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SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR MINERAL WOOL PRODUCTION 

PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection.

“National Emission Standards Mineral Wool Production.” This is a new information 

collection request (ICR), and the EPA tracking number is 1799.06. 

(b) Short Characterization.

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

Mineral Wool Production NESHAP (40 CFR part 63, subpart DDD). 

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

mineral wool production facilities. There are an estimated 7 facilities subject to the Mineral 

Wool Production NESHAP. The affected source is any mineral wool production facility that is 

engaged, either in part or in whole, in the production of mineral wool and that is located at a 

plant site that is a major source as defined in 40 CFR part 63.2.

The proposed amendments would require HAP-specific emission limits for COS, HF, and 

HCl from cupolas; revised emission limits for formaldehyde and new emission limits for phenol, 

and methanol from 3 new subcategories of combined collection/curing operations; and new 

requirements for periods of startup and shutdown. The proposed emission limits for COS can be 

met by cost effective measures such as changes in raw materials and 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.
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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 

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

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact Organization Telephone No.

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

Lee Houlditch Amerrock Products LP 205-516-9164

John Dolin Industrial Insulation Group LLC 281-605-4630

Tom Lund Isolatek International 260-356-2040 

ext. 328

Christopher Bullock Rock Wool Mfg Co. 205-699-6121

Steve Edris Thermafiber, Inc.260-563-2111 

ext. 224

John Bolden USG Interiors 312-436-5587
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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 DDD are owners or operators of any existing or new 

facility engaged in mineral wool production operations. Mineral wool production facilities are 

primarily classified under NAICS code 327993, Mineral Wool Manufacturing.

There are an estimated 7 facilities that would be subject to the proposed amendments to 

the NESHAP. No new mineral wool production 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 Mineral Wool Production source category.
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(ii) Respondent Activities. The respondent activities that will be required by the 

proposed amendments to the Mineral Wool Production NESHAP are identified in Table 3 and 

are introduced in section 6(a).

(iii) Summary of Requirements. EPA is including in Table 2 an estimate of the burden 

associated with performing an affirmative defense. EPA is providing this as an illustrative 

example of the potential additional administrative burden a source may incur to assert in an 

Affirmative Defense in response to an action to enforce the standards set forth in the applicable 

subpart. 

This illustrative estimate is not considered a duplicate estimate of cost under the General 

Duty to Minimize Emissions clause under 63.6(e)(1)(i), which states: “At all times, the owner 

and operator must operate and maintain any affected source, including associated air pollution 

control equipment and monitoring equipment, in a manner consistent with safety and good air 

pollution control practices for minimizing emissions. Determining whether such operation and 

maintenance procedures are being used will be based on information available to the 

Administrator which may include, but is not limited to, monitoring results, review of operation 

and maintenance procedures, review of operation and maintenance records, and inspection of the 

source.” 

To provide the public with an estimate of the relative magnitude of the burden associated 

with an assertion of the affirmative defense position adopted by a source, EPA provides an 

administrative adjustment to this ICR that estimates the costs of the notification, recordkeeping 

and reporting requirements associated with the assertion of the affirmative defense. EPA’s 

estimate for the required notification, reports and records, including the root cause analysis, 

associated with a single incident totals approximately $3,141 and is based on the time and effort 

required of a source to review relevant data, interview plant employees, and document the events 

surrounding a malfunction that has caused an exceedance of an emission limit. The estimate also 

includes time to produce and retain the records and reports for submission to EPA. EPA 

provides this illustrative estimate of this burden because these costs are only incurred if there has 

been a violation and a source chooses to take advantage of the affirmative defense. 

In this source category, it is unlikely that a control device malfunction would cause an 
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exceedence of any emission limit. For reasons explained in the FRN, we have asserted that 

although a cost for affirmative defense is possible, we believe that malfunctions are unlikely. 

Thus for these source categories, EPA is not assigning any burden associated with affirmative 

defense.

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

Information Management

(a) Agency Activities.

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

Production NESHAP are provided in Table 4 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 mineral wool 

production operations as a firm having no more than 500 employees. There are six companies 

operating the 7 mineral wool production facilities and five of the six companies are small 

businesses. The proposed amendments would result in significant adverse impacts on one of the 

small entities; EPA estimates that one producer will experience an annualized cost of greater than 

six percent of their revenue in the Mineral Wool Production source category. The impacts to 

most producers affected by this proposed rule are annualized costs of less than one percent of 

their revenues using the most current year available for revenue data. The proposed amendments 
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would and 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 3 for the Mineral Wool Production 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 Mineral Wool 

Production NESHAP are shown in Table 3. 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 Mineral Wool 

Production NESHAP are presented in Table 3. 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 2010 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 $36.97/hour. Wages for management labor are taken from "Glass and Glass 

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

$47.38/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 
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to represent respondent labor costs are: technical at $77.64 /hour, management at $99.50 /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 proposed 

amendments to the Mineral Wool Production NESHAP. The proposed amendments would

require affected facilities to purchase new monitoring systems and conduct new performance 

testing. 

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

collection requirements of the proposed amendments to the Mineral Wool Production NESHAP.

(iv) Affirmative Defense/Root Cause Analysis/Malfunction Costs. EPA’s estimate for a 

root cause analysis is based on general experience to calculate the time and effort required of a 

source to review relevant data, interview plant employees, and reconstruct the events prior to a 

malfunction in order to determine primary and contributing causes. The level of effort also 

includes time to produce and retain the report in document form so that the source will have it 

available should EPA or state enforcement agencies ever request to review it.

TABLE 2. COST ESTIMATE FOR ROOT CAUSE ANALYSIS

Personnel 

Number of 

Personnel 

Time 

Requirement 

(hours)

Total 

Hours

Hourly Rate 

($/hr) Total

Technical Personnel 3 6 18 98.20 $1,768

Managerial Personnel 2 6 12 114.49 $1,374

Total 5 30 $3,141

 (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 
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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 4.

The Agency labor rates are from the Office of Personnel Management (OPM) 2010

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/10tables/pdf/gs_h.pdf.

The government employee labor rates are $15.63/hour for clerical (GS-6, Step 3), $28.88 for 

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 7 existing facilities that are subject to the Mineral Wool 

Production NESHAP. No new sources are expected during the next 3 years. Consequently, the 

average number of mineral wool respondents during the 3-year period of this ICR is 2.33.

For the proposed amendments to the Mineral Wool Production 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 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. The average annual burden 

for the recordkeeping and reporting requirements in the proposed amendments to subpart DDD

for the 7 existing facilities that are subject to the Mineral Wool Production NESHAP is 
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106.5 person-hours, with an annual average cost of $85,348. No capital costs would be expected

for the proposed amendments.

(ii) The Agency tally. The average annual Federal Government cost is $970 for 

21.5 hours for the proposed amendments to subpart DDD. The bottom line Agency burden hours

and costs presented in Table 4 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.

(f) Reasons for Change in Burden.

EPA provides an adjustment to this ICR that estimates the costs of the notification, 

recordkeeping and reporting requirements associated with the assertion of the affirmative 

defense. EPA’s estimate for the required notification, reports and records, including the root 

cause analysis, associated with a single incident totals approximately [ $3,141 ] and is based on 

the time and effort required of a source to review relevant data, interview plant employees, and 

document the events surrounding a malfunction that has caused an exceedance of an emission 

limit. The estimate also includes time to produce and retain the records and reports for 

submission to EPA. 

For the purpose of estimating the annual burden in this category, EPA is attributing no 

instances of affirmative defense. The costs below are illustrative of affirmative defense, which 

we see sources having no need for, given the technical reasons explained in the FRN.

(g) Burden Statement

The average annual respondent burden for the proposed amendments to the Mineral Wool 

Production NESHAP is estimated at 46 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 
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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-2010-1041, 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 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-2010-1041) in any correspondence.
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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 3. ANNUAL RESPONDENT BURDEN AND COST -- AMENDMENTS TO MINERAL WOOL PRODUCTION 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 instructionsb4 1 8 2.33 18.6 1 1.9 $1,625

B. Required activitiesc (compliance testing) $33,143 1 2.33 $77,223

C. Create informationc8 2 16 2.33 37.2 2 3.8 $3,250

D. Gather existing information N/A

E. Write report 8 1 8 2.33 18.6 1 1.9 $1,625

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 2.33 18.6 1 1.9 $1,625

I. Time for audits N/A

TOTAL LABOR BURDEN AND COST (SALARY) 93 4 9.5 $85,348

TOTAL NUMBER OF ANNUAL RESPONSES 7

ANNUAL CAPITAL COSTSd

TOTAL ANNUALIZED COSTS $85,348

N/A = not applicable.

a

 This ICR uses the following labor rates: $99.50 for managerial labor, $77.64 for technical labor, and $42.76 for clerical labor. These rates are based on the U.S. Department of 

Labor, Bureau of Labor Statistics, Occupational Employment and Wages, May 2010.

b There are an estimated 7 existing facilities; no new facilities are expected; the average number expected to read the rule during the 3-yr compliance period is 7 / 3 = 2.33.

cThe average facility cost for COS, HF, HCl, formaldehyde, phenol, and methanol testing was calculated to be $232,000 / 7 facilities = $33,143.

d

 There would be no capital costs associated with the reporting and recordkeeping requirements of the proposed amendments.
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TABLE 4. ANNUAL BURDEN AND COST TO THE AGENCY ---- AMENDMENTS TO MINERAL WOOL PRODUCTION 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)

Cost

a

, $

Report Review:

 Review compliance test reports for COS, 

HF, and HCl for cupolas and 

formaldehyde, phenol, and methanol for 

collection/curing operationsb

8 1 8 2.33 18.6 1 1.9 $970

TOTAL BURDEN AND COST $970

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) 2010 General Schedule, which excludes locality rates of pay.

b Assumes Agency will review all of the annual reports - including the COS, HF, HCl, formaldehyde, phenol, and methanol emissions testing.
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ATTACHMENT 1. INFORMATION REQUIREMENTS ---- AMENDMENTS TO MINERAL WOOL PRODUCTION NESHAP

Requirement Citation for existing sources Citation for new sources General Provisions citation

COS, HF, and HCl limit for cupolas § 63.1178(a)(2)(i) § 63.1178(a)(2)(ii)

HF limit for cupolas § 63.1178(a)(3) § 63.1178(a)(3)

§ 63.1178(a)(4) § 63.1178(a)(4)

Formaldehyde limit for combined 

collection/curing operations 

§ 63.1179 § 63.1179

Phenol limit for combined 

collection/curing operations 

§ 63.1179 § 63.1179

Methanol limit for combined 

collection/curing operations 

§ 63.1179 § 63.1179

Notifications § 63.1191 § 63.1191 N/A

Plans

 Operation and Maintenance Plan N/A N/A N/A

Records

 Monitoring/inspection information § 63.1192 § 63.1192 N/A

Reports § 63.1193 § 63.1193 40 CFR 63.10(e)