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MEMORANDUM

Date: March 12, 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, 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); two of 

those facilities with a total of three furnaces will need to install control equipment to comply with 

the proposed standards. 

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. 
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II. GAS-FIRED GLASS-MELTING FURNACES

 

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. The combined annualized cost is $100,000 per scrubber. Some of 

the highest chromium compound emitting furnaces are located at major source facilities and those 

cost impacts will be attributed to subpart NNN.

The total cost for the five facilities to comply with the proposed area source rule is estimated to be 

$380,000 per year. 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 all of the facilities, the eight gas-fired furnaces emit 

approximately 65 pounds of chromium compounds annually1. We identified three gas-fired 

furnaces with emission rates above the proposed emission limit and their associated annual 

emissions of 5, 25, and 35 pounds of chromium compounds, respectively. With the assumption 

 

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Forty-six electric furnaces contribute 15 pounds of chromium annually to make a total of 80 pounds of chromium emitted 

from all area sources.
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that additional controls on the three furnaces will reduce chromium compound emissions to a level 

that would meet the proposed emission limit, approximately 53 pounds of chromium compounds 

would be reduced annually at area sources. These reductions come from the three gas fired 

furnaces at area sources currently emitting above the proposed emission limit of 6 x 10-5pounds 

chromium per ton glass pulled. When these meet the proposed limit, we estimate an 80 percent 

reduction in chromium compounds would be achieved compared to current baseline emissions.
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Table 1. Summary of Costs for Wool Fiberglass Manufacturing Facilities to Comply with Proposed Area Source Rule

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. 

 - Emissions reductions for Knauf Lanett are estimated to be 1 lb Cr/yr for furnace 1 and 21 lbs Cr/yr for furnace 2. 

Glass-Melting Furnaces Total Facility Cost

Annual 

O&M 

Costs

Cr 

Testing 

Cost

Cost 

Effectivnss ($ 

/ lb Cr 

Company reduced)

Facility

Location

Source 

Type*

Steel 

Shell

Electric 

Cold 

Top

Air 

Gas

Oxy 

Fuel

Tota

l # 

# 

subject 

to area 

rule

Annualized 

Capital 

Cost*

Cr 

Reductions 

(lb/yr)

Total 

Annual 

Facility

Cost

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

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

3 Guardian Kingman, AZ SynMnr 1 1 0 0 0 0 0 -

4 Johns Manville McPherson, KS Area 5 5 0 0 0 0 0 -

5 Johns Manville Penbryn, NJ Area 3 3 0 0 0 0 0 -

6 Johns Manville Richmond, IN Area 1 1 0 0 0 0 0 -

7 Johns Manville Waterville, OH Area 6 6 0 0 0 0 0 -

8 Johns Manville Willows, CA Area 6 6 0 0 0 0 0 -

9 Johns Manville Winder, GA Area 5 5 0 0 0 0 0 -

10 Knauf Lanett, AL Area 2 2 2 54,800 145,200 20,000 22 220,000 10,000

11 Knauf Shasta Lake, CA Area 1 1 0 0 0 0 0 -

12 Owens-Corning Delmar, NY Area 2 2 2 27,400 72,600 20,000 31 120,000 3,800

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

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

15 Owens-Corning Kansas City, KS Area 1 2 3 2 0 0 20,000 20,000 NA

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

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

18 Owens-Corning Santa Clara, CA Area 2 2 0 0 0 0 0 -

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

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

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

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

23 Guardian Inwood, WV Major 2 2 0 0 0 0 0

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

25 Guardian Winnsboro, SC Major 1 1 0 0 0 0 0

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

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

28 Knauf Shelbyville, IN Major 2 2 0 0 0 0 0

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

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

Totals 42 25 4 12 83 8 $82,200 $217,800 $80,000 23 $380,000 $7,200