastewater generation, and several other operating parameters

for each of their existing scrubber s . Append ix 1 contains a complete list of all the information EPA requested for scrubbers, however, because th e majority of facilities submitted this information as confidential business information (CBI), facility responses are not included in this memo. The EPA compiled these ICR responses, and using the operating parameters (also considered CBI) of the three

furnaces estimated to need caustic scrubbers, estimated the amount of water needed to operate the scrubbers, as well as the wastewater and solid was te that would be generated. The calculated impact

estimates are provided in Table 1.

### 2 Table 1. Estimated Water and Solid Waste Impacts for Caustic Scrubbers on Fur n aces Impacts per facility Total industry impacts

Water flow rate into scrubber (gpm) 1 

### 155 465 Percent of scrubber water from recycled facility wastewater 1 

### 60 60

Total non

- recycled water necessary (gallons per year) 2 

### 33 M 99 M

Total scrubber effluent rate (gpm) 1 

### 4.9 4.9 Percent scrubber wastewater recycled 1 

### 50 50

Total wastewater generated (gallons per year) 3 

### 1.3M 4.8M Total solid waste collected (lb/yr) 1 

### 468,000 1.4M

(1) Estimates from ICR responses . (2) Calculation: 155 (gpm) x 60 (min/hr) x 8760 (hrs/yr) x (100%

- 60%). (3) Calculation: 4.9 (gpm) x 60 (min/hr) x 8760 (hrs/yr) x (100%

- 50%).



### III. Energy Impacts and GHG Emissions from Electricity Usage

The amount of electricity required to operate a control device (i.e., caustic scrubber) was calculated using the information summarized in Table 1. The electricity costs associated with operating a scrubber derive from fan requirements to overcome the pressure drop in the column, ductwork, and other parts of the control system, and pump requirements to re

- circulate the water. According to the EPA’s Ai r Pollution Control Cost Manual, fan and pump energy requirements can be calculated by using equation

3

- 1 and 3

- 2, respectively.

Equation 3

- 1

Energy fan 

### = 1

. 17 x 10 − 4 

### x G i 

### x P

e Equation 3

- 2

Energy pump 

### = 0

. 746 x 2

. 52 x 10 − 4 

### x Li x P

e

Where Gi is the gas flow rate entering the scrubber, P is the total pressure drop, Li is the liquid flow rate entering the scrubber , P is the pressure of the pump which we assume to be 60 ft of

water and e is the efficiency of the device

.

The av erage gas flow rate entering the scrubber for the three furnaces is 17,000 acfm, the average estimated pressure drop for the scrubber is 7.8 inches of water, and the average estimated liquid flow is 155 gallons per minute. Using equations 3

- 1 and 3

- 2 and a n estimated efficiency of 0.7 for both the pump and the fan, we estimated the energy required to be 43kWh for the fan, and 3kWh for the pump.

Energy fan 

### = ( 1

. 17 x 10 − 4 

### ) x ( 17

, 000 ) x ( 7

. 8 )

0

. 7 = 22 kW h

Energy pump 

### = ( 0

. 746 ) x ( 2

. 52 x 1 0 − 4 

### ) x ( 60 ) x ( 155 )

0

. 7 = 2 kW h

Assuming operating hours is 8,760 per year, the total annual energy required for each scrubber is:

### 3 24 kW

h r x 8

, 760 h rs

yr = 210

, 000 kW h / yr

This results in 631,000 kWh per year for all three scrubbers. We used the natural gas emission factor (in kilograms [kg]/MMBtu) from the General Stationary Fuel Combustion Sources subpart (40 CFR part 98, subpart C) of the Greenhouse Gas Reporting Rule (listed in Table 2) to estimate the secondary emissions

for CO 2 

### , CH 4 

### , and N 2 

### O.

Table 2. Emission Factors from General Stationary Fuel Combustion Sources (40 CFR part 98, subpart C)

Fuel Default CH 4 

### emission factor (kg CH 4 

### /MM Btu) Default N 2 

### O

emission factor (kg N 2 

### O/MM Btu) Default CO 2 

### emission factor (kg C O 2 

### /MM Btu)

Natural Gas 1.0 × 10−03 1.0 × 10−04 53.02



### Global warming potentials of 1 for CO 2 

### , 21 for CH 4 

### , and 310 for N 2 

### O (from Table A

- 1 to subpart A of part 98) were used to estimate CO 2 

### equivalent emissions (CO 2 

### eq). First we converted kWh to MMBtu as

follows:

631

, 000 kW h x 0

. 0034 MMBtu

kW h = 2

, 100 MMBtu

Using the values in Table 2 we estimated CH 4 

### , N 2 

### 0, and CO 2 

### , emissions as 2.1 kg/yr (5 lbs/yr), 0.21 kg/yr (0.5 lbs/yr), and 111,000 kg/yr (245,000 lbs/yr), respectively. We then calculated the CO 2 

### eq emissions based on the global warming potentials above as follows:

CO 2 eq 

### lb

yr = 245000 lb CO 2



### yr + � 21 x 5 lb CH 4



### yr � + ( 310 x 0

. 5 lb N 2 

### O

yr )

This results in 245,300 lbs CO 2eq 

### per year for all three scrubbers.

# Appendix 1. ICR Questionnaire for Scrubbers

4 FORM C

- 2

AIR POLLUTION CONTROL

II. Scrubber

- NA

For each scrubber: Scrubber 1 Scrubber 2

Process line(s) (identification name/number) Equipment/process(es) controlled. Include emission point designations (e.g., E3, E4 from plot plan)

Latitude (decimal degrees, six decimal places)

Longitude (decimal degrees, six decimal places)

Stack or vent height (units)

Stack or vent diameter (units)

Manufacturer and model

Date of original installation

Type (e.g., venturi, orifice)

Gas flow rate to scrubber (acfm @ ° F)

Inlet gas temperature ( ° F)

Outlet gas temperature ( ° F)

Inlet grain loading (gr/dscf)

Outlet grain loading (gr/dscf)

Average stack opacity (%)

Water flow rate to scrubber (gpm)

Percent of scrubber water from recycled wastewater Source of scrubbing water and type of pretreatment. Substance(s) added as part of pretreatment and amount used (gpm or lbs/hr)

HAP composition of wastewater (mg/L)

Concentration (mg/L) of dissolved and suspended solids in scrubbing water

Scrubbing water temperature ( ° F)

Liquid/gas ratio (gal/10 3 acfm)

Pressure drop across scrubber (in. H 2 O gauge)

Amount of wastewater generated (gpd)

Amount of wastewater recycled (gpd)

Amount of wastewater disposed of (gpd)

Method of wastewater disposal

Quantity of solid waste collected (lbs/yr)

Quantity of solid waste recycled (lbs/yr)

Quantity of solid waste disposed of (lbs/yr)

Method of solid waste disposal

Vendor guarantee on scrubber efficiency (attach copy)

Nature and frequency of preventive maintenance procedures Problems experienced with control device within the last five years; how were problems solved?

Continuous monitoring method(s) used to monitor scrubber performance,

inclu ding parameters monitored