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MEMORANDUM

Date: November 3, 2011

Subject: Estimated Cost Impact for Wool Fiberglass Manufacturing Industry to Comply

with Proposed Residual Risk and Technology Review (RTR) Amendments

Wool Fiberglass Manufacturing RTR

RTI Project No. 0213199.010

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 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 29 facilities in the U.S. producing wool fiberglass. A recent 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 that information, we estimate that only 2 wool 

fiberglass manufacturing facilities will be subject to the NESHAP (subpart NNN) requirements on 

the compliance date of the proposed amendments (e.g., 2013). 

We estimate that there are 2 major source facilities with bonded lines producing heavy density 

products and/or pipe insulation that will incur additional testing costs to demonstrate compliance 

with the new (proposed) phenol and methanol emission limits for forming and curing operations. 

Those 2 major source facilities would incur additional testing costs to demonstrate compliance 

with the new (proposed) chromium (Cr) compounds, hydrogen fluoride (HF) and hydrogen 

chloride (HCl) emission limits for their melting furnaces. Table 1 summarizes the above 

information and associated cost impacts.

Additionally, based on emissions test data received, there are three furnaces (located at three 

different facilities) that do not currently meet the chrome limit that is being proposed. If for some 

reason these facilities do not become area sources by the compliance date of the proposed rule, we 

are estimating that two of the furnaces will have to add additional controls (caustic scrubber) and 

one, due to exceptionally high chrome emissions, will have to replace the refractory brick lining of 

the furnace. The cost estimates for this scenario are located in Table 2. 
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Table 1. Summary of Costs for Wool Fiberglass Mfg Facilities to Comply with Proposed RTR Amendments 

Pipe or 

Heavy 

Density 

Product 

Lines

Melting Furnaces Forming/Curing Operations 

on FA Lines for Pipe Insulation or 

Heavy Density Products

Total 

Facility Cost

Cr Control 

Eqmt

Annualized 

Cost

# 

Furnaces Testing Costa

Facility Location # FA Lines Test Cost

1 CertainTeed Athens, GA 0 2 0 0 0 0

2 CertainTeed Chowchilla, CA 0 1 0 0 0 0

3 CertainTeed Kansas City, KS 0 2 0 0 0 0

4 FiberTEK Lakeland, FL 0 2 0 0 0 0

5 Guardian Albion, MI 0 4 0 0 0 0

6 Guardian Inwood, WV 0 2 0 0 0 0

7 Guardian Kingman, AZ 0 1 0 0 0 0

8 Guardian Mineral Wells, MS 0 2 0 0 0 0

9 Guardian Winnsboro, SC 0 1 0 0 0 0

10 Johns Manville Cleburne, TX 0 3 0 0 0 0

11 Johns Manville Defiance, OH Yes 0 8 40,000 2 26,000 66,000

12 Johns Manville McPherson, KS 0 3 0 0 0 0

13 Johns Manville Penbryn, NJ 0 1 0 0 0 0

14 Johns Manville Richmond, IN 0 2 0 0 0 0

15 Johns Manville Waterville, OH 0 6 0 0 0 0

16 Johns Manville Willows, CA 0 6 0 0 0 0

17 Johns Manville Winder, GA 0 5 0 0 0 0

18 Knauf Lanett, AL 0 2 0 0 0 0

19 Knauf Shasta Lake, CA 0 1 0 0 0 0

20 Knauf Shelbyville, IN 0 2 0 0 0 0

21 Owens-Corning Delmar, NY 0 2 0 0 0 0

22 Owens-Corning Eloy, AZ 0 2 0 0 0 0

23 Owens-Corning Fairburn, GA 0 3 0 0 0 0

24 Owens-Corning Kansas City, KS 0 3 0 0 0 0

25 Owens-Corning Mount Vernon, OH 0 3 0 0 0 0

26 Owens-Corning Newark, OH Yes 0 4 20,000 2 26,000 46,000

27 Owens-Corning Salt Lake City, UT 0 2 0 0 0 0

28 Owens-Corning Santa Clara, CA 0 2 0 0 0 0

29 Owens-Corning Waxahachie, TX 0 3 0 0 0 0

SubTotal $0 80 $60,000 4 $52,000 $112,000
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Table 1 notes:

a- Furnace testing costs reflect incremental costs for Cr, HF, and HCl testing; current test requirements for PM not included.

Table 2. Summary of Control Costs for Glass-Melting Furnaces that Do Not Currently Meet the Proposed Chromium Limit 

Control Option Estimated 

Capital Cost*

($MM)

Estimated

Annual Cost 

($MM)

Total HAP 

Emissions 

Reductions 

(pounds per year)

Cost Effectiveness 

in $ per pound

No. Facilities

Change out of refractory 

brick lining

6.0 0.3 900 333 1

Installation of NaOH 

scrubber

0.25 0.1 70 1,400 2

* These costs are presented as example costs only and were not used in calculating the cost impacts associated with the proposed amendments. If the 

facilities with the 3 existing furnaces currently not meeting the proposed chrome emission limit (based on the most recent test results) do not become area 

sources and are subject to the NESHAP amendments, these are estimates of the control costs and cost effectiveness for those furnaces.
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II. 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 being proposed in the RTR amendments:

Emission 

Source

HAP Test 

Method

Test Cost

(in 2010 $)

Comment

Melting 

Furnaces

Cr compounds 29 $7,000

HF and HCl 320 $5,000

Forming and 

Curing 

(combined)

Phenol and Methanol 

(already testing for 

formaldehyde)

318 $14,000 $12,000 for each 

additional test