**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for**  **Mineral Wool Production (40 CFR**  **Pa rt**  **63, Subpart**  **DDD) (Renewal)**  **, 1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD) (Renewal ) , EPA I CR Number 1799.08, OMB Control Number 2060

- 0362 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Mineral Wool Production were proposed on May 8, 1997 , and promulgated on June 1, 1999. These regulations appl y to new and existing mineral wool production facilities with cupolas and/or curing ovens

. Th e s e standard s appl y to owners or operators located at a plant site that is a major source of hazardous air pollutant (HAP) emissions. This signifies that the plant emits , or has the potential to emit , any

single HAP at a rate of 9.07 megagrams (10 tons) or more per year or any combination of HAPs at a rate of 22.68 megagrams (25 tons) or more per year. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR part 63, subpart DDD

. In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operati on of an affected facility, or any period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP

. Any owner/ope rator subject to the provisions of this part 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 are sent to the delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of 1.5 affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, an average of six respondents per ye ar will be subject to the standard s , and no additional respondents per year will become subject to the standard. The Office of Management and Budget (OMB) approved the currentl y active I CR without any

“Terms of Clearance.”2

All of the mineral wool production facilities in the United States are owned and operated by the mineral wool production industry (the “Affected Public”). None of the facilities in the United States are owned by state, local, tribal or the Federal government entities . They are all privately

- owned , for

- profit businesses. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD) (Renewal). The “burden ” to the Federal Government is attributed entirely to work perf

ormed by either F ederal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD) (Renewal)

. **2. Need for and Use of the Collection 2(a)**  **Need/Authority for the Collection** The EPA 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. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, HAP emissions from mineral wool production either cause or contribute to air pollution that may reasonably

be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR part 63, subpart DDD

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard s ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in l egal proceedings. Performance tests are required in order to determine an affected facility ’ s initial3

capability to comply

with the emission standard s
. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard 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 properl y installed and operated, leaks are being detected and repaired , and the standard is being met. The performance test may also be observed. The required s emiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for c ompliance determinations.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 63, subpart DDD

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

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

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary

source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information Sy stem (OTIS) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts.4

Industry trade associations and other interested partie s were provided an opportunity to comment on the burden associated with the standard s as they w ere being developed and the standard s have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted : 1) the North American Insulation Manufacturing Association , at ( 703 ) 684

- 0084 ; and 2) Rock Wool Manufacturing Company In c orporated, at ( 800 ) 874

- 762 5

. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received. **3(d) Effects of Less Frequent Collection**  Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. I f the information required by these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

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

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

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

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

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).5

**3(g) Sensitive Questions**
The reporting or recordkeeping requirements in the standard do not include sensitive questions.
**4. The Respondents and the Information Requested**  **4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are mineral wool manufacturing facilities . The United States Standard Industrial Classification ( SI C ) code s for the respondents affected b y the standards is SI C 3296 , which corresponds to the North American Industry Classification Sy stem (NAI CS ) code 327993 for mineral wool manufacturing. **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Mineral Wool Production (40 CFR P art 63, S ubpart DDD)

. A source must make the following reports:

**Notification s**  Applicability 63.9(a), 63.1191(a) Construction/reconstruction 63.9(b)(3

- 4), 63.1191(b) Actual startup 63.9(b) (2) and (4) Special compliance requirements 63.9(d), 63.1191(c) Initial performance test 63.9(e), 63.1191(d) Compliance status 63.9(h), 63.1191(e) Request for extension of compliance, adjustments to time periods, and changes in information 63.9(c), (i

- j)

**Reports** Report of performance test results 63.10(d)(2), 63.1193(a) Startup, shutdown, and malfunction plans 63.6(c)(3), 63.1193(b) Startup, shutdown, and malfunction reports 63.6(e)(3), 63.10(d)(5), 63.1191(c) Operations, maintenance, and monitoring plan 63.6(e)(1

- 2), 63.1193(d)6 **Reports** Semiannual excess emissions report 63.10(e)(3), 63.1193(e) Semiannual no excess emissions report 63.10(e)(3), 63.1193(f) A source must keep the following records:
**Recordkeeping** Startup, shutdown, malfunctions, including process equipment, air pollution control equipment, maintenance performed, and actions taken outside the scope of existing plans 63.10(b), 63.1192(a) Maintain records of the following information:

- Cupola production (melt) rate [Mg/hr) or (tons/hr)]

- All bag leak detection sy stem alarms

- Free

- formaldehyd e content of each resin lost and binder formulation

- Incinerator operating temperature and results of incinerator inspections 63.1192(b)

Retain records for five ye ars 63.1192(c) Retain records on microfilm, on computer, on disks, magnetic tape disks, or on microfiche 63.1192(d) Report information on paper or on a labeled computer disk using available computer software 63.1192(e)
Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respon dents use electronic reporting.7 **(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for control device. Perform initial performance test, Reference Method 1, 2, 3, or 3A, 4, 5, 10, and 318 test s , and repeat performance tests 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 verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipm ent has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information :8 **Agency Activities** Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

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

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

- owned facilities. EP A uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and l arge entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, th e overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

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

– NESHAP for Mineral Wool9

Production (40 CFR Part 63, Subpart DDD) (Renewal)

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

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 1 , 5 81 hours ( Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 121.44 ($ 57.83 + 110%) Technical $ 100.23 ($ 47.73 + 110%) Clerical $ 50.51 ($ 24.05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

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

costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one

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

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**10

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

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

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

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F) Baghouse Leak Detection $22,350 0 $0 $750 6 $4,500
Total $0 $4,500 The total capital/startup costs for this I CR are $ 0 . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $ 4,500

. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $4,500

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

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respond ents , periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 15,920

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

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

. 21 (GS

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

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

rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Co st

– NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs**11

Based on our research for this I CR, on average over the next three ye ars, approximately six ex isting respondents will be subject to the standard. It is estimated that no additional respondents will become subject annuall y . The overall average number of respondents, as shown in the table below , is sixper year. The number of respondents is cal culated using the following table that addresses the three ye ars covered b y this ICR.

**Number of Respondents**

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

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 6 0 0 6
2 0 6 0 0 6
3 0 6 0 0 6 Average 0 6 0 0 6 1 New respondent include sources with constructed, reconstructed and modified affected facilities.

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 6

. The total number of annual responses per ye ar is calculated using the following table:12 **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D

Notification of applicability 0 1 0 0 Notification of construction/reconstruction 0 1 0 0 Notification of actual startup 0 1 0 0 Notification of special compliance requirements 0 1 0 0 Notification of initial performance test 0 1 0 0 Notification of compliance status 0 1 0 0 Excess emissions report 1.2 2 0 2.4 Report of no excess emissions 4.8 2 0 9.6 Quality improvement plan 0 1 0 0 Startup, shutdown, and malfunction report 0 1 0 0 Total 12 The number of Total Annual Responses is 12

. The total annual labor costs are $153,066

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 1,581 at a cost of $153,066

. Details regarding these estimates may

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

– NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 13 2 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $4,500

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance13

(O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 353 labor hours at a cost of $15, 920 . See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD) (Renewal)

. **6(f) Reasons for Change in Burden**
There is no change in the respondent labor hours in this I CR compared to the previous I CR. This is due to two considerations : 1) the reporting requirements have not changed over the past three ye ars and are not anticipated to change over the next three ye ars ; and 2) the growth rate for the industry is very low, negative or n on - existent, so there is no significant change in the overall labor h ours. However, there is an adjustment increase in the respondent labor costs due to the use of updated labor rates. There is a decrease in Agency labor hours and costs due to a mathem atical correction. The previous ICR incorrectly calculated the number of hours associated with review of excess emissions reports. This ICR corrects the error, which results in a decrease of 55 hours and an associated decrease in labor costs. **6(g) Bur den Statement**  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 13 2 hours per response. “ Burden ” means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying informati on, 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 val id OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for t his I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0678

. 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 the14

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 document. The documents are al so available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

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

- 17 52

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

- HQ

- OECA

- 20 12

- 0678 and OMB Control Number 2060

- 0362 in any correspondence.
**Par t B of the Supporting Statement**  This part is not applicable because no statistical methods were used in collecting this information.15

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

**– NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD)**  **(Renewal)**

Burden Items (A) Person h ours per o ccurrence (B)

Occurrences per respondent per Year (C)

Person h ours per respondent per year (AxB) (D)

Respondents per year (a) (E)

Technical person h ours per y ear (CxD) (F)

Managerial person hours per y ear (Ex0.05) (G)

Clerical person hours per year (Ex0.10) (H)

Total Cost per year, $

1. Applications N/A 2. Survey and Studies N/A 3. Reporting Requirements A. Read Instructions c 4 1 4 0 0 0 0 $0 B. Required Activities Initial p erformance t est d 421 1 421 0 0 0 0 $0 Repeat performance te st d, e 421 0.2 84.2 0 0 0 0 $0 Operations, maintenance, and mo nitoring plan f 40 1 40 0 0 0 0 $0 Startup, shutdown, and malfunction plan g 40 1 40 0 0 0 0 $0 C. Create Information See 3B D. Gather Existing Information See 3B E. Write Reports Notification of applicability h 2 1 2 0 0 0 0 $0 Notification of c onstruction/ r econstruction h 2 1 2 0 0 0 0 $0 Notification of actual startup h 2 1 2 0 0 0 0 $0 Notification of special compliance requirements h 2 1 2 0 0 0 0 $0 Notification of i nitial p erformance t est h 2 1 2 0 0 0 0 $0 Notification of c om

pliance s tatus h 2 1 2 0 0 0 0 $016

Burden Items (A) Person h ours per o ccurrence (B)

Occurrences per respondent per Year (C)

Person h ours per respondent per year (AxB) (D)

Respondents per year (a) (E)

Technical person h ours per y ear (CxD) (F)

Managerial person hours per y ear (Ex0.05) (G)

Clerical person hours per year (Ex0.10) (H)

Total Cost per year, $
Request for extension of compliance adjustment to time periods, and changes in information h 2 1 2 0 0 0 0 $0 Report of p erformance t est See 3B Excess e missions r eport i 16 2 32 1.2 38.4 1.92 3.84 $4,275.96 Report of no e xcess emission j 8 2 16 4.8 76.8 3.84 7.68 $8,551.91 Quality i mp rovement p lan k 40 1 40 0 0 0 0 $0 Startup, shutdown, and malfunction report l 8 2 16 0 0 0 0 $0 **Subtotal for Reporting**  **132. 5**  **$12,827.87** 4. Recordkeeping Requirements A. Read Instructions m 4 1 4 2.1 8.4 0.42 0.84 $935.37 B. Plan Activities See 3E C. Implement Activities See 3E D. Develop Record System See 3E E. Time to Enter Information Records of operating parameters and emissions n 4 52 208 6 1,248 62.4 124.8 $138,968.54 F. Time to transmit or disclose information o 0.25 2 0.5 6 3 0.15 0.3 $334.06 G. Time to Train Personnel N/A H. Time for Audits N/A **Subtotal for Recordkeeping 1,448.3**  **$140,237.97 Total Labor Burden and Cost**  **(rounded) 1,58**  **1 $153,06**  **6**17

**Assu mptions**  :

a We have assumed that the average number of respondents potentially subject to this rule is 6. There will be no additional new sources over the three

- year period of this ICR. b This ICR uses the following labor rates: $121.44 for Managerial, $100.23 for Technical, and $50.51 for Clerical.

c We have assumed that it will take each respondent 4 hours to read instructions.
d We have assumed that it will take 421 hours for each respondent to complete performance test based on the following: (1.7 sou rces per plant x 130 hours per source +200 hours for calibration, retesting, sample analysis, etc) for a total of 421 hours.

e We have assumed that 20% of respondents will have to repeat performance test due to failure. f We have assumed that each of the respondents will take 40 hours to prepare the operation, maint enance, and monitoring plan. g We have assumed that each of the respondents will take 40 hours to prepare the startup, shutdown, and malfunction plan. h We have assumed that each of the respondents will take 2 hours to write reports. i We have assumed that 20% of respondents will ea ch take 16 hours two times per year to w rite excess emission reports. j We have assumed that 80% of respondents will take 8 hours two times per year to complete the report for no excess emissions. k We have assumed that 10% of facilities are required to prepare a quality imp rovement plan each year. l We have assumed that each respondent will take 8 hours two times per year to complete a startup, shutdown, and malfunction report.

m We have assumed that 35% of respondents will each take 4 hours to read instructions.

n We have assumed that each respondent will take 4 hours 52 times per year to enter information.

o We have assumed that it will take each respondent 15 minutes (0.25 hours) two times per year to transmit of disclose information.18

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

**– NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD)**  **(Renewal)**

Activity (A) EPA Hours per o ccurrence (B)

Number of o ccurrences per Year (C)

EPA Hours per Year (AxB) (D)

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

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

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

Total cost per year $

Initial p erformance t ests New or modified f

acility 40 1 40 0 0 0 0 $0 Repeat p erformance t ests New or modified f

acility c 40 0.2 8 0 0 0 0 $0 Report r eview Notification of applicability 2 1 0 Notification of c onstruction/ r econstruction 2 1 2 0 0 0 0 $0 Notification of a ctual s tartup 2 1 2 0 0 0 0 $0 Notification of special compliance requirements 1 1 1 0 0 0 0 $0 Notification of i nitial p erformance t est 2 1 2 0 0 0 0 $0 Notification of c om

pliance s tatus 2 1 2 0 0 0 0 $0 Request for e xtension of c om pliance, a djustment to time p eriods, and c hanges in information 2 1 2 0 0 0 0 $0 Quality i mp rovement plan d 40 1 40 0 0 0 0 $0 Operations, maintenance, and monitoring plan 40 1 40 0 0 0 0 $0 Startup, s hutdown, and malfunction plan e 40 1 40 0 0 0 0 $0 Report of p erformance t est 40 1 40 0 0 0 0 $0 Excess e missions r eport f 20 2 40 1.2 48 2.4 4.8 $2,487.5819

Activity (A) EPA Hours per o ccurrence (B)

Number of o ccurrences per Year (C)

EPA Hours per Year (AxB) (D)

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

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

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

Total cost per year $
Report of no excess emissions g 2 2 4 4.8 19.2 0.96 1.92 $995.03 Startup, s hutdown, and malfunction report h 20 2 40 6 240 12 24 $12,437.88 **Total Labor Burden and Cost (rounded)**  **353 $15,920**  Assumptions:

a We have assumed that the average number of respondents potentially subject to this rule is 6. There will be no additional ne w sources over the three

- year period of this ICR. b This ICR uses the following labor rates: $62.27 for Managerial, $46.21 for Technical, and $25.01 for Clerical.

c We have assumed that 20% of respondents will fail the performance test. d We have assumed that it will take 40 hours for each respondent to review the quality imp ro vement plan report.

e We have assumed that it will take 40 hours for each respondent to review the startup, shutdown, and malfunction plan. f We have assumed that 20% of respondents will take 20 hours to review the excess emi ssions report. g We have assumed that 80% of respondents will take 2 hours to review the report of no excess emissions. h We have assumed that each respondent will take 20 hours to review the startup, shutdown, malfunction report.