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MEMORANDUM

Date: March 11, 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 
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combined annualized cost is $100,000 per scrubber. 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.

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. 

The total industry cost to comply with the proposed amendments is estimated to be $1.21 million 

per year. 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.
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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 annual 

emissions of 13, 15, and 442 pounds of chromium compounds, respectively. 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 total 

emission reduction (123 tons of organic HAP) results in a cost effectiveness of $6,750 per ton of 

organic HAP reduced. On an individual facility basis, the cost effectiveness for the RS and FA 

manufacturing lines ranged from $1,153 to $14,755 per pound of organic HAP reduced.
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Table 1. Summary of Costs for Wool Fiberglass Mfg Facilities to Comply with Proposed RTR Amendments

Source 

Type

Gas-Fired Furnaces Rotary Spin (RS) and Flame Attenuation (FA) Lines

Total 

Facility 

Cost 

($)

Annualized 

Capital 

Cost*

Annual 

O&M 

Cost

# Gas

Fired 

Furnaces

Cr 

Testing 

Cost

Cost 

Effectiveness 

($ /lb Cr 

reduced)

RS

Mfg 

Bonded

Lines

Addt’l RS 

Control 

(O & M) 

Costs***

Flame Atten. 

(FA) Mfg 

Bonded 

Lines

RS and 

FA Mfg 

Line 

Testing 

Cost

Cost Effectiveness 

($/ton HAP

Company reduced)

Facility 

Location

1 CertainTeed Kansas City, KS Major 54,800 145,200 2 20,000 497 1 0 0 3,000 NA 223,000

2 Guardian Albion, MI Major 0 0 0 0 - 2 0 0 5,400 NA 5,400

3 Guardian Inwood, WV Major 0 0 0 0 - 2 125,000 0 5,400 8,693 130,400

4 Guardian Mineral Wells, MS Major 0 0 0 0 - 1 0 0 3,000 NA 3,000

5 Guardian Winnsboro, SC Major 0 0 0 0 - 1 125,000 0 3,000 2,612 128,000

6 Johns Manville Cleburne, TX Major 0 0 1 10,000 NA 1 125,000 2 7,800 14,755 142,800

7 Johns Manville Defiance, OH Major 0 0 2 20,000 NA 4 125,000 11 36,600 3,220 181,600

8 Knauf Shelbyville, IN Major 0 0 0 0 - 4 0 0 10,200 NA 10,200

9 Owens-Corning Newark, OH Major 27,400 72,600** 2 20,000 10,000 1 125,000 0 3,000 1,506 248,000

10 Owens-Corning Waxahachie, TX Major 0 1 10,000 NA 1 125,000 0 3,000 1,153 138,000

11 Guardian Kingman, AZ SynMnr 0

12 CertainTeed Chowchilla, CA Area 0

13 CertainTeed Athens, GA Area 0

14 Johns Manville McPherson, KS Area 0

15 Johns Manville Penbryn, NJ Area 0

16 Johns Manville Richmond, IN Area 0

17 Johns Manville Waterville, OH Area 0

18 Johns Manville Willows, CA Area 0

19 Johns Manville Winder, GA Area 0

20 Knauf Lanett, AL Area 0

21 Knauf Shasta Lake, CA Area 0

22 Owens-Corning Delmar, NY Area 0

23 Owens-Corning Eloy, AZ Area 0

24 Owens-Corning Fairburn, GA Area 0

25 Owens-Corning Kansas City, KS Area 0

26 Owens-Corning Mount Vernon, OH Area 0

27 Owens-Corning Salt Lake City, UT SynMnr 0

28 Owens-Corning Santa Clara, CA Area 0

29 Owens-Corning Nephi, UT SynMnr 0

30 Owens-Corning Lakeland, FL Area 0

$82,200 $217,800 8 $80,000 $835 18 $750,000 13 $80,400 $6,750 $1,210,400

Table 1 notes: * Annualized capital cost is based on interest rate of 7% and 15 year equipment life.

** One (high-emitting) furnace already scheduled for replacement.

*** There are no HF/HCl testing costs since the final rule requires work practice standards.