1 SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR WOOL FIBERGLASS MANU FACTURING 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 Manufacturi ng 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 a ny existing, new, or reconstructed Wool Fiberglass Manufacturing facilities. Per the applica bility section of subpart NN, only the gasfired glass-melting furnaces at a Wool Fiberglass Manufac turing facility that are located at a plant site that is an area source as defined in 40 CFR part 63.2 a re 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 f acilities because those facilities will be subject to major source rule requirements under subpart NNN. The final NESHAP would require gas-fired glass-melting furna ces to meet emission limits for chromium compounds which may be met by shortening th e furnaces’ operational life, installing add-on air pollution control equipment such as a sodium hydrox ide scrubber, pollution prevention measures (i.e., raw material substitution) or changing t he brick refractories in the glass-melting furnaces. The requirements are explained further in the f ollowing paragraphs. The information collection requirements associated wit h the area source NESHAP are listed

in Attachment 1.2

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 un der CAA section 112(c). A major source is a stationary source that emits or has the potentia l to emit more than 10 tons per year (tpy) of any single HAP or more than 25 tpy of any combination of HA P. 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 th e maximum degree of emission reductions of HAP achievable (after considering cost, energy requir ements, 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 de velopments 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 t o certain CAA section 112(d) standards whether the emissions limitations provide an ample mar gin 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 indiv idual 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 a dopt 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 fact ors in doing so. Certain records and reports are necessary for the Admi nistrator to confirm the compliance status of sources subject to NESHAP, identify any new o r reconstructed sources subject to the standards, and confirm that the standards are being achie ved on a continuous basis. These recordkeeping and reporting requirements are specifically auth orized by section 114 of the Clean Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP Gen eral Provisions. The3

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 mus t keep each record for 5 years following the date of each occurrence, measurement, mai ntenance, 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 ca n identify facilities that may not be in compliance and decide which facilities, records, or proce sses may need inspection.

3. Nonduplication, Consultations, and Other Collection Criteria (a) Nonduplication. A computer search of EPA’s ongoing ICRs revealed no duplica tion of informationgathering efforts. (b) Public Notice Required Prior to ICR Submission to OMB. This section is not applicable because this is a rule-r elated 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 COLLE CTION ACTIVITIES

Contact Organization Telephone No. Angus Crane North American Insulation Manufacturers Asso ciation 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 303-978-21614

(d) Effects of Less Frequent Collection. If the relevant information was collected less freque ntly, 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 c laim of confidentiality is made will be safeguarded according to the Agency policies set forth in T itle 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, Marc h 23, 1979). (g) Sensitive Questions. This section is not applicable because this ICR does n ot 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 opera tors of any existing or new facility engaged in Wool Fiberglass Manufacturing operation s. Wool Fiberglass Manufacturing facilities are primarily classified under NAICS code 327993. There are an estimated 5 facilities that would be subjec t 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 Fi berglass 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. H owever, 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 amendment s. (b) Information Requested.5

(i) Data Items, Including Recordkeeping Requirements. Attachment 1, Information Requirements, summarizes the data items, including recordkee ping 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 iden tified in Table 2 and are introduced in section 6(a). 5. The Information Collected–Agency Activities, Collection Met hodology, 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 sectio n 6(c). (b) Collection Methodology and Management

. Data and records maintained by the respondents are tabul ated and published for use in compliance and enforcement programs of the delegated permit ting 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 fa cilities. EPA uses the AFS for tracking air pollution compliance and enforcement by loca l and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegat ed authorities can edit, store, retrieve and analyze the data.6

(c) Small Entity Flexibility.

The Small Business Administration defines a small ent ity engaging in Wool Fiberglass Manufacturing operations as a firm having no more than 500 employees. There are three companies operating the five Wool Fiberglass Manufacturin g facilities that are expected to be affected by this rule and none of the three companies a re small businesses. The final area source NESAHP would create new requirements for compliance test ing for existing sources and associated notification requirements, recordkeeping, and re porting requirements. (d) Collection Schedule

. The specific frequency for each information collectio n activity within this request is shown in Table 2 for the Wool Fiberglass Manufacturing Source C ategory. 6. Estimating the Burden and Cost of the Collection (a) Estimating Respondent Burden. The annual burden estimates for the final Wool Fibergl ass 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 av oid double counting costs associated with the major source rule (subpart NNN) final amendment s. (b) Estimating Respondent Costs.

The information collection activities for the fina l 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 c osts 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 Depart ment of Labor, Bureau of Labor Statistics, Occupational Employment and Wages, May 2014 avai lable at http://www.bls.gov/oes/current/naics4_327200.htm . Wages for technical labor are based on "Glass and Glass Product Manufacturing – architectural and engineeri ng," with a total compensation of $34.74/hour. Wages for management labor are taken from "Gla ss and Glass Product7

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-b urdened hourly wage rates used to represent respondent labor costs are: technical at $72.95/hour, mana gement 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 c ollection requirements of the final area source Wool Fiberglass Manufacturing NESHAP. The final area s ource 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 informati on 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 enforceme nt program, and, therefore, is not attributable to the ICR. The only costs that the Fe deral government will incur are user costs associated with the analysis of the reported informati on, as presented in Table 3. The Agency labor rates are from the Office of Perso nnel Management (OPM) 2013 General Schedule, which excludes locality rates of pay. These r ates can be obtained from Salary Table 2015-GS available on the OPM website, http://www.opm.gov/po licy-data-oversight/payleave/salaries-wages/salary. The government employee l abor rates are $15.94/hour for clerical (GS-8

6, Step 3), $29.46 for technical (GS-12, Step 1), and $39.70/hr for m anagement (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 ar e: 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-forma ldehyde binders at the bonded lines, and we estimate that there will be five existing facilit ies 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 y ear. For the final Wool Fiberglass Manufacturing NESHAP for Area Sources, the components

of the total annual burden attributable to this ICR inc lude reading the area source NESHAP; conducting the performance testing to demonstrate complian ce with the chromium compounds emission limits; reporting the results of those emissi ons 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, prese nted in Table 2 are calculated by adding person-hours per year down e ach column for technical, managerial, and clerical staff, and by adding down the cos t column. The average annual burden for the recordkeeping and reporting requirements in the final ar ea source NESHAP (subpart NN) for the five existing facilities with gas-fired furnaces th at are subject to the Wool Fiberglass Manufacturing NESHAP for Area Sources is 78 person-hours, w ith 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 dow n each column for technical, managerial, and clerical staff, and by adding down the cos t column. (iii) Variations in the annual bottom line. This section does not apply since no significant variation is anticipated.9

(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 res ources expended by persons to generate, maintain, retain, or disclose or provide information t o or for a Federal agency. This includes the time needed to review instructions; develop, acquire, inst all, and utilize technology and systems for the purposes of collecting, validating, and verifying infor mation, processing and maintaining information, and disclosing and providing information; adjus t 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; comple te and review the collection of information;

and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is no t required to respond to a collection of information unless it displays a currentl y 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 b urden, including through the use of automated collection techniques, EPA has established a pub lic docket for this ICR under Docket ID No. EPA-HQ-OAR-2010-1042 which is available for online v iewing at http://www.regulations.gov , or in person viewing at the Air and Radiation Docket a nd 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 Readi ng 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 A ir 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 in dex listing of the contents of the public docket, and to access those documents in the public docket t hat are available electronically. When in the system, select “search,” then key in the Docke t ID Number identified above. Also, you can10

send comments to the Office of Information and Regulato ry 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-2010-1042) in any correspondence.

PART B This section is not applicable because statistical met hods are not used in data collection

associated with the final rule.11TABLE 2. ANNUAL RESPONDENT BURDEN AND COST -- WOOL FIBERGLASS MANUFACTURING NESHAP AREA SOURCESBurden item(A)Personhours peroccurrence(B)No. ofoccurrencesperrespondent(C)Person-hoursperrespondent(C=A*B)(D)Respondentsper year(E)Technicalperson-hoursper year(E=C*D)(F)Managementperson-hoursper year(E*0.05)(G)Clericalpersonhours peryear (E*0.1)(H)Costa, $1. ApplicationsN/A2. Surveys and Studies N/A3. Acquisition, Installation, and Utilization ofTechnology and SystemsN/A4. Reporting RequirementsA. Read instructionsb4 1 8 1.67 13.4 0.7 1.3 $1,111B. Required activitiesc(compliance testing) 0 1 1.67$26,720C. Create informationd8 2 16 1.6726.7 1.3 2.7 $2,209D. Gather existing information N/AE. Write report8 1 8 1.67 13.4 0.7 1.3 $1,1115. Recordkeeping RequirementsA. Read instructions See 4AB. Plan activitiesN/AC. Implement activities N/AD. Develop record system N/AE. Time to enter information 0.5 1 0.5 1.67 0.84 0.05 0.08 $70F. Time to train personnel N/AG. Time to adjust existing ways to comply withpreviously applicable requirementsN/AH. Time to transmit or disclose information 8 1 8 1.67 13.4 0.71.3 $1,111I. Time for auditsN/ATOTAL LABOR BURDEN AND COST (SALARY)67.7 3.5 6.7 $32,334TOTAL NUMBER OF ANNUAL RESPONSES5ANNUAL CAPITAL COSTSdTOTAL ANNUALIZED COSTS$32,334N/A = not applicable.aThis 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 based on the U.S. Departmentof Labor, Bureau of Labor Statistics, Occupational Employment and Wages, May 2015.bAn estimated 5 existing facilities and no new facilities (5total) are expected to have gas-fired furnaces and be subject to subpart NN; the average number expected to readthe rule during the 3-yr compliance period is 5/3 = 1.67.cThe 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.dThere would be no capital costs associated with the reportingand recordkeeping requirements of the final area source NESHAP.123. ANNUAL BURDEN AND COST TO THE AGENCY ---- WOOL FIBERGLASS MANUFACTURING NESHAP AREA SOURCESBurden item(A)Person-hoursper occurrence(B)Occurrencesper respondent(C)EPA personhours/year(C=A*B)(D)Facilitiesper year(E)Technicalpersonhours/year(E=C*D)(F)Managementperson-hours/year(F=0.05*E)(G)Clerical personhours/year(G=0.1*E)(H)Costa, $Report Review:Review compliance test reports for Crcompounds for gas-fired furnaces8 1 8 1.67 13.4 0.7 1.3 $917TOTAL BURDEN AND COST $917aThis ICR uses the following average hourly labor rates: $63.52for managerial (GS-13, Step 5), $47.14 (GS-12, Step 1) for technical, and $25.50 (GS-6, Step 3) for clerical.These rates are from the Office of Personnel Management (OPM) 2013 General Schedule, which excludes locality rates of pay.13ATTACHMENT 1. INFORMATION REQUIREMENTS ---- WOOL FIBERGLASS MANUFACTURING NESHAP AREA SOURCESRequirement Citation for existing sources Citation fornew sources General Provisions citationCr 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/APlansOperation and Maintenance Plan N/A N/A N/ARecordsMonitoring/inspection information § 63.883 § 63.883 N/AReports§ 63.886(b) and (c) § 63.886(b) and (c) 40 CFR 63.10(e)