1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NSPS
SUBPART
PPP
STANDARDS
OF
PERFORMANCE
FOR
WOOL
FIBERGLASS
INSULATION
MANUFACTURING
PLANTS
AND
NESHAP
SUBPART
NNN
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
FOR
SOURCE
CATEGORIES:
WOOL
FIBERGLASS
MANUFACTURING
PLANTS
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
Wool
Fiberglass;
including
NSPS
Subpart
PPP
­
Standards
of
Performance
for
Wool
Fiberglass
Insulation
Manufacturing
Plants
and
NESHAP
Subpart
NNN
­
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Wool
Fiberglass
Manufacturing.

1(
b)
Short
Characterization/
Abstract
This
ICR
includes
two
Clean
Air
Act
standards
for
the
wool
fiberglass
industry.
Both
the
NSPS
and
MACT
standards
include
basic
recordkeeping
and
reporting;
including
initial
notifications,
performance
testing,
semiannual
excess
emission
reports,
and
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility.
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
EPA
Regional
Office.

NSPS
Subpart
PPP.
The
New
Source
Performance
Standards
(
NSPS)
for
Wool
Fiberglass
Insulation
Manufacturing
Plants
were
proposed
on
February
7,
1984
and
promulgated
on
February
25,
1985.
These
standards
apply
to
each
rotary
spin
wool
fiberglass
insulation
manufacturing
line,
which
commenced
construction,
modification,
or
reconstruction
after
February
2,
1984.
The
purpose
of
this
NSPS
is
to
control
the
emissions
of
particulate
matter
from
each
rotary
spin
wool
fiberglass
insulation
manufacturing
line.
The
standards
limit
particulate
emissions
to
5.5
kilogram
per
megagram
(
11.0
lb/
ton)
of
molten
glass
used
to
manufacture
the
product.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
60
Subpart
PPP.
Recordkeeping
requirements
specific
to
wool
fiberglass
insulation
manufacturers
include
continuous
measurements
of
control
device
operating
parameters.
Where
a
wet
scrubbing
control
device
is
used,
the
owner
or
operator
of
an
affected
facility
must
measure
the
gas
pressure
drop
across
each
scrubber
and
the
scrubbing
liquid
flow
rate
to
each
scrubber
no
less
than
once
every
four
hours.
Owners
or
operators
who
comply
using
a
wet
electrostatic
precipitator
control
device
must
measure
the
primary
and
secondary
current
and
voltage
in
each
electrical
field
and
the
inlet
water
flow
rate
no
less
than
once
every
four
hours.
All
records
and
reports
of
this
information
1
Although
there
are
an
estimated
76
wool
fiberglass
manufacturing
lines
at
29
facilities,
we
are
assuming
that
only
one
rotary
spin
manufacturing
line
exists
at
each
facility.

2
must
be
retained
for
a
period
of
two
years.
Approximately
29
sources
are
currently
subject
to
NSPS
Subpart
PPP,
and
it
is
estimated
that
no
new
sources
will
become
subject
to
the
standard
over
the
next
three
years.
1
The
cost
burden
of
NSPS
Subpart
PPP
on
the
wool
fiberglass
insulation
manufacturing
industry
will
be
$
113,918.09
(
See
Exhibit
13).
NESHAP
Subpart
NNN.
The
Maximum
Achievable
Control
Technology
(
MACT)
for
Wool
Fiberglass
Manufacturing
Plants
were
proposed
on
March
31,
1997
and
promulgated
on
June
14,
1999.
These
standards
apply
to:
each
glass
melting
furnace
located
at
a
wool
fiberglass
manufacturing
plant;
each
rotary
spin
(
RS)
manufacturing
line
producing
building
insulation;
each
new
and
existing
flame
attenuation
(
FA)
manufacturing
line
that
produces
pipe
products;
and
each
new
FA
manufacturing
line
that
produces
heavy
density
products.
Facilities
that
manufacture
mineral
wool
from
rock
or
slag
are
not
subject
to
the
proposed
rule
but
are
subject
to
a
separate
MACT
standard
for
mineral
wool
production.
A
facility
that
is
determined
to
be
an
area
source
would
not
be
subject
to
this
MACT
standard
The
owner
or
operator
subject
to
this
MACT
must
demonstrate
compliance
with
the
requirements
of
this
subpart
by
no
later
than
June
14,
2002
for
an
existing
manufacturing
line
or
upon
startup
for
a
new
manufacturing
line
The
purpose
of
this
MACT
standard
is
to
control
the
emissions
of
hazardous
air
pollutants.
A
surrogate
approach,
where
particulate
matter
(
PM)
serves
as
a
surrogate
for
HAP
metals
and
formaldehyde
serves
as
a
surrogate
for
organic
HAPs,
is
employed
to
allow
easier
and
less
expensive
testing
and
monitoring
requirements.
The
proposed
emission
limits
are
provided
in
Exhibit
1.

EXHIBIT
1
Process
Emission
Limit
Existing
Facilities
New
Facilities
Furnace
0.25
kg
of
PM
per
Mg
of
glass
pulled.
0.25
kg
of
PM
per
Mg
of
glass
pulled.

RS
Manufacturing
Line
0.6
kg
of
formaldehyde
per
Mg
of
glass
pulled
0.40
kg
of
formaldehyde
per
Mg
of
glass
pulled
FA
Manufacturing
Line
3.4
kg
of
formaldehyde
per
Mg
of
glass
pulled
(
for
Pipe
Insulation);
None
(
for
Heavy
Density)
3.4
of
formaldehyde
per
Mg
of
glass
pulled
(
for
Pipe
Insulation;
3.9
kg
of
formaldehyde
per
Mg
of
glass
pulled.

Recordkeeping
requirements
specific
to
wool
fiberglass
insulation
manufacturers
include
2
Three
of
the
29
facilities
subject
to
NSPS
Subpart
PPP
are
considered
area
sources
and
are
not
subject
to
MACT
Subpart
NNN.

3
continuous
measurements
of
control
device
operating
parameters
(
e.
g.,
bag
leak
detection
system
monitoring
parameters
for
uncontrolled
glass­
melting
furnaces,
scrubber
operating
parameters
when
used
to
comply
with
formaldehyde
emission
limits).
Records
and
reports
must
be
retained
for
a
total
of
5
years.
A
more
detailed
description
of
recordkeeping
requirements
for
MACT
Subpart
NNN
can
be
found
in
Exhibit
7.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
63
Subpart
NNN.
Approximately
26
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
new
sources
will
become
subject
to
the
standard
over
the
next
three
years.
2
The
estimated
annual
cost
burden
of
MACT
Subpart
NNN
on
the
wool
fiberglass
insulation
manufacturing
industry
will
be
$
919,002
(
See
Exhibit
14).

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
111
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
new
stationary
sources
that
reflect:
.
.
.
application
of
the
best
technological
system
of
continuous
emissions
reduction
which
(
taking
into
consideration
the
cost
of
achieving
such
emissions
reduction,
or
any
non­
air
quality
health
and
environmental
impact
and
energy
requirements)
the
Administrator
determines
has
been
adequately
demonstrated
[
Section
111(
a)(
l)].
The
Agency
refers
to
this
charge
as
selecting
the
best
demonstrated
technology
(
BDT).
Section
111
also
requires
that
the
Administrator
review
and,
if
appropriate,
revise
such
standards
every
four
years.
In
the
Administrator's
judgment,
particulate
emissions
from
wool
fiberglass
insulation
manufacturing
plants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NSPS
were
promulgated
for
this
source
category
at
40
CFR
Part
60
­
Subpart
PPP.
EPA
is
also
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
the
Administrator's
judgment,
HAP
emissions
from
wool
fiberglass
manufacturing
plants
also
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
a
MACT
standard
was
promulgated
for
this
source
category
at
40
CFR
Part
63
­
Subpart
NNN.
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
or
methods
(
in
accordance
with
such
methods
at
4
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
D)
sample
such
emissions;
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications;
and
(
G)
provide
such
other
information
as
he
may
reasonably
require.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
particulates
and
HAPs
from
wool
fiberglass
insulation
manufacturing
plants
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
particulates
from
wool
fiberglass
insulation
manufacturing
plants
are
the
result
of
operation
of
each
rotary
spin
wool
fiberglass
insulation
manufacturing
line.
Emissions
of
HAPs
from
wool
fiberglass
manufacturing
plants
are
the
result
of
operation
of
each
glass
melting
furnace
and
each
RS
and
FA
manufacturing
line.
These
standards
rely
on
the
capture
of
particulate
and
HAPs
emissions
by
control
equipment
such
as
a
wet
scrubbing
control
device
or
an
electrostatic
precipitator.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
the
standard
is
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
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
both
40
CFR
Part
60
Subpart
PPP
and
40
CFR
Part
63
Subpart
NNN.
If
the
standard
has
not
been
delegated
the
information
is
sent
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
their
own
similar
regulation
to
implement
the
Federal
Regulation,
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
Standard.
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
the
ICR
for
NSPS
Subpart
PPP
was
published
in
the
Federal
Register
on
October
29,
1999.
An
announcement
of
a
public
comment
period
for
the
renewal
of
the
ICR
for
MACT
Subpart
NNN
was
published
in
the
Federal
Register
on
January
21,
2000.
3
MACT
Subpart
NNN
also
includes
facilities
that
manufacture
fiberglass
for
liquid
and
air
filtration.
However,
the
majority
of
the
facilities
(~
90%)
manufacture
fiberglass
for
building
insulation.

5
3(
c)
Consultations
No
comments
were
received
on
the
two
notices
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
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
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
60
Subpart
PPP
or
40
CFR
Part
63
Subpart
NNN
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
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
contained
in
40
CFR
Part
60
Subpart
PPP
or
40
CFR
Part
63
Subpart
NNN
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
for
NSPS
Subpart
PPP
and
MACT
Subpart
NNN
are
wool
fiberglass
insulation
manufacturing
plants.
3
They
are
listed
6
under
SIC
Code
3296.
The
government
is
in
the
process
of
transitioning
to
the
new
North
American
Industrial
Classification
System
(
NAICS).
The
NAICS
code
for
this
industry
is
327993.

4(
b)
INFORMATION
REQUESTED
(
I)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
60
Subpart
PPP
and
40
CFR
Part
63
Subpart
NNN.
A
source
subject
to
NSPS
Subpart
PPP
and
MACT
Subpart
NNN
must
comply
with
the
notification,
monitoring,
and
recordkeeping
requirements
listed
in
the
following
exhibits.

EXHIBIT
2
NSPS
Subpart
PPP
­
Notification
Reports
Construction/
reconstruction
60.7(
a)(
1)

Anticipated
startup
60.7(
a)(
2)

Actual
startup
60.7(
a)(
3)

Initial
performance
test
60.8(
d)

Physical
or
operational
change
60.7(
a)(
4)

EXHIBIT
3
NSPS
Subpart
PPP
­
Monitoring
Reports
Initial
performance
test
results
60.8
(
a)

Semiannual
reports
of
exceedances
of
control
device
operating
parameters
60.684(
d)

EXHIBIT
4
NSPS
Subpart
PPP
­
Recordkeeping
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
60.7(
b)

Continuous
measurements
of
control
device
operating
parameters
60.684
(
a)
and
(
b)

EXHIBIT
5
MACT
Subpart
NNN
­
Notification
Reports
Applicability
63.9
(
a),
63.1389(
a)(
1­
3)
MACT
Subpart
NNN
­
Notification
Reports
7
Construction/
reconstruction
63.9
(
b)(
3)
and
(
4),
63.1389(
a)(
4)

Anticipated
startup
63.9
(
b)(
4)
and
(
5)

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

Special
compliance
requirements
63.9
(
d),
63.1389(
a)(
5)

Initial
performance
test
63.9
(
e),
63.1389(
a)(
6)

Continuous
monitoring
system
notifications
63.9
(
g)

Compliance
status
63.9
(
h),
63.1389(
a)(
7)

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

EXHIBIT
6
MACT
Subpart
NNN
­
Monitoring
Reports
Operations,
maintenance,
and
monitoring
plan
63.6
(
e)(
1)­(
e)(
2),
63.1383
(
a)

Report
of
performance
test
results
63.10
(
d)(
2),
63.1386
(
b)

Startups,
shutdowns,
and
malfunctions
plan
and
reports
63.6
(
e)(
3),
63.10(
d)(
5),
63.1386
(
c)

Excess
emissions
63.1386
(
e)

EXHIBIT
7
MACT
Subpart
NNN
­
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)(
2),
63.1386
(
d)
MACT
Subpart
NNN
­
Recordkeeping
8
Continuous
measurements
of
control
device
operating
parameters:
­
bag
leak
detection
system
alarms
­
ESP
parameter
values
used
to
measure
performance
­
Air
temperature
above
the
molten
glass
in
a
cold
top
furnace
­
Uncontrolled
glass­
melting
furnace
parameter
values
to
measure
performance
­
The
formulation
of
each
binder
patch
and
the
LOI
and
density
for
each
product
manufactured
­
Process
parameter
level(
s)
for
RS
and
FA
manufacturing
lines
that
use
process
modifications
to
comply
with
the
emission
limits
­
Scrubber
pressure
drop,
scrubbing
liquid
flow
rate,
and
any
chemical
additive
­
Incinerator
operating
temperature
and
the
results
from
periodic
inspection
of
incinerator
components
­
Glass
pull
rate
63.1386(
d)(
2)(
i­
ix)

EXHIBIT
8
Respondent
Activities
for
NSPS
Subpart
PPP
and
MACT
Subpart
NNN
Read
instructions.

Install,
calibrate,
maintain,
and
operate
continuous
monitoring
system
for
MACT
subpart
NNN
sources.
Install,
calibrate,
maintain,
and
operate
CMS
for
pressure
drop
and
liquid
supply
pressure
for
wet
scrubber
for
NSPS
subpart
PPP
sources.

Perform
initial
performance
test.
Methods
1­
5,
316
or
318,
method
for
determining
LOI,
method
for
determining
free­
formaldehyde
content
of
resin,
and
method
for
the
determination
of
product
density
are
used
for
MACT
subpart
NNN
sources.
Reference
Method
5E
for
particulates
is
used
NSPS
subpart
PPP
sources.
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.
Respondent
Activities
for
NSPS
Subpart
PPP
and
MACT
Subpart
NNN
9
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.

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
information
required
under
40
CFR
Part
60
Subpart
PPP
and
40
CFR
Part
63
Subpart
NNN:

EXHIBIT
9
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
Aerometric
Information
Retrieval
System
(
AIRS)
database
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,
and
the
operating
conditions
under
which
compliance
was
achieved.
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
10
source
operation
and
maintenance,
and
for
compliance
determinations.
Information
contained
in
the
reports
is
entered
into
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.
The
records
required
by
NSPS
Subpart
PPP
must
be
retained
by
the
owner
or
operator
for
two
years.
The
records
required
by
MACT
Subpart
NNN
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
There
are
no
small
businesses
affected
by
this
standard.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Tables
3
and
4.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Tables
3
and
4
document
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
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
(
40
CFR
§
60.680
and
40
CFR
§
63.1380).
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
for
NSPS
Subpart
PPP
is
estimated
at
2,074
hours.
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
for
MACT
Subpart
NNN
is
estimated
at
17,024
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
NSPS
and
MACT
programs,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
I)
Estimating
Labor
Costs
This
ICR
uses
a
technical
labor
rate
of
$
54.94
per
hour,
a
management
labor
rate
of
$
73.93,
4
The
wage
rate
has
been
loaded
by
adding
110%
overhead.

5
The
previous
ICR
assumed
that
all
facilities
subject
to
Subpart
NNN
would
come
into
compliance
during
the
first
year
following
the
effective
date.
We
believe
this
assumption
to
be
incorrect.
We
are
assuming
that
compliance
with
this
standard
will
occur
over
the
first
three
years
following
the
effective
date
(
leading
up
to
the
compliance
deadline
of
June
14,
2002).
Therefore
we
assume
that
one­
third,
or
eight
(
8)
facilities,
came
into
compliance
within
the
first
year
following
the
effective
date.
The
capital
costs
associated
with
these
eight
(
8)
facilities
would
be
captured
in
the
previous
ICR.
The
capital
costs
for
the
remaining
18
facilities
will
be
captured
in
this
ICR.

11
and
a
clerical
labor
rate
of
$
34.42
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rate
is
from
column
1:
Total
Compensation.
4
For
NSPS
Subpart
PPP
only
technical
hours
are
used
to
satisfy
the
reporting
and
recordkeeping
requirements
since
this
standard
is
older
and
more
simplistic.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
capital
and
operations
and
maintenance
(
O&
M)
costs
for
NSPS
Subpart
PPP
are
associated
with
the
particulate
matter
monitoring
equipment.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
Because
no
new
sources
are
anticipated
for
this
source
category
over
the
next
three
years,
the
capital
startup
costs
are
zero.
The
annual
operations
and
maintenance
costs
associated
with
the
particular
monitoring
equipment
are
$
16,500.
The
capital
and
O&
M
costs
for
MACT
Subpart
NNN
are
associated
with
baghouse
leak
detection
monitoring,
furnace
temperature
monitoring,
and
formaldehyde
emission
monitoring.
The
capital/
startup
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
There
are
approximately
19
baghouses
located
at
11
wool
fiberglass
manufacturing
facilities.
Approximately
one­
third,
or
six
(
6),
of
these
baghouses
are
already
in
compliance5.
We
estimate
that
the
remaining
two­
thirds,
or
13
baghouses,
located
at
seven
(
7)
facilities,
will
come
into
compliance
before
the
compliance
date.
The
capital
cost
for
baghouse
leak
detection
monitoring
is
estimated
at
$
9,100
per
baghouse.
O&
M
costs
for
baghouse
leak
detection
monitoring
are
estimated
at
$
500
per
year
per
baghouse.
There
are
an
estimated
13
cold­
top
electric
furnaces
at
six
(
6)
facilities.
Approximately
onethird
or
four
(
4),
of
these
furnaces
are
already
in
compliance.
The
remaining
two­
thirds,
or
nine
(
9)
furnaces,
will
come
into
compliance
before
the
compliance
date.
The
capital
cost
for
furnace
temperature
monitors
is
estimated
at
$
1,500
per
monitor.
There
are
no
O&
M
costs
associated
with
furnace
temperature
monitors.
There
are
approximately
48
RS
and
FA
manufacturing
lines
that
need
to
be
modified
to
correlate
between
formaldehyde
emissions
and
process
parameters.
Approximately
one­
third,
or
16
manufacturing
lines,
are
already
in
compliance.
The
remaining
two­
thirds,
or
32
manufacturing
lines,
will
come
into
compliance
before
the
compliance
date.
The
capital
cost
for
modifying
each
line
is
estimated
to
cost
$
15,000.
Total
annualized
capital/
start
up
cost
is
$
204,000
($
611,800/
3).
There
are
no
O&
M
costs
associated
with
formaldehyde
emissions
monitoring.
6
For
this
table
the
term
"
units"
is
used
to
describe
each
individual
piece
of
equipment
not
each
plant.
Note
however,
that
the
average
annual
cost
is
calculated
"
per
facility"
not
"
per
unit."

12
(
iii)
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Exhibits
10
and
11
provide
a
summaries
of
the
capital
and
O&
M
costs
associated
with
both
NSPS
Subpart
PPP
and
MACT
Subpart
NNN,
respectively.

EXHIBIT
10
NSPS
Subpart
PPP
Capital/
Startup
and
Operating
and
Maintenance
(
O&
M)
Costs
Continuous
Monitoring
Device
(
A)
Startup
Cost
for
1
Affected
Facility
(
B)
#
of
New
Affected
Facilities
to
Startup
(
C)
Total
Startup
(
D=
BxC)
Annual
O&
M
Costs
for
1
Affected
Facility
(
E)
#
of
Affected
Facilities
with
O&
M
(
F)
Total
O&
M
(
G=
ExF)

Particulate
Matter
Monitoring
N/
A
0
$
0
$
16,500
29
$
478,500
Average
Annual
Cost
Per
Facility
$
0
$
16,500
EXHIBIT
11
MACT
Subpart
NNN
Capital/
Startup
and
Operating
and
Maintenance
(
O&
M)
Costs
Continuous
Monitoring
Device
(
A)
Startup
Cost
for
1
Affected
Facility
(
B)
#
of
New
Affected
Units
to
Startup6
(
C)
Total
Startup
(
D=
BxC)
Annual
O&
M
Costs
for
1
Affected
Facility
(
E)
#
of
Affected
Units
with
O&
M
(
F)
Total
O&
M
(
G=
ExF)

Baghouse
Leak
Detection
$
9,100
13
$
118,300
$
500
13
$
6,500
MACT
Subpart
NNN
Capital/
Startup
and
Operating
and
Maintenance
(
O&
M)
Costs
7
This
average
is
based
on
18
facilities
that
will
come
into
compliance
during
this
ICR
time
period
(
average
annual
startup
cost
per
facility
=
(
total
startup
cost/
number
of
facilities)/
3).

8
This
average
is
based
on
26
total
facilities
that
will
be
operating
mid­
way
through
this
ICR
period
(
average
annual
O&
M
cost
per
facility
=
(
total
O&
M
cost/
number
of
facilities)/
3).

9
There
are
only
29
wool
fiberglass
manufacturing
facilities
in
the
United
States;
however
26
of
these
29
are
subject
to
both
standards.

13
Furnace
Temperature
Monitoring
$
1,500
9
$
13,500
$
0
0
$
0
Formaldehyde
Emission
Monitoring
$
15,000
32
$
480,000
$
0
0
$
0
Average
Annual
Cost
Per
Facility
$
11,3307
$
838
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.
The
average
annual
federal
government
cost
for
NSPS
Subpart
PPP
during
the
3
years
of
the
ICR
is
estimated
to
be
$
4024.04.
The
average
annual
federal
government
cost
for
MACT
Subpart
NNN
during
the
3
years
of
the
ICR
is
estimated
to
be
$
53,264.
This
cost
is
based
on
a
federal
government
employee
salary
at
the
GS­
10
Step
1
grade
plus
110%
overhead
which
is
equal
to
$
34.69
per
hour.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Exhibit
12
provides
a
summary
of
the
combined
respondent
burdens
for
both
NSPS
Subpart
PPP
and
MACT
Subpart
NNN,
including
the
total
number
of
annual
responses
and
the
total
burden
hours
required
to
comply
with
these
two
standards.

EXHIBIT
12
Total
Combined
Burden:
NSPS
Subpart
PPP
and
MACT
Subpart
NNN
Standard
Number
of
Respondents
Total
Annual
Responses
Total
Hours
Requested
NSPS
Subpart
PPP
29
58
2,074
MACT
Subpart
NNN
26
70
17,024
Total
Combined
Burden
299
128
19,098
14
The
estimated
number
of
respondents
to
NSPS
Subpart
PPP
and
MACT
Subpart
NNN
is
29
and
26
respectively.
We
estimate
that
the
total
combined
burden
hours
associated
with
these
two
standards
will
be
19,098
hours.
These
hours
include
the
time
required
to
prepare
annual
responses
to
Agency
information
requests
as
well
as
recordkeeping
and
monitoring
requirements.
Details
upon
which
this
estimate
is
based
appear
in
tables
3
and
4
attached.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
Exhibits
13
and
14
provide
summaries
of
the
estimated
overall
cost
burden
of
NSPS
Subpart
PPP
and
MACT
Subpart
NNN
on
the
wool
fiberglass
industry
and
EPA
for
the
next
three
years.
For
a
detailed
breakdown
of
the
costs,
see
Tables
1­
4
attached.

EXHIBIT
13
NSPS
Subpart
PPP
Summary
of
the
Estimated
Overall
Burden
Industry
Burden
(
Hours)
Industry
Cost
($)
EPA
Burden
(
Hours)
EPA
Cost
($)

Annual
Average
(
for
3
years)
2,074
$
113,918
116
$
4,024
EXHIBIT
14
MACT
Subpart
NNN
Summary
of
the
Estimated
Overall
Burden
Year
Industry
Burden
(
Hours)
Industry
Cost
($)
EPA
Burden
(
Hours)
EPA
Cost
($)

First
Year
15,872
$
856,795
1,949
$
71,219
Second
Year
20,826
$
1,124,229
2,065
$
75,241
Third
Year
14,375
$
775,981
385
$
13,332
Total
51,073
$
2,757,006
4,399
$
159,793
Annual
Average
17,024
$
919,002
1,466
$
53,264
The
overall
annual
cost
burden
associated
with
these
two
standards
on
the
wool
fiberglass
manufacturing
industry
is
estimated
at
$
1,032,920.
The
Agency
burden
associated
with
these
two
standards
is
estimated
at
$
57,288.
10
The
previous
ICR
for
MACT
Subpart
NNN
was
approved
on
5/
31/
97
and
covers
the
first
three
years
following
promulgation
of
the
standard;
June
14,
1999
thru
June
14,
2002.
However,
since
the
previous
ICR
expires
on
May
31,
2000,
this
ICR
will
overlap
the
previous
ICR
for
two
years,
covering
June
1,
2000
thru
June
1,
2003.

15
6(
f)
Reasons
for
Change
in
Burden
The
primary
source
used
to
estimate
the
number
of
facilities
subject
to
NSPS
Subpart
PPP
and
MACT
Subpart
NNN
was
the
United
States
Geological
Survey
(
USGS).
In
addition,
the
North
American
Insulation
Manufacturers
Association's
website
provided
additional
information
on
the
profile
of
the
wool
fiberglass
insulation
industry.
Basically,
there
is
slight
decrease
(
116)
in
Burden
Hours
from
the
previous
ICR.
The
formula
used
to
calculate
labor
rates
on
the
previous
ICRs
has
been
replaced
by
1999
rates
identified
by
the
Bureau
of
Labor
Statistics.
As
a
result,
the
technical,
management,
and
clerical
labor
rates
are
approximately
$
20.00
per
hour
higher
than
the
previous
rate.
The
change
in
labor
rate
and
the
increased
number
of
facilities
subject
to
NSPS
Subpart
PPP
are
the
two
primary
factors
contributing
to
the
$
64,568
increase
in
cost
burden
from
the
previous
ICR.
The
change
in
labor
rate
is
the
primary
reason
for
the
increased
annual
cost
burden
on
industry
subject
to
MACT
Subpart
NNN
from
$
541,000
to
$
919,002.
We
expect
existing
facilities
to
continue
to
come
into
compliance
with
MACT
Subpart
NNN
during
the
first
two
years
of
this
ICR
in
an
effort
to
meet
the
June
14,
2002
compliance
date.
However,
in
the
third
year
of
this
ICR,
we
expect
all
existing
facilities
to
be
in
compliance
with
this
MACT
and
thus
expect
a
decrease
in
the
overall
burden
on
the
industry
(
see
Table
4
(
a
­
c)).
10
6(
g)
Burden
Statement
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.
Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
NW,
Washington,
D.
C.
20460;
and
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.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.

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