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 In formation 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 I CR Number 116 0.09, OMB Control Number 2060

- 0114 1(b) Short Characterization/Abstract
This Information Collection Request (I CR) 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 W ool 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 lin e, 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 particulat e 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, 1 999. 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 produ cts; 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 f

acility 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.
Ingeneral, all NSPS and NESHAP stand ards require initial notifications, performance tests, and periodic reports. Owners or operators are also required to maintain records of the2

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 provisio ns 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 p art 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, su bpart 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 ye ars. The number of affected sources subject to these re gulations 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 I CR 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 Manufacturin g (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 f or 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.
Inaddition, 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 s uch 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 su ch 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 Secti on 114(a)(3); and (G) provide such other information as the Administrator may reasonably

require.

Inthe Administrator's judgment, particulate emissions and hazardous air pollutant (HAP) emissions from wool fiberglass manufacturing plants cause or contrib ute 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) Pra ctical 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. Emiss ions 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 und er which compliance was achieved. The semiannual reports are4

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 requ irements described in this I CR 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 neces sary 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 h ave 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 . I f a state or local agency has adopted its own similar standards to imple ment 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 I CR 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) Consultation s
In formation provided by

the North American Insulation Manufacturing Association (NAIMA) in preparation of the most recent approved I CR was used as the primary source for determining the number of affected sources subject to these standards.
In dustry 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 compli ance purposes.
Itis our policy

to carefully

review any

comments received since the last I CR renewal including those submitted in response to the first Federal Register notice, and to respond appropriately

. 3(d) Effects of Less Frequent Collection
Les s frequent information collection would decrease the margin of assurance that plants5

are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practic es are applied and emission limitations are met. I f 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 sub mitted 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 I nformation 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. 1 The United States Standard Industrial Classification (SI C) code for the respondents affected by the standards is 3296, which corresponds to the North American Industry Classification System (NAI CS) code 327993. 4(b) Information Requested (i) Data Items The 40 CFR part 63, subpart NN N 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

- ye ar records retention re quirement is consistent with the part 70 permit program and the five

- ye ar 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 I CR 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) In itial performance test 60.8(d) Phy sical or operati onal change 60.7(a)(4) In itial 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/reconstruc tion 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) In itial 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) 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 6 3, 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 furna ce parameter values to measure performance

- The formulation of each binder patch and the L OIand 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

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

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

- ix)

Some of the respondents ar e 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 pl ant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting systems are still not widely used. At this time, it is estimated that approxim ately 10 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities Read instructions.8 Respondent Activities In stall, 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 L OI ; method for determining fre e - 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 sy stems for the purpose of collecting, validating, and verifyi ng 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: Age ncy 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 Obs erve 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, analy

ze, an d maintain data in the Air Facility Sy stem (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 p rograms. 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 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 co mpliance 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 analy ze 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. Acc ording 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 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 meets the SBA definition of a small business.” 5(d) Collection Schedule The specific frequency

for each informati on 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 Fib erglass 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 industr y for 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. 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 recordkeeping10

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 experien ce with the NSPS and NESHAP programs; the previously approved I CR; and any comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs
This I CR uses the following labor rates: $114.77 per hour for Executive, Administrative, and Man agerial 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 L abor, Bureau of Labor Statistics, March, 2009, “Table 2. Civilian workers, by occupational and industry grou p”. 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 particulat e 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 ye ars, 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 Re spondent (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&M 2 (G)

Total O&M, (E X F)

Baghouse Leak Detection $9,100 0 0 $500 20 $10,000

Furnace Tem perature 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 associate d with either 40 CFR part 60, subpart PPP or 40 CFR part 63, subpart NNN.
The total O&M cost for this I CR 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 I CR is estimated to be $488,500.

2 In order to calculate O&M c osts for 40 CFR part 63, subpart NNN, the estimates provided in column F we re 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 the re 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 I CR for 40 CFR part 60, subpart PPP is estimated to be $6,535. The average annual Agency cost during the three years of the I CR for 40 C FR 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. Deta ils 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 Fibergl ass 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 6413 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, s ubpart 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 ov er the three

- ye ar period (i.e., the total of the number of new respondents over the three

- ye ar 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 annu al 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 15,9 28 $1,497,983 507 $22,504 0 $10,00014 Industry Burden Agency Burden Capital Costs O&M Costs Hours Dollars ($) 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 I CR, due to an adjustment. Total labor hours for this I CR are 18, 559 rather than 18,216 in the previous I CR because the previous I CR 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 p er 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 re spondents is very low, negative or non

existent. There is an increase in both respondent and Agency costs resulting from labor rate increases from 2003 to 2009. This I CR uses 2009 labor rates because burden and cost calculations in this I CR were expand ed to include managerial and clerical labor rates, and the previous I CR only

provided a technical labor rate for 2003. This I CR is therefore updated to present the most recent available labor rates for each of the three labor categories. An apparent di fference of $500 in O&M costs is attributable to rounding to the nearest thousand in the previous renewal; this I CR renewal presents more exact figures. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of in formation 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 tim e 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 otherwis e 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 est ablished a public docket for this I CR under15

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 sy stem , select “search,” then key in the docket ID number identified in this d ocument. 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 Publi c 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 comment s 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 the EPA Docket ID Number EPA

- HQ

- OECA

- 2009

- 0530 and OMB Control Number 2060

- 0 114 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 I

nformation 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.