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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 is 1160.10.

(b) Short Characterization.

This ICR covers information collection requirements in the proposed NESHAP for Wool 

Fiberglass Manufacturing Area Sources (40 CFR part 63, subpart NN). 

The potential respondents are owners or operators of any existing, new, or reconstructed

Wool Fiberglass Manufacturing facilities. Per the applicability section of subpart NN, only the 

gas-fired glass-melting furnaces at a Wool Fiberglass Manufacturing facility that are located at a 

plant site that is an area source as defined in 40 CFR part 63.2 are affected by this rule. Of the 20

facilities that are area sources of HAP emissions, 5 facilities operating 8 gas-fired glass-melting 

furnaces will be subject to the area source requirements. The major source facilities operating gasfired furnaces may become area sources in the next few years and will be subject to the area source 

requirements. We 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 

limits for chromium 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 refractories in the 

glass-melting furnaces. The requirements are explained further in the following paragraphs.

The information collection requirements associated with the area source NESHAP are

listed in Attachment 1.
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2. Need For and Use of the Collection

(a) Need/Authority for the Collection.

Section 112 of the Clean Air Act (CAA) requires 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 emits 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 potential 

to emit more than 10 tpy of any single HAP and more than 25 tpy 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, energy 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 

112(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 protect 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 environmental 

effect, but must consider cost, energy, safety, and other relevant factors in doing so. 

Certain records and reports are necessary for the Administrator to confirm the compliance 

status of sources subject to NESHAP, identify any new or reconstructed sources 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. The 
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recordkeeping and reporting requirements for title 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 ensure 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 which facilities, 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 informationgathering efforts.

(b) Public 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 were developed in consultation with individual companies, 

State agencies, and trade associations. 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 North American Insulation Manufacturers 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 303-978-2161
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(d) Effects of Less Frequent Collection.

If the relevant information was collected less frequently, the delegated permitting authority 

(State or EPA) will not be reasonably assured that a facility is in compliance with the standards.

(e) General Guidelines.

None of the guidelines in 5 CFR 1320.6 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 does not involve matters of a sensitive 

nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Potential respondents under subpart NN are owners or operators of any existing or new 

facility engaged in Wool Fiberglass Manufacturing operations. Wool Fiberglass Manufacturing

facilities are primarily classified under NAICS code 327993.

There are an estimated 5 facilities that would be subject to the proposed area source 

NESHAP. There are currently 8 gas-fired glass-melting furnaces 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 facilities 

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 new area 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) Information Requested.
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(i) Data Items, Including Recordkeeping Requirements. Attachment 1, Information 

Requirements, summarizes the data items, including recordkeeping and reporting requirements, for 

the Wool Fiberglass Manufacturing source category.

(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 and 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 area source Wool Fiberglass 

Manufacturing NESHAP are provided 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 authority. EPA is the 

permitting authority until the State agency is delegated authority to implement the final

amendments to the rule. Therefore, information 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 for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated authorities can edit, store, retrieve and analyze the data.
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(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 

affected by this rule and none of the three companies are small businesses. The proposed area 

source NESAHP would create new requirements for compliance testing for existing sources and 

associated notification requirements, recordkeeping, and reporting 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 Source Category.

6. Estimating the Burden and Cost of the Collection

(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. As 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 Wool 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, May 2013 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 $38.03/hour. Wages for management labor are taken from "Glass and Glass 
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Product Manufacturing – management, business, and financial," with a total compensation of 

$52.54/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 labor costs are: technical at $79.86 /hour, management at $110.33 /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 area 

source Wool Fiberglass Manufacturing NESHAP. The proposed area source rule would require 

affected facilities to purchase new monitoring systems and conduct new performance testing. 

(iii) Annualizing Capital Costs. No capital costs are associated with the information 

collection requirements for the proposed area source Wool 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 can 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 

NESHAP General Provisions, no operational costs will 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 sources 

that is part of EPA’s overall compliance and enforcement program, and, therefore, is not 

attributable to the ICR. The only costs that the Federal government will 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) 2013

General Schedule, which excludes locality rates of pay. These rates can be obtained from Salary 

Table 2013-GS available on the OPM website, http://www.opm.gov/oca/12tables/pdf/gs_h.pdf.

The government employee labor rates are $15.63/hour for clerical (GS-6, Step 3), $28.88 for 
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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 Agency 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. Industry is phasing out phenol-formaldehyde binders at the bonded 

lines, and we estimate that there will be five existing facilities subject to the proposed area source 

requirements during 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 this ICR include reading the area source 

NESHAP; conducting the performance testing to demonstrate compliance with the chromium 

compounds emission limits; reporting the 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 technical, 

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 facilities with gas-fired furnaces that 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 Federal Government 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.
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(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, 

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 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-2010-1042 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 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 Air Docket is (202) 566-1927. 

An electronic version of the public docket 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 can 
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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 relevant Docket ID Number (EPA-HQ-OAR-2010-1042) in any correspondence.

PART B

This section is not applicable because statistical methods are not used in data collection 

associated with the proposed rule. 
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TABLE 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) 

Costa, $ 

1. Applications N/A

2. Surveys and Studies N/A

3. Acquisition, Installation, and Utilization of 

Technology and Systems

N/A

4. Reporting Requirements

A. Read instructionsb 4 1 8 1.67 13.4 0.7 1.3 $1,200

B. Required activitiesc (compliance testing) $16,000 1 1.67 $26,720

C. Create informationd 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 $1,200

5. Recordkeeping Requirements 

A. Read instructions See 4A

B. Plan activities N/A

C. Implement 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 $1,200

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 COSTSd

TOTAL ANNUALIZED COSTS $32,703

N/A = not applicable.

a

 This ICR uses the following labor rates: $110.33 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 Employment and Wages, May 2013.

b An estimated 5 existing facilities and no new facilities (5 total) are expected to have gas-fired furnaces and be subject to subpart NN; the average 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 testing was calculated to be: (8 gas-fired furnaces) x ($10,000 per test) = $80,000 / 5 facilities = $16,000.

d There would be no capital costs associated with the reporting and recordkeeping requirements of the area source NESHAP.
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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 personhours/year 

(C=A*B)

(D) 

Facilities 

per year

(E) 

Technical personhours/year 

(E=C*D)

(F) 

Management 

person-hours/year 

(F=0.05*E)

(G) 

Clerical personhours/year 

(G=0.1*E)

(H)

Costa, $

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 following average hourly labor rates: $62.27 for managerial (GS-13, Step 5), $46.21 (GS-12, Step 1) for technical, and $25.01 (GS-6, Step 3) for clerical. 

These rates are from the Office of Personnel Management (OPM) 2012 General Schedule, which excludes locality rates of pay.
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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 glassmelting furnaces 

§ 63.882(a)(1)(iii) § 63.882(a)(1)(iii)

Notifications § 63.886(a) § 63.886(a) N/A

Plans

 Operation and Maintenance Plan N/A N/A N/A

Records

 Monitoring/inspection information § 63.883 § 63.883 N/A

Reports § 63.886(b) and (c) § 63.886(b) and (c) 40 CFR 63.10(e)