1 SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR WOOL FIBERGLASS MANUFACTURING AT AREA SOURCES

PART A

1.0 Identification of the Information Collection
(a) Title and Number of the Information Collection.

“ National Emission Standards Wool Fiberglass Manufacturing Area Sources

. ” This is a

new information collection request (ICR) , and the EPA tracking number i s 1160.10

. (b) Short Characterization. This ICR covers information collection requirements i n the proposed NESHAP f or Wool Fiberglass Manufacturing Area Sources ( 40 CFR part 63, subpart NN )

. The p otential respondents are owners or operators of any existing , new , or reconstructed Wool Fiberglass Manufacturing facilities

. Per the applicability section of subpart NN, o nly the

gas

- fired glass

- melting furnaces at a Wool Fiberglass Manufacturing facility that are located at a plant site that is a n area source as defined in 40 CFR part 63.2 a re affected by this rule

. Of the 2 0
facilities that are area sources of HAP emissio ns , 5 facilities operating 8 gas

- fired glass

- melting
furnaces will be subject to the area source requirements. The major source facilities operating gas

fired furnaces may become area sources in the next few years and will be subject to the area source

re quir e ments. W e are not including costs for those new facilities because those facilities will be subject to major source rule requirements under subpart NNN.
The proposed NESHAP would require gas

- fired glass

- melting furnaces to meet emission
limit s for chr omium compounds which may be met by shortening the furnaces’ operational life, installing add

- on air pollution control equipment such as a sodium hydroxide scrubber, pollution prevention measures (i.e., raw material substitution) or changing the brick ref ractories in the glass

- melting furnaces

. T he requirements are explained further in the following paragraphs.
The information collection requirements associated with the area source NESHAP are listed in Attachment 1

.2

2. Need For and Use of the Collection (a) Need/Authority for the Collection

. Section 112 of the C lean Air Act (C AA ) require s EPA to establish NESHAP for both major and area sources of HAP that are listed for regulation under CAA section 112(c). A major source is a stationary source that emi ts or has the potential to emit more than 10 tons per year ( tpy ) of any single HAP or more than 25 tpy of any combination of HAP

. An area source is a stationary
source that is not a major source (i.e., an area source does not emit and does not have the po tential
to emit more than 10 t py of any single HAP and more than 25 t py of any combination of HAP )

. For major sources, these technology

- based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, energ y requirements, and non

- air quality health and environmental impacts) and are commonly referred to as maximum achievable control technology (MACT) standards. Section 112(d)(6) requires EPA to review these technology

- based standards and to revise them “as necessary (taking into account developments in practices, processes, and control technologies)” no less frequently than every 8 years. In addition, section 112(f) of the CAA requires EPA to determine for source categories subject to certain CAA section
11 2(d) standards whether the emissions limitations provide an ample margin of safety to protect public health. For MACT standards for HAP “classified as a known, probable, or possible human carcinogen " that " do not reduce lifetime excess cancer risks to the individual most exposed to emissions from a source in the category or subcategory to less than 1

- in

- 1 million,” EPA must promulgate residual risk standards for the source category (or subcategory) as necessary to provide an ample margin of safety to prote ct public health. In doing so, EPA may adopt standards equal to existing MACT standards, if EPA determines that the existing standards are sufficiently protective. EPA must also adopt more stringent standards, if necessary, to prevent an adverse environm ental effect, but must consider cost, energy, safety, and other relevant factors in doing so. Certain records and reports are nec essary for the Administrator to confir m the compliance
status of sources subject to NESHAP , identify any new or reconstructe d s ources subject to the standards, and confirm that the standards are being achieved on a continuous basis. These recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions

. The3

recordkeeping and reporting requirements for t itle V permits are contained in 40 CFR 70.6 and 40
CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or
record. (b) Use/Users of the Data. The information will be used by the delegated authority (State agency , or Regional Administrator if there is no delegated State agency) to ens ure that the standards and other requirements are being achieved. Based on review of the recorded information at the site and the reported information, the delegated permitting authority can identify facilities that may not be in compliance and decide whi ch facilitie s, records, or processes may need inspection

. 3. Nonduplication, Consultations, and Other Collection Criteria (a) Nonduplication. A computer search of EPA ’ s ongoing ICRs revealed no duplication of information

gathering efforts. (b) Pu blic Notice Required Prior to ICR Submission to OMB. This section is not applicable because this is a rule

- related ICR. (c) Consultations.
The proposed amendments w ere developed in consultation with individual companies , State agencies, and trade associat ion s . The non

- EPA persons consulted on the information
collection activities are identified in Table 1.
TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact Organization Telephone No. Angus Crane N orth A merican Insulation Manufact urers Association 703

- 684

- 0084 Mike Pettis Owens Corning 740

- 827

- 7087 Carlos Davis CertainTeed Corporation 913

- 342

- 6624 Steve Aldridge Knauf Insulation 317

- 398

- 4434 Jeffrey Tarde Johns Manville 303

- 978

- 21614

(d) Effects of Less Frequent Collection

. If the relevant information was collected less frequently, the delegated permitting authority (State or EPA) w ill not be reasonably assured that a facility is in compliance with the standards. (e) General Guidelines

. None of the guidelines in 5 CFR 13 20.6 are being exceeded. (f) Confidentiality. All 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 (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979). (g) Sensitive Questions. This section is not applicable because this ICR do es not involve matters of a sensitive

nature. 4. The Respondents and the Information Requested (a) Respondents/NAIC S Codes

. Potential respondents under s ubpart NN are owners or operators of any existing or new facility engaged in Wool Fiberglass Manufactur ing operations

. Wool Fiberglass Manufacturing facilities are primarily classified under NAICS code 3 2 7 993

. The re are an estimated 5 facilities that w ould be subject to the proposed a rea source NESHAP

. There are currently 8 gas

- fired glass

- melting furnace s at these 5 facilities and 3 of those furnaces would require additional chromium reduction measures to meet the proposed chromium compound emission limit

. We are not aware of any new Wool Fiberglass Manufacturing facilit ies being constructed; however, we do expect most, if not all of the remaining major source facilities

to convert to non

- HAP binders and become area sources. However , we are not including any costs
for n ew area sources during the 3-year period of this ICR to avoid double counting costs ass ociated with the major source rule (subpart NNN) proposed amendments

. (b) Information Requested.5

(i) Data Items, Including Recordkeeping Requirements. Attachment 1 , Information Requirements, summarize s the data items, including recordkeeping and report ing requirements , for
the Wool Fiberglass Manufacturing s ource c ategor y

. (ii) Respondent Activities. The respondent activities that will be required by the proposed Wool Fiberglass Manufacturing NESHAP for area sources are identified in Table 2 an d are introduced in section 6(a).
5. The Information Collected

– Agency Activities, Collection Methodology, and Information Management (a) Agency Activities.
The Agency activities associated with the proposed a rea source Wool Fiberglass Manufacturing NESHAP are p rovided in Table 3 and are introduced in section 6(c). (b) Collection Methodology and Management

. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs of the delegated permitting authori ty

. EPA is the permitting authority until the State agency is delegated authority to implement the final
amendments to the rule. Therefore, i nformation contained in any report submitted to the Regional
Administrator will be entered into the Air Facility System (AFS), which is operated and maintained by EPA ’ s Office of Compliance. AFS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the AFS f or tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA r egional offices and EPA headquarters. EPA and its delegated a uthorities can edit, store, retrieve and analyze the data.6

(c) Small Entity Flexibility.
The Small Business Administration defines a small entity engaging in Wool Fiberglass Manufacturing operations as a firm having no more than 500 employees

. There are three companies operating the five Wool Fiberglass Manufacturing facilities that are expected to be

a ffected by this rule and none of the three companies are small businesses. T he proposed area source NESAHP would create new requirements for compliance testing f or existing sources and
associated notification requirements , recordkeeping, and report ing requirements

. (d) Collection Schedule

. The specific frequency for each information collection activity within this request is shown
in Table 2 for the Wool Fiberglass Manufacturing S ource C atego ry. 6. Estimating the Burden and Cost of the Collec tion (a) Estimating Respondent Burden.
The annual burden estimates for the proposed Wool Fiberglass Manufacturing NESHAP
for Area Sources are shown in Table 2

. These numbers were derived from estimates based on EPA’s experience with other standards. A s discussed previously, there are no burden estimates provided for new sources during the 3-year period of this ICR to avoid double counting costs associated with the major source rule (subpart NNN) proposed amendments

. (b) Estimating Respondent Costs.
The information collection activities for the proposed W ool Fiberglass Manufacturing
NESHAP for Area Sources are presented in Table 2. Because the data are already collected by respondents as part of normal operations , no respondent development costs are associated with the
information collection activities. (i) Estimating Labor Costs . Labor rates and associated costs are based on Bureau of Labor Statistics (BLS) data. Technical, management, and clerical average hourly rates for private industry workers were taken from the United States Department of Labor, Bureau of Labor Statistics, Occupational Employment and Wages, Ma y 20 1 3 available at http://www.bls.gov/oes/current/naics4_327200.htm

. Wages for technical labor are based on

" Glass and Glass Product Manufacturing

– architectural and engineering , " with a total compensation of $ 3 8. 03 /hour. Wages for management labor are taken from " Glass and Glass7

Product Manufacturing

– management, busi ness, and financial , " with a total compensation of $ 5 2.54 /hour. Wages for clerical labor are based on " Glass and Glass Product Manufacturing

– production, planning, and expediting clerks , " with a total compensation of $ 19.00 /hour. These rates represent salaries plus fringe benefits and do not include the cost of overhead. An overhead rate of 110 percent is used to account for these costs. The fully

- burdened hourly wage rates used to represent respondent la bor costs are: technical at $ 79.86 /hour , mana gement at $ 1 10.33 /hour , and clerical at $ 39.90 /hour

. (ii) Estimating Capital and Operations and Maintenance (O&M) Costs

. No capital costs
or O & M costs are associated with the information collection requirements of the proposed a rea

source Wool Fiber glass Manufacturing NESHAP. The proposed a rea source rule w ould require affected facilities to purchase new m onitoring systems and conduct new performance testing. (i ii ) Annualizing Capital Costs

. No capital costs are associated with the information collection requirements for the proposed a rea source W ool Fiberglass Manufacturing NESHAP. (c) Estimating Agency Burden and Cost

. Because the information collection requirements were developed as an incidental part of standards development, no costs c an be attributed to the development of the information collection requirements. Because reporting and recordkeeping requirements on the part of the respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the part 63
NES HAP General Provisions, no operational costs w ill be incurred by the Federal Government. Publication and distribution of the information are part of the Compliance Data System, with the result that no Federal costs can be directly attributed to the ICR. Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of sour ces that is part of EPA’ s overall compliance and enforcement program, and, therefore, is not attributable to the ICR. The only cos ts that the Federal government w ill incur are user costs associated with the analysis of the reported information, as presented in Table 3

. The Agency labor rates are from the Office of Personnel Management (OPM) 20 1 3
General Schedule , which excludes loca lity rates of pay. These rates can be obtained from Salary
Table 20 1 3

- GS available on the OPM website, http://www.opm.gov/oca/12tables/pdf/gs_h.pdf

. The government employee labor rates are $ 15.6 3 /hour for clerical (GS

- 6, Step 3), $ 28.88 for8

technical (GS

- 12, Step 1), and $ 38.92 /hr for management (GS

- 13, Step 5). These rates were increased by 60 percent to include fringe benefits and overhead. The fully

- burdened wage rates used to represent Agen cy labor costs are: clerical at $ 25.01 /hour ; technical at $ 46.21 /hour , and management at $ 62.27 /hour

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

. There are an estimated 30 existing facilities that are currently manufacturing wool fiberglass in the United States

. I ndustry is phasing out phenol

- formaldehyde binders at the bonded lines, and we estimate that there will be five existing facilities subject to the proposed a rea source requirements du ring the next 3 years. Consequently, the average number of wool fiberglass respondents during the 3

- year period of this ICR is 5 facilities / 3 = 1.67 per year

. For the proposed Wool Fiberglass Manufacturing NESHAP for Area Sources , the components of the total annual burden attributable to t his ICR include reading the area source N ESHAP ; conducting the performance testing to demonstrate compliance with the chromium compounds emission limits ; reporting th e results of those emissions tests ; and complying with all
other monitoring, recordkeeping and reporting activities for the NESHAP. (e) Bottom Line Burden Hours and Cost Tables. (i) Respondent tally. The bottom line respondent burden hours and costs, presented in
Table 2 are calculated by adding person

- hours per year down each column for tech nical, managerial, and clerical staff, and by adding down the cost column. The average annual burden for the recordkeeping and reporting requirements in the proposed area source NESHAP ( subpart NN )
for the five existing f

acilities with gas

- fired furnaces t hat are subject to the Wool Fiberglass Manufacturing NESHAP for Area Sources is 77 person

- hours , with an annual average cost of $ 32, 703

. No capital costs would be expected for the proposed rule requirements

. (ii) The Agency tally. The average annual Fe deral Go vernment cost is $ 695 for 15 hours
for the proposed subpart NN requirements

. The bottom line Agency burden hours and costs presented in Table 3 are calculated by adding person

- hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column. (iii) Variations in the annual bottom line. This section does not apply since no significant variation is anticipated.9

(f) Reasons for Change in Burden. This section does not apply because this is a new ICR. (g) Burden Statement The average annual respondent burden for the proposed Wool Fiberglass Manufacturing
NESHAP for Area Sources is estimated at 77 hours

. Burden means the total time, effort, or financial resources expended by persons to generate,
mai ntain, 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 inf ormation, 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 informatio n; 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 currently valid OMB control number. The OMB
control numbers for EPA ’ s regulations in 40 CFR part 63 are listed in 40 CFR part 9. To comment on the Agency’s need for this information the accuracy of the provided burden estimates, and any suggestions for minimizing respondent burden, including through the use of automated collection techniques, EPA has established a public docket for this ICR under
Docket ID No. EPA

- HQ

- OAR

- 2010

- 104 2 which is available for online viewing at http://www.regulations.gov , or in person viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room B

- 102, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading R oom 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 Air Docket is (202) 566

- 1927

. An e lectronic version of the public dock et is available at http://www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public 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 above. Also, you can10

send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17 th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please
include the relevant Docket ID Number ( EPA

- HQ

- OAR

- 2010

- 104 2 ) in any c orrespondence.

PART B This section is not applicable because statistical methods are not used in data collectio n associated with the proposed rule.11

T ABLE 2 . ANNUAL RESPONDENT BURDEN AND COST

-- WOOL FIBERGLASS MANUFACTURING NESHAP AREA SOURCES

Burden item (A) Person

- hours per occurrence (B)

No. of
occurrences per respondent (C)

Person

- hours per respondent ( C=A*B) (D)

Respondents per year (E)

Technical person - hours per year (E=C*D) (F)

Management person - hours per year (E*0.05) (G)

Clerical person - hours per year (E*0.1) (H)

Cost a , $ 1. Applications N/A 2. Surveys and Studies N/A 3. Ac quisition, Installation, and Utilization of Technology and Systems N/A
4. Reporting Requirements A. Read instructions b 4 1 8 1.67 13.4 0.7 1.3 $ 1 , 2 00 B. Required activities c (compliance testing) $ 1 6 , 0 00 1 1.67 $ 26,720 C. Create information d 8 2 16 1.67 26.7 1.3 2.7 $ 2, 383 D. Gather existing information N/A E. Write report 8 1 8 1.67 13.4 0.7 1.3 $ 1,2 00 5. Recordkeeping Requirements A. Read instructions See 4A B. Plan activities N/A C. Imp lement activities N/A D. Develop record system N/A E. Time to enter information See 4C F. Time to train personnel N/A G. Time to adjust existing ways to comply with previously applicable requirements N/A

H. Time to transmit or disclose information 8 1 8 1.67 13.4 0.7 1.3 $ 1,2 00 I. Time for audits N/A TOTAL LABOR BURDEN AND COST (SALARY) 66.9 3.4 6.6 $ 32, 703 TOTAL NUMBER OF ANNUAL RESPONSES 5 ANNUAL CAPITAL COSTS d TOTAL ANNUALIZED COSTS $ 32, 703 N/A = not applicable.

a T his ICR uses the following labor rates : $ 1 10.33 for managerial labor, $ 79.86 for technical labor, and $ 39.90 for clerical labor. These rates are based on the U.S. Department of Labor, Bureau of Labor Statistics, Occupational Emp loyment and Wages, Ma y 201 3

. b A n estimated 5 existing facilities and no new facilities ( 5 total) are expected to have gas

- fired furnaces and be subject to subpart NN; the av erage number expected to read the rule during the 3

- yr compliance period is 5 / 3 = 1.67

. c The average facility cost for Cr compound te sting was calculated to be : ( 8 gas

- fired furnaces ) x ( $10,000 per test ) = $ 8 0 ,000 / 5 facilities = $ 1 6 , 0 00

. d There would be no capital costs associated with the reporting and recordkeeping requir ements of the area source NESHAP

.12

3 . ANNUAL BURDEN AND COST TO THE AGENCY

-- -- WOOL FIBERGLASS MANUFACTURING NESHAP AREA SOURCES

Burden item (A) Person

- hours per occurrence (B)

Occurrences per respondent (C)

EPA person

hours/year (C=A*B) (D)

Facilit ies per year (E)

Technical person

hours/year ( E = C * D ) (F)

Management person - hours/year ( F =0.05* E ) (G)

Clerical person

hours/year ( G =0.1* E ) (H)

Cost a , $ Report Review: Review compliance test reports for Cr compounds for gas

- fired furnaces 8 1 8 1.67 13.4 0.7 1.3 $ 695
TOTAL BURDEN AND COST $ 695

a This ICR uses the followin g average hourly labor rates: $ 62.27 for m anagerial (GS

- 13, Step 5), $4 6.21 (GS

- 12, Step 1 ) for technical , and $2 5.01 (G S

- 6, Step 3) for c lerical. These rates are fr om the Office of Personnel Management (OPM) 20 1 2 General Schedule , which excludes locality rates of pay

.13

ATTACHMENT 1. INFORMATION REQUIREMENTS

-- -- WOOL FIBERGLASS MANUFACTURING NESHAP AREA SOURCES

Requirement Citation for existing sources Citation for new sources General Provisions citation Cr compound limit for gas - fired glass

melting fu rnaces § 63. 8 82 (a)( 1 ) (iii) § 63. 8 82 (a)( 1 ) (iii)
Notifications § 63. 8 86(a) § 63. 8 86(a) N/A Plans Operation and Maintenance Plan N/A N/A N/A Records Monitoring/inspection information § 63. 8 83 § 63. 8 83 N/A Reports § 63. 8 86(b) and (c) § 63. 8 86(b) and (c) 40 CFR 63.10 (e)