## 1 **MEMORANDUM** Date: March 1 2 , 2013 Subject: Costs and Emission Reductions for the Proposed Wool Fiberglass Manufacturing

NESHAP

- Area Source s RTIProject 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 b y 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.” B ased on a review of the current permit status of all sources and recent information provided b y 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 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 s ome of the major source facilities have already s witched 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 b y 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 f acilities (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

- ye ar equipment life and 7% interest rate. The annual operati on 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 furnace s 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 ye ar. Table 1 summarizes the above information and associated cost impacts.
**III. COMPL**  **IANCE 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** 

**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 ye ar* $10,000 *Reduced test

frequency not included in this cost analys is. 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 emission limits . **IV. EMISSION REDUCTIONS**  Based on the recent test data provided b y all of the facilities, the eight gas

- fired furnaces emit approximately

65 pounds of chromium compounds annually 1 

## . 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

1 

### 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 - 5 

## pounds 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.

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

**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 analy**  **sis.**

**- A** **nnualized capital cost is based on interest rate of 7% and 15 y ear**  **equipment life**
**.**

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

### Glass **- Me**  **lting Furnaces Total Facility**  **Cost**

**Annual O&M**  **Costs Cr** 

**Testing Cost**  **Cost Effectivnss ($**  **/ lb Cr reduced)**  **Company Facility** 

**Location Source** 

**Ty pe** * **Steel**

**Shell Electric** 

**Cold Top**  **Air**

**Gas Ox** **y Fuel**  **Tota**

**l # #**  **subject to area**  **rule Annual**  ****

**ized Capital**  **Cost*** **Cr Redu**  **** **ctions (lb/y** **r) Total** 

**Annual Facility**  **Cost** 1 CertainTeed Athens, GA **Area 1**  **1 2**  **1 0**  **0 1**  **0 ,000**  **10,000 NA**  2 CertainTeed Chowchilla, CA **Area 1**  **1 1**  **0 0**  **1 0**  **,000 10,000**  **NA** 3 Guardian Kingman, AZ **Sy nMnr**  **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 Wi llows, CA **Area 6**  **6 0**  **0 0**  **0 0**  **-** 9 Johns Manville Wi nder, GA **Area 5**  **5 0**  **0 0**  **0 0**  **-** 10 Knauf Lanett, AL **Area 2**  **2 2**  **54,800 145,200**  **2 0,000**  **22 2**  **2 0,000**  **10 ,000**  11 Knauf Shasta Lake, CA **A rea**  **1 1**  **0 0**  **0 0**  **0 -**  12 Owens
- Corning Delmar, NY **Area 2**  **2 2**  **27,400 72,600**  **20 ,000**  **31 120**  **, 0**  **00 3**  **, 8**  **00** 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 2**  **0,000 2**  **0 ,000**  **NA** 16 Owens
- Corning Mount Vernon, OH **Area 3**  **3 0**  **0 0**  **0 0**  **-** 17 Owens
- Corning Salt Lake City, UT **Sy nMnr**  **2 2**  **0 0**  **0 0**  **0 -**  18 Owens
- Corning Santa Clara, CA **A rea**  **2 2**  **0 0**  **0 0**  **0 -**  19 Owens
- Corning Nephi, UT **Sy nMnr**  **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, W V **Major 2**  **2 0**  **0 0**  **0 0**  24 Guardian Mineral W ells, MS **Major 2**  **2 0**  **0 0**  **0 0**  25 Guardian Wi nnsboro, 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**  2 9 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 $**  **380 ,**  **0 00**  **$ 7,2**  **00**