SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Mineral
Wool
Production
(
40
CFR
part
63,
subpart
DDD)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Mineral
Wool
Production
(
40
CFR
part
63,
subpart
DDD)

1(
b)
Short
Characterization/
Abstract
The
NESHAP
regulations
published
at
40
CFR
part
63,
subpart
DDD
were
proposed
on
May
8,
1997,
and
promulgated
on
June
1,
1999.
These
regulations
apply
to
each
cupola
and/
or
curing
oven
located
at
a
mineral
wool
production
facility
commencing
construction
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
part
63,
subpart
DDD.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
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
sources
subject
to
NESHAP.

Any
owner
or
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
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

Approximately
12
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
there
will
be
no
additional
sources
subject
to
the
regulation
in
the
next
three
years.
It
is
further
assumed
that
there
is
a
total
of
approximately
18
cupolas
operating
at
these
12
sources.
This
information
was
provided
by
the
North
American
Insulation
Manufacturing
Association
(
NAIMA).
All
but
two
of
the
12
sources
are
members
of
NAIMA.

The
Office
of
Management
and
Budget
(
OMB)
approved
the
currently
active
information
collection
request
(
ICR)
without
any
"
Terms
of
Clearance."

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
2
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
or
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,
particulates
and
formaldehyde
emissions
from
the
production
of
mineral
wool
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
DDD.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
particulates
and
formaldehyde
emissions
from
mineral
wool
production
facilities
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
particulates
and
formaldehyde
from
Mineral
Wool
Production
are
the
result
of
operation
of
the
cupola
and
curing
ovens.
This
standard
relies
on
a
fabric
filter
for
particulate
emission
control
for
cupolas
and
a
thermal
incinerator
for
formaldehyde
control
for
curing
ovens.
The
notifications
required
in
the
applicable
regulations
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,
and
leaks
are
being
detected
and
repaired
and
the
regulations
are
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
This
standard
requires
respondents
to
install
fabric
filter
bag
leak
detection
systems
and
initiate
corrective
action
procedures
in
the
event
of
an
operating
problem.
Failure
to
initiate
corrective
actions
within
1
hour
of
the
alarm
would
constitute
a
violation
of
the
emissions
limit.
3
The
standards
also
require
respondents
to
continuously
monitor
and
record
the
operating
temperature
of
each
thermal
incinerator.
An
average
temperature
in
any
3­
hour
period
that
falls
below
the
average
established
during
the
initial
performance
test
is
considered
a
violation
of
the
applicable
emission
standard.
Additionally,
all
respondents
are
required
to
continuously
monitor
and
record
the
cupola
production
(
melt)
rate,
and
respondents
with
affected
curing
ovens
are
required
to
monitor
and
record
the
formaldehyde
content
of
each
binder
formulation
used
to
manufacture
bonded
products.
These
requirements
pose
no
additional
burden
upon
the
industry
because
cupola
melt
rate
and
binder
formulation
are
currently
monitored
and
recorded
as
customary
business
practices.
Monitoring
of
the
melt
rate
(
i.
e.,
amount
of
rock
and
slag
charged
into
the
cupola)
is
necessary
to
maintain
the
proper
raw
materials
ratio.
Monitoring
of
binder
formaldehyde
content
is
necessary
to
ensure
product
specifications,
which
include
binder
formulation,
are
being
achieved.
Respondents
would
be
required
to
maintain
records
of
this
specific
information
to
ensure
that
the
standards
are
being
achieved
and
maintained.

The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping,
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
DDD.

3(
a)
Nonduplication
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
(
68
FR
27059)
on
May
19,
2003.
No
comments
were
received
on
the
4
1
This
standard
applies
to
cupolas
and
curing
ovens
located
at
mineral
wool
production
facilities.
However,
for
this
ICR
it
is
assumed
that
no
additional
equipment
is
needed
to
meet
the
monitoring
requirements
for
the
curing
ovens.
Therefore,
capital
costs
and
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
associated
only
with
the
cupolas,
specifically
the
capital
cost
and
O&
M
costs
associated
with
the
installation
and
operation
of
a
baghouse
leak
detection
system.
burden
published
in
the
Federal
Register.

3(
c)
Consultations
In
estimating
the
affected
number
of
sources
and
the
growth
rate
of
mineral
wool
production
facilities
subject
to
this
standard,
EPA
contacted
Angus
Crane
of
the
North
American
Insulation
Manufacturers
Association
(
NAIMA)
at
(
703)
684­
0084.
All
but
two
of
the
12
mineral
production
facilities
subject
to
this
standard
are
members
of
NAIMA.
Therefore,
NAIMA
was
able
to
provide
us
with
accurate
estimates
regarding
the
number
of
existing
facilities,
the
number
of
affected
units
located
at
these
facilities
and
the
predicted
growth
rate
of
the
industry
over
the
next
three
years.
NAIMA
indicated
that
there
are
currently
12
mineral
wool
production
plants
located
in
the
United
States.
There
is
a
total
of
approximately
18
affected
units
(
e.
g.,
cupolas)
1
located
at
these
plants.
Due
to
increased
competition
from
the
cellulose
insulation
manufacturing
industry,
particularly
in
the
mobile
home
production
sector,
NAIMA
estimates
that
there
will
be
no
growth
in
the
mineral
wool
production
industry
over
the
next
three
years.

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
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
Section
1320.5.

These
standards
require
affected
facilities
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.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
5
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

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
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
mineral
wool
production
facilities.
The
SIC
(
United
States
Standard
Industrial
Classification)
code
for
the
respondents
affected
by
the
standards
is
SIC
3296
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
code
327993
for
mineral
wool
production
facilities.

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
NESHAP
for
Mineral
Wool
Production
(
40
CFR
part
63,
subpart
DDD)

A
source
must
make
the
following
reports:
6
NESHAP
subpart
DDD
­
Notification
Reports
Applicability
63.9(
a),
63.1191(
a)

Construction/
reconstruction
63.9(
b)(
3)
and
(
4),
63.1191(
b)

Actual
startup
63.9(
b)(
2)
and
(
4)

Special
compliance
requirements
63.9(
d),
63.1191(
c)

Initial
performance
test
63.9(
e),
63.1191(
d)

Compliance
status
63.9(
h),
63.1191(
e)

Request
for
extension
of
compliance,
adjustments
to
time
periods,
and
changes
in
information
63.9(
c),(
i)
and
(
j)

NESHAP
subpart
DDD
­
Monitoring
Reports
Report
of
performance
test
results
63.10(
d)(
2),
63.1193(
a)

Startup,
shutdown,
and
malfunctions
plan
63.6(
c)(
3),
63.1193(
b)

Startups,
shutdowns,
and
malfunctions
plan
and
reports
63.6(
e)(
3),
63.10(
d)(
5),
63.1193(
c)

Operations,
maintenance,
and
monitoring
plan
63.6(
e)(
1)­(
e)(
2),
63.1193(
d)

Semiannual
excess
emissions
report
63.10(
e)(
3),
63.1193(
e)

Semiannual
no
excess
emissions
report
63.10(
e)(
3),
63.1193(
f)

A
source
must
keep
the
following
records:
7
NESHAP
subpart
DDD
­
Recordkeeping
General
recordkeeping
requirements
(
e.
g.,
startups,
shutdowns,
and
malfunctions
including
process
equipment,
air
pollution
control
equipment,
maintenance
performed,
and
actions
taken
outside
the
scope
of
the
existing
plans)
63.10(
b),
63.1192(
a)

Maintain
records
of
the
following
information:
­
Cupola
production
(
melt)
rate
(
Mg/
hr
(
tons/
hr)
of
melt)
­
All
bag
leak
detection
system
alarms
­
Free­
formaldehyde
content
of
each
resin
lot
and
binder
formulation
­
Incinerator
operating
temperature
and
results
of
incinerator
inspections
63.1192(
b)

Retain
records
for
five
years
following
the
date
of
each
occurrence,
measurement,
corrective
action,
maintenance
record,
or
report.
The
most
recent
two
years
of
records
must
be
retained
at
the
facility.
63.1192(
c)

Retain
records
on
microfilm,
on
a
computer,
on
computer
disks,
on
magnetic
tape
disks,
or
on
microfiche.
63.1192(
d)

Report
the
required
information
on
paper
or
on
a
labeled
computer
disk
using
commonly
available
and
compatible
computer
software.
63.1192(
e)

Presently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
leaks
and
spills
of
mercury.
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.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically,
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
estimated
that
approximately
10%
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
8
Respondent
Activities
for
NESHAP
subpart
DDD
Read
instructions.

All
monitoring
systems
and
equipment
must
be
installed,
operational,
and
properly
calibrated
before
the
performance
test.

Perform
initial
performance
test.
Use
the
following
methods
found
in
Appendix
A
of
part
60:
Method
1
for
the
selection
of
the
sampling
port
locations
and
the
number
of
sampling
ports,
Method
2
for
stack
gas
velocity
and
volumetric
flow
rate,
Method
3
or
3A
for
oxygen
and
carbon
dioxide
for
diluent
measurement
needs
to
correct
the
concentration
measurements
to
a
standard
basis,
Method
4
for
moisture
content
of
the
stack
gas,
Method
5
for
the
concentration
of
PM,
Method
10
for
the
concentration
of
CO
(
using
the
continuous
sampling
option
described
in
section
7.1.1
of
the
method).
Also,
use
Method
318
in
Appendix
A
to
part
63
for
the
concentration
of
formaldehyde
or
CO
and
the
method
described
to
determine
the
free
formaldehyde
content
of
each
resin
lot.
All
tests
are
repeated
if
necessary.

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.
9
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
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
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
and
annual
emission
inventory
data
for
more
than
100,000
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.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
five
years.
10
5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
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
requirements
the
minimum
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
in
Table
1:
Annual
Burden
of
Reporting
and
Recordkeeping
Requirements,
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Mineral
Wool
Production
(
40
CFR
part
63,
subpart
DDD).

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.
Where
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
3,018.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.
11
2
For
this
table,
the
number
of
respondents
is
the
number
of
cupolas
that
are
required
to
have
leak
detection
systems
installed
on
their
baghouses.
It
is
estimated
that
there
are
18
cupolas
located
at
12
facilities.
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
following
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.

Managerial
$
93.04
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
costs
associated
with
the
information
collection
activities
in
the
subject
standard(
s)
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor(
s)
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startu
p
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M2
(
G)
Total
O&
M,
(
E
X
F)

Baghouse
Leak
Detection
$
14,900
0
$
0
$
500
18
$
9,000
12
The
compliance
date
for
this
standard
was
June
2,
2002.
Therefore,
all
existing
facilities
incurred
capital
costs
during
the
previous
ICR
time
period.
Since
we
estimate
that
no
new
facilities
will
startup
over
the
next
three
years,
capital
costs
associated
with
this
standard
for
this
ICR
period
will
be
zero.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
estimated
to
be
$
9,000.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
9,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.
The
continuous
monitoring
costs
that
are
included
in
this
section
consist
only
of
those
capital/
startup
and
O&
M
costs
that
a
source
incurs
as
a
result
of
the
standard.
Some
continuous
monitoring
costs
may
not
be
included
in
this
section.
For
instance,
if
a
particular
industry
typically
utilizes
a
control
device
that
must
have
a
continuous
monitor
(
e.
g.,
temperature,
pressure
drop,
etc.)
to
function
properly,
and
the
recordkeeping
of
additional
measurements
beyond
the
minimum
is
required
by
the
standard,
then
there
is
no
capital/
startup
or
O
&
M
cost,
but
there
is
a
labor
cost
to
record
the
additional
readings.
Such
a
cost
would
not
appear
in
this
section,
but
in
the
industry
burden
Section
6(
d)
below.

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
$
27,211.
This
ICR
uses
the
following
labor
rates:

Managerial
$
53.22
(
GS­
13,
Step
5,
$
33.26
x
1.6)
Technical
$
39.49
(
GS­
12,
Step
1,
$
24.68
x
1.6)
Clerical
$
21.38
(
GS­
6,
Step
3,
$
13.36
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
These
rates
can
be
obtained
from
the
OPM
web
site,
13
3
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.
http://
www.
opm.
gov/
oca/
payrates/
index/
htm.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
(
Average
Annual
EPA
Resource
Requirement).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
12
existing
sources
are
subject
to
the
standard.
It
is
estimated
that
no
new
sources
will
become
subject
to
the
regulation
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
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
Respondents3
(
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
12
0
0
12
2
0
12
0
0
12
3
0
12
0
0
12
Average
0
12
0
0
12
.
To
avoid
double­
counting
respondents,
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three­
year
period
of
this
ICR
is
12.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:
14
Total
Annual
Responses
(
A)
Number
of
New
Respondents
(
B)
Number
of
Reports
for
New
Respondents
(
C)
Number
of
Existing
Respondent
s
(
D)
Number
of
Reports
for
Existing
Respondents
(
F)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
AxB)+(
CxD)+
F
0
9
12
2
0
24
The
number
of
Total
Annual
Responses
is
24.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
estimated
to
be
$
190,906.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1:
Annual
Burden
of
Reporting
and
Recordkeeping
Requirements,
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Mineral
Wool
Production
(
40
CFR
part
63,
subpart
DDD)

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
9,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
appear
in
Tables
1
and
2.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment
in
burden
hours.
The
primary
reason
for
the
adjustment
in
burden
hours
is
due
to
the
fact
that
the
compliance
date
of
June
2,
2002,
has
passed
and
all
existing
facilities
have
already
submitted
all
required
notifications
and
completed
all
required
performance
testing.
Therefore
the
remaining
burden
on
the
industry
is
primarily
the
operation
and
maintenance
of
the
control
equipment
(
e.
g.,
baghouse
leak
detection
systems)
and
the
semiannual
reporting.

The
decrease
in
burden
hours
can
also
be
attributed
to
the
fact
that
there
is
one
less
existing
facility
subject
to
the
standard
and
10
fewer
cupolas
at
these
facilities.
As
mention
in
Section
3(
c)
this
is
attributed
primarily
to
the
fact
that
the
mineral
wool
production
industry
is
encountering
increased
competition
from
the
cellulose
insulation
manufacturing
industry,
particularly
in
the
mobile
home
insulation
market.
15
The
increase
in
labor
costs
associated
with
this
ICR
is
due
to
the
increase
in
wage
rates
provided
by
the
United
States
Department
of
Labor,
Bureau
of
Statistics.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
126
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's
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
OECA­
2003­
0029,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
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
OECA
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OECA­
2003­
0029)
and
OMB
control
number
(
2060­
0362)
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
