
MEMORANDUM

DATE:		January 11, 2018
TO: 		Wet-Formed Fiberglass Mat Production NESHAP Docket 
      Docket ID: EPA-HQ-OAR-2004-0309
SUBJECT:	Cost Impacts of Wet-Formed Fiberglass Mat Production Risk and Technology Review Proposal
Overview
This regulatory action proposes to eliminate the startup, shutdown, and malfunction (SSM) exemption included in the 2002 Wet-Formed Fiberglass Mat Production National Emission Standards for Hazardous Air Pollutants (NESHAP), consistent with the United States Court of Appeals decision in Sierra Club v. EPA 551 F.3d 1019 (D.C. Cir. 2008). Eliminating the SSM exemption will remove the requirements and associated burden for SSM plans and periodic SSM reports.
A one-time burden for reviewing requirements of the amended rule has been estimated.

The adjustments described above are expected to result in a total industry-wide annual cost of $200.

Impacts to Affected Entities

To estimate the costs associated with these changes to recordkeeping and reporting requirements, information previously developed as part of the Information Collection Request (ICR) process was consulted.

The proposed removal of the SSM exemption would result in the emissions standards in the rule applying at all times. Based on discussions with affected entities, we believe facilities are already operating control technologies during all periods of that wet-formed fiberglass mat is being produced and therefore would incur no costs associated with additional operation of controls. We also proposed to eliminate the requirement for the development of a SSM plan as required under 40 CFR 63.2986(g)(3). The 2002 NESHAP required this plan to be developed by the compliance date of April 11, 2005, for existing sources and April 11, 2002 or startup, for new or reconstructed sources, with no requirement for updates to the plan. Because there is no requirement for updates, no cost savings are estimated for the proposed removal of this provision. All affected facilities are anticipated to experience a small cost savings associated with the proposed removal of recordkeeping and reporting requirements specific to SSM events. Currently, facilities are required to maintain SSM records, as outlined under 40 CFR 63.2998(e)(5) and (f), and report on SSM events under 63.3000(c)(5) (iv) and (vii), and 63.3000(e).

Eight hours have been estimated for affected facilities to read and understand the requirements of the amended rule. 
  
Table 2 below summarizes the ICR renewal burden estimates associated with (1) SSM recordkeeping and reporting requirements that this action proposes to eliminate; and (2) review of the amended rule by affected facilities. These figures have been adjusted to reflect seven responding facilities, and updated labor rates have also been used.
Labor rates were updated using the United States Department of Labor, Bureau of Labor Statistics, survey titled May 2016 National Occupational Employment and Wage Estimates United States." The rates are from column 8, "Mean hourly wage." The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.  
Table 1. Wage Rate by Labor Category (2016$)

                               Occupational Code
                       BLS Mean Wage Estimate, in 2016$
                         Loaded Wage (+110%), in 2016$
Technical
                                    51-8090
                                    $30.65
                                    $64.37
Managerial
                                    11-1021
                                    $58.70
                                    $123.27
Clerical
                                    43-6010
                                    $19.39
                                    $40.72

As shown in Table 2, these proposed changes to recordkeeping and reporting requirements are estimated to result in a total industry-wide annual cost of $200.
Table 2. Annual Respondent Burden and Cost (2016$)
                                  Burden Item
                                      (A)
                          Person-Hours per Occurrence
                                      (B)
                  No. of Occurrences per respondent per year
                                      (C)
                         Hours per respondent per year
                                      (D)
                             Respondents per year
                                      (E)
                           Technical Hours per year
                                    (=C*D)
                                      (F)
                           Management Hours per year
                                   (=E*0.05)
                                      (G)
                            Clerical Hours per year
                                   (=E*0.1)
                                      (H)
                                     Cost
                  Startup, shutdown, malfunction report[(a)]
                                      (8)
                                      (2)
                                     (16)
                                      (1)
                                     (16)
                                     (0.8)
                                     (1.6)
                                   ($1,194)
                  Review amended rule requirements [(][b][)]
                                       8
                                       1
                                       8
                                     2.33
                                     18.64
                                     0.93
                                     1.86
                                    $1,390
                             Total Burden and Cost
                                    rounded
                                       
                                       
                                       
                                       
                                     3.03
                                       3
                                     $196
                                     $200
 The currently approved ICR assumed that 15 percent of respondents will have a startup, shutdown, or malfunction occur that is not managed according to the regulation. Given that there are now an estimated 7 affected facilities, this results in an estimate of 1 respondent per year.
 There are an estimated 7 respondents.  Estimate assumes that, on average each year, the number of respondents reviewing the amended rule is 2.33 respondents per year (7 / 3) years = 2.33.
