1 **MEMORANDUM** Date: March 11 , 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 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 re -proposed RTR amendments
. **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 currentl y 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 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, w e 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. The2

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 AN** **D 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 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 in sulation
. 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 cost s 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 b ased 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 ye ar* $ 10 ,000 *Reduced test

frequency not included in this cost anal ys is. Collection/ Curing (combined) Phenol and

Methanol (already testing formaldehyde) 318 $1 5 ,000 (combined p henol & methanol) 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 proposed amendments
.3

**V. EMISSION REDUCTIONS**  **A. Gas**  **- Fired Glass**  **- Melting Furnaces**  Based on the recent test data provided b y 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 p ercent 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 b y 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) annually . 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 meet 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 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.4

**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 ($) Annual ized Capital Cost* Annual

O&M Cost # Gas

Fired Furn aces Cr Testing Cost Cost

Effec tiveness ($ /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 Effec tiveness ($/ton HAP reduced) Company Facili ty

Location 1 CertainTeed Kansas City, KS Major 54,800 145,200 2 20,000 4 97 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 W ells , MS Major 0 0 0 0 - 1 0 0 3,000 NA 3,000 5 Guardian Wi nnsboro, SC Major 0 0 0 0 - 1 125,000 0 3,000 2,612 128,000 6 Johns Manville Cleburn e, 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 Maj or 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 Wa xahachie , 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 Chowchil la, CA Area 0 13 CertainTeed Athens, GA A rea 0 14 Johns Manville McPherson, KS Area 0 15 Johns Manville Penbryn, NJ Area 0 16 Johns Manvil le Richmond, IN Area 0 17 Johns Manvil le Waterville, OH Area 0 18 Johns Manvil le Wi llows, CA Area 0 19 Johns Manvil le Wi nder, GA Area 0 20 Knauf Lanett , AL Area 0 21 Knauf Shasta Lake, CA Area 0 22 Owens - Cornin g Delmar, NY Area 0 23 Owens - Cornin g 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 - em itting) furnace already scheduled for replacement. ** * The re are no HF/HCl testing costs since the final rule requires work practice standards
.