SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR part 60, subpart PPP) 

and NESHAP for Wool Fiberglass Manufacturing (40 CFR part 63, subpart NNN)

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR part 60, subpart PPP) and 

NESHAP for Wool Fiberglass Manufacturing (40 CFR part 63, subpart NNN) (Renewal),

EPA ICR Number 1160.09, OMB Control Number 2060-0114

1(b) Short Characterization/Abstract

This Information Collection Request (ICR) includes two Clean Air Act (CAA) standards 

for the wool fiberglass manufacturing industry. Both the New Source Performance Standards 

(NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) standards 

include: basic recordkeeping and reporting, including initial notifications; performance testing; 

semiannual excess emission reports; and occurrence and duration of any startup, shutdown, or 

malfunction in the operation of an affected facility. All reports are sent to the delegated state or 

local authority. In the event that there is no such authority, the reports are sent directly to the 

EPA regional office.

The NSPS for Wool Fiberglass Insulation Manufacturing Plants, published at 40 CFR 

part 60, subpart PPP, were proposed on February 7, 1984 and promulgated on February 25, 1985. 

These regulations apply to each rotary spin (RS) wool fiberglass insulation manufacturing line, 

which commenced construction, modification, or reconstruction after February 2, 1984. The 

purpose of this NSPS is to control the emissions of particulate matter from each RS wool 

fiberglass insulation manufacturing line. The standards limit particulate emissions to 5.5 

kilograms per megagram (11.0 lb./ton) of molten glass used to manufacture the product.

The NESHAP for Wool Fiberglass Manufacturing, published at 40 CFR part 63, subpart 

NNN, were proposed on March 31, 1997 and promulgated on June 14, 1999. These regulations 

apply to each glass melting furnace located 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 heavy 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 is determined to be an area source would not be subject to this 

NESHAP standard. This information is being collected to assure compliance 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. Owners or operators are also required to maintain records of the 
2

occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected 

facility or any period during which the monitoring system is inoperative. These notifications, 

reports, and records are essential in determining compliance and are required of all sources 

subject to both the NSPS and NESHAP.

Any owner or 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 years following the date 

of such measurements, maintenance reports, and records. Any owner or 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 following the date of such measurements, maintenance 

reports, and records. All reports for both the NSPS and NESHAP 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 appropriate U.S. Environmental Protection Agency (EPA) regional office.

Approximately 32 sources are currently subject to 40 CFR part 60, subpart PPP. 

Approximately 29 sources are subject to 40 CFR part 63, subpart NNN. It is anticipated that no 

new sources will become subject to either the NSPS or NESHAP regulation in the next three 

years. 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 currently active ICR without 

any “Terms of Clearance.”

The burden to the “Affected Public” may be found below in both Table 1: Annual 

Respondent Burden: NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR part 

60, subpart PPP) (Renewal) and Table 2: Annual Respondent Burden: NESHAP for Wool 

Fiberglass Manufacturing (40 CFR part 63, subpart NNN) (Renewal). 

The burden to the “Federal Government” is attributed entirely to work performed by

Federal employees or government contractors. This burden may be found below in both Table 3: 

Average Annual EPA Burden: NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 

CFR part 60, subpart PPP) (Renewal) and Table 4: Average Annual EPA Burden: NESHAP for 

Wool Fiberglass Manufacturing (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, as amended, to establish 

standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of 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 adequately demonstrated. 

Section 111(a)(l).
3

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.

The EPA also is 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 (HAPs). These standards are applicable to new or existing sources of 

hazardous air pollutants and shall require the maximum degree of emissions reduction.

In addition, section 114(a) states that the Administrator may require any owner or 

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 Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, particulate emissions and hazardous air pollutant (HAP) 

emissions from wool fiberglass manufacturing plants 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

The control of emissions of particulates and HAPs from wool fiberglass manufacturing 

plants requires not only the installation of properly designed equipment but also the operation 

and maintenance of that equipment. Emissions of particulates from wool fiberglass insulation 

manufacturing plants are the result of operation of each RS wool fiberglass insulation 

manufacturing line. Emissions of HAPs from wool fiberglass manufacturing plants are the result 

of operation of each glass melting furnace and each RS and FA manufacturing line. These 

standards rely on the capture of particulate and HAPs emissions by control equipment such as a 

wet scrubbing control device or an electrostatic precipitator. The notifications required in the 

applicable regulations 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 devices are properly installed and operated 

and the regulations are being met. Performance test reports are needed as these are the Agency’s 

record of a source's initial capability to comply with the emission standards and serve as a record 

of the operating conditions under which compliance was achieved. The semiannual reports are 
4

used for problem identification, as a check on source operation and maintenance, and for 

compliance determinations. The information generated by the monitoring, recordkeeping and 

reporting requirements described in this ICR is used by the Agency to ensure that plants affected 

by the NSPS and/or NESHAP continue to operate the control equipment and achieve compliance 

with the regulation. Adequate monitoring, recordkeeping, and reporting are necessary to ensure 

compliance with the applicable regulations, as required by the Clean Air Act. The information 

collected from recordkeeping and reporting requirements is also used for targeting inspections 

and is of sufficient quality to be used as evidence in court.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under both 40 CFR part 60, 

subpart PPP and 40 CFR part 63, subpart NNN.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state 

or local agency. If a state or local agency has adopted its own similar standards to implement the 

Federal standards, a copy 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, no duplication 

exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register at 74 FR 38004 on July 30, 2009. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

Information provided by the North American Insulation Manufacturing Association 

(NAIMA) in preparation of the most recent approved ICR was used as the primary source for 

determining the number of affected sources subject to these standards.

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.

It is our policy to carefully review any comments received since the last ICR renewal 

including those submitted in response to the first Federal Register notice, and to respond 

appropriately.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that plants 
5

are continuing to meet the standards. Requirements for information gathering 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 

frequently, the likelihood of detecting poor operation and maintenance of control equipment and 

noncompliance would decrease.

3(e) General Guidelines

None of these reporting or recordkeeping requirements violate any of the regulations 

established by OMB at 5 CFR 1320.5.

3(f) Confidentiality

The required information has been determined not to be confidential. However, 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

None of the reporting or recordkeeping requirements contains sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements for 40 CFR part 60, 

subpart PPP and 40 CFR part 63, subpart NNN are wool fiberglass manufacturing plants.1The 

United States Standard Industrial Classification (SIC) code for the respondents affected by the 

standards is 3296, which corresponds to the North American Industry Classification System 

(NAICS) code 327993.

4(b) Information Requested 

(i) Data Items

The 40 CFR part 63, subpart NNN standards require affected facilities 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-year records retention 

requirement is consistent with the part 70 permit program and the five-year statute of limitations 

on which the permit program is based. Also, the retention of records for five years would allow 

 

1

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

However, the majority of the plants (90 percent) manufacture fiberglass for building insulation. 
6

EPA to establish the compliance history of a source and any pattern of compliance for purposes 

of determining the appropriate level of enforcement action. Historically, EPA has found that the 

most flagrant violators frequently have violations extending beyond the five years. EPA would 

be prevented from pursuing the worst violators due to the destruction or nonexistence of records 

if records were retained for less than five years.

The 40 CFR part 60, subpart PPP standards require affected facilities to maintain all 

records, including reports and notifications for at least two years.

All data in this ICR that is recorded and/or reported is required by 40 CFR part 60, 

subpart PPP and/or 40 CFR part 63, subpart NNN. A source subject to 40 CFR part 60, subpart 

PPP and/or 40 CFR part 63, subpart NNN must comply with the notifications, monitoring, and 

recordkeeping requirements listed in the following exhibits.

Reports for 40 CFR part 60, subpart PPP

Construction/reconstruction 60.7(a)(1)

Actual startup 60.7(a)(3)

Initial performance test 60.8(d)

Physical 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)

Reports for 40 CFR part 63, subpart NNN

Applicability 63.9(a), 63.1389(a)(1-3)

Construction/reconstruction 63.9(b)(3) and (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 system 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)

Startup, shutdown, and malfunction plans and 

reports 63.6(e)(3), 63.10(d)(5), 63.1386(c)

Excess emissions 63.1386(e)
7

A source must maintain the following records:

Recordkeeping for 40 CFR part 60, subpart PPP

Startups, shutdowns, malfunctions, and periods where the continuous 

monitoring system is inoperative 60.7(b)

Records are required to be retained for two years 60.7(f)

Continuous measurements of control device operating parameters 60.684(d)

Recordkeeping for 40 CFR part 63, subpart 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 system alarms

- ESP parameter values used to measure performance

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

- Uncontrolled glass-melting furnace parameter values to measure 

performance

- The formulation of each binder patch and the LOI and density

for each product manufactured

- Process parameter levels for RS and FA manufacturing lines that 

use process modifications to comply with the emission limits

- Scrubber pressure drop, scrubbing liquid 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)

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 recordkeeping at 

a plant site. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.
8

Respondent Activities

Install, calibrate, maintain, and operate continuous monitoring system for 40 CFR part 63, 

subpart NNN sources. Install, calibrate, maintain, and operate CMS for pressure drop and 

liquid supply pressure for wet scrubber for 40 CFR part 60, subpart PPP sources.

Perform initial performance test. Methods 1-5, 316 or 318; method for determining LOI; 

method for determining free-formaldehyde content of resin; and method for the determination 

of product density are used for 40 CFR part 63, subpart NNN sources. Reference Method 5E 

for particulates is used 40 CFR part 60, subpart PPP sources. All tests are repeated if 

necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Adjust the existing ways to comply with any previously applicable instructions and 

requirements.

Train personnel to be able to respond to a collection of information.

Transmit or otherwise disclose the information.

5. The Information Collected: Agency Activities, Collection Methodology, and Information 

Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and excess emissions 

reports required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect the source to 

determine whether the pollution control devices are properly installed and operated. 
9

Performance test reports are used by the Agency to discern a source’s initial capability to comply

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.

Information contained in the reports is entered into the AFS, which is operated and 

maintained by the EPA Office of Compliance. AFS is the EPA database for the collection, 

maintenance, and retrieval of compliance and annual emission inventory data for more than 

100,000 industrial and government-owned plants. EPA uses the AFS for tracking air pollution 

compliance and enforcement by local and state regulatory agencies and EPA regional offices and 

EPA Headquarters. EPA and its delegated Authorities can edit, store, retrieve, and analyze the 

data.

The records required by 40 CFR part 60, subpart PPP must be retained by the owner or 

operator for two years. The records required by 40 CFR part 63, subpart NNN must be retained 

by the owner or operator for five years.

5(c) Small Entity Flexibility

There are no small businesses affected by this regulation. According to the Wool 

Fiberglass Insulation Manufacturing Industry – Background Information for Proposed 

Standards (EPA-450/3-82-022a): “The Small Business Administration (SBA) definition of a 

small business for SIC 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 meets 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 both Table 1: Annual Respondent Burden: NSPS for Wool Fiberglass Insulation 

Manufacturing Plants (40 CFR part 60, subpart PPP) (Renewal) and Table 2: Annual Respondent 

Burden: NESHAP for Wool Fiberglass Manufacturing (40 CFR part 63, subpart NNN)

(Renewal).

6. Estimating the Burden and Cost of the Collection

Tables 1 and 2 document the computation of individual burdens for the recordkeeping 

and reporting requirements applicable to the industry for the subparts included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. 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 
10

and reporting requirements for 40 CFR part 60, subpart PPP is estimated to be 2,631 hours. 

The average annual burden to industry over the next three years from these recordkeeping and 

reporting requirements for 40 CFR part 63, subpart NNN is estimated to be 15,928 hours. 

The total number of labor hours for both subparts is 18,559. 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 programs; the previously approved ICR; and any

comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: $114.77 per hour for Executive, Administrative, 

and Managerial labor; $97.59 per hour for Technical labor, and $48.26 per hour for Clerical 

labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

March, 2009, “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.

Managerial $114.77 ($54.65 + 110%)

Technical $97.59 ($46.47 + 110%)

Clerical $48.26 ($22.98 + 110%)

Managerial and administrative labor hours for 40 CFR part 60, subpart PPP and 40 CFR part 63, 

subpart NNN were estimated to be approximately 5 percent and 10 percent, respectively, of the 

estimated technical labors. 

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The capital/startup costs and operations and maintenance (O&M) costs for 40 CFR part 

60, subpart PPP are associated with the particulate matter monitoring equipments. The 

capital/startup costs are one-time costs when the facility becomes subject to the standard. 

Because no new sources are anticipated for this source category over the next three years, the 

capital startup costs are zero. The annual O&M costs associated with the particulate monitoring 

equipment are $16,500.

The capital and O&M costs for 40 CFR part 63, subpart NNN are associated with 

baghouse leak detection monitoring, furnace temperature monitoring, and formaldehyde emission 

monitoring. The capital/startup costs are one-time costs when a facility becomes subject to the 

standard. Because no new sources are anticipated for this source category over the next three 

years, the capital startup costs are zero. O&M costs for baghouse leak detection monitoring are 

estimated at $500 per year per baghouse. There are no O&M costs associated with furnace 

temperature monitors or formaldehyde emissions monitoring.
11

(iii) Capital/Startup vs. Operation and Maintenance Costs

NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR part 60, subpart 

PPP)

Capital/Startup vs. Operation and Maintenance 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 

Respondent

s with O&M

(G)

Total O&M,

(E X F)

Particulate 

Matter 

Monitoring

$15,000 0 $0 $16,500 29 $478,500

NESHAP for Wool Fiberglass Manufacturing (40 CFR part 63, subpart NNN)

Capital/Startup vs. Operation and Maintenance Costs

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startu

p Cost

(B X C)

(E)

Annual 

O&M Costs 

for One 

Respondent

(F)

Number of 

Respondent

s with 

O&M2

(G)

Total O&M,

(E X F)

Baghouse 

Leak 

Detection

$9,100 0 0 $500 20 $10,000

Furnace 

Temperature 

Monitoring

$1,500 0 0 $0 15 $0

Formaldehyd

e Emission 

Monitoring

$15,000 0 0 $0 50 $0

Because there are no new sources expected over the next three years, there are no capital 

costs associated with either 40 CFR part 60, subpart PPP or 40 CFR part 63, subpart NNN.

The total O&M cost for this ICR is $488,500. This is the sum of the totals of column G 

in the two tables above.

The total respondent cost has been calculated as the addition of the capital/startup costs 

and the annual O&M costs. The average annual cost for capital/startup and O&M to industry

over the next three years of the ICR is estimated to be $488,500.

 

2

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.
12

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis 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 publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR for 40 CFR part 60, 

subpart PPP is estimated to be $6,535. 

The average annual Agency cost during the three years of the ICR for 40 CFR part 63, 

subpart NNN is estimated to be $22,504. 

This cost is based on the average hourly labor rate as follows:

Managerial $61. 36 (GS-13, Step 5, $38.35 + 60%)

Technical $45.52 (GS-12, Step 1, $28.45 + 60%)

Clerical $24.64 (GS-6, Step 3, $15.40 + 60%)

These rates are from the Office of Personnel Management (OPM), 2009 General 

Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to 

account for the benefit packages available to government employees. Details upon which this 

estimate is based appear below in both Table 3: Average Annual EPA Burden: NSPS for Wool 

Fiberglass Insulation Manufacturing Plants (40 CFR part 60, subpart PPP) (Renewal) and Table 

4: Average Annual EPA Burden: NESHAP for Wool Fiberglass Manufacturing (40 CFR part 63, 

subpart NNN) (Renewal). Managerial and administrative labor hours were estimated to be 

approximately 5 percent and 10 percent, respectively, of the estimated technical labors. 

6(d) Estimating the Respondent Universe and Total Burden and Costs

Approximately 32 and 29 sources currently are subject to 40 CFR part 60, subpart PPP 

and 40 CFR part 63, subpart NNN, respectively. We estimate that no additional sources per year 

will become subject to either regulation in the next three years.

Respondent Universe and Number of Responses Per Year

Regulation 

Citation

(A)

Average 

Number of 

New

Respondents 

per Year

(B)

Number of 

Reports for 

New

Sources

(C)

Number of 

Existing 

Respondent

s

(D)

Number of 

Reports for 

Existing 

Sources

(E)

Number of 

Respondents 

That Keep 

Records But 

Do Not 

Submit 

Reports

(F)

Total Annual 

Responses =

(AxB)+(CxD)+F

40 CFR part 60, 

subpart PPP 0 5 32 2 0 64
13

Respondent Universe and Number of Responses Per Year

Regulation 

Citation

(A)

Average 

Number of 

New

Respondents 

per Year

(B)

Number of 

Reports for 

New

Sources

(C)

Number of 

Existing 

Respondent

s

(D)

Number of 

Reports for 

Existing 

Sources

(E)

Number of 

Respondents 

That Keep 

Records But 

Do Not 

Submit 

Reports

(F)

Total Annual 

Responses =

(AxB)+(CxD)+F

40 CFR part 63, 

subpart NNN 0 8 29 4 0 116

The number of total respondents for 40 CFR part 60, subpart PPP and 40 CFR part 63, 

subpart NNN is 61. This number is the sum of column A and column C of the Respondent 

Universe and Number of Responses per Year table. This represents the number of existing 

sources plus the number of new sources averaged over the three-year period (i.e., the total of the 

number of new respondents over the three-year period divided by three years).

The number of Total Annual Responses for both 40 CFR part 60, subpart PPP and 40 

CFR part 63, subpart NNN is 180. This is the sum of column F of the Respondent Universe and 

Number of Responses per Year table above.

The total annual labor costs for 40 CFR part 60, subpart PPP is $247,457. The total 

annual labor costs for 40 CFR part 63, subpart NNN is $1,497,983. The total annual labor costs 

for both standards are equal to $1,745,440. Details upon which this estimate is based below

appear in both Table 1: Annual Respondent Burden: NSPS for Wool Fiberglass Insulation 

Manufacturing Plants (40 CFR part 60, subpart PPP) (Renewal) and Table 2: Annual Respondent 

Burden: NESHAP for Wool Fiberglass Manufacturing (40 CFR part 63, subpart NNN)

(Renewal).

Note that the total annual capital and O&M costs to the regulated entity are $488,500. 

These costs are detailed in section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

Costs.

6(e) Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the respondents 

appear in the attached Tables 1 thru 4. A summary of the bottom line burden hours and costs 

appears below.

Industry Burden Agency Burden Capital Costs O&M Costs

Hours Dollars ($) Hours Dollars ($) Dollars ($) Dollars ($)

40 CFR Part 60, 

Subpart PPP 2,631 $247,457 147 $6,535 0 $478,500

40 CFR part 63, 

subpart NNN 15,928 $1,497,983 507 $22,504 0 $10,000
14

Industry Burden Agency Burden Capital Costs O&M Costs

Hours Dollars ($) Hours Dollars ($) Dollars ($) Dollars ($)

Total 18,559 $1,745,440 635 $29,039 0 $488,500

6(f) Reasons for Change in Burden

There is an increase of 343 hours in the total labor hours for this ICR, due to an 

adjustment. Total labor hours for this ICR are 18,559 rather than 18,216 in the previous ICR 

because the previous ICR did not include managerial and clerical hours for 40 CFR part 60, 

subpart PPP. This adjustment also results in a slight increase in the per-respondent labor hours, 

from 101 to 103 hours per response. 

Although these adjustments resulted in an increase in calculated burden hours, the 

regulations have not changed over the past three years and are not anticipated to change over the 

next three years. Additionally, the growth rate for the respondents is very low, negative or nonexistent. 

There is an increase in both respondent and Agency costs resulting from labor rate 

increases from 2003 to 2009. This ICR uses 2009 labor rates because burden and cost 

calculations in this ICR were expanded to include managerial and clerical labor rates, and the 

previous ICR only provided a technical labor rate for 2003. This ICR is therefore updated to 

present the most recent available labor rates for each of the three labor categories. 

An apparent difference of $500 in O&M costs is attributable to rounding to the nearest 

thousand in the previous renewal; this ICR renewal presents more exact figures.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 103 hours per response. Burden means the total time, effort, or financial 

resources expended by 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 systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply 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’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this 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 ICR under 
15

Docket ID Number EPA-HQ-OECA-2009-0530. 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 the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents also are 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 Avenue, 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 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2009-0530 and OMB Control Number 2060-0114 in any

correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
A B C D E F G H I

Reporting/Recordkeeping Requirements (a, b)

Hours/

Occurrence

Occurrences/

Year

Hours/Year

(C = A x B)

Respondents/

Year

Technical

Hours/Year

(C*D)

Managerial

Hours/Year

(E*0.05)

Clerical

Hours/Year

(E*0.10)

Total

Hours/Year

(H=E+F+G)

Total

Costs/Year (c) 

1. Applications N/A N/A N/A N/A N/A N/A N/A N/A N/A

2. Survey and Studies N/A N/A N/A N/A N/A N/A N/A N/A N/A

3. Reporting Requirements

A. Read Instructions (d) 1 1 1 0 0.00 0.00 0.00 0.00 $0

B. Required Activities

Initial Performance Tests (e) 72 1 72 0 0.00 0.00 0.00 0.00 $0

Repeat of Performance Tests (f) 72 0.2 14.4 0 0.00 0.00 0.00 0.00 $0

C. Create Information

D. Gather Existing Information

E. Write Report

Notification of Construction/Reconstruction (g) 2 1 2 0 0.00 0.00 0.00 0.00 $0

Notification of Actual Startup (g) 2 1 2 0 0.00 0.00 0.00 0.00 $0

Notification of Physical or Operational Change (g) 2 1 2 0 0.00 0.00 0.00 0.00 $0

Notification of Initial Performance Test (g) 2 1 2 0 0.00 0.00 0.00 0.00 $0

Report of Performance Test Included in 3B

Semiannual Exceedance Report (h) 4 2 8 32 256.00 12.80 25.60 294.40 $27,688

Reporting Subtotal 294 $27,688

4. Recordkeeping Requirements

A. Read Instructions Included in 3A

B. Plan Activities Included in 3B

C. Implement Activities Included in 3B

D. Develop Record System N/A N/A N/A N/A N/A N/A N/A N/A N/A

E. Time to Enter Information 

Records of Operating Parameters and Emissions (i, j) 0.25 250 62.5 32 2,000.00 100.00 200.00 2,300.00 $216,309

Records of Startups, Shutdowns, and Malfunctions (k) 1 1 1 32 32.00 1.60 3.20 36.80 $3,461

F. Train Personnel N/A N/A N/A N/A N/A N/A N/A N/A N/A

G. Audits N/A N/A N/A N/A N/A N/A N/A N/A N/A

Recordkeeping Subtotal 2,337 $219,770

TOTAL ANNUAL BURDEN 2,631 247,457

Footnotes:

b) Assume zero new plants per year.

d) Assume one hour is required to read instructions.

f) Assume 20% of initial performance tests are repeated due to failures.

g) Assume two hours are required for notification preparation.

h) Assume four hours are required to prepare semiannual report.

i) Assume one quarter-hour is required to record operating parameters.

j) Assume 250 operating days per year.

k) Assume one hour per year is required to record startups, shutdowns, malfunctions, etc.

TABLE 1: ANNUAL RESPONDENT BURDEN: NSPS FOR WOOL FIBERGLASS INSULATION MANUFACTURING PLANTS (40 CFR Part 60, Subpart PPP) (Renewal)

a) Assume 32 affected plants.

c) This ICR uses the following labor rates: Managerial $114.77 ($54.65 + 110%); Technical $97.59 ($46.47 + 110%); and Clerical $48.26 ($22.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor 

Statistics, March 2009, Table 2. Civilian workers, by occupational and industry group. The rates are from column 1, "Total compensation". The rates have been increased by 110% to account for the benefit packages available to those employed 

by private industry. This ICR assumes that Managerial hours are 5% of Technical hours, and Clerical hours are 10% of Technical hours.

e) Assume 72 hours are required to complete initial performance tests.
A B C D E F G H I

Reporting/Recordkeeping Requirement (a, b)

Hours/

Occurrence

Occurrences/

Year

Hours/Year

(C = A*B)

Respondents/

Year

Technical

Hours/Year

(C*D)

Managerial

Hours/Year

(E*0.05)

Clerical

Hours/Year

(E*0.10)

Total

Hours/Year

(H=E+F+G)

Total

Costs/Year (c) 

1. Applications N/A N/A N/A N/A N/A N/A N/A N/A N/A

2. Survey and Studies N/A N/A N/A N/A N/A N/A N/A N/A N/A

3. Reporting Requirements

A. Read Instructions (d) 1 1 1 0 0.00 0.00 0.00 0.00 $0

B. Required Activities

Initial Performance Tests (e) 980 1 980 0 0.00 0.00 0.00 0.00 $0

Repeat of Performance Tests (f) 980 0.2 196 0 0.00 0.00 0.00 0.00 $0

Operations, Maintenance, and Monitoring Plan (g) 40 1 40 0 0.00 0.00 0.00 0.00 $0

Startup, Shutdown, and Malfunction Plan (h) 40 1 40 0 0.00 0.00 0.00 0.00 $0

C. Create Information Included in 3B

D. Gather Existing Information Included in 3B

E. Write Report

Notification of Applicability (i) 2 1 2 0 0.00 0.00 0.00 0.00 $0

Notification of Construction/Reconstruction (i) 2 1 2 0 0.00 0.00 0.00 0.00 $0

Notification of Actual Startup (i) 2 1 2 0 0.00 0.00 0.00 0.00 $0

Notification of Special Compliance Requirements (i) 2 1 2 0.00 0.00 0.00 0.00 $0

Notification of Initial Performance Test (i) 2 1 2 0 0.00 0.00 0.00 0.00 $0

Notification of Compliance Status (i) 2 1 2 0 0.00 0.00 0.00 0.00 $0

Request for Extension of Compliance, Adjustments to 

Time Periods, and Changes in Information (i, j) 2 1 2 0 0.00 0.00 0.00 0.00 $0

Report of Performance Test Included in 3B

Excess Emissions Report (k, l) 16 2 32 5.8 185.60 9.28 18.56 213.44 $20,073

Report of No Excess Emissions (m, n) 1 2 2 23.2 46.40 2.32 4.64 53.36 $5,018

Quality Improvement Plan (o) 40 1 40 0 0.00 0.00 0.00 0.00 $0

Startup, Shutdown, and Malfunction Report (p, q) 8 2 16 2.9 46.40 2.32 4.64 53.36 $5,018

Reporting Subtotal 320.16 30,110.21

4. Recordkeeping Requirements

A. Read Instructions Included in 3A

B. Plan Activities Included in 3B

C. Implement Activities Included in 3B

D. Develop Record System N/A N/A N/A N/A N/A N/A N/A N/A N/A

E. Time to Enter Information 

Records of Operating Parameters and Emissions (r) 9 52 468 29 13,572.00 678.60 1,357.20 15,607.80 $1,467,873

F. Train Personnel N/A N/A N/A N/A N/A N/A N/A N/A N/A

G. Audits N/A N/A N/A N/A N/A N/A N/A N/A N/A

Recordkeeping Subtotal 15,608 $1,467,873

TOTAL ANNUAL BURDEN 15,928 1,497,983

Footnotes:

b) Assume zero new plants per year.

d) Assume one hour is required to read instructions.

f) Assume 20% of initial performance tests are repeated due to failures.

g) Assume 40 hours are required to prepare the Operations, Maintenance, and Monitoring Plan.

h) Assume 40 hours are required to prepare the Startup, Shutdown, and Malfunction Plan.

i) Assume two hours are required for the preparation of notifications and requests for Extension of Compliance, Adjustments to Time Periods, and Changes in Information.

j) Assume one request per respondent for Extension of Compliance, Adjustments to Time Periods, and Changes in Information.

k) Assume 16 hours are required to prepare Excess Emissions Reports.

l) Assume 20% of plants are required to submit Excess Emissions Reports.

m) Assume one hour is required to prepare No Excess Emissions Reports.

n) Assume 80% of plants are required to submit No Excess Emissions Reports.

o) Assume 40 hours are required to prepare the Quality Improvement Plan.

p) Assume eight hours are required to prepare Startup, Shutdown, and Malfunction Reports.

q) Assume 10% of plants are required to submit annual Startup, Shutdown, and Malfunction Reports.

r) Assume nine hours per week are required to record information required by the standard.

TABLE 2: ANNUAL RESPONDENT BURDEN: NESHAP FOR WOOL FIBERGLASS MANUFACTURING (40 CFR Part 63, Subpart NNN) (Renewal)

a) Assume 29 affected plants.

c) This ICR uses the following labor rates: Managerial $114.77 ($54.65 + 110%); Technical $97.59 ($46.47 + 110%); and Clerical $48.26 ($22.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor 

Statistics, March 2009, Table 2. Civilian workers, by occupational and industry group. The rates are from column 1, "Total compensation". The rates have been increased by 110% to account for the benefit packages available to those employed 

by private industry. This ICR assumes that Managerial hours are 5% of Technical hours, and Clerical hours are 10% of Technical hours.

e) Assume 980 hours are required to complete initial performance tests.
(A) (B) (C) (D) (E) (F) (G) (H) (I)

Reporting/Recordkeeping Requirement (a, b)

EPA

Hours/

Occurrence

Occurrences/

Plant/Year

EPA

Hours/Year

(C=A*B)

Plants/

Year

Technical

Hours/Year

(C*D)

Managerial

Hours/Year

(E*0.05)

Clerical

Hours/Year

(E*0.10)

Total

Hours/Year

(H=E+F+G)

Total

Costs/Year

1. Initial Performance Tests

A. New or Modified plant (d, e) 24 1 24 0 0 0 0 0 $0 

2. Repeat Performance Tests

A. New or Modified plant (d, f) 24 0.2 4.8 0 0 0 0 0 $0 

3. Report Review

A. New or Modified plant

Notification of Construction/Reconstruction (g) 2 1 2 0 0 0 0 0 $0 

Notification of Actual Startup (h) 1 1 1 0 0 0 0 0 $0 

Notification of Physical or Operational Change 2 1 2 0 0 0 0 0 $0 

Notification of Initial Performance Test (h) 1 1.2 1.2 0 0 0 0 0 $0 

Review Performance Test Results (i) 8 1.2 9.6 0 0 0 0 0 $0 

Review Semiannual Exceedance/No Exceedance Reports (j) 2 2 4 32 128 6 13 147 $6,535 

Report Review Subtotal 147 $6,535 

TOTAL ANNUAL BURDEN 147 $6,535 

Footnotes:

b) Assume zero new plants per year.

e) Assume 100 percent of new plants will be visited.

f) Assume 20% of initial performance tests are repeated due to failures.

g) Assume two hours are required to review construction notification.

h) Assume one hour is required to review startup and initial performance test notifications.

i) Assume eight hours are required to review performance test results.

j) Assume two hours are required to review existing plant emission reports.

TABLE 3: AVERAGE ANNUAL EPA BURDEN, NSPS FOR WOOL FIBERGLASS INSULATION MANUFACTURING PLANTS (40 CFR Part 60, Subpart PPP) (Renewal)

d) Assume 24 hours per plant are required to participate with performance testing.

c) This ICR uses the following labor rates: Managerial $61.36 (GS-13, Step 5, $38.35 + 60%); Technical $45.52 (GS-12, Step 1, $28.45 + 60%); and Clerical $24.64 (GS-6, Step 3, $15.40 + 60%). These rates are from the Office of Personnel 

Management (OPM), 2009 General Schedule, which excludes locality rates of pay. The rates have been increased by 60% to account for the benefit packages available to government employees. This ICR assumes that Clerical hours are 10% of 

Technical hours and Managerial hours are 5% of Technical hours.

a) Assume 32 existing plants.
(A) (B) (C) (D) (E) (F) (G) (H) (I)

Reporting/Recordkeeping Requirement (a, b)

EPA

Hours/

Occurrence

Occurrences/

Plant/Year

EPA

Hours/Year

(C=A*B)

Plants/

Year

Technical

Hours/Year

(C*D)

Managerial

Hours/Year

(E*0.05)

Clerical

Hours/Year

(E*0.10)

Total

Hours/Year

(H=E+F+G)

Total

Costs/Year

1. Initial Performance Tests

A. New or Modified plant (d) 40 1 40 0 0 0 0 0 $0 

2. Repeat Performance Tests

A. New or Modified plant (e) 40 0.2 8 0 0 0 0 0 $0 

3. Report Review

A. New or Modified plant

Notification of Applicability (f) 2 1 2 0 0 0 0 0 $0 

Notification of Construction/Reconstruction (f) 2 1 2 0 0 0 0 0 $0 

Notification of Actual Startup (f) 2 1 2 0 0 0 0 0 $0 

Notification of Special Compliance Requirements (f) 1 1 1 0 0 0 0 $0 

Notification of Initial Performance Test (f) 2 1 2 0 0 0 0 0 $0 

Notification of Compliance Status (f) 2 1 2 0 0 0 0 0 $0 

Request for Extension of Compliance, Adjustments to Time 

Periods, and Changes in Information (g) 2 1 2 0 0 0 0 0 $0 

Report of Initial Performance Test (h) 40 1 40 0 0 0 0 0 $0 

Excess Emissions Report (i, j) 20 2 40 5.8 232 12 23 267 $11,844 

Report of No Excess Emissions (j, k) 2 2 4 23.2 93 5 9 107 $4,738 

Quality Improvement Plan (l) 40 1 40 0 0 0 0 0 $0 

Startup, Shutdown, and Malfunction Plan (l) 40 1 40 0 0 0 0 0 $0 

Operations, Maintenance, and Monitoring Plan (l) 40 1 40 0 0 0 0 0 $0 

Startup, Shutdown, and Malfunction Report (j, m) 20 2 40 2.9 116 6 12 133 $5,922 

Report Review Subtotal 507 $22,504 

TOTAL ANNUAL BURDEN 507 $22,504 

Footnotes:

b) Assume zero new plants per year.

e) Assume 20% of initial performance tests are repeated due to failures.

f) Assume two hours are required to review notifications.

g) Assume one request per respondent for Extension of Compliance, Adjustments to Time Periods, and Changes in Information.

h) Assume 40 hours are required to review initial performance test results.

i) Assume 20% of plants are required to prepare Excess Emissions reports.

j) Assume 20 hours are required to review reports.

k) Assume 80% of plants are required to prepare No Excess Emissions reports.

l) Assume 40 hours are required to review plans.

m) Assume 10% of plants are required to submit annual Startup, Shutdown, and Malfunction Reports.

TABLE 4: AVERAGE ANNUAL EPA BURDEN: NESHAP FOR WOOL FIBERGLASS MANUFACTURING (40 CFR Part 63, Subpart NNN)

d) Assume 40 hours per plant are required to participate with performance testing.

a) Assume 29 existing plants.

c) This ICR uses the following labor rates: Managerial $61.36 (GS-13, Step 5, $38.35 + 60%); Technical $45.52 (GS-12, Step 1, $28.45 + 60%); and Clerical $24.64 (GS-6, Step 3, $15.40 + 60%). These rates are from the Office of Personnel 

Management (OPM), 2009 General Schedule, which excludes locality rates of pay. The rates have been increased by 60% to account for the benefit packages available to government employees. This ICR assumes that Clerical hours are 10% of 

Technical hours and Managerial hours are 5% of Technical hours.