1 

SUPPORTING STATEMENT 

NATIONAL EMISSION STANDARDS FOR WOOL FIBERGLASS MANUFACTURING 

AT AREA SOURCES 

PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection. 

“National Emission Standards Wool Fiberglass Manufacturing Area Sources.” This is a 

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

 (b) Short Characterization. 

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

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

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

Wool Fiberglass Manufacturing facilities. Per the applicability section of subpart NN, only the gasfired glass-melting furnaces at a Wool Fiberglass Manufacturing facility that are located at a plant 

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

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

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

requirements. We are not including costs for those new facilities because those facilities will be 

subject to major source rule requirements under subpart NNN.

The final NESHAP would require gas-fired glass-melting furnaces to meet emission limits 

for chromium compounds which may be met by shortening the furnaces’ operational life, installing 

add-on air pollution control equipment such as a sodium hydroxide scrubber, pollution prevention 

measures (i.e., raw material substitution) or changing the brick refractories in the glass-melting 

furnaces. The requirements are explained further in the following paragraphs. 

The information collection requirements associated with the area source NESHAP are listed 

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

(a) Need/Authority for the Collection. 

 Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP for both major 

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

is a stationary source that emits or has the potential to emit more than 10 tons per year (tpy) of any 

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

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

more than 10 tpy of any single HAP and more than 25 tpy of any combination of HAP). For major 

sources, these technology-based standards must reflect the maximum degree of emission reductions 

of HAP achievable (after considering cost, energy requirements, and non-air quality health and 

environmental impacts) and are commonly referred to as maximum achievable control technology 

(MACT) standards. Section 112(d)(6) requires EPA to review these technology-based standards 

and to revise them “as necessary (taking into account developments in practices, processes, and 

control technologies)” no less frequently than every 8 years. In addition, section 112(f) of the CAA 

requires EPA to determine for source categories subject to certain CAA section 112(d) standards 

whether the emissions limitations provide an ample margin of safety to protect public health. For 

MACT standards for HAP “classified as a known, probable, or possible human carcinogen" that 

"do not reduce lifetime excess cancer risks to the individual most exposed to emissions from a 

source in the category or subcategory to less than 1-in-1 million,” EPA must promulgate residual 

risk standards for the source category (or subcategory) as necessary to provide an ample margin of 

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

standards, if EPA determines that the existing standards are sufficiently protective. EPA must also 

adopt more stringent standards, if necessary, to prevent an adverse environmental effect, but must 

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

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

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

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

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

Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The 
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recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and 40 

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

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

record. 

 (b) Use/Users of the Data.

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

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

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

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

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

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.

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

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

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

(c) Consultations. 

The final amendments were developed in consultation with individual companies, State 

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

activities are identified in Table 1. 

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES 

Contact Organization Telephone No. 

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

Mike Pettis Owens Corning 740-827-7087 

Carlos Davis CertainTeed Corporation 913-342-6624 

Steve Aldridge Knauf Insulation 317-398-4434 

Jeffrey Tarde Johns Manville 303-978-2161 
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(d) Effects of Less Frequent Collection.

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

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

(e) General Guidelines. 

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

(f) Confidentiality.

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

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

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

by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 

1979).

(g) Sensitive Questions. 

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

nature. 

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

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

facility engaged in Wool Fiberglass Manufacturing operations. Wool Fiberglass Manufacturing 

facilities are primarily classified under NAICS code 327993. 

There are an estimated 5 facilities that would be subject to the final area source NESHAP. 

There are currently 8 gas-fired glass-melting furnaces at these 5 facilities and 3 of those furnaces 

would require additional chromium reduction measures to meet the final chromium compound 

emission limit. We are not aware of any new Wool Fiberglass Manufacturing facilities being 

constructed; however, we do expect most, if not all of the remaining major source facilities to 

convert to non-HAP binders and become area sources. However, we are not including any costs 

for new area sources during the 3-year period of this ICR to avoid double counting costs associated 

with the major source rule (subpart NNN) final amendments. 

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

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

the Wool Fiberglass Manufacturing source category. 

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

Fiberglass Manufacturing NESHAP for area sources are identified in Table 2 and are introduced in 

section 6(a). 

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

Information Management

(a) Agency Activities.

 The Agency activities associated with the final area source Wool Fiberglass Manufacturing 

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

(b) Collection Methodology and Management. 

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

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

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

rule. Therefore, information contained in any report submitted to the Regional Administrator will 

be entered into the Air Facility System (AFS), which is operated and maintained by EPA’s Office of 

Compliance. AFS is EPA’s database for the collection, maintenance, and retrieval of compliance 

data for approximately 125,000 industrial and government-owned facilities. EPA uses the AFS for 

tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA 

regional offices and EPA headquarters. EPA and its delegated authorities can edit, store, retrieve 

and analyze the data. 
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(c) Small Entity Flexibility.

 The Small Business Administration defines a small entity engaging in Wool Fiberglass 

Manufacturing operations as a firm having no more than 500 employees. There are three 

companies operating the five Wool Fiberglass Manufacturing facilities that are expected to be 

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

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

associated notification requirements, recordkeeping, and reporting requirements. 

(d) Collection Schedule. 

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

in Table 2 for the Wool Fiberglass Manufacturing Source Category. 

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

 The annual burden estimates for the final Wool Fiberglass Manufacturing NESHAP for 

Area Sources are shown in Table 2. These numbers were derived from estimates based on EPA’s 

experience with other standards. As discussed previously, there are no burden estimates provided 

for new sources during the 3-year period of this ICR to avoid double counting costs associated 

with the major source rule (subpart NNN) final amendments. 

(b) Estimating Respondent Costs.

 The information collection activities for the final Wool Fiberglass Manufacturing NESHAP 

for Area Sources are presented in Table 2. Because the data are already collected by respondents 

as part of normal operations, no respondent development costs are associated with the information 

collection activities. 

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

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

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

Statistics, Occupational Employment and Wages, May 2014 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 

$34.74/hour. Wages for management labor are taken from "Glass and Glass Product 
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Manufacturing – management, business, and financial," with a total compensation of $53.31/hour. 

Wages for clerical labor are based on "Glass and Glass Product Manufacturing – production, 

planning, and expediting clerks," with a total compensation of $20.36/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 $72.95/hour, management at $111.95/hour, and clerical at 

$42.76/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 final area source 

Wool Fiberglass Manufacturing NESHAP. The final area source rule would require affected 

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

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

collection requirements for the final area source Wool Fiberglass Manufacturing NESHAP. 

(c) Estimating Agency Burden and Cost. 

 Because the information collection requirements were developed as an incidental part of 

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

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

are required under the operating permits rules in 40 CFR part 70 or part 71 and the part 63 

NESHAP General Provisions, no operational costs will be incurred by the Federal Government. 

Publication and distribution of the information are part of the Compliance Data System, with the 

result that no Federal costs can be directly attributed to the ICR. Examination of records to be 

maintained by the respondents will occur incidentally as part of the periodic inspection of sources 

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

attributable to the ICR. The only costs that the Federal government will incur are user costs 

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

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

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

2015-GS available on the OPM website, http://www.opm.gov/policy-data-oversight/payleave/salaries-wages/salary. The government employee labor rates are $15.94/hour for clerical (GS-
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6, Step 3), $29.46 for technical (GS-12, Step 1), and $39.70/hr for management (GS-13, Step 5). 

These rates were increased by 60 percent to include fringe benefits and overhead. The fullyburdened wage rates used to represent Agency labor costs are: clerical at $25.50/hour; technical at 

$47.14/hour, and management at $63.52/hour. 

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

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

in the United States. Industry is phasing out phenol-formaldehyde binders at the bonded lines, and 

we estimate that there will be five existing facilities subject to the final area source requirements 

during the next 3 years. Consequently, the average number of wool fiberglass respondents during 

the 3-year period of this ICR is 5 facilities/3 = 1.67 per year. 

For the final Wool Fiberglass Manufacturing NESHAP for Area Sources, the components 

of the total annual burden attributable to this ICR include reading the area source NESHAP; 

conducting the performance testing to demonstrate compliance with the chromium compounds 

emission limits; reporting the results of those emissions tests; and complying with all other 

monitoring, recordkeeping and reporting activities for the NESHAP. 

(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent tally. The bottom line respondent burden hours and costs, presented in 

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

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

the recordkeeping and reporting requirements in the final area source NESHAP (subpart NN) for 

the five existing facilities with gas-fired furnaces that are subject to the Wool Fiberglass 

Manufacturing NESHAP for Area Sources is 78 person-hours, with an annual average cost of 

$32,334. No capital costs would be expected for the final rule requirements. 

(ii) The Agency tally. The average annual Federal Government cost is $917 for 15 hours 

for the final subpart NN requirements. The bottom line Agency burden hours and costs presented 

in Table 3 are calculated by adding person-hours per year down each column for technical, 

managerial, and clerical staff, and by adding down the cost column. 

(iii) Variations in the annual bottom line. This section does not apply since no significant 

variation is anticipated. 
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(f) Reasons for Change in Burden.

 This section does not apply because this is a new ICR.

 (g) Burden Statement 

 The average annual respondent burden for the final Wool Fiberglass Manufacturing 

NESHAP for Area Sources is estimated at 78 hours. 

Burden means the total time, effort, or financial resources expended by persons to generate, 

maintain, retain, or disclose or provide information to or for a Federal agency. This includes the 

time needed to review instructions; develop, acquire, install, and utilize technology and systems for 

the purposes of collecting, validating, and verifying information, processing and maintaining 

information, and disclosing and providing information; adjust the existing ways to comply with any 

previously applicable instructions and requirements; train personnel to be able to respond to a 

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

and transmit or otherwise disclose the information. 

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

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

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

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

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

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

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

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

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

NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 

4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the 

Reading Room is (202) 566-1744, and the telephone number for the Air Docket is (202) 566-1927. 

An electronic version of the public docket is available at http://www.regulations.gov. This site can 

be used to submit or view public comments, access the index listing of the contents of the public 

docket, and to access those documents in the public docket that are available electronically. When 

in the system, select “search,” then key in the Docket ID Number identified above. Also, you can 
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send comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please 

include the relevant Docket ID Number (EPA-HQ-OAR-2010-1042) in any correspondence. 

PART B 

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

associated with the final rule. 
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TABLE 2. ANNUAL RESPONDENT BURDEN AND COST -- WOOL FIBERGLASS MANUFACTURING NESHAP AREA 

Burden item 

(A) 

Personhours 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) 

1. Applications N/A 2. Surveys and Studies N/A 3. Acquisition, Installation, and Utilization of Technology and Systems 

N/A 

4. Reporting Requirements A. Read instructionsb 4 1 8 1.67 13.4 0.7 B. Required activitiesc (compliance testing) 0 1 1.67 C. Create informationd 8 2 16 1.67 26.7 1.3 D. Gather existing information N/A E. Write report 8 1 8 1.67 13.4 0.7 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 0.5 1 0.5 1.67 0.84 0.05 F. Time to train personnel N/A G. Time to adjust existing ways to comply with previously applicable requirements 

N/A 

H. Time to transmit or disclose information 8 1 8 1.67 13.4 0.7 I. Time for audits N/A TOTAL LABOR BURDEN AND COST (SALARY) 67.7 3.5 TOTAL NUMBER OF ANNUAL RESPONSES 5 ANNUAL CAPITAL COSTSdTOTAL ANNUALIZED COSTS 

N/A = not applicable. a This ICR uses the following labor rates: $111.95 for managerial labor, $72.95 for technical labor, and $42.76 for clerical labor. These rates are ba

of Labor, Bureau of Labor Statistics, Occupational Employment and Wages, May 2015. b An estimated 5 existing facilities and no new facilities (5 total) are expected to have gas-fired furnaces and be subject to subpart NN; the average the rule during the 3-yr compliance period is 5/3 = 1.67. c The average facility cost for Cr compound testing was calculated to be: (8 gas-fired furnaces) x ($10,000 per test) = $80,000/5 facilities = $16,000. d There would be no capital costs associated with the reporting and recordkeeping requirements of the final area source NESHAP. 
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 3. ANNUAL BURDEN AND COST TO THE AGENCY ---- WOOL FIBERGLASS MANUFACTURING NESHAP AREA SO

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) 

Report Review: Review compliance test reports for Cr compounds for gas-fired furnaces 8 1 8 1.67 13.4 0.7 TOTAL BURDEN AND COST 

a This ICR uses the following average hourly labor rates: $63.52 for managerial (GS-13, Step 5), $47.14 (GS-12, Step 1) for technical, and $25.50 

These rates are from the Office of Personnel Management (OPM) 2013 General Schedule, which excludes locality rates of pay.
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ATTACHMENT 1. INFORMATION REQUIREMENTS ---- WOOL FIBERGLASS MANUFACTURING NESHAP AREA S

Requirement Citation for existing sources Citation for new sources General P

Cr compound limit for gas-fired glassmelting furnaces § 63.882(a)(1)(i) § 63.882(a)(1)(i) Notifications § 63.886(a) § 63.886(a) N/A Plans  Operation and Maintenance Plan N/A N/A N/A Records  Monitoring/inspection information § 63.883 § 63.883 N/A Reports § 63.886(b) and (c) § 63.886(b) and (c) 40 CFR 63.10