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,

Cortney
DRAFT – For Review by EPA Workgroup

1

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

January 2013

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

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

and Wool Fiberglass Manufacturing Risk and Technology Review (RTR) standards. These

standards are to be proposed on March 15, 2013. Promulgation of these standards is scheduled 

to occur on January 30, 2014. The report presents impacts to firms affected by the 

requirements in the proposed rules 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 the 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 

would 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 promulgation of the 1999 

NESHAP, sources had modified certain processes by using HAP-free binders instead of phenolicformaldehyde binders (76 FR 72777). When a facility completely phases out its use of phenolformaldehyde binders it generally becomes an area source 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/formaldehyde 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 replacement of phenol/formaldehyde binders with non-HAP binders is an 

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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 rulemaking would also apply to gas-fired furnace operations at wool 

fiberglass manufacturing 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 

the 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 sources. 

 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 such 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 

Wool Fiberglass Area Source NESHAP. January 2013. 

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3", Left + 3.5", Left

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3", Left + 3.5", Left
DRAFT – For Review by EPA Workgroup

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

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

Traditional 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 commercial 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 ceiling tile, wall board, spray-on insulation, cement, and mortar. 

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

including melting, fiberizing and curing. Production of mineral wool is a high temperature, 

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

proprietary fiberizing technologies are employed worldwide. Glass wool furnaces are 

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

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” product 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 a 
DRAFT – 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, mineral wool manufacturing facilities are included in NAICS 

327993. The industry’s revenue for 2011 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 2011.

2

 

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

Administration (750 company employees 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 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 represents the maximum price increase in affected 

product needed for the company to completely recover 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. Small 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 profits.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. 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 estimate 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 

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 0.006 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 -0.86, and the price elasticity of supply for the 

industry is estimated at -0.7.7 With the responsiveness of mineral wool demand and supply 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

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

$592,000 (2011 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 conditioning 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 superior 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 may 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 improve certain 

properties, such as borides 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 materials 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 information 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/OAQPS/SPPD/NRG, “Estimated Cost Impact for Mineral Wool 

Production Industry to Comply with the Proposed Residual Risk and Technology Review (RTR) Amendments 

Mineral Wool RTR,” January 31, 2013.

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The costs used as input to the economic impact analysis 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 are 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 company 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 is 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 represents 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 in 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 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. 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 estimate 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 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. 

As mentioned earlier, wool 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 facilities with major HAP sources affected by this proposal, and 

these firms are shown in Table 1. None of these firms is a small business as defined by the SBA 

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

NAICS code). Each of these firms has revenues in excess of $3 billion in 2011, 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 Saint-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 that Are Affected by the Proposed Rule, their Revenues and 

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

Wool Fiberglass Firm Annual Revenues 

in 2011 (billions)

Total Annualized 

Costs (2011

dollars)f

Annualized Costs as a 

Percentage of Annual 

Revenues in 2011

Owens Corning

$5.30c

$324,400 0.006

Formatted Table

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spacing: 1.5 lines
DRAFT – For Review by EPA Workgroup

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Johns Manville (owned by 

Berkshire-Hathaway)

$143.69d 386,000 0.0003

Certain Teed (owned by SaintGobain)

$56.31b 223,000 0.0004

Guardian, Inc.

$5.60e 266,800 0.005

Knauf, Inc. (owned by Gebr. 

Knauf 

Verwaltungsgesellschaft) KG

$3.02 10,200 0.000003

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 2011 annual report for Saint-Gobain, Inc., found at http://www.saintgobain.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 2011 Berkshire-Hathaway annual report 

athttp://www.berkshirehathaway.com/2011ar/2011ar.pdf, p. 24. 

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

f Costs are taken from RTI International to U.S. EPA/OAQPS/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,” January 31, 2013.

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

costs as a percent of sales or revenues, is less than 0.007 percent for each affected parent firm

based on using available revenue data for 2011 to be consistent with the year for the cost 

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DRAFT – For Review by EPA Workgroup

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

$1,210,000 (2011 dollars). The price elasticity of demand for the wool fiberglass industry is 

estimated at -0.811, 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 rules for the mineral wool and wool 

fiberglass manufacturing categories together are $1,260,000 (2011 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 for this rule for these 

industries. 

For the proposed rules, 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 small 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 rules, five 

mineral wool companies are small firms, and none of the small firms is affected significantly. 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/Publicationdetails.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/

TradeElasticities.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 certification 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 

the proposed rules for the earlier 2011 RTR proposal based on anticipated significant impacts to 

affected small businesses (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: January 31, 2013

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. 0213199.001.007

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 limits.

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 facilities 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 sulfide (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 lines 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.
2

II. COMPLIANCE TESTING COSTS 

Mr. Steffan Johnson of EPA’s Measurement Policy Group provided the following estimates for 

compliance testing based on the test methods included in the final RTR amendments:

Emission 

Source

HAP Test 

Method

Test Costs 

(in 2011 $)

Test 

Frequency

Annualized 

Test Costs

(in 2011 $)

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

$15,000 

(combined 

phenol & 

methanol)

Every 

5 years $3,000

$12,000 for 

each additional 

test ($2,400 

annualized)
3

Table 1. Summary of Mineral Wool Production Facilities Costs to Comply with RTR Amendments

Cupolasa Combined Collection/Curing

#

Cupolas

Annualized 

(New) COS 

Testing Costb

# Bonded 

Lines

Annualized 

(New) Testing

Costc

Facility Location

Annualized 

(New) HCl/HF 

Testing Costb

Total Facility Incremental 

Annualized (New) Costs

Industrial 

Insulation 

Group (IIG)

Phenix City, AL 1 2,800 800 1 3,000 $6,600

Thermafiber Wabash IN 2 5,200 1,600 1 3,000 $9,800

USG 

Interiors

Red Wing, MN 2 5,200 1,600 0 0 $6,800

USG 

Interiors

Walworth, WI 1 2,800 800 0 0 $3,600

Amerrock 

Products

Nolanville, TX 2 5,200 1,600 0 0 $6,800

Isolatek Int’l Huntington, 

IN

2 5,200 1,600 0 0 $6,800

Rock Wool 

Mfg

Leeds, AL 1 2,800 800 1 3,000 $6,600

Roxul USA Byhalia, MS 2 5,200 1,600 2 5,400 $12,200

SubTotal 13 $34,400 $10,400 5 $14,400 $59,200

a – 8 of the 13 cupolas currently have (or will have) incineration/afterburner controls. 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. 1-07

RTI Project No. 0213199.001.007

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, 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 wool fiberglass manufacturing facilities 

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 water flow rates, liquid to gas ratios, pressure 

drop, wastewater generation, and several other operating parameters for each of their existing scrubbers. 

Appendix 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 Water and Solid Waste Impacts for Caustic Scrubbers on Furnaces

Impacts per facility Total industry impacts 

Water flow rate into scrubber (gpm)1 194 582

Percent of scrubber water from recycled facility wastewater1 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 recycled1 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 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 Air 

Pollution Control Cost Manual, fan and pump energy requirements can be calculated by using equation 

3-1 and 3-2, respectively. 

Equation 3-1

Energyfan = 1.17 x 10−4x Gix P

e

Equation 3-2

Energypump = 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 pressure drop for the scrubber is 9.8 inches of water, and the average estimated liquid flow is 

194 gallons per minute. Using equations 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 43kWh for the fan, and 3kWh for the pump. 

Energyfan = (1.17 x 10−4) x (26,000) x (9.8)

0.7 = 43 kWh

Energypump = (0.746) x (2.52 x 10−4) x (60) x (194)

0.7 = 3 kWh

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

46kW

hr

x 8,760

hrs

yr = 403,000 kW/yr

This results in 1.2 million kWh per year (1,200 megawatts) 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 CO2, CH4, and N2O. 
3

Table 2. Emission Factors from General Stationary Fuel Combustion Sources 

(40 CFR part 98, subpart C)

Fuel

Default CH4

emission factor

(kg CH4/MMBtu)

Default N2O 

emission factor

(kg N2O/MMBtu)

Default CO2

emission factor

(kg CO2/MMBtu)

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

Global warming potentials of 1 for CO2, 21 for CH4, and 310 for N2O (from Table A-1 to subpart A of 

part 98) were used to estimate CO2 equivalent emissions (CO2eq). First we converted kWh to MMBtu as 

follows: 

1,200,000 kWh x

0.0034MMBtu

kWh = 4,100 MMBtu

Using the values in Table 2 we estimated CH4, N20, and CO2, emissions as 4.1 kg/yr (9 lbs/yr), 0.41 

kg/yr (0.9 lbs/yr), and 217,000 kg/yr (478,000 lbs/yr), respectively. Wethen calculated the CO2eq 

emissions based on the global warming potentials above as follows:

CO2eq

lb

yr = 478,000

lbCO2

yr

+ �21 x 9

lb CH4

yr � + (310 x 0.9

lb N2O

yr )

This results in 478,500 lbs CO2eq per year for all three scrubbers. 
1

MEMORANDUM

Date: February 28, 2013

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

NESHAP - Residual Risk and Technology Review (RTR) Amendments

Wool Fiberglass Manufacturing RTR

RTI Project No. 0213199.001.007

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

there are 10 major source facilities with 8 gas-fired glass-melting furnaces and 31 manufacturing 

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, we estimate that there are currently three gas-fired furnaces 

located at two facilities that cannot meet the proposed chromium compounds emission limit. We 

have estimated the cost impact for those facilities 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 operation and maintenance (O&M) costs were estimated to be $72,600 per unit. The 
2

highest 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, we estimate that there will be 10 facilities subject to the final rule requirements with 18

RS manufacturing lines making bonded product. Two of those facilities also have 13 bonded 

flame attenuation (FA) lines producing heavy density products and/or pipe insulation. Based on 

facility information collected 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. Therefore, 

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 costs to 

demonstrate compliance with the new phenol and methanol emission limits for forming and curing 

operations. 

Table 1 summarizes the above information and associated cost impacts.

IV. COMPLIANCE TESTING 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 Costs 

(in 2011 $)

Test 

Frequency

Annualized 

Test Costs 

(in 2011 $)

Comment

Gas-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

$15,000 

(combined 

phenol & 

methanol)

Every 

5 years $3,000

$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 proposed 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 

controls 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 compared 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 600 tons of organic HAP (i.e., formaldehyde, 

phenol, and methanol) annually. We identified eight manufacturing lines with emission rates 

above the proposed emission limits. With the assumption that additional controls on the eight 

rotary spin (RS) manufacturing lines will reduce organic HAP emissions to a level that would 

meet the proposed emission limits, approximately 123 tons of organic HAP would be reduced 

annually at major sources – which represents a 20 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

Flame 

Atten. 

(FA) Mfg

Bonded

Lines

RS and 

FA Mfg 

Line 

Testing

Cost

Total 

Facility Cost

Annual 

O&M Cost

# Gas

Fired 

Furnaces

Cr 

Testing 

Company Cost

Facility 

Location

Source 

Type

Annualized 

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 20,000 1 0 0 3,000 223,000

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 4 125,000 11 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 Area 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 3,000 248,000

26 Owens-Corning Salt Lake City, UT SynMnr 0

27 Owens-Corning Santa Clara, CA Area 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) furnace already scheduled for replacement.**There 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: Costs and Emission Reductions for the Proposed Wool Fiberglass Manufacturing 

NESHAP - Area Sources

RTI Project No. 0213199.001.007

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 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, there are 10 facilities that are major sources (subject to the 

existing MACT rule, subpart NNN) and 20 area source facilities (with a total of 54 glass-melting 

furnaces). However, only five of the area source facilities with a total of eight furnaces meet the 

proposed applicability requirements in the proposed area source NESHAP (subpart NN). 

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 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 would currently be subject to the proposed area source rule under subpart 

NN. The following cost impacts are based on the estimated five facilities and eight gas-fired 

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

II. GAS-FIRED GLASS-MELTING FURNACES
2

 

Based on emissions test data received, we estimate that there are currently eight gas-fired furnaces 

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

have estimated the add-on control cost impact for those facilities (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 operation and maintenance (O&M) costs were 

estimated to be $72,600 per unit. Some of the highest chromium compound emitting furnaces are

located at major source facilities and those cost impacts will be attributed to subpart NNN.

Table 1 summarizes the above information and associated cost impacts.

III. COMPLIANCE TESTING 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 

Costs 

(2011 $)

Test 

Frequency

Annualized 

Test Costs 

(2011 $)

Comment

GlassMelting 

Furnace

PM (surrogate 

for HAP metals)

5

and

29

(combined)

$10,000 Every 

year*

$10,000

*Reduced test 

frequency not 

included in this 

Chromium cost analysis. 

Compounds

* The proposed rule allows 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 emission limits.

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 proposed emission limit and their 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 emission 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 Manufacturing Facilities to Comply with Proposed Area Source Rule

Glass-Melting Furnaces Total Facility Cost

Annual 

O&M Costs

Cr 

Testing 

Cost

Total 

Annual 

Facility 

Company Cost

Facility 

Location

Source 

Type*

Steel 

Shell

Electric 

Cold 

Top

Air 

Gas

Oxy 

Fuel

Total 

# 

# 

subject 

to area 

rule

Annualized 

Capital 

Cost*

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

2 CertainTeed Chowchilla, CA Area 1 1 1 0 0 10,000 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 20,000 220,000

18 Knauf Shasta Lake, CA Area 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 20,000 120,000

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 20,000 20,000

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 Area 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 $380,000

Table 1 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. 

 - Annualized 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. 1-07

RTI Project No. 0213199.001.007

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 control 

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 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 water flow 

rates, liquid to gas ratios, pressure drop, wastewater generation, and several other operating parameters

for each of their existing scrubbers. Appendix 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. 
2

Table 1. Estimated Water and Solid Waste Impacts for Caustic Scrubbers on Furnaces

Impacts per facility Total industry impacts 

Water flow rate into scrubber (gpm)1 155 465

Percent of scrubber water from recycled facility wastewater1 60 60

Total non-recycled water necessary (gallons per year)2 33M 99 M

Total scrubber effluent rate (gpm)1 4.9 4.9

Percent scrubber wastewater recycled1 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 Air 

Pollution Control Cost Manual, fan and pump energy requirements can be calculated by using equation 

3-1 and 3-2, respectively. 

Equation 3-1

Energyfan = 1.17 x 10−4x Gix P

e

Equation 3-2

Energypump = 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 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 an 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. 

Energyfan = (1.17 x 10−4) x (17,000) x (7.8)

0.7 = 22 kWh

Energypump = (0.746) x (2.52 x 10−4) x (60) x (155)

0.7 = 2 kWh

Assuming operating hours is 8,760 per year, the total annual energy required for each scrubber is: 
3

24 kW

hr

x 8,760

hrs

yr = 210,000 kWh/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 CO2, CH4, and N2O. 

Table 2. Emission Factors from General Stationary Fuel Combustion Sources 

(40 CFR part 98, subpart C)

Fuel

Default CH4

emission factor

(kg CH4/MMBtu)

Default N2O 

emission factor

(kg N2O/MMBtu)

Default CO2

emission factor

(kg CO2/MMBtu)

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

Global warming potentials of 1 for CO2, 21 for CH4, and 310 for N2O (from Table A-1 to subpart A of 

part 98) were used to estimate CO2 equivalent emissions (CO2eq). First we converted kWh to MMBtu as 

follows: 

631,000 kWh x

0.0034MMBtu

kWh = 2,100 MMBtu

Using the values in Table 2 we estimated CH4, N20, and CO2, 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 CO2eq 

emissions based on the global warming potentials above as follows:

CO2eq

lb

yr = 245000

lbCO2

yr

+ �21 x 5

lb CH4

yr � + (310 x 0.5

lb N2O

yr )

This results in 245,300 lbs CO2eq 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/103 acfm)

 Pressure drop across scrubber (in. H2O 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, 

including parameters monitored