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

The purpose of this memorandum is to present the estimated costs 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).  

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. 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



Table 1 notes:

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.

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



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