1 SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR WOOL FIBERGLASS MANUFACTURING

PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection.

“ National Emission Standards Wool F iberglass Manufacturing

. ” This is a new information collection request (ICR)
, and the EPA tracking number i s 1160.10. (b) Short Characterization. This ICR covers information collection requirements i n the proposed amendments to the Wool Fiberglass Manu facturing NESHAP ( 40 CFR part 63, subpart NNN )

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

. Per the applicability section of subpart NNN, the following sources at a W ool Fiberglass Manufacturing facility are covered: each glass

- melting furnace, each rotary spin (RS) manufacturing line, and each flame attenuation (FA) manufacturing line producing a bonded product using a phenol

- formaldehyde based binder, and
that is loc ated at a plant site that is a major source as defined in 40 CFR part 63.2. The re are 30
facilities currently producing Wool Fiberglass and we estimate that only 1 0 facilities are currently major sources of HAP emissions and subject to subpart NNN requirem ents. (We also
know that s ome of the 1 0 facilities have s witched binders on some, but not all of their manufacturing lines .)
The proposed NESHAP a mendments would require gas

- fired glass

- melting furnaces to

meet new chromium compound emission limits and re vised particulate emission limits for all glass

- melting furnaces; revised emission limits for formaldehyde and new emission limits for phenol, and methanol from RS and FA manufacturing lines ; and new requirements for periods of startup and shutdown. The pr oposed NESHAP amendments would require gas

- fired glass

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

- on air pollution control equipment such2

as a sodium hydroxi de scrubber, pollution prevention measures (i.e., raw material substitution) or changing the brick refractories in the glass

- melting furnaces. T he other proposed emission limits are currently being met by all facilities . T hese amendments are explained fur ther in the following paragraphs.
The information collection requirements associated with the proposed amendments to the
NESHAP are listed in Attachment 1

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

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

. For major sources, these technology

- based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, 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, pro cesses, 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 a mple 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 ca tegory 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 more3

stringent standards, if necessary, to prevent an adverse environmental effect, but must consider cost, energy, safety, and oth er relevant factors in doing so. Certain records and reports are nec essary for the Administrator to confir m the compliance
status of sources subject to NESHAP
, identify any new or reconstructed s ources subject to the standards, and confirm that the stan dards 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 recordkeeping and re porting requirements for t itle V permits are contained in 40 CFR 70.6 and
40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report,
or record. (b) Use/Users of the Data. The information will be used by the delegated authority (State agency
, or Regional Administrator if there is no delegated State agency) to ensure that the standards and other requirements are being achie ved. 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 facilitie s, records, or processes may need inspection

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

gathering efforts. (b) Public Notice Required Prior to ICR Submission to OMB.
This se ction is not applicable because this is a rule

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

- EPA persons consulted on the information
colle ction activities are identified in Table 1.4

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact Organization Telephone No. Angus Crane N orth A merican 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
(d) Effects of Less Frequent Collection.
If the relevant information was collected less frequently, the delegated permitting authority (State or EPA) w ill not be reasonably assured that a facility is in compliance with the
standards. (e) General Guidelines

. None of the guidelines in 5 CFR 1320.6 are being exceeded. (f) Confidentiality.
All information su bmitted 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, 19 76; 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/NAIC S Codes

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

. Wool Fiberglass Manufacturing facilities are pr imarily classified under NAICS code 3 2 7 993
, Mineral Wool Manufacturing

. The re are an estimated 1 0 facilities that w ould be subject to the proposed amendments to
the NESHAP

. All 10 facilities manufacture a bonded product using a phenol

- formaldehyde
based b inder on at least one FA or RS line and have at least one glass

- melting furnace. We are5

aware of one new w ool f

iberglass m anufacturing facility that was recently constructed, but it is not expected to be a major source of HAP emissions; therefore, no new s ources are expected during the 3-year period of this ICR. (b) Information Requested. (i) Data Items, Including Recordkeeping Requirements. Attachment 1
, Information Requirements, summarize s the data items, including recordkeeping and reporting requirem ents , for the Wool Fiberglass Manufacturing s ource c ategor y

. (ii) Respondent Activities. The respondent activities that will be required by the proposed amendments to the Wool Fiberglass Manufacturing NESHAP are identified in Table 2

an d are introduced in section 6(a).
5. The Information Collected

– Agency Activities, Collection Methodology, and Information Management (a) Agency Activities.
The Agency activities associated with the proposed amendments to the Wool Fiberglass Manufacturing NESHAP are provid ed 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, i nformation contained in any report submitted to the Regional Administrator will be entered into the Air Facility Syste m (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 tr acking air pollution compliance and enforcement by local and state regulatory agencies, EPA r egional offices and EPA headquarters. EPA and its delegated a uthorities can edit, store, retrieve and analyze the data. (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 four6

companies operating the 10 Wool Fiberglass Manufacturing facilities that are expected to be
af fected by this rule and none of the companies are small businesses. The proposed amendments
would not result in significant adverse impacts on any of the small entities

. T he proposed
amendments would create new requirements for compliance testing f or exis ting 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 M anufacturing S ource C atego ry. 6. Estimating the Burden and Cost of the Collection (a) Estimating Respondent Burden.
The annual burden estimates for the proposed amendments to the Wool Fiberglass Manufacturing NESHAP are shown in Table 2

. These numbe rs were derived from estimates based on EPA’s experience with other standards. No burden estimates are provided for new sources because no new facilities are expected to become affected sources during the 3

- year period of this ICR. (b) Estimating Respon dent Costs.
The information collection activities for the proposed amendments to the Wool Fiberglass Manufacturing NESHAP are presented in Table 2. Because the data are already collected by respondents as part of normal operations
, no respondent developm ent 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
in dustry workers were taken from the United States Department of Labor, Bureau of Labor Statistics, Occupational Employment and Wages, Ma y 20 1 3 available at http://www.bls.gov/oes/current/naics4 _327200.htm

. Wages for technical labor are based on

" Glass and Glass Product Manufacturing

– architectural and engineering
, " with a total compensation of $ 38. 03 /hour. Wages for management labor are taken from " Glass and Glass Product Manufacturing

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

–7

production, planning, and expediting clerks
, " with a total compensation of $ 19.00 /hour. These

ra tes represent salaries plus fringe benefits and do not include the cost of overhead. An overhead rate of 110 percent is used to account for these costs. The fully

- burdened hourly wage rates used to represent respondent la bor costs are: technical at $ 79. 86 /hour , management at $ 1 10.33 /hour
, and clerical at $ 39.90 /hour

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

. No capital costs
or O & M costs are associated with the information collection requirements of the proposed
amendmen ts to the Wool Fiberglass Manufacturing NESHAP. The proposed amendments do not require affected facilities to purchase new m onitoring systems , but do require affected facilities

to conduct new performance testing to demonstrate compliance with the new emi ssion limits

. (i ii ) Annualizing Capital Costs

. No capital costs are associated with the information collection requirements for the proposed amendments to the Wool Fiberglass Manufacturing
NESHAP. (c) Estimating Agency Burden and Cost

. Because th e 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 w ill be incurred by the Federal Government. Publication and distribution of the information are par t of the Compliance Data System, with the result that no Federal costs can be directly attributed to the ICR. Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of sour ces that is part of EPA’ s overall compliance and enforcement program, and, therefore, is not attributable to the ICR. The only costs that the Federal government w ill incur are user costs associated with the analysis of the reported information, as presented in Table 3

. The Agency labor rates are from the Office of Personnel Management (OPM) 20 1 3
General Schedule
, which excludes locality rates of pay. These rates can be obtained from Salary
Table 20 10

- GS available on the OPM website, http://www.opm.gov/oca/13tables/pdf/gs_h.pdf

. The government employee labor rates are $ 15.63 /hour for clerical (GS

- 6, Step 3), $ 28.88 for8

technical (GS

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

- 13, Step 5). These rates were
increas ed 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. I ndustry is phasing out phenol

- formaldehyde binders at the
bonded lines, and we estimate that there will be 10 facilities subject to the proposed amendments.
No new major sources are expected during the next 3 years. Consequently, the average number
of wool fiberglass respondents during the 3

- year period of this ICR is 10 facilities / 3 = 3.33 respondents per yea r

. For the proposed amendments to the Wool Fiberglass Manufacturing NESHAP , the components of the total annual burden attributable to this ICR include reading the amendments to
the NESHAP ; conducting the performance testing to demonstrate compliance with the proposed
emission limits ; and reporting th e results of those emissions tests ; all other recordkeeping and reporting activities are already accounted for in the ICR for the NESHAP. (e) Bottom Line Burden Hours and Cost Tables. (i) Respondent tally. Th e 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 reco rdkeeping and reporting requirements in the proposed amendments to subpart NNN
for the 10 existing facilities that are subject to the Wool Fiberglass Manufacturing NESHAP is
153 person

- hours
, with an annual average cost of $ 46,789

. No capital costs associ ated with recordkeeping and reporting would be expected for the proposed amendments

. (ii) The Agency tally. The average annual Federal Go vernment cost is $ 1,366 for
30.3 hours for the proposed amendments to subpart NNN

. The bottom line Agency burden ho urs 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.9

(iii) Variations in the annual bottom line. This section does not appl y since no significant variation is anticipated. (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 amendments to the Wool Fiberglass Manuf

acturing NESHAP is estimated at 153 hours per facility

. 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 ne eded 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 e xisting 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 dis close 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 a re 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 est ablished a public docket for this ICR under
Docket ID No. EPA

- HQ

- OAR

- 2010

- 104 2 which is available for online viewing at http://www.regulations.gov , or in person viewing at the Air and Radiation Docket and
Informa tion 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 e lectronic version of the public docket is available at http://www.regulations.gov. This site c an be used to submit or view public comments, access the10

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

- HQ

- OAR

- 2010

- 104 2 ) in any c orrespondence.

PART B This section is not applicable because statistical methods are not used in data collection
associated with the proposed rule

.11

TABLE 2 . ANNUAL RESPONDENT BURDEN & COST PROPOSED AMENDMENTS TO W OOL FIBERGLASS MANUFACTURING NESHAP

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 - h ours per year (E*0.05) (G)

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

Cost a , $ 1. Applications N/A 2. Surveys and Studies N/A 3. Acquisition, Installation, and Utilization of Technology and Systems N/A
4. Reporting Requirem ents A. Read instructions b 8 1 8 3.33 26.6 1.3 2.7 $ 2, 375 B. Required activities c (compliance testing) $ 1 0 ,4 8 0 1 3.33 $ 34
, 898 C. Create information 8 2 16 3.33 53.3 2.7 5.3 $ 4, 766 D. Gather existing information N/A E. Write re port 8 1 8 3.33 26.6 1.3 2.7 $ 2, 375 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 3.33 26.6 1.3 2.7 $ 2, 375 I. Time for audits N/A T OTAL LABOR BURDEN AND COST (SALARY) 133.1 6.6 13.4 $ 46
, 789 TOTAL NUMBER OF ANNUAL RESPONSES 7 ANNUAL CAPITAL COSTS d TOTAL ANNUALIZED COSTS $ 4 6, 789 N/A = not applicable.

a T his ICR uses the following labor rates : $ 1 10.33 for managerial labor, $ 79 .86 for technical labor, and $ 39.90 for clerical labor. These rates are based on the U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment and Wages, Ma y 201 3

. b There are an estimated 10 existing facilities; no new facilities are expected; the average number expected to read the rule during the 3

- yr compliance period is 10 / 3 = 3.33

. c The average facility cost for new Cr compound, phenol, and methanol testing was calculated to be $ 1 04,800 / 10 facilities = $ 1 0 ,4 8 0

. d There wo uld be no capital costs associated with the reporting and recordkeeping requirements of the proposed amendments

.12

3 . ANNUAL BURDEN AND COST TO THE AGENCY

-- -- PROPOSED AMENDMENTS TO WOOL FIBERGLASS MANUFACTURING NESHAP

Burden item (A) Person

- hours per occurrence (B)

Occurrences per respondent (C)

EPA person

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

Facilities per year (E)

Technical person

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

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

Clerical person

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

Cost a , $ Report Rev iew: Review compliance test reports for Cr compounds for glass

- melting furnaces and f ormaldehyde , phenol, and methanol for RS and FA manufacturing lines b 8 1 8 3.33 26.4 1.3 2.6 $ 1,366

TOTAL BURDEN AND COST $ 1,366

a This ICR uses the f

ollowin g average hourly labor rates: $ 62.27 for m anagerial (GS

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

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

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

. b Assumes Agency will review all of the annual reports

- including the new Cr compounds, phenol, and methanol emissions testing

.13

ATTACHMENT 1. INFORMATION REQUIREMENTS

-- -- PROPOSED AMENDMENTS TO WOOL FIBERGLASS MANUFACTURING NESHAP

Requirement Citation for existing sources Citation for new sources General Provisions citation Work practice standards for HF and HCl emissions for glass furnace s § 63. 1 382 ( a)( 1 ) (ii) § 63. 1 382 ( a)( 1 ) (ii)
Cr compound limit for gas - fired glass

melting fu rnaces § 63. 1 382 (a)( 1 ) (iii) § 63. 1 382 (a)( 1 ) (iii)
Formaldehyde limit for RS mfg lines § 63. 1 382(a)(2) (i) § 63. 1382(a)(2) (ii) Phenol limit for RS mfg lines § 63.1382(a)(2) (i) § 63.1382(a)(2) (ii) Methanol limit for RS mfg lines § 63.1382(a)(2) ( i) § 63.1382(a)(2) (ii) Formaldehyde limit for FA mfg lines § 63.1382(a)( 3 ) (i) § 63. 1382(a)( 3 ) )ii) Phenol limit for FA mfg lines § 63.1382(a)( 3 ) (i) § 63. 1382(a)( 3 ) (ii) Methanol limit for FA mfg lines § 63.1382(a)( 3 ) (i) § 63. 1382(a)( 3 ) (ii) No tifications § 63. 1386(a) § 63. 1386(a) N/A Plans Operation and Maintenance Plan N/A N/A N/A Records Monitoring/inspection information § 63. 1383 § 63. 1383 N/A Reports § 63. 1386(b) and (c) § 63. 1386(b) and (c) 40 CFR 63.10 (e)