1 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 Woo l Production

. ” This is a new information collection request (ICR)
, and the EPA tracking number i s 1799.06

. (b) Short Characterization. This ICR covers information collection requirements i n the proposed amendments to the
Mineral Woo l Production NESHAP ( 40 CFR part 63, subpart DDD )

. The p otential respondents are owners or operators of any existing
, new , or reconstructed
mineral woo l production facilities

. The re are an estimated 8 facilities subject to the Mineral

Woo l 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 a nd 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 cupolas to meet emission limits for COS ; 3 new subcategories of combined collection/curing operations to meet revised emission limits for formaldehyde and new emission limits for phenol and methanol ; and affected sources to meet new requirements for period s 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 . T hese 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 C lean Air Act (C AA ) require s 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 ) o f 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 t py of any single HAP and more than 2 5 t py 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 impac ts) 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, processe s, 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 categor y 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 e xisting 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 re levant factors in doing so. Certain records and reports are nec essary for the Administrator to confir m the compliance
status of sources subject to NESHAP
, identify any new or reconstructed s ources 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 reporti ng requirements for t itle V permits are contained in 40 CFR 70.6 and3

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, repo rt,
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 facilitie s, 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 information

gathering 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 w ere developed in consultation with individual companies
, State agencies, and trade association s . 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 N orth A merican Insulation Manufacturers Association 703

- 684

- 0084 Lee Houlditch Amerrock Products LP 205

- 516

- 9164 John Dolin Ind ustrial 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 Inter iors 312

- 436

- 55874

(d) Effects of Less Frequent Collection.
If the relevant information was collected less frequently, the delegated permitting authority (State or EPA) w ill 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 Quest ions. 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/NAIC S Codes

. Potential respondents under s ubpart DDD are owners or operators of any ex isting or new facility engaged in mineral wool production operations

. Mineral wool production facilities are primarily classified under NAICS code 3 2 7 993
, Mineral Wool Manufacturing

. The re are an estimated 7 existing facilities that w ould be subject to th e proposed
amendments to the NESHAP

. In addition, one new mineral wool production facility was recently constructed
, and is expected to be in production during the 3-year period of this ICR. (b) Information Requested. (i) Data Items, Including Recordke eping Requirements. Attachment 1
, Information Requirements, summarize s the data items, including recordkeeping and reporting requirements
, for the Mineral Woo l Production s ource c ategor y

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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 2 an d

are introduced in section 6(a).
5. The Information Collected

– Agency Activities, Collection Methodology, and Information Management (a) Agency Activit ies.
The Agency activities associated with the proposed amendments to the Mineral Woo l
Production NESHAP are provided in Table 3 and are introduced in section 6(c). (b) Collection Methodology and Management

. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs of the delegated permitting authority

. EPA is the permitting authority until the State agency is delegated authority to implement the final
amendments to the rule. Therefore, i nf ormation 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 retriev al 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 r egional offices and EPA headquarters.
EPA and its delegated a uthorities can edit, store, retrieve and analyze the data.6

(c) Small Entity Flexibility. The Small Business Administration defines a small entity engaging in mineral wool prod u ction operations as a firm having no more than 500 employees

. There are six companies operating the 8 mineral wool production facilities and five of the six companies are small
businesses. The proposed amendments would not result in significant adverse impacts on any of
the small entities in the Mineral Woo l Produc tion s ource c ategor y

. 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. T he proposed amendments
would create new requiremen ts for compliance testing f or existing sources and associated notification requirements , recordkeeping, and reporting requirements

. (d) Collection Schedule

. The specific frequency for each information collection activity within this request is
shown in Table 2 for the Mineral Woo l Production S ource C atego ry. 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 2

. 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 2. Because the data are already collected by respondents as part of normal operations
, no res pondent 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 rate s for private industry workers were taken from the United States Department of Labor, Bureau of Labor Statistics, Occupational Employment and Wages, Ma y 20 1 3 available at7

http://www.bls.gov/oe s/current/naics4_327200.htm

. Wages for technical labor are based on

" Glass and Glass Product Manufacturing

– architectural and engineering
, " with a total compensation of $ 38. 03 /hour. Wages for management labor are taken from " Glass and Glass
Product Ma nufacturing

– management, business, and financial
, " with a total compensation of $ 5 2.54 /hour. Wages for clerical labor are based on " Glass and Glass Product Manufacturing

– production, planning, and expediting clerks
, " with a total compensation of $ 19.00 /hour. These rates represent salaries plus fringe benefits and do not include the cost of overhead. An overhead rate of 110 percent is used to account for these costs. The fully

- burdened hourly wage rates used to represent respondent la bor costs are: t echnical at $ 79.86 /hour , management at $ 1 10.33 /hour
, and clerical at $ 39.90 /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 p roposed
amendments to the Mineral Woo l Production NESHAP. The proposed amendments w ould not require affected facilities to purchase new m onitoring systems , but would require all facilities to
conduct new performance testing to demonstrate compliance with the new emission limits

. (i ii ) Annualizing Capital Costs

. No capital costs are associated with the information collection requirements of the proposed amendments to the Mineral Woo l Production NESHAP. (c) Estimating Agency Burden and Cost

. Becaus e 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 w ill 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 sour ces 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 w ill incur are user costs associated with the analysis of the reported information, as presented in Table 3

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The Agency labor rates are from the Office of Personnel Management (OPM) 20 10
General Schedule
, which excludes locality rates of pay. These rates can be obtained from Salary
Table 20 1 3

- GS available on the OPM website, http://www.opm.gov/oca/13tables/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
inc reased 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 Unive rse and Total Burden and Costs

. There are an estimated 7 existing facilities that are subject to the Mineral Wool
Production N ESHAP

. One new source is being constructed and is expected to be completed
within the next 3 years. Consequently, the average nu mber of mineral wool respondents during
the 3

- year period of this ICR is 8 divided by 3 = 2. 67

. For the proposed amendments to the Mineral Woo l Production NESHAP , the components of the total annual burden attributable to this ICR include reading the amend ments to
the NESHAP ; conducting the performance testing to demonstrate compliance with the proposed
emission limits ; and reporting th e results of those emissions tests ; all other recordkeeping and reporting activities are already accounted for in the ICR f or the NESHAP. (e) Bottom Line Burden Hours and Cost Tables. (i) Respondent tally. The bottom line respondent burden hours and costs, presented in
Table 2 are calculated by adding person

- hours per year down each column for technical, managerial, and cler ical 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 8 facilities that are subject to the Mineral Woo l Production NESHAP is 123 person

- hours
, with an annual average cost of $ 2 5
, 8 50 . No capital costs would be expected for the proposed
amendments

. (ii) The Agency tally. The average annual Federal Go vernment cost is $ 1,085 for
25 hours for the proposed amendments to subpart DDD

. The bot tom line Agency burden hours9

and costs presented in Table 3 are calculated by adding person

- hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column. (iii) Variations in the annual bottom line. T his section does not apply since no significant variation is anticipated. (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 proposed amendments to the Mineral Wool
Production NESHAP is estimated at 40 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
i ncludes 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 inform ation; 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 transm it 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 tech niques, 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 Radiatio n 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 holi days. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the10

Air Docket is (202) 566

- 1927

. An e lectronic version of the public docket is available at http://www.regulation s.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,” the n 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 17 th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include th e relevant Docket ID Number ( EPA

- HQ

- OAR

- 2010

- 1041 ) in any c orrespondence.

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 2 . ANNUAL RESPONDENT BURDEN AND COST

– P ROPOSED AMENDMENTS TO MINERAL WOO L 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)

Ma nagement person - hours per year (E*0.05) (G)

Clerical person - hours per year (E*0.1) (H)

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

4. R eporting Requirements A. Read instructions b 8 1 8 2. 67 21.4 1 .1 2.1 $ 1,9 14 B. Required activities c (compliance testing) $ 6
, 1 00 1 2. 67 $ 1 6,287 C. Create information 8 2 16 2. 67 42.8 2 .1 4.3 $ 3, 821 D. Gather existing information N/A E. Write report 8 1 8 2. 67 21.4 1 .1 2.1 $ 1,9 14 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. 67 21.4 1 .1 2.1 $ 1,9 14 I. Time for audi ts N/A TOTAL LABOR BURDEN AND COST (SALARY) 107 5.4 10.6 $ 2 5,850 TOTAL NUMBER OF ANNUAL RESPONSES 8 ANNUAL CAPITAL COSTS d TOTAL ANNUALIZED COSTS $ 2 5
, 8 50 N/A = not applicable.

a T his ICR uses the following labor rates : $ 1 10.33 for manager ial labor, $ 79.86 for technical labor, and $ 39.90 for clerical labor. These rates are based on the U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment and Wages, Ma y 201 3

. b There are an estimated 7 existing facilities and 1 new facility being constructed ; the average number expected to read the rule during the 3

- yr compliance period is 8 / 3 = 2. 67

. c The average facility cost for new COS , HF/HCl, phenol, and methanol testing was calculated to be $ 48,800 / 8 facilities = $ 6
, 1 00

. d There would be no capital costs associated with the reporting and recordkeeping requirements of the proposed amendments

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3 . ANNUAL BURDEN AND COST TO THE AGENCY

-- -- PROPOSED AMENDMENTS TO MINERAL WOOL PRODUCTION NESHAP

Burden item (A) Person

- ho urs per occurrence (B)

Occurrences per respondent (C)

EPA person

hours/year (C=A*B) (D)

Facilities per year (E)

Technical person

hours/year ( E = C * D ) (F)

Management person - hours/year ( F =0.05* E ) (G)

Clerical person

hours/year ( G =0.1* E ) (H)

Cost a , $ Re port Review: Review compliance test reports for COS for cupolas and f

ormaldehyde , phenol, and methanol for collection/curing operations b 8 1 8 2. 67 21.4 1 .1 2.1 $ 1,085

TOTAL BURDEN AND COST $ 1,085

a This ICR uses the followin g average hourly labor rates: $ 62.27 for m anagerial (GS

- 13, Step 5), $4 6.21 (GS

- 12, Step 1 ) for technical
, and $2 5.01 (G S

- 6, Step 3) for c lerical. These rates are from the Office of Personnel Management (OPM) 20 1 2 General Schedule
, which excludes locality rates of pay

. b Assumes Agency will review all of the annual reports

- including the new COS, phenol, and methanol emissions testing

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ATTACHMENT 1. INFORMATION REQUIREMENTS

-- -- PROPOSED AMENDMENTS TO MINERAL WOO L PRODUCTION NESHAP

Requirement Citation for exis ting sources Citation for new sources General Provisions citation COS limit for cupolas § 63. 1178 (a)( 2 ) (i) § 63. 1178(a)(2)(ii) Formaldehyde limit for combined collection/curing operations § 63. 1179 § 63. 1179
Phenol limit for combined collection/cur

ing 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 inf ormation § 63. 1192 § 63. 1192 N/A Reports § 63. 1193 § 63. 1193 40 CFR 63.10 (e)