SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Wet-Formed Fiberglass Mat Production (40 CFR Part 63, Subpart HHHH)

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Wet-formed Fiberglass Mat Production (40 CFR Part 63, Subpart HHHH) 

(Renewal), ICR 1964.05, OMB Control Number 2060-0496. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Wetformed Fiberglass Mat Production (40 CFR part 63, subpart HHHH) were proposed on May 26, 

2000 (65 FR 34251), and promulgated on April 11, 2002 (67 FR 17823). These standards apply 

to new and existing component processes at industrial facilities that manufactured Wet-formed 

fiberglass mat, including: preparation of glass fibers, formation of fibers into a fiberglass mat, 

saturation with urea-formaldehyde binder solution, curing and drying the binder-coated 

fiberglass mat, cooling the mat, and trimming, cutting, and packaging. 

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in 

the operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U. S.

Environmental Protection Agency (EPA) regional office.

 Based on our consultations with industry representatives, there is an average of one 

production line per facility.

Over the next three years, an average of 14 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. 

The active (previous) ICR had the following Terms of Clearance (TOC):

“This ICR renewal is approved for three years. The Agency is 

reminded to review and update estimates of respondent universe 

and burden as appropriate prior to resubmission of this ICR.”
2

EPA has addressed each item of concern in the TOC by consulting with industry on the 

respondent universe and burden, and by updating the burden calculation using the most recent 

labor rates. 

The “Affected Public” is owners and operators of wet-formed fiberglass mat production. 

The burden to the “Affected Public” may be found below in Table 1; Annual Respondent Burden 

and Cost: NESHAP for Wet-formed Fiberglass Mat Production (40 CFR Part 63, Subpart 

HHHH) (Renewal). The burden to the “Federal Government” burden is attributed entirely to 

work performed by federal employees or government contractors; this burden may be found 

below in Table 2: Average Annual EPA Burden and Cost: NESHAP for Wet-formed Fiberglass 

Mat Production (40 CFR Part 63, Subpart HHHH) (Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, hazardous air pollutant emissions from component 

processes at industrial facilities manufacturing wet-formed fiberglass mats cause or contribute to 

air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, 

the NESHAP were promulgated for this source category at 40 CFR part 63, subpart HHHH.

2(b) Practical Utility/Users of the Data
3

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which where promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor. 

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard is being met. 

The performance test may also be observed.

The required semiannual compliance certifications are used to determine periods of 

excess emissions, identify problems at the facility, verify operation/maintenance procedures and 

for compliance determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart

HHHH.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency 

can be sent to the Administrator in lieu of the report required by the Federal standards. 

Therefore, no duplication exists.

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

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (76 FR 26900) on May 9, 2011. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projection of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping 
4

and reporting provisions in the standard, is the Online Tracking Information System (OTIS) 

which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database 

for the collection, maintenance, and retrieval of all compliance data. The growth rate for the 

industry is based on our consultation with the Agency’s internal industry experts. 

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed. In developing 

this ICR, we contacted: 1) the Nonwoven Engineers and Technologist (NET), a division of the 

Technical Association of the Pulp and Paper Industry (TAPPI), at (828) 439-3226; 2) and GAF,

at (972) 851-0408. 

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any 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 (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 
5

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners or operators 

of wet-formed fiberglass mat production, which provides the substrate for several roofing 

products. The Standard Industrial Classification (SIC) Code for wet-formed fiberglass mat 

production is classified under SIC 3329325, a subset of SIC 3329, Pressed and Blown Glass, Not 

Elsewhere Classified, which corresponds to the North American Industrial Classification System 

(NAICS) code 327212, Non-woven Fabric Mills.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NESHAP for Wetformed Fiberglass Mat Production (40 CFR Part 63, Subpart HHHH). 

A source must make the following reports:

Notifications

Initial notification requirements 63.9(b)(1)

Notification of compliance status when a source becomes subject 

to the standard

63.9(h), 63.3000(b)

Notification that source is subject to special compliance 

requirements, if applicable

63.9(d)

Notification of performance test 63.7(b), 63.9(e)

Rescheduled of performance test 63.7(b)(2)

Demonstration of continuous monitoring system 63.9(g)

Change in information already provided 63.9(j)

Request for an extension of compliance with relevant standard 63.9(c)

Reports

Application for approval of the construction or reconstruction of 63.5(6)(d)
6

Reports

a new major affected source, or reconstruction of a major 

affected source

Performance test results 63.10(d)(2), 63.3000(d)

Startup, shutdown and malfunction plan 63.6(e)(3)

Periodic startup, shutdown and malfunction reports 63.10(d)(5)(i), 63.3000(e)

Progress reports for compliance extension (if applicable) 63.6(i)

Semiannual compliance reports 63.3000(b)

A source must keep the following records:

Recordkeeping

Startup, shutdown and malfunction plan 63.6(e)(3)

All reports and notifications 63.10(b)(1)

Records of startup, shutdown, and malfunction of process 

equipment

63.10(b)(2)(i), (iv-v)

Records of malfunctions of air pollution control equipment 63.10(b)(2)(ii)

Any applicability determination that demonstrates why owner or 

operator believes source is unaffected

63.10(b)(3)

Records of maintenance of air pollution control equipment 63.10(b)(2)(iii)

Records of flow monitoring system performance evaluations, 

malfunctions, calibrations, and adjustments

63.10(b)(2)(vi-xi), 

63.10(c)

Documentation required for waiver of recordkeeping or reporting 

requirements (if applicable)

63.10(b)(2)(xii)

Documentation of initial notifications 63.10(b)(2)(xiv)

Five-year retention of records 63.10(b)(1), 63.2999(a)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

Also, regulatory agencies, in cooperation with the respondents, continue to create 

reporting systems to transmit data electronically. However, electronic reporting systems are still 

not widely used. At this time, it is estimated that approximately 10 percent of the respondents 

use electronic reporting. 

(ii) Respondent Activities
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Respondent Activities

Read instructions.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of 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.

Transmit, or otherwise disclose the information.

Currently, sources are using monitoring equipment that provide parameter data in an 

automated way e.g., continuous parameter monitoring system. Although personnel at the source 

still need to evaluate the data, this type of monitoring equipment has significantly reduced the 

burden associated with monitoring and recordkeeping. 

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

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the OTIS. 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. Data and 

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

enforcement programs. The report of annual compliance tests is used for problem identification, 

as a check on source operation and maintenance, and for compliance determinations.
8

Information contained in the reports is entered into OTIS which is operated and 

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

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

government-owned facilities. EPA uses OTIS 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.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the

development of the regulation. Two of the 14 existing facilities subject to this NESHAP are 

classified as small businesses under the Small Business Administration definition (750 or fewer 

company employees). Due to technical considerations involving the process operations and the 

types of control equipment employed, the recordkeeping and reporting requirements are the same 

for both small and large entities. The Agency considers these to be minimum requirements 

needed to ensure compliance and, therefore, cannot reduce them further for small entities. 

To the extent that larger businesses can use economies of scale to reduce their burden, the 

overall burden will be reduced. 

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost: NESHAP for Wet-formed 

Fiberglass Mat Production (40 CFR Part 63, Subpart HHHH) (Renewal). 

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The 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.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 3,421 ( Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 
9

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.42 ($57.82 + 110%) 

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

September 2011, Table 2. “Civilian Workers, by occupational and industry group”. The rates are 

from column 1, “Total compensation”. The rates have been increased by 110 percent to account 

for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The only costs to the regulated industry resulting from information collection activities 

required by the subject standard are labor costs. There are no capital/startup or operation and 

maintenance costs. 

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs

The only type of industry costs associated with the information collection activity in the 

regulations is labor costs. There are no capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$23,038. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2011 General Schedule,
10

which excludes locality, rates of pay. The rates have been increased by 60 percent to account 

for the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost: NESHAP for Wetformed Fiberglass Mat Production (40 CFR Part 63, Subpart HHHH) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

14 existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 14 per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

Respondents That Submit Reports

Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 14 0 0 14

2 0 14 0 0 14

3 0 14 0 0 14

Average 0 14 0 0 14

1

New respondent include sources with constructed, reconstructed and modified affected facilities. 

.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 14.

The total number of annual responses per year is calculated using the following table:

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents 

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses 

E=(BxC)+D
11

Total Annual Responses

Initial Notifications 0 5 0 0

Performance test reports 0 1 0 0

Semiannual compliance 

reports 14 2 0 28

Startup, shutdown and 

malfunction reports 2 2 0 4

Total 32

The number of Total Annual Responses is 32.

The total annual labor costs are $327,771. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost: NESHAP for Wet-formed 

Fiberglass Mat Production (40 CFR Part 63, Subpart HHHH) (Renewal). 

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2 (below), respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 3,421 at a cost of $327,771. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost: NESHAP for 

Wet-formed Fiberglass Mat Production (40 CFR Part 63, Subpart HHHH) (Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 107 hours per response.

There are no capital/startup and O&M costs to the regulated entity. 

(ii) The Agency Tally

The average annual Agency burden and cost over the next three years is estimated to be 

511 labor hours at a cost of $23,038. See below Table 2: Average Annual EPA Burden and 

Cost: NESHAP for Wet-formed Fiberglass Mat Production (40 CFR Part 63, Subpart HHHH) 

(Renewal).

6(f) Reasons for Change in Burden

There is an adjustment increase in the total estimated burden hours and costs for both the 

respondents and the Agency as currently identified in the OMB Inventory of Approved Burdens. 

This increase is not due to any program changes. The increase in the burden and cost reflects the 

time and cost to conduct performance tests, which is required every five years of the rule, and to 
12

review test results. In addition, this ICR uses updated labor rates in estimating the costs for the 

respondents and the Agency.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 107 hours per response. 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 valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

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

burden estimates, and any suggested methods for minimizing respondent burden, including the 

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

Docket ID Number EPA-HQ-OECA-2011-0250. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the 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 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 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 docket center is (202) 566-1752. 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 EPA Docket ID 

Number EPA-HQ-OECA-2011-0250 and OMB Control Number 2060-0496 in any

correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
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Table 1. Annual Respondent Burden and Cost: NESHAP for Wet-formed Fiberglass Mat Production (40 CFR Part 63, Subpart

 HHHH) (Renewal)

Burden item (A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours per 

year

(Ex0.1)

(H)

Cost, $ b

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, Installation, and Utilization 

of Technology and Systems

N/A

4. Reporting Requirements

A. Read instructions 1 1 1 0 0 0 0 $0 

B. Required activities:

 i. Initial performance tests: c  200 1 200 0 0 0 0 $0 

 ii. 5-year performance test c 221 1 221 4.67 1,032.07 51.60 103.21 $113,725.58

 iii. Repeat of performance test c 221 1 221 0.93 205.53 10.28 20.55 $22,648.03

 iv. Monitoring of operations and 

equipment: d

 See 5E

 v. Operation, maintenance, monitoring 

plan

40 1 40 0 0 0 0 $0 

 vi. Startup, shutdown, malfunction plan 40 1 40 0 0 0 0 $0 

 D. Gather Existing Information See 4B,

and 5E

 E. Write report a, c

 i. Notification of compliance status 2 1 2 0 0 0 0 $0 

 ii. Notification of actual startup 2 1 2 0 0 0 0 $0 

 iii. Notification of construction/

reconstruction

2 1 2 0 0 0 0 $0 
14

Table 1. Annual Respondent Burden and Cost: NESHAP for Wet-formed Fiberglass Mat Production (40 CFR Part 63, Subpart

 HHHH) (Renewal)

Burden item (A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours per 

year

(Ex0.1)

(H)

Cost, $ b

 iv. Notification of performance test 2 1 2 4.67 9.34 0.47 0.93 $999.36

 v. Notification of actual startup 2 1 2 0 0 0 0 $0

 vi. Reports of performance test 4 1 4 4.67 18.68 0.93 1.87 $2,057.99

 vii. Report of monitoring exceedances e 16 2 32 11.2 358.4 17.92 35.84 $39,492.82

 viii. Report of no excess emission e

8 2 16 2.8 44.8 2.24 4.48 $4,936.60

 ix. Startup, shutdown, malfunction 

report f

8 2 16 2 32 1.6 3.2 $3,526.14

Subtotal for Reporting Requirements 1,955.94

5. Recordkeeping Requirements

 A. Read instructions See 4A

 B. Plan activities See 4B

 C. Implement activities See 4B

 D. Develop record system N/A

 E. Time to enter and transmit all 

information required by the rule g

1.75 52 91 14 1,274 63.7 127.4 $140,384.60

 F. Time to train personnel N/A

 G. Time for audits N/A

Subtotal for Recordkeeping Requirements 1,465.1

Subtotals Labor Burdens and Costs 2,974.82 148.74 297.48 $327,753.12

TOTAL LABOR BURDEN AND COSTS 

(Rounded) 3,421 $327,771
15

Assumptions:

a

 There are an estimated 14 respondents (i.e., wet-formed fiberglass mat production facilities), 13 with one production line and one with two lines, which are subject to this 

standard. We have assumed that there will be no new lines constructed over the three year period of this ICR. 

b

This ICR uses the following labor rates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 per hour 

for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, “Table 2.Civilian Workers, by occupational and 

industry group.” The rates are from column 1, “Total compensation”. The rates have been increased by 110% to account for the benefit packages available to those 

employed by private industry.

c We have assumed that all sources are in compliance with initial rule requirements including the initial performance test. The rule requires a performance test every five 

years since the initial test was conducted, which is applicable for this ICR renewal. We have estimated that each performance test will take approximately 21 hours to 

complete it since sources will be using EPA Method 316 to measure formaldehyde and applicable test methods specified in the NESHAP to determine resin freeformaldehyde content and the loss-on-ignition of the fiberglass mat. In addition, we have assumed that it will take approximately 200 hours to conduct the pretest survey, 

equipment calibration, and sample analysis and report preparation for a total of 221 hours per performance test. We have further assumed that 20 percent of the

performance tests fail and will have to be repeated. There are an estimated 14 respondents. Averaged over the 3-year period of this ICR, the number of respondents per year 

conducting the performance test is 4.67. 

d

 Monitoring of operations include: 1) monitoring operating parameters for control equipment (i.e., thermal oxidizer or other control equipment); 2) urea-formaldehyde 

(UF) resin solids application rate; 3) resin-free formaldehyde content; 4) loss-on-ignition; 5) UF-to-latex ratio in the binder; 6) weight of the final mat product per 

roofing square; and 7) average nonwoven wet-formed fiberglass mat production rate (roofing square per hour).

e We have assumed that approximately 80 percent of the 14 respondents (or 11.2) will report no excess emissions twice a year and approximately 20 percent (or 2.8) will 

report no excess emissions twice a year. 

f We have assumed that 2 of the 14 facilities will have a startup, shutdown or malfunction (SSM) that is not managed according to the SSM plan.

g We have assumed it takes each source approximately 1.75 hours per week to record and transmit the information and that a year will consist of 52 weeks.
16

Table 2. Average Annual EPA Burden and Cost: NESHAP for Wet-formed Fiberglass Mat Production (40 CFR Part 63, Subpart 

HHHH) (Renewal)

Activity (A)

EPA personhours per

occurrence

(B)

No. of

occurrences

per plant

per year

(C)

EPA 

personhours per

plant per

year

(C=AxB)

(D)

Plants

per

year a

(E)

Technical

personhours

per year

(E=CxD)

(F)

Management

personhours

per year

(Ex0.05)

(G)

Clerical

personhours per

year

(Ex0.1)

(H)

Cost, $ e

Initial Notifications: applicability, 

performance test, compliance status a 2 3 6 0 0 0 0 $0.00 

Notifications: 5-year performance test, 

compliance status b 2 1 2 4.67 9.33 0.47 0.93 $483.70 

Review reports of excess emissions c

16 2 32 11.2 358.4 17.92 35.84 $18,573.90 

Review reports of no excess emissions c

8 2 16 2.8 44.8 2.24 4.48 $2,321.74 

Review of startup, shutdown, malfunction 

report d 8 2 16 2 32 1.6 3.2 $1,658.38 

TOTAL ANNUAL BURDEN AND COST 

(rounded) 511 $23,038

Assumptions:

a There are an estimated 14 respondents (i.e., wet-formed fiberglass mat production facilities), 13 with one production line and one with two lines, which are subject 

to this standard. We have assumed that all sources are in compliance with initial rule requirements and that there will be no new lines constructed over the three year 

period of this ICR.

b The rule requires a performance test every five years since the initial test was conducted, which is applicable for this ICR renewal. The number of respondents that will 

conduct the performance test, averaged over the 3-year period of this ICR, is 4.67 (14 / 3 = 4.67). 

c We have assumed that approximately 80 percent of the 14 respondents (or 11.2) will report no excess emissions twice a year and approximately 20 percent (or 2.8) 

will report no excess emissions twice a year. 

d We have assumed that two of 14 respondents per year will have a startup, shutdown, or malfunction occurrence that is not managed according to the plan.

e This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate 

of $62.27 (GS-13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS-6, Step 3, $15.63 x 1.6). These rates 

are from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.