1 SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR WOOL FIBERGLASS MANU FACTURING AT MAJOR 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.” 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 amendments to the Wool Fiberglass Manufacturing NESHAP (40 CFR part 63, subpart NNN). 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 NNN, the following sources at a Wool Fiberglass Manufacturing faci lity are covered: each glass-melting furnace and each flame attenuation (FA) manufacturing lin e 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 major sourc es of HAP emissions and subject to subpart NNN requirements. (We also know that some of the 10 fac ilities have switched binders on some, but not all of their manufacturing lines.) The final NESHAP amendments would require gas-fired glass-m elting furnaces to meet new chromium compound emission limits and revised particula te emission limits for all glassmelting furnaces; revised emission limits for formaldeh yde and new emission limits for phenol, and methanol from FA manufacturing lines; and new requirement s for periods of startup and shutdown. The final NESHAP amendments would require gas-fir ed glass-melting furnaces to meet emission limits for chromium compounds which may b e met by shortening the furnaces’ operational life, pollution prevention measures (i.e., r aw material substitution), or changing the2

brick refractories in the glass-melting furnaces. The f inal emission limits for FA lines are currently being met by all facilities. These amendments are expl ained further in the following paragraphs. The information collection requirements associated wit h the final 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 regula tion under CAA section 112(c). A major source is a stationary source that emits or has the po tential to emit more than 10 tons per year (tpy) of any single HAP or more than 25 tpy of any combi nation of HAP. An area source is a stationary source that is not a major source (i.e., a n 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 techn ology-based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, energy requirements, and non-air quality health and environmenta l impacts) and are commonly referred to as maximum achievable control technology (MACT) standa rds. 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 techno logies)” no less frequently than every 8 years. In addition, section 112(f) of the CAA requires EP A to determine for source categories subject to certain CAA section 112(d) standards whether th e emissions limitations provide an ample margin of safety to protect public health. For MA CT standards for HAP “classified as a known, probable, or possible human carcinogen" that "do n ot 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 stan dards for the source category (or subcategory) as necessary to provide an ample margin of s afety 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.3

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. 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 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 740-827-70874

Contact Organization Telephone No. 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 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 i n 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 n ot 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 oper ators of any existing or new facility engaged in Wool Fiberglass Manufacturing operation s. Wool Fiberglass Manufacturing facilities are primarily classified under NAICS code 327993, M ineral Wool Manufacturing. There are an estimated 10 facilities that would be subjec t to the final amendments to the NESHAP. All 10 facilities manufacture a product on at lea st one FA line and have at least one glass-melting furnace. We are aware of one new wool fi berglass manufacturing facility that was recently constructed, but it is not expected to be a maj or source of HAP emissions; therefore, no new sources are expected during the 3-year period of this IC R. (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 amendments to the Wool Fiberglass Manufacturing NESHAP a re identified 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 amen dments to the Wool Fiberglass Manufacturing NESHAP are provided in Table 3 and are introduc ed in section 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 aut hority to implement the final amendments to the rule. Therefore, information conta ined in any report submitted to the Regional Administrator will be entered into the Air Facility S ystem (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 approx imately 125,000 industrial and government-owned facilities. EPA uses the AFS for tra cking 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, retrie ve and analyze the data. (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 four companies operating the 10 Wool Fiberglass Manufacturing fac ilities that are expected to be affected by this rule and none of the companies are sma ll businesses. The final amendments would not result in significant adverse impacts on any of the small entities. The final amendments6

would create new requirements for compliance testing for existing sources and associated notification requirements, recordkeeping, and reporting requir ements. (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 amendments t o the Wool Fiberglass Manufacturing NESHAP are shown in Table 2. These number s were derived from estimates based on EPA’s experience with other standards. No burde n estimates are provided for new sources because no new facilities are expected to becom e affected sources during the 3-year period of this ICR. (b) Estimating Respondent Costs.

The information collection activities for the fina l amendments to the Wool Fiberglass Manufacturing NESHAP are presented in Table 2. Because th e data are already collected by respondents as part of normal operations, no respondent de velopment 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 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 e ngineering," with a total compensation of $34.74/hour. Wages for management labor are taken from "Glass and Glass Product Manufacturing – management occupations," with a tota l 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 to7

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 c ollection requirements of the final amendments to the Wool Fiberglass Manufacturing NESHAP. The final amendments do not require affected facilities to purchase new monitoring sy stems, 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 informati on collection requirements for the final amendments to th e 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 recordkeepin g 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 inform ation 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 occ ur incidentally as part of the periodic inspection of sources that is part of EPA’s overall co mpliance 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 reporte d information, as presented in Table 3. The Agency labor rates are from the Office of Perso nnel Management (OPM) 2015 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.o pm.gov/policy-data-oversight/payleave/salaries-wages/salary-tables/pdf/2015/GS_h.pdf. The gove rnment employee labor rates are $15.94/hour for clerical (GS-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 b y 60 percent to include fringe benefits8

and overhead. The fully-burdened wage rates used to represen t 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 ph enol-formaldehyde binders at the bonded lines, and we estimate that there will be 10 facilitie s subject to the final amendments. No new major sources are expected during the next 3 years. Conse quently, 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 final amendments to the Wool Fiberglass Manufa cturing NESHAP, the components of the total annual burden attributable to th is ICR include reading the amendments to the NESHAP; conducting the performance testing to demonst rate compliance with the final emission limits; and reporting the results of those emi ssions tests; all other recordkeeping and reporting activities are already accounted for in the IC R 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 fina l amendments to subpart NNN for the 10 existing facilities that are subject to the Wool Fib erglass Manufacturing NESHAP is 156 person-hours, with an annual average cost of $46,142. No ca pital costs associated with recordkeeping and reporting would be expected for the final am endments. (ii) The Agency tally. The average annual Federal Government cost is $1,805 for 30.3 hours for the final amendments to subpart NNN. The b ottom line Agency burden hours and costs presented in Table 3 are calculated by adding person-h ours 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.9

This section does not apply because this is a new ICR. (g) Burden Statement The average annual respondent burden for the final amendm ents to the Wool Fiberglass Manufacturing NESHAP is estimated at 156 hours per facility. Burden means the total time, effort, or financial res ources expended by persons to generate, maintain, retain, or disclose or provide info rmation 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, an d verifying information, processing and maintaining information, and disclosing and providing infor mation; adjust the existing ways to comply with any previously applicable instructions and requi rements; train personnel to be able to respond to a collection of information; search data so urces; complete and review the collection of information; and transmit or otherwise disclose the i nformation. 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 respon dent burden, including through the use of automated collection techniques, EPA has establis hed a public docket for this ICR under Docket ID No. EPA-HQ-OAR-2010-1042 which is available for on line viewing 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 Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding lega l holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone n umber for the Air Docket is (202) 566-1927. An electronic version of the public docket is av ailable 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 th e system, select “search,” then key in the

Docket ID Number identified above. Also, you can send comments to the Office of Informat ion10

and Regulatory Affairs, Office of Management and Budget, 725 17 th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include t he relevant Docket ID Number (EPA-HQ-OAR-2010-1042) in any correspondence.

PART B This section is not applicable because statistical me thods are not used in data collection

associated with the final rule.11TABLE 2. ANNUAL RESPONDENT BURDEN & COST FINAL AMENDMENTS TO WOOL FIBERGLASS MANUFACTURING NESHAPBurden 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 instructionsb8 1 8 3.33 26.6 1.3 2.7 $2,201B. Required activities(compliance testing) 0 1 3.33$34,898C. Create information 8 2 16 3.3353.3 2.7 5.3 $4,417D. Gather existing information N/AE. Write report8 1 8 3.33 26.6 1.3 2.7 $2,2015. 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 3.33 1.67 0.83 0.17 $222F. 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 3.33 26.6 1.32.7 $2,201I. Time for auditsN/ATOTAL LABOR BURDEN AND COST (SALARY)134.8 7.4 13.6 $46,142TOTAL NUMBER OF ANNUAL RESPONSES10ANNUAL CAPITAL COSTSdTOTAL ANNUALIZED COSTS$46,142N/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.bThere are an estimated 10 existing facilities; no new facilities are expected; the average number expected to read the ruleduring the 3-yr compliance period is 10/3 = 3.33.cThe average facility cost for new Cr compound, phenol, and methanol testing was calculated to be $104,800/10 facilities = $10,480.dThere would be no capital costs associated with the reporting and recordkeeping requirements of the final amendments.123. ANNUAL BURDEN AND COST TO THE AGENCY ---- FINALAMENDMENTS TO WOOL FIBERGLASS MANUFACTURING NESHAPBurden 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 glass-melting furnaces andformaldehyde, phenol, and methanol forFA manufacturing linesb8 1 8 3.33 26.4 1.3 2.6 $1,805TOTAL BURDEN AND COST $1,805aThis 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) 2015 General Schedule, which excludes locality rates of pay.bAssumes Agency will review all of the annual reports - including the new Cr compounds, phenol, and methanol emissions testing.13ATTACHMENT 1. INFORMATION REQUIREMENTS ---- FINAL AMENDMENTS TO WOOL FIBERGLASS MANUFACTURING NESHAPRequirement Citation for existing sources Citation fornew sources General Provisions citationWork practice standards for HF andHCl emissions for glass furnaces§ 63.1382(a)(1)(iii) and (b)(11) § 63.1382(a)(1)(iii) and (b)(11)PM limit for glass-melting furnaces§ 63.1382(a)(1)(i) § 63.1382(a)(1)(i)Cr compound limit for gas-fired glassmelting furnaces§ 63.1382(a)(1)(ii) § 63.1382(a)(1)(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/APlansOperation and Maintenance Plan N/A N/A N/ARecordsMonitoring/inspection information § 63.1383 § 63.1383 N/AReports§ 63.1386(c) and (d) § 63.1386(c) and (d) 40 CFR 63.10(e)