MEMORANDUM

Date:	October 20, 2011



Subject:	Energy and Environmental Impacts for Wool Fiberglass
Manufacturing Industry to Comply with Proposed Residual Risk and
Technology Review (RTR) Amendments 

Wool Fiberglass Manufacturing RTR

RTI Project No. 0213199.000.010

From:	Dave Reeves, RTI International



To:	Susan Fairchild

OAQPS/SPPD/NRG (D243-02)

U.S. Environmental Protection Agency

The purpose of this memorandum is to present the estimated energy and
environmental impacts for the wool fiberglass manufacturing industry to
comply with the proposed RTR amendments.

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).  

ENERGY AND ENVIRONMENTAL IMPACTS  

The 2 estimated major source facilities with bonded lines producing
heavy density products and/or pipe insulation will not have to install
any additional add-on control equipment to demonstrate compliance with
the new (proposed) emission limits and other requirements.  Therefore,
there are no energy or environmental impacts associated with the
proposed requirements. 

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