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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 Fiberglass Manufacturing.” This is a new 

information collection request (ICR), and the EPA tracking number is 1160.10.

(b) Short Characterization.

This ICR covers information collection requirements in the proposed amendments to the 

Wool Fiberglass Manufacturing NESHAP (40 CFR part 63, subpart NNN). 

The potential 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 Wool 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 located at a plant site that is a major source as defined in 40 CFR part 63.2. There are 30

facilities currently producing Wool Fiberglass and we estimate that only 10 facilities are 

currently major sources of HAP emissions and subject to subpart NNN requirements. (We also 

know that some of the 10 facilities have switched binders on some, but not all of their 

manufacturing lines.)

The proposed NESHAP amendments would require gas-fired glass-melting furnaces to 

meet new chromium compound emission limits and revised 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 proposed NESHAP amendments would require gas-fired glassmelting furnaces to meet emission limits for chromium compounds which may be met by 

shortening the furnaces’ operational life, installing add-on air pollution control equipment such 
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as a sodium hydroxide scrubber, pollution prevention measures (i.e., raw material substitution) 

or changing the brick refractories in the glass-melting furnaces. The other proposed emission 

limits are currently being met by all facilities. These amendments are explained further 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 Clean Air Act (CAA) requires EPA to establish NESHAP for both 

major and area sources of HAP that are listed for regulation under CAA section 112(c). A major 

source is a stationary source that emits or has the potential to emit more than 10 tons per year 

(tpy) of any single HAP or more than 25 tpy of any combination of HAP. An area source is a 

stationary source that is not a major source (i.e., an area source does not emit and does not have

the potential to emit more than 10 tpy of any single HAP and more than 25 tpy of any 

combination of HAP). For major sources, these technology-based standards must reflect the 

maximum degree of emission reductions of HAP achievable (after considering cost, energy 

requirements, and non-air quality health and environmental impacts) and are commonly referred 

to as maximum achievable control technology (MACT) standards. Section 112(d)(6) requires 

EPA to review these technology-based standards and to revise them “as necessary (taking into 

account developments in practices, processes, and control technologies)” no less frequently than 

every 8 years. In addition, section 112(f) of the CAA requires EPA to determine for source 

categories subject to certain CAA section 112(d) standards whether the emissions limitations 

provide an ample margin of safety to protect public health. For MACT standards for HAP 

“classified as a known, probable, or possible human carcinogen" that "do not reduce lifetime 

excess cancer risks to the individual most exposed to emissions from a source in the category or 

subcategory to less than 1-in-1 million,” EPA must promulgate residual risk standards for the 

source category (or subcategory) as necessary to provide an ample margin of safety to protect 

public health. In doing so, EPA may adopt standards equal to existing MACT standards, if EPA 

determines that the existing standards are sufficiently protective. EPA must also adopt more 
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stringent standards, if necessary, to prevent an adverse environmental effect, but must consider 

cost, energy, safety, and other relevant factors in doing so. 

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

status of sources subject to NESHAP, identify any new or reconstructed sources subject to the 

standards, and confirm that the standards are being achieved on a continuous basis. These 

recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean 

Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The 

recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and 

40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 

years following the date of each occurrence, measurement, maintenance, corrective action, report,

or record.

(b) Use/Users of the Data.

The information will be used by the delegated authority (State agency, or Regional 

Administrator if there is no delegated State agency) to ensure that the standards and other 

requirements are being achieved. Based on review of the recorded information at the site and the 

reported information, the delegated permitting authority can identify facilities that may not be in 

compliance and decide which facilities, records, or processes may need inspection. 

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.

A computer search of EPA’s ongoing ICRs revealed no duplication of informationgathering efforts.

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

This section is not applicable because this is a rule-related ICR.

(c) Consultations.

The proposed amendments were developed in consultation with individual companies, 

State agencies, and trade associations. The non-EPA persons consulted on the information 

collection activities are identified in Table 1.
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TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact Organization Telephone No.

Angus Crane North American Insulation Manufacturers Association 703-684-0084

Mike Pettis Owens Corning 740-827-7087

Carlos Davis CertainTeed Corporation 913-342-6624

Steve Aldridge Knauf Insulation 317-398-4434

Jeffrey Tarde Johns Manville 303-978-2161

(d) Effects of Less Frequent Collection.

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

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

standards.

(e) General Guidelines.

None of the guidelines in 5 CFR 1320.6 are being exceeded.

(f) Confidentiality.

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

be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart 

B--Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 

17674, March 23, 1979).

(g) Sensitive Questions. 

This section is not applicable because this ICR does not involve matters of a sensitive 

nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

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

facility engaged in Wool Fiberglass Manufacturing operations. Wool Fiberglass Manufacturing

facilities are primarily classified under NAICS code 327993, Mineral Wool Manufacturing.

There are an estimated 10 facilities that would be subject to the proposed amendments to 

the NESHAP. All 10 facilities manufacture a bonded product using a phenol-formaldehyde 

based binder on at least one FA or RS line and have at least one glass-melting furnace. We are 
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aware of one new wool fiberglass manufacturing facility that was recently constructed, but it is 

not expected to be a major source of HAP emissions; therefore, no new sources are expected 

during the 3-year period of this ICR.

(b) Information Requested.

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

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

for the Wool Fiberglass Manufacturing source category.

(ii) Respondent Activities. The respondent activities that will be required by the 

proposed amendments to the Wool Fiberglass Manufacturing NESHAP are identified in Table 2

and are introduced in section 6(a).

5. The Information Collected–Agency Activities, Collection Methodology, and 

Information Management

(a) Agency Activities.

The Agency activities associated with the proposed amendments to the Wool Fiberglass 

Manufacturing NESHAP are provided in Table 3 and are introduced in section 6(c).

(b) Collection Methodology and Management.

Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs of the delegated permitting authority. EPA is the 

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

amendments to the rule. Therefore, information contained in any report submitted to the 

Regional Administrator will be entered into the Air Facility System (AFS), which is operated and 

maintained by EPA’s Office of Compliance. AFS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the AFS for tracking air pollution compliance and 

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

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

(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 four
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companies operating the 10 Wool Fiberglass Manufacturing facilities that are expected to be 

affected 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. The proposed

amendments would create new requirements for compliance testing for existing sources and 

associated notification requirements, recordkeeping, and reporting requirements. 

(d) Collection Schedule.

The specific frequency for each information collection activity within this request is 

shown in Table 2 for the Wool Fiberglass Manufacturing Source Category.

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

The annual burden estimates for the proposed amendments to the Wool Fiberglass 

Manufacturing NESHAP are shown in Table 2. These numbers 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 Respondent 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 development costs are associated with 

the information collection activities.

(i) Estimating Labor Costs. Labor rates and associated costs are based on Bureau of 

Labor Statistics (BLS) data. Technical, management, and clerical average hourly rates for private 

industry workers were taken from the United States Department of Labor, Bureau of Labor 

Statistics, Occupational Employment and Wages, May 2013 available at 

http://www.bls.gov/oes/current/naics4_327200.htm. Wages for technical labor are based on 

"Glass and Glass Product Manufacturing – architectural and engineering," with a total 

compensation of $38.03/hour. Wages for management labor are taken from "Glass and Glass 

Product Manufacturing – management, business, and financial," with a total compensation of 

$52.54/hour. Wages for clerical labor are based on "Glass and Glass Product Manufacturing –
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production, planning, and expediting clerks," with a total compensation of $19.00/hour. These 

rates represent salaries plus fringe benefits and do not include the cost of overhead. An overhead 

rate of 110 percent is used to account for these costs. The fully-burdened hourly wage rates used 

to represent respondent labor costs are: technical at $79.86 /hour, management at $110.33 /hour, 

and clerical at $39.90 /hour.

(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. No capital costs 

or O & M costs are associated with the information collection requirements of the proposed

amendments to the Wool Fiberglass Manufacturing NESHAP. The proposed amendments do not

require affected facilities to purchase new monitoring systems, but do require affected facilities 

to conduct new performance testing to demonstrate compliance with the new emission limits. 

(iii) 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 the information collection requirements were developed as an incidental part of 

standards development, no costs can be attributed to the development of the information 

collection requirements. Because reporting and recordkeeping requirements on the part of the 

respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the 

part 63 NESHAP General Provisions, no operational costs will be incurred by the Federal 

Government. Publication and distribution of the information are part of the Compliance Data 

System, with the result that no Federal costs can be directly attributed to the ICR. Examination 

of records to be maintained by the respondents will occur incidentally as part of the periodic 

inspection of sources that is part of EPA’s overall compliance and enforcement program, and, 

therefore, is not attributable to the ICR. The only costs that the Federal government will incur 

are user costs associated with the analysis of the reported information, as presented in Table 3.

The Agency labor rates are from the Office of Personnel Management (OPM) 2013

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

Table 2010-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 for 
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technical (GS-12, Step 1), and $38.92/hr for management (GS-13, Step 5). These rates were 

increased by 60 percent to include fringe benefits and overhead. The fully-burdened wage rates 

used to represent Agency labor costs are: clerical at $25.01/hour; technical at $46.21/hour, and 

management at $62.27/hour. 

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

There are an estimated 30 existing facilities that are currently manufacturing wool 

fiberglass in the United States. Industry is phasing out phenol-formaldehyde binders at the 

bonded lines, and we estimate that there will be 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 year.

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 the 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. The bottom line respondent burden hours and costs, presented in 

Table 2 are calculated by adding person-hours per year down each column for technical, 

managerial, and clerical staff, and by adding down the cost column. The average annual burden 

for the recordkeeping and reporting requirements in the proposed 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 associated with 

recordkeeping and reporting would be expected for the proposed amendments.

(ii) The Agency tally. The average annual Federal Government cost is $1,366 for 

30.3 hours for the proposed amendments to subpart NNN. The bottom line Agency burden hours

and costs presented in Table 3 are calculated by adding person-hours per year down each column 

for technical, managerial, and clerical staff, and by adding down the cost column. 
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(iii) Variations in the annual bottom line. This section does not apply 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 Manufacturing 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 needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 

to respond to a collection of information; search data sources; complete and review the collection 

of information; and transmit or otherwise disclose the information.

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

collection of information unless it displays a currently valid OMB control number. The OMB 

control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9.

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

burden estimates, and any suggestions for minimizing respondent burden, including through the 

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

Docket ID No. EPA-HQ-OAR-2010-1042 which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation Docket and 

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room B-102, 1301 

Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The 

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

Air Docket is (202) 566-1927. An electronic version of the public docket is available at 

http://www.regulations.gov. This site can be used to submit or view public comments, access the 
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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 17th Street, NW, Washington, 

DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID Number 

(EPA-HQ-OAR-2010-1042) in any correspondence.

PART B

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

associated with the proposed rule.
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TABLE 2. ANNUAL RESPONDENT BURDEN & COST PROPOSED AMENDMENTS TO WOOL 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-hours 

per year

(E*0.05)

(G) 

Clerical 

person-hours 

per year 

(E*0.1)

(H) 

Costa, $ 

1. Applications N/A

2. Surveys and Studies N/A

3. Acquisition, Installation, and Utilization of 

Technology and Systems

N/A

4. Reporting Requirements

A. Read instructionsb 8 1 8 3.33 26.6 1.3 2.7 $2,375

B. Required activitiesc (compliance testing) $10,480 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 report 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

TOTAL LABOR BURDEN AND COST (SALARY) 133.1 6.6 13.4 $46,789

TOTAL NUMBER OF ANNUAL RESPONSES 7

ANNUAL CAPITAL COSTSd

TOTAL ANNUALIZED COSTS $46,789

N/A = not applicable.

a

 This ICR uses the following labor rates: $110.33 for managerial labor, $79.86 for technical labor, and $39.90 for clerical labor. These rates are based on the U.S. Department of 

Labor, Bureau of Labor Statistics, Occupational Employment and Wages, May 2013.

b 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 $104,800 / 10 facilities = $10,480.

d

 There would be no capital costs associated with the reporting and recordkeeping requirements of the proposed amendments.
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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 personhours/year 

(C=A*B)

(D) 

Facilities 

per year

(E) 

Technical personhours/year 

(E=C*D)

(F) 

Management 

person-hours/year 

(F=0.05*E)

(G) 

Clerical personhours/year 

(G=0.1*E)

(H)

Costa, $

Report Review:

 Review compliance test reports for Cr 

compounds for glass-melting furnaces and 

formaldehyde, phenol, and methanol for 

RS and FA manufacturing linesb

8 1 8 3.33 26.4 1.3 2.6 $1,366

TOTAL BURDEN AND COST $1,366

a

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

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

b Assumes Agency will review all of the annual reports - including the new Cr compounds, phenol, and methanol emissions testing.
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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 furnaces

§ 63.1382(a)(1)(ii) § 63.1382(a)(1)(ii)

Cr compound limit for gas-fired glassmelting furnaces 

§ 63.1382(a)(1)(iii) § 63.1382(a)(1)(iii)

Formaldehyde limit for RS mfg lines § 63.1382(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)

Notifications § 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)