**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY** 
**NSPS/NESHAP for**  **Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60,**  **Subpart PPP and 40 CFR Part 63, Subpart NNN) (Renewal)** 
**1. Identification of the Information Collection 1(a) Title of the Information Collection**  NSPS/NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP and 40 CFR Part 63, Subpart NNN) (Renewal) , EPA I CR Number 1160.12 , OMB Control Number 2060

- 01 14 **1(b) Short Characterization/Abstract**  The New Source Performance Standards (NSPS) for Wool Fiberglass Insulation Manufacturing Plants were proposed on February 7, 1984 , promulgated on February 25, 1985 , and amended on October 17, 2000 . These regulations apply to ne w and existing facilities with rotary spin (RS) wool fiberglass insulation manufacturing line s. The purpose of this NSPS is to control the emissions of particulate matter from each RS wool fiberglass insulation manufacturing line. The standard limits par ticulate emissions to 5.5 kilograms per megagram (11.0 lb./ton) of molten glass used to manufacture the product. New facilities include those that commenced construction, modification , or reconstruction after the date of proposal.
The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Wool Fiberglass Insulation Manufacturing Plants were proposed on March 31, 1997, promulgated on June 14, 1999 , and amended on April 20, 2006 . These regulations apply to each glass melting furnace locate d at a wool fiberglass manufacturing plant ; each RS manufacturing line producing building insulation; each new and existing flame attenuation (FA) manufacturing line that produces pipe products; and each new FA manufacturing line that produces heav y density products. Plants that manufacture mineral wool from rock or slag are not subject to the proposed rule, but they

are subject to a separate NESHAP standard for mineral wool production. A facility that i s determined to be an area source would not be subject to this NESHAP standard. New facilities include tho se that commenced construction or reconstruction after the date of proposal. This information is being collected to assure co mpliance with 40 CFR part 60, subpart PPP and 40 CFR part 63, subpart NNN

. In general, all NSPS and NESHAP standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also required to maintain re cords of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS and NESHAP

. Any owner/operator subject to the provisions of 40 CFR part 60, subpart PPP shall maintain a file of these measurements, and retain the file for at least two ye ars following the2

date of such measurements, maintenance reports, and records. An y owner/operator subject to the provisions of 40 CFR part 63, subpart NNN shall maintain a file of these measurements, and retain the file for at least five years follow ing the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority . In the event that there is no such delegated authority, the reports are sent directly to the U

. S

. Environmental Protecti on Agency

(EPA) regional office.
Over the next three ye ars, an average of 61 respondents per ye ar will be subject to the se standard s , and no additional respondents will become subject to the se standard s annuall y
. There are a pproximately

32 sources currentl y subject to 40 CFR part 60, subpart PPP , and 29 sources subject to 40 CFR part 63, subpart NNN. The number of affected sources subject to these regulations was estimated based on information available from the North American Insulation Manufacturing Association (NAIMA). The Office of Management and Budget (OMB) approved the currentl y active I CR without any

“Terms of Clearance.” The burden to the “Affected Public” may be found below in Table 1 a : Annual Respondent Burden and Cost

– NSPS for Wo ol Fibergl ass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP ) (Renewal) , and below in Table 1 b : Annual Respondent Burden and Cost

– NESHAP for Wool Fibergl ass Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN) (Renewal) . The “ burd en ” to the Federal Government is attributed entirely to work performed b y either F ederal employees or government contractors and may be found below in Table 2 a : Average Annual EPA Burden and Cost

– NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP ) (Renewal) , and below in Table 2 b : Average Annual EPA Burden and Cost

– NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN) (Renewal)

. **2. Need for and Use of the Collection 2(a)**  **Need/Authority for the Collection** The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological sy stem o f continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality health and environmental impact and energy requirements) the Administrator determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years.3

The EPA is also charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction.
Inaddition, section 114(a) states that the Administrator may require any owner/operator subject to any

requirement of this Act to: (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Sec tion 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, particulate emissions and hazardous air pollutant (HAP) emissions from wool fiberglass insulation manufacturing p lants either cause or contribute to air pollution that may

reasonably

be anticipated to endanger public health or welfare. Therefore, the NSPS and NESHAP were promulgated for this source category at 40 CFR part 60, subpart PPP, and 40 CFR part 63, subpart NNN , respectively

. **2(b) Practical Utility/Users of the Data** Both the recordkeeping and reporting requirements in the standards ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standards. Continuous emission monitors are used to ensure compliance with the standards at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standards are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control de vices are properl y installed and operated, leaks are being detected and repaired , and the standard is being met. The performance test may also be observed.4

The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 60, subpart PP P and 40 CFR part 63, subpart NNN

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or lo cal agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 77 FR 63813 ) on October 17, 2012. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of all complianc e data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed and the standard has been previously

reviewed to determine the minimum information needed for compliance purposes. In developing this I CR, we contacted : 1) the North American Insulation Manufacturing Association (NAIMA) , at ( 7 03 ) 684

- 0084 ; and 2) Central States Insulation Association (CSIA) , at ( 888 ) 294

- 0084

. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received.5

**3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information g athering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequentl y, the proper operation and m aintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines**
These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR part 1320, secti on 1320.5. The NESHAP standard require s the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. Th e retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
The reporting or recordkeeping requirements in the standard do not include sensitive question s. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are wool fiberglass insulation manufacturing p lants 1 . The United States Standard Industrial Classification ( SI C )

1 40 CFR part 63, subpart NNN also includes plants that manufacture fiberglass for liquid and air filtration.6

code for the respondents affected b y the standards is SI C 3296 , which corresponds to the North American Industry

Classification Sy stem (NAI CS ) code 327993 for M ineral W ool M anufacturing. **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NSPS/ NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR P art 60, S ubpart PPP , and 40 CFR P art 63, S ubpart NNN)

. A source must make the following reports:

**Notification s**  **/Reports ( 40 CFR**  **P art 60,**  **S ubpart PPP)**  Construction/reconstruction 60.7(a)(1) Actual startup 60.7(a)(3) Initial performance test 60.8(d) Phy sical or operational change 60.7(a)(4) Initial performance test results 60.8(a) Semiannual reports of exceedances of control device operating parameters 60.684(d)

**Notification s/Reports (**  **40 CFR P**  **art 63, S**  **ubpart NNN)** Applicability 63.9(a), 63.1389(a)(1

- 3) Construction/reconstruction 63.9(b)(3

- 4 ) , 63.1389(a)(4) Actual startup 63.9(b)(2) and (4) Special compliance requirements 63.9(d), 63.1389(a)(5) Initial performance test 63.9(e), 63.1389(a)(6) Continuous monitoring sy stem notifications 63.9(g) Compliance status 63.9(h), 63.1389(a)(7) Request for extension of compliance, adjustments to time periods, and changes in information 63.9(c), (i) and (j), 63.43 Operations, maintenance, and monitoring plan 63.6(e)(1)

- (e)(2), 63.1383(a) Report of performance test results 63.10(d)(2), 63.1386(b)

However, the majority of the plants (90 percent) manufacture fiberglass for building insulation.7

**Notification s/Reports (**  **40 CFR P**  **art 63, S**  **ubpart NNN)** Startup, shutdown, and malfunction plans and reports 63.6(e)(3), 63.10(d)(5), 63.1386(c) Excess emissions 63.1386(e) A source must keep the following records:

**Recordkeeping (**  **40 CFR P**  **art 60, S**  **ubpart PPP)** Startups, shutdowns, malfunctions, and periods where the continuous monitoring system is inoperative 60.7(b) Records are required to be retained for two ye ars 60.7(f) Continuous measurements of control device operating parameters 60.684(d)

**Recordkeeping (**  **40 CFR P**  **art 63, S**  **ubpart NNN)** General recordkeeping requirements (e.g., startups, shutdowns, and malfunctions including process equipment, air pollution control equipment, maintenance performed, and actions taken outside the scope of the existing plans) 63.10(b)(2), 63.1386(d)
Continuous measurements of control device operating parameters:

- Bag leak detection sy stem alarms

- ESP parameter values used to measure performance

- Air temperature above the molten glass in a cold top furnace

- Uncontrolled glass

- melt ing furnace parameter values to measure performance

- The formulation of ea ch binder patch and the LOI and density for each product manufactured

- Process parameter lev els for RS and FA manufacturing lines that use process modifications to comply with the emission limits

- Scrubber pressure drop, scrubbing liq uid flow rate, and any chemical additive

- Incinerator operating temperature and the results from periodic inspection of incinerator components

- Glass pull rate 63.1386(d)(2)(i

- ix)

Electronic Reporting8

Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordke eping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at approximately 10 percent of all the respon dents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for 40 CFR part 63, subpart NNN sources

. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure f

or wet scrubber for 40 CFR part 60, subpart PPP sources. Perform initial performance test, Reference Methods 1

- 5, 316 or 318; method for determining LO I; method for determining free

- formaldeh yd e content of resin; and method for the determination of produ ct density , and repeat performance tests if necessary for 40 CFR part 63, subpart NNN sources

. Perform initial performance test, Reference Method 5E test, and repeat performance tests if necessary for 40 CFR part 60, subpart PPP sources

. Write the notif

ications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information

. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y9

reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodo logy, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, storage, and distribution of the required information.
**Agency Activities** Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are p roperl y installed and operated. Performance test reports are used b y the Agency to dis cern a source ’ s initial capability to compl y with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification , as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA he adquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y 40 CFR part 60, subpart PP must be retained by the owner/operator for two years . The records required by 40 CFR part 63, subpart NNN must be retained b y the owner/operator for five ye ars
. **5(c) Small Entity Flexibility** There are no small entities (i.e., small businesses) affected b y this regulation. According to the Wo ol Fiberglass Insulation Manufacturing Industry

– Background Information for10

Proposed Standards ( EPA

- 450/3

- 82

- 022a): “The Small Business Administration (SBA) definition of a small business for SI C code 3296 Mineral Wool is 750 employees. All of the four publicly

- held firms that manufacture wool fiberglass insulation have more than 750 employees. Therefore, none of the firms meet the SBA definition of a small business. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown below in Table 1 a : Annual Respondent Burden and Cost

– NSPS for Wool Fibergl ass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP) (Renewal) , and below in Table 1 b : Annual Respondent Burden and Cost

– NESHAP for Wool Fibergl ass Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for each of the subparts included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver appropriate, speci fic tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 18,559 ( Total Labor Hours from Table s 1 a , and 1b below). This estimate includes 2,631 hours for 40 CFR part 60, subpart PPP, and 15,928 hours for 40 CFR part 63, subpart NNN. These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS and NESHAP program s , the previousl y approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 121.44 ($ 57.83 + 110%) Technical $ 100.23 ($ 47.73 + 110%) Clerical $ 50.51 ($ 24.05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March11

2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated w ith the information collection activities in the subject standards are both labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. Th e capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**
**Capital/Startup vs. Operation and Maintenance (O&M) Costs**  (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M 1 (G)

Total O&M, (E X F)
**NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR P**  **art 60, S**  **ubpart PPP)** Particulate Matter Monitoring $15,000 0 $0 $16,500 29 $478,500

**NESHAP for Wool Fiberglass Manufacturing Plants**  **(40 CFR P**  **art 63, S**  **ubpart NNN)** Baghouse Leak Detection $9,100 0 0 $500 20 $10,000

Furnace Tem perature Monitoring $1,500 0 0 $0 15 $0

Formaldehyde Emission Monitoring $15,000 0 0 $0 50 $0

1 In order to calculate O&M costs for 40 CFR part 63, subpart NNN, the estimates provided in column F were not based on the number of respondents but, instead, based on the total number of continuous monitoring devices that exist within the industry. For example, we estimate that there are 20 baghouses used within the wool fiberglass manufacturing industry. Some respondents may have more than one baghouse located at their facility. The total capital/startup costs for this I CR are zero. This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $488,500. This is the total of column G.12 The average annual cost for capital/startup and operation and maintenance costs to industry , over the next three years of the ICR , is estimated to be $ 488,500 . This estimate includes $478,500 for 40 CFR part 60, subpart PPP , and $10,000 for 40 CFR part 63, subpart NNN

. These are recordkeeping costs

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those co sts associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents , periodic inspection of sources of emissions, and the publicati on and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $29,478 . This estimate includes $6,634 for 40 CFR part 60, subpart PPP, and $22,844 for 40 CFR part 63, subpart NNN

. Thi s cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% )
These rates are from the Office of Personnel Management (OPM) , 2012 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appear below in T able 2 a : Average Annual EPA Burden and Cost

– NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP ) (Renewal) , and below in Table 2 b : Average Annual EPA Burden and Cost

– NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximatel y 61 existing respondents will be subject to the standard. Approximately 32 sources are currentl y subject to 40 CFR part 60, subpart PPP , and 29 sources are subject to 40 CFR part 63, subpart NNN. It is estimated that no additional respondent s will becom e subject to these standards annually . The overall average number of respondents, as shown in the table below is 61 per ye ar. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.13 **Number of Respondents**

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D)

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 61 0 0 61
2 0 61 0 0 61
3 0 61 0 0 61 Average 0 61 0 0 61 1 New respondent include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 61. The total number of annual responses per ye ar is calculated using the following table:
**Total Annual Responses** (A) Information Collection Activity (B)
Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D **40 CFR part 60, subpart PPP** Semiannual Exceedance Report 32 2 0 64 **40 CFR part 63, subpart NNN** Excess Emissions Report 29 2 0 58 Startup, Shutdown, and Malfunction Report 1 2.9 2 0 5.8

Total 12 7.8
1 Assume 10% of the plants are required to submit annual Startup, Shutdown, and Malfunction Reports

. The number of Total Annual Responses is 128

. The total annual labor costs are $ 1,797,060. This includes $254,776 for 40 CFR part 60, subpart PPP, and $1,542,284 fo r 40 CFR part 63, subpart NNN. Details regarding these estimates may

be found below in Table 1 a : Annual Respondent Burden and Cost

– NSPS for Wool Fibergl ass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP) (Renewal) , and below in Table 1 b : Annual Respondent Burden and Cost

– NESHAP for Wool Fibergl ass14

Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours for both subparts are 18,559 at a cost of $1,797,060 ; this which includes 2,631 hours at a cost of $254,776, for 40 CFR part 60, subpart PPP, and 15,928 hours at a cost of $1,542,284, for 40 CFR part 63, subpart NNN

. Details regarding these estimates may

be found below in Table 1 a : Annual Respondent Burden and Cost

– NSPS for Wool Fibergl ass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP) (Renewal) , and below in Table 1 b : Annual Respondent Burden and Cost

– NESHAP for Wool Fibergl ass Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 4 1 hours per response for 40 CFR part 60, subpart PPP, and 2 49 hours per response for 40 CFR part 63, subpart NNN

. The total annual capital/startup and O&M costs to the regulated entity are $478,500 for 40 CFR part 60, subpart PPP, and $10,000 for 40 CFR part 63, subpart NNN

. The total annual capital/startup and O&M costs for both subparts are $488,500. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

**(ii) The Agency Tally** The combined, average annual Agency burden and cost over next three years is estimated to be 654 labor hours at a cost of $29,478 (see below Tables 2a and 2b). The average annual Agency burden and cost is estimated to be 147 labor hours at a cost of $6,634 for 40 CFR part 60, subpart PPP, and 507 labor hours at a cost of $22,844 for 40 CFR part 63, subpart NNN. See below Table 2 a : Average Annual EPA Burden and Cost

– NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP ) (Renewal) , and below in Table 2 b : Average Annual EPA Burden and Cost

– NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN ) (Renewal)

. **6(f) Reasons for Change in Burden** There is no change in the labor hours in this I CR compared to the pervious ICR. This is due to two considerations : 1) the regulations have not changed over the past three years ; and 2) the growth rate for the industry is very low, negative or non

- existent, so there is no significant change in the overall burden . However, there is an adjustment increase in the total estimated labor costs. The change in cost estimates occurred because the labor rates have increased since the last I CR. This ICR used the most recent labor rates in calculating all burden costs.15

Additionally , the annual public reporting and recordkeeping burden for this collection of information has increased from 103 hours per response to 145 hours per response (41 hours per response for 40 CFR part 60, subpart PPP, and 2 49 hours per response for 40 CFR part 63, subpart NNN) . This is due to a correction in the total number of annual responses. The total number of annual responses decreased from 180 to 128. To calculate the number of responses, the previous ICR assumed that all 29 sources subject to subpart NNN were required to submit Startup, Shutdown, and Malfunction (SSM) reports semiannually

. This method was inconsistent with the Table 1 burden calculation, which assumed only 10% of all sources submit such reports. This I CR corrected the number of sources for submitting SSM reports, which results in a decrease in the number of responses for su bpart NNN. **6(g) Burden Statement** The combined, annual public reporting and recordkeeping burden for this collection of information is estimated to average 145 hours per industry response. “ Burden ” means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for thi s information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

–HQ

–O ECA

–2012

–0658. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of th e docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 1 752

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include th e EPA Docket ID Number EPA

- HQ

- OECA

- 2012

–0658 and OMB Control Number 2060

- 0114 in any16

correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.17

**Table 1 a**  **: Annual Respondent Burden and Cost**

**– NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60,**  **Subpart PPP) (Renewal)**

Burden Items (A) Hours per Occurrence (B)

Occurrences per Year (C)

Hours per Year (AxB) (D)

Respondents per Year a (E)

Technical Hours per Year (CxD) (F)

Managerial Hours per Year (Ex0.05) (G)

Clerical Hours per Year (Ex0.10) (H)

Cost, $ b

1. Applications N/A 2. Survey and Studies N/A 3. Reporting Requirements A. Read i nstructions c 1 1 1 0 0 0 0 $0 B. Required a ctivities Initial p erformance t ests d 72 1 72 0 0 0 0 $0 Repeat p erformance t ests e 72 0.2 14.4 0 0 0 0 $0 C. Create i nformation D. Gather e xisting i nformation E. Write Report Notification of c onstruction/reconstruction f 2 1 2 0 0 0 0 $0 Notification of a ctual s tartup f 2 1 2 0 0 0 0 $0 Notification of p hysical or o perational change f 2 1 2 0 0 0 0 $0 Notification of i nitial p erformance t est f 2 1 2 0 0 0 0 $0 Report of p erformance t est Included in 3B Semiannual e xceedance report g 4 2 8 32 256 12.8 25.6 $28,506.37 **Subtotal for Reporting**  **Requirements 294**  **.4 $28,506.37**  4. Recordkeeping Requirements A. Read i nstructions Included in 3A B. Plan a ctivities Included in 3B C. Implement a ctivities Included in 3B18

Burden Items (A) Hours per Occurrence (B)

Occurrences per Year (C)

Hours per Year (AxB) (D)

Respondents per Year a (E)

Technical Hours per Year (CxD) (F)

Managerial Hours per Year (Ex0.05) (G)

Clerical Hours per Year (Ex0.10) (H)

Cost, $ b

D. Develop r ecord s y s tem N/A E. Time to e nter i nformation 40 CFR Part 60, Subpart PPP Records of o perating p arameters and e missions h, i 0.25 250 62.5 32 2,000 100 200 $222,706.00 Records of s tartups, s hutdow ns, and malfunctions j 1 1 1 32 32 1.6 3.2 $3,563.30 F. Train Personnel N/A G. Audits N/A **Subtotal for Recordkeeping**  **Requirements 2,33**  **6.8 $226,269.30**  **Total Annual Burden and Cost (rounded)**  **2,631 $254,776** 
**Assu mptions:** 

a We have a ssume d that there are approximately 32 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.

. b This ICR uses the following labor rates: Managerial $121.44 ($57.83 + 110%), Technical $100.23 ($47.73 + 110%), and Clerical $50.5 1 ($24.05 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical hours.
c We have a ssume d that it will take each respondent one hour to read instructions. d We assume that it will take each respondent 72 hours to complete initial performance tests.
e We a ssume that 20 percent of respondents will have to repeat the initial performance tests due to failures

. f We a ssume that each respondent will take two hours to prepare notification reports. g We a ssume that each respondent will take fo ur hours to prepare semiannual report. h We a ssume that 0.25 hours is required to record operating parameters. i We a ssume that each respondent will take 250 days per year to enter operating parameters and emissions records

. j We a ssume that it will take one hour per years for each respondent to record startups, shutdowns, malfunctions.etc.19

**Table 1 b**  **: Annual Respondent Burden and Cost**

**– N**  **ESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part**  **6 3**  **, Subpart NNN**  **) (Renewal)**

Burden Items (A) Hours per Occurrence (B)

Occurrences per Year (C)

Hours per Year (AxB) (D)

Respondents per Year a (E)

Technical Hours per Year (CxD) (F)

Managerial Hours per Year (Ex0.05) (G)

Clerical Hours per Year (Ex0.10) (H)

Cost, $ b

1. Applications N/A 2. Survey and Studies N/A 3. Reporting Requirements A. Read i nstructions c 1 1 1 0 0 0 0 $0 B. Required a ctivities Initial p erformance t ests d 980 1 980 0 0 0 0 $0 Repeat p erformance t ests e 980 0.2 196 0 0 0 0 $0 Operations, maintenance, and monitoring p lan f 40 1 40 0 0 0 0 $0 Startup, s hutdown, and m alfunction p lan g 40 1 40 0 0 0 0 $0 C. Create i nformation D. Gather e xisting i nformation E. Write Report Notification of applicability h 2 1 2 0 0 0 0 $0 Notification of c onstruction/r econstruction h 2 1 2 0 0 0 0 $0 Notification of a ctual st artup h 2 1 2 0 0 0 0 $0 Notification of special c om pliance r equirements h 2 1 2 0 0 0 0 $0 Notification of i nitial p erformance t est h 2 1 2 0 0 0 0 $0 Notification of c om

pliance s tatus h 2 1 2 0 0 0 0 $0 Request for e xtension of c om pliance, adjustments to time p eriods, and c hanges in i nformation h, i 2 1 2 0 0 0 0 $020

Burden Items (A) Hours per Occurrence (B)

Occurrences per Year (C)

Hours per Year (AxB) (D)

Respondents per Year a (E)

Technical Hours per Year (CxD) (F)

Managerial Hours per Year (Ex0.05) (G)

Clerical Hours per Year (Ex0.10) (H)

Cost, $ b

Report of p erformance t est Included in 3B Excess e missions r eport j, k 16 2 32 5.8 185.6 9.28 18.56 $20,667.12 Report of no e xcess e missions l , m 1 2 2 23.2 46.4 2.32 4.64 $5,166.78 Quality i mp rovement p lan n 40 1 40 0 0 0 0 $0 Startup, s hutdown, and m alfunction p lan o, p 8 2 16 2.9 46.4 2.32 4.64 $5,166.78 **Subtotal for Reporting**  **Requirements 320**  **.16 $31,000.68**  4. Recordkeeping Requirements A. Read i nstructions Included in 3A B. Plan a ctivities Included in 3B C. Implement a ctivities Included in 3B D. Develop re cord s y s tem N/A E. Time to e nter i nformation Records of o perating p arameters and e missions q 9 52 468 29 13,572 678.6 1,357.2 $1,511,282.92 F. Train Personnel N/A G. Audits N/A **Subtotal for Recordkeeping**  **Requirements 15,60**  **7.8 $1,511,282.92**  **Total Annual Burden and**  **C ost (rounded)**  **15,928 $1,542,284** 

**Assu mptions:** 
a We have a ssume d that there are approximately 29 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. b This ICR uses the following labor rates: Managerial $121.44 ($57.83 + 110%), Technical $100.23 ($47.73 + 110%), and Clerical $50.51 ($24.05 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical hours.
c We have a ssume d that it will take each respondent one hour to read instructions. d We assume that it will take each respondent 980 hours to complete initial performance tests.21

e We a ssume that 20 percent of respondents will have to repeat the initial performance tests due to failures

. f We a ssume that each respondent will take 40 hours to prepare the o perations, maintenance, and monitoring p lan. g We assume that each respondent will take 40 hours to prepare the startup, shutdown, and malfunc tion plan. h We assume that it will take each respondent two hours to prepare each of the notifications. i We assume that it will take each respondent one hour to w rite the extension of compliance; adjustments to time periods, and changes in information reports. j We assume that it will take each respondent 16 hours to prepare excess emissions reports. k We assume that 20 percent of respondents are required to prepare excess emissions reports. l We assume that each respondent will take one hour to prepare no excess emissions reports.
m We assume that 80 percent of respondents will submit the no excess emissions reports.
n We assume that 40 percent of respondents are required to prepare the quality improvement plan.
o We assume that 10 percent of respondent will take eight hours to prepare startup, shutdown, and malfunction reports. p We assume that 10 percent of respondents are required to submit annual startup, shutdown, malfunction reports. q We assume that it will take each respondent nine hours each week to record records of operating parameters and emissions.22

**Table 2 a**  **: Average Annual EPA Burden and Cost**

**– NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part**  **60, Subpart PPP**  **) (Renewal)**

Burden Items (A) EPA Hours per Occurrence (B)

Occurrences per Year (C)

EPA Hours per Year (AxB) (D)

Plants per Year a (E)

Technical Hours per Year (CxD) (F)

Managerial Hours per Year (Ex0.05) (G)

Clerical Hours per Year (Ex0.10) (H)

Cost, $ b

1. Initial p erformance t ests A

. New or modified p lant c 24 1 24 0 0 0 0 $0 2. Repeat p erformance t ests A. New or modified p lant c, d 24 0.2 4.8 0 0 0 0 $0 3. Report Review A

. New or modified p lant Notification of c onstruction/r econstruction 2 1 2 0 0 0 0 $0 Notification of a ctual s tartup 1 1 1 0 0 0 0 $0 Notification of p hysical or o perational change 2 1 2 0 0 0 0 $0 Notification of i nitial p erformance t est 1 1.2 1.2 0 0 0 0 $0 Review p erformance t est r esults e 8 1.2 9.6 0 0 0 0 $0 Review s emiannual e xceedance/n o e xceedance r eports f 2 2 4 32 128 6.4 12.8 $6,633.54 Subtotal Annual Burden 128 6.4 12.8 $6,633.54 **Total Annual Burden and Cost (rounded)**  **147 $6,634** 
**Assu mptions:** 
a We have a ssume d that there are approximately 32 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. b This ICR uses the following labor rates: Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) , Technical $46.21 (GS

- 12, Step 1, $28.88 + 60 %), and Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%). These rates are from the Office of Personnel Management (OPM), 2012 General Schedule, which exclud es locality rates of pay. The rates have been increased by 60 percent to account for the benefit packa ges available to government employees. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical hours.
c We have assumed that it will take 24 hours for each new plant to participate in the performance testin g. d We assume that 20 percent of new or modified plants will have to repeat performance test due to failures.
e We assume that each new or modified plant will take eight hour 1.2 times per year to review the performance test results repo rts. f We have assumed that each plant will take two hours two times per year to review the semiannual exceedance/no exceedance repo rts.23

**Table 2 b**  **: Average Annual EPA Burden and Cost**

**– NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR**  **Part 63, Subpart NNN) (Renewal)** 

Burden Items (A) EPA Hours per Occurrence (B)

Occurrences per Year (C) EPA

Hours per Year (AxB) (D)

Plants per Year a (E) Technical Hours per Year (CxD) (F)

Managerial Hours per Year (Ex0.05) (G)

Clerical Hours per Year (Ex0.10) (H)

Cost, $ b

1. Initial p erformance t ests A. New or modified plant c 40 1 40 0 0 0 0 $0 2. Repeat p erformance t ests A. New or modified plant c, d 40 0.2 8 0 0 0 0 $0 3. Report Review A

. New or modified p lant Notification of applicability e 2 1 2 0 0 0 0 $0 Notification of c onstruction/r econstruction e 2 1 2 0 0 0 0 $0 Notification of a ctual s tartup e 2 1 2 0 0 0 0 $0 Notification of special c om pliance requirements e 1 1 1 0 0 0 0 $0 Notification of i nitial p erformance t est e 2 1 2 0 0 0 0 $0 Notification of c om

pliance s tatus e 2 1 2 0 0 0 0 $0 Request for e xtension of c om pliance, a djustments to time p eriods, and c hanges in i nformation f 2 1 2 0 0 0 0 $0 Report of i nitial p erformance t est 40 1 40 0 0 0 0 $0 Excess e mi ssions r eport g 20 2 40 5.8 232 11.6 23.2 $12,023.28 Report of n o e xcess e missions h 2 2 4 23.2 92.8 4.64 9.28 $4,809.31 Quality i mp rovement p lan i 40 1 40 0 0 0 0 $0 Startup, s hutdown, and m alfunction p lan i 40 1 40 0 0 0 0 $0 Operations, maintenance, and monitoring p lan i 40 1 40 0 0 0 0 $0 Startup, s hutdown, and m alfunction r eport j 20 2 40 2.9 116 5.8 11.6 $6,011.64 Subtotal Annual Burden 440.8 22.04 44.08 $22,844.24 **Total Annual Burden and Cost (rounded)**  **507 $22,844** 24

**Assu mptions:**  a We have a ssume d that there are approximately 29 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years. b This ICR uses the following labor rates: Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) , Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%), and Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%). These rates are from the Office of Personnel Management (OPM), 2012 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account fo r the benefit packages available to government em ployees. This ICR assumes that Clerical hours are 10% of Technical hours and Managerial hours are 5% of Technical hours. c We have assumed that it will take 40 hours for each new plant to participate in th e performance testing. d We assume that 20 percent of new or modified plants will have to repeat performance test due to failures. e We assume that each new or modified plant will take two hour once per year to review the n otification reports. f We assume that each new or modified plant will take two hours once per year to completed request. g We assume that 20 percent of plants will each take 20 hours twice per year to review excess emissions report. h We assume that 80 percent of plants will each take two hours twice per year to review the no excess emissions report. i We assume that it will take 40 hours once per year to review plan s
. j We assume that it will take 20 hours twice per year to review startup, shutdown, and malfunction report.