SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Mineral Wool Production (40 CFR Part 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 ICR 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 apply to new and existing mineral wool production facilities with cupolas and/or 

curing ovens. These standards apply 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 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 affected facilities subject to NESHAP. 

Any owner/operator 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 directly 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 years, an average of six respondents per year will be subject to the 

standards, and no additional respondents per year will become subject to the standard. 

The Office of Management and Budget (OMB) approved the currently active ICR 

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 performed by either Federal 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

reasonably 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 standards 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 legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 
3

capability to comply with the emission standards. 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 properly 

installed and operated, leaks are being detected and repaired, and the standard is being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

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 directly to the 

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

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

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.

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

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

in the Federal Register (77 FR 63813) on October 17, 2012. No comments were received on the 

burden published in the Federal 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 System (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 parties were provided an opportunity to 

comment on the burden associated with the standards as they were being developed and the 

standards 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 

Incorporated, at (800) 874-7625.

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. If the information required by these standards was 

collected less frequently, 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-year records retention requirement is consistent with 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).
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 (SIC) codes for the 

respondents affected by the standards is SIC 3296, which corresponds to the North American 

Industry Classification System (NAICS) 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 by the NESHAP for 

Mineral Wool Production (40 CFR Part 63, Subpart DDD).

A source must make the following reports:

Notifications

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 system alarms

 - Free-formaldehyde content of each resin lost and binder

 formulation

 - Incinerator operating temperature and results of 

incinerator

 inspections 

63.1192(b)

Retain records for five years 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 

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

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

electronic reporting.
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 tests, 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 

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

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

maintaining information.

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

providing information.

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 system). Although personnel 

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

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, analyze, and maintain data in the Online Tracking Information System (OTIS). 

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 properly installed and operated. 

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

with the emission standard. Data and records maintained by the respondents are tabulated and 

published for use in compliance and enforcement programs. The semiannual reports are used for 

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

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS 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 OTIS 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.

The records required by this regulation must be retained by the owner/operator for five 

years.

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 types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large 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, 

the 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 Wool 
9

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 ICR. The 

individual burdens are expressed under standardized headings believed to be consistent 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 requirements is estimated to be 1,581 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 ICR 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 by 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 type 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) Costs

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

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 ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR 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 ICR 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 analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as 

the examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$15,920. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (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 Cost – 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 ICR, on average over the next three years, approximately

six existing respondents will be subject to the standard. It is estimated that no additional

respondents will become subject annually. The overall average number of respondents, as 

shown in the table below, is sixper year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

Year

(A)

Number of New 

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. 

.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 6. 

The total number of annual responses per year 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, respectively, 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 132 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 Maintenance 
13

(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 ICR compared to the 

previous ICR. This is due to two considerations: 1) the reporting requirements have not changed 

over the past three years and are not anticipated to change over the next three years; and 2) the 

growth rate for the industry is very low, negative or non-existent, so there is no significant 

change in the overall labor hours. 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 mathematical 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) Burden Statement

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

is estimated to average 132 hours per response. “Burden” means the total time, effort, or 

financial resources expended by persons to generate, maintain, retain, or disclose or provide 

information to or for a Federal agency. This includes the time needed to review instructions; 

develop, acquire, install, and utilize technology and systems for the purposes of collecting, 

validating, and verifying information, processing and maintaining information, and disclosing 

and providing information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

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 the 
14

contents of the docket, and to access those documents in the public docket that are available 

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

in this document. The documents are also 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 

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

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

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

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

Number EPA-HQ-OECA-2012-0678 and OMB Control Number 2060-0362 in any

correspondence. 

Part 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 

hours per 

occurrence

(B) 

Occurrences 

per 

respondent

per Year

(C) 

Person

hours per 

respondent

per year 

(AxB)

(D) 

Respondents 

per year (a)

(E) 

Technical 

person

hours per 

year 

(CxD)

(F) 

Managerial 

person

hours per 

year 

(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 c4 1 4 0 0 0 0 $0

B. Required Activities

Initial performance test d421 1 421 0 0 0 0 $0

Repeat performance test d, e421 0.2 84.2 0 0 0 0 $0

Operations, maintenance, and 

monitoring plan f40 1 40 0 0 0 0 $0

Startup, shutdown, and 

malfunction plan g40 1 40 0 0 0 0 $0

C. Create Information See 3B

D. Gather Existing Information See 3B

E. Write Reports

 Notification of applicability h2 1 2 0 0 0 0 $0

Notification of 

construction/ reconstruction h2 1 2 0 0 0 0 $0

Notification of actual startup h2 1 2 0 0 0 0 $0

Notification of special 

compliance requirements h2 1 2 0 0 0 0 $0

Notification of initial 

performance test h2 1 2 0 0 0 0 $0

Notification of compliance 

status h2 1 2 0 0 0 0 $0
16

Burden Items

(A) 

Person 

hours per 

occurrence

(B) 

Occurrences 

per 

respondent

per Year

(C) 

Person

hours per 

respondent

per year 

(AxB)

(D) 

Respondents 

per year (a)

(E) 

Technical 

person

hours per 

year 

(CxD)

(F) 

Managerial 

person

hours per 

year 

(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 h2 1 2 0 0 0 0 $0

Report of performance test See 3B

Excess emissions report i16 2 32 1.2 38.4 1.92 3.84 $4,275.96

Report of no excess emission j8 2 16 4.8 76.8 3.84 7.68 $8,551.91

Quality improvement plan k40 1 40 0 0 0 0 $0

Startup, shutdown, and 

malfunction report l8 2 16 0 0 0 0 $0

Subtotal for Reporting 132.5 $12,827.87

4. Recordkeeping Requirements

A. Read Instructions m4 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 n4 52 208 6 1,248 62.4 124.8 $138,968.54

F. Time to transmit or disclose

information o0.25 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) 1,581 $153,066
17

Assumptions:

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 sources 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, maintenance, 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 each take 16 hours two times per year to write 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 improvement 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 

occurrence

(B)

Number of

occurrences 

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 performance tests

New or modified facility 40 1 40 0 0 0 0 $0

Repeat performance tests

New or modified facility c40 0.2 8 0 0 0 0 $0

Report review

Notification of applicability 2 1 0

Notification of construction/

reconstruction 2 1 2 0 0 0 0 $0

Notification of actual startup 2 1 2 0 0 0 0 $0

Notification of special compliance 

requirements 1 1 1 0 0 0 0 $0

Notification of initial performance test 2 1 2 0 0 0 0 $0

Notification of compliance status 2 1 2 0 0 0 0 $0

Request for extension of compliance, 

adjustment to time periods, and changes 

in information 2 1 2 0 0 0 0 $0

Quality improvement plan d40 1 40 0 0 0 0 $0

Operations, maintenance, and monitoring 

plan 40 1 40 0 0 0 0 $0

Startup, shutdown, and malfunction 

plan e40 1 40 0 0 0 0 $0

Report of performance test 40 1 40 0 0 0 0 $0

Excess emissions report f20 2 40 1.2 48 2.4 4.8 $2,487.58
19

Activity

(A) 

EPA Hours 

per 

occurrence

(B)

Number of

occurrences 

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 g2 2 4 4.8 19.2 0.96 1.92 $995.03

Startup, shutdown, and malfunction 

report h20 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 new 

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 improvement 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 emissions 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.