SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NSPS
for
Wool
Fiberglass
Insulation
Manufacturing
Plants
(
40
CFR
part
60,
subpart
PPP)
and
NESHAP
for
Wool
Fiberglass
Manufacturing
Plants
(
40
CFR
part
63,
subpart
NNN)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NSPS
for
Wool
Fiberglass
Insulation
Manufacturing
Plants
(
40
CFR
part
60,
subpart
PPP)
and
NESHAP
for
Wool
Fiberglass
Manufacturing
Plants
(
40
CFR
part
63,
subpart
NNN)

1(
b)
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
includes
two
Clean
Air
Act
standards
for
the
wool
fiberglass
manufacturing
industry.
Both
the
NSPS
and
NESHAP
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
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

The
New
Source
Performance
Standards
(
NSPS)
for
the
regulations
published
at
40
CFR
part
60,
subpart
PPP
were
proposed
on
February
7,
1984,
and
promulgated
on
February
25,
1985.
These
regulations
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
kilograms
per
megagram
(
11.0
lb./
ton)
of
molten
glass
used
to
manufacture
the
product.

The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
the
regulations
published
at
40
CFR
part
63,
subpart
NNN
were
proposed
on
March
31,
1997,
and
promulgated
on
June
14,
1999.
These
regulations
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.
Plants
that
manufacture
mineral
wool
from
rock
or
slag
are
not
subject
to
the
proposed
rule
but
are
subject
to
a
separate
NESHAP
standard
for
mineral
wool
production.
A
facility
that
is
determined
to
be
an
area
source
would
not
be
subject
to
this
NESHAP
standard.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
60,
subpart
PPP
and
40
CFR
part
63,
subpart
NNN.
2
In
general,
all
NSPS
and
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
both
the
NSPS
and
NESHAP.

Any
owner
or
operator
subject
to
the
provisions
of
40
CFR
part
60,
subpart
PPP
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
Any
owner
or
operator
subject
to
the
provisions
of
40
CFR
part
63,
subpart
NNN
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
for
both
the
NSPS
and
NESHAP
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
32
sources
are
currently
subject
to
40
CFR
part
60,
subpart
PPP.
Approximately
29
sources
are
subject
to
40
CFR
part
63,
subpart
NNN.
It
is
estimated
that
no
new
sources
will
become
subject
to
either
the
NSPS
or
NESHAP
regulation
in
the
next
three
years.
The
number
of
affected
sources
subject
to
these
regulations
was
estimated
based
on
information
available
from
the
North
American
Insulation
Manufacturing
Association
(
NAIMA).

TERMS
OF
CLEARANCE
The
Office
of
Management
and
Budget
(
OMB)
provided
the
following
terms
of
clearance:

This
ICR
is
approved
for
three
years,
and
represents
a
consolidation
of
activities
previously
covered
by
OMB
numbers
2060­
0114
and
2060­
0359,
the
NSPS
and
NESHAP
MACT
standard
information
collections
for
the
Wool
Fiberglass
Insulation
Manufacturing
Plants.
The
agency
should
submit
to
OMB
a
request
to
change
the
burden
associated
with
2060­
0359
in
order
to
avoid
doublecounting
of
burden
associated
with
those
activities.
In
addition,
before
resubmitting
this
ICR
for
extension,
the
agency
should
revise
estimates
of
the
number
of
respondents
as
appropriate,
taking
into
consideration
agency
experience
with
these
facilities.

The
Office
of
Environmental
Information
(
OEI)
has
submitted
a
Paperwork
Reduction
Act
(
PRA)
Change
Worksheet
(
OMB
83­
C)
for
OMB's
approval
July
26,
2002,
which
was
subsequently
approved,
and
the
burden
for
the
second
ICR
has
been
reduced
to
zero
and
placed
on
"
Inactive"
status.
This
ICR
covers
both
subparts.
The
number
of
respondents
was
revised
3
based
on
information
available
on
EPA's
On­
line
Targeting
and
Information
System
(
OTIS)
as
well
as
from
the
NAIMA's
website.

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
(
CAA),
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.

The
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
(
HAPs).
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,
particulate
emissions
and
HAP
emissions
from
wool
4
fiberglass
manufacturing
plants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NSPS
and
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
part
60,
subpart
PPP
and
40
CFR
part
63,
subpart
NNN
respectively.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
particulates
and
HAPs
from
wool
fiberglass
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
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
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.
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
plants
affected
by
the
NSPS
and/
or
NESHAP
continue
to
operate
the
control
equipment
and
achieve
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
both
40
CFR
part
60,
subpart
PPP
and
40
CFR
part
63,
subpart
NNN.

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
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
5
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
on
September
26,
2002.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
Information
provided
by
the
North
American
Insulation
Manufacturing
Association
(
NAIMA)
was
used
as
the
primary
source
for
determining
the
number
of
affected
sources
subject
to
these
standards.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
plants
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
1320.5.

3(
f)
Confidentiality
The
required
information
has
been
determined
not
to
be
confidential.
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
6
1
40
CFR
part
63,
subpart
NNN
also
includes
plants
that
manufacture
fiberglass
for
liquid
and
air
filtration.
However,
the
majority
of
the
plants
(~
90%)
manufacture
fiberglass
for
building
insulation.
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
for
40
CFR
part
60,
subpart
PPP
and
40
CFR
part
63,
subpart
NNN
are
wool
fiberglass
manufacturing
plants.
1
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
United
States
Standard
Industrial
Classification)
3296
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
327993.

4(
b)
Information
Requested
(
i)
Data
Items
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
with
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
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.

All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
part
60,
subpart
PPP
and/
or
40
CFR
part
63,
subpart
NNN.
A
source
subject
to
40
CFR
part
60,
subpart
PPP
and/
or
40
CFR
part
63,
subpart
NNN
must
comply
with
the
notifications,
monitoring
and
recordkeeping
requirements
listed
in
the
following
exhibits.

Reports
for
40
CFR
part
60,
subpart
PPP
Construction/
reconstruction
60.7(
a)(
1)
7
Reports
for
40
CFR
part
60,
subpart
PPP
Actual
startup
60.7(
a)(
3)

Initial
performance
test
60.8(
d)

Physical
or
operational
change
60.7(
a)(
4)

Initial
performance
test
results
60.8(
a)

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

Reports
for
40
CFR
part
63,
subpart
NNN
Applicability
63.9(
a),
63.1389(
a)(
1­
3)

Construction/
reconstruction
63.9(
b)(
3)
and
(
4),
63.1389(
a)(
4)

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),
63.43
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)

Startup,
shutdown,
and
malfunction
plans
and
reports
63.6(
e)(
3),
63.10(
d)(
5),
63.1386(
c)

Excess
emissions
63.1386(
e)

A
source
must
maintain
the
following
records:
8
Recordkeeping
for
40
CFR
part
60,
subpart
PPP
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative.
60.7(
b)

Records
are
required
to
be
retained
for
2
of
Years.
60.7(
f)

Continuous
measurements
of
control
device
operating
parameters
60.684(
d)

Recordkeeping
for
40
CFR
part
63,
subpart
NNN
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)

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)

(
ii)
Respondent
Activities
9
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
continuous
monitoring
system
for
40
CFR
part
63,
subpart
NNN
sources.
Install,
calibrate,
maintain,
and
operate
CMS
for
pressure
drop
and
liquid
supply
pressure
for
wet
scrubber
for
40
CFR
part
60,
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
40
CFR
part
63,
subpart
NNN
sources.
Reference
Method
5E
for
particulates
is
used
40
CFR
part
60,
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.

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
10
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
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
retrieval
of
compliance
and
annual
emission
inventory
data
for
more
than
100,000
industrial
and
government­
owned
plants.
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
40
CFR
part
60,
subpart
PPP
must
be
retained
by
the
owner
or
operator
for
two
years.
The
records
required
by
40
CFR
part
63,
subpart
NNN
must
be
retained
by
the
owner
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
11
There
are
no
small
businesses
affected
by
this
regulation.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Average
Annual
Burden
of
Reporting
and
Recordkeeping
Requirements,
NSPS
for
Wool
Fiberglass
Insulation
Manufacturing
Plants
(
40
CFR
part
60,
subpart
PPP)
and
Table
2:
Average
Annual
Burden
of
Reporting
and
Recordkeeping
Requirements,
NESHAP
for
Wool
Fiberglass
Manufacturing
Plants
(
40
CFR
part
63,
subpart
NNN).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Tables
1
and
2
document
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subparts
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
for
the
40
CFR
part
60,
subpart
PPP
is
estimated
to
be
2,288
hours.
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
for
the
40
CFR
part
63,
subpart
NNN
is
estimated
to
be
15,928
hours.
The
total
number
of
labor
hours
for
both
subparts
is
18,216.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NSPS
and
NESHAP
programs,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
89.94
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
61.66
per
hour
for
Technical
labor,
and
$
38.39
per
hour
for
Clerical
labor.
These
rate(
s)
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2002,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
12
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
$
89.94
($
42.83
+
110%)
Technical
$
61.66
($
29.36
+
110%)
Clerical
$
38.39
($
18.28
+
110%)

For
40
CFR
part
63,
subpart
NNN,
managerial
and
administrative
labor
hours
were
estimated
to
be
approximately
5%
and
10%
of
the
estimated
technical
labors
respectively.
For
40
CFR
part
60,
subpart
PPP,
only
technical
hours
are
used
to
satisfy
the
recordkeeping
and
reporting
requirements
since
this
standard
is
older
and
the
ICR
is
more
simplistic.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
capital
startup
costs
and
operations
and
maintenance
(
O&
M)
costs
for
40
CFR
part
60,
subpart
PPP
are
associated
with
the
particulate
matter
monitoring
equipments.
The
capital
startup
costs
are
one­
time
costs
when
the
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
O&
M
costs
associated
with
the
particulate
monitoring
equipment
are
$
16,500.

The
capital
and
O&
M
costs
for
40
CFR
part
63,
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.
Because
no
new
sources
are
anticipated
for
this
source
category
over
the
next
three
years,
the
capital
startup
costs
are
zero.
O&
M
costs
for
baghouse
leak
detection
monitoring
are
estimated
at
$
500
per
year
per
baghouse.
There
are
no
O&
M
costs
associated
with
furnace
temperature
monitors
or
formaldehyde
emissions
monitoring.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
13
2
In
order
to
calculate
O&
M
costs
for
40
CFR
part
63,
subpart
PPP,
the
estimates
provided
in
column
F
were
not
based
on
the
number
of
respondents
but
instead
on
the
total
number
continuous
monitoring
devices
that
exist
within
the
industry.
For
example,
we
estimate
that
there
are
20
baghouses
used
within
the
wool
fiberglass
manufacturing
industry.
Some
respondents
may
have
more
than
one
baghouse
located
at
their
facility.
NSPS
for
Wool
Fiberglass
Insulation
Manufacturing
Plants
(
40
CFR
part
60,
subpart
PPP)
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&
M
(
G)
Total
O&
M,
(
E
X
F)

Particulate
Matter
Monitoring
$
15,000
0
$
0
$
16,500
29
$
478,500
NESHAP
for
Wool
Fiberglass
Manufacturing
Plants
(
40
CFR
part
63,
subpart
NNN)
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
$
9,100
0
0
$
500
20
$
10,000
Furnace
Temperature
Monitoring
$
1,500
0
0
$
0
15
$
0
Formaldehyde
Emission
Monitoring
$
15,000
0
0
$
0
50
$
0
Because
there
are
no
new
sources
expected
over
the
next
three
years,
there
are
no
capital
14
costs
associated
with
either
40
CFR
part
60,
subpart
PPP,
or
40
CFR
part
63,
subpart
NNN.
This
is
the
sum
of
the
totals
of
column
D
in
the
two
tables
above.
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
$
488,500.
This
is
the
sum
of
the
totals
of
column
G
in
the
two
tables
above.
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
are
estimated
to
be
$
488,500.
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.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
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
Agency
cost
during
the
three
years
of
the
ICR
for
40
CFR
part
60,
subpart
PPP
is
estimated
to
be
$
5,055.
The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
for
40
CFR
part
63,
subpart
NNN
is
estimated
to
be
$
19,523.
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
39.49.
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Tables
3:
Average
Annual
EPA
Resource
Requirement,
NSPS
for
Wool
Fiberglass
Insulation
Manufacturing
Plants
(
40
CFR
part
60,
subpart
PPP)
and
Table
4:
NESHAP
for
Wool
Fiberglass
Manufacturing
Plants
(
40
CFR
part
63,
subpart
NNN).
For
40
CFR
part
63,
subpart
NNN,
managerial
and
administrative
labor
hours
were
estimated
to
be
approximately
5%
and
10%
of
the
estimated
technical
labors
respectively.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Approximately
32
and
29
sources
are
currently
subject
to
40
CFR
part
60,
subpart
PPP
and
40
CFR
part
63,
subpart
NNN
respectively.
We
estimate
that
no
additional
sources
per
year
will
become
subject
to
either
regulation
in
the
next
three
years.
15
Respondent
Universe
and
Number
of
Responses
Per
Year
Regulation
Citation
(
A)
Average
Number
of
New
Respondents
per
Year
(
B)
Number
of
Reports
for
New
Sources
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
=
(
AxB)+(
CxD)+
F
40
CFR
part
60,
subpart
PPP
0
5
32
2
0
64
40
CFR
part
63,
subpart
NNN
0
8
29
4
0
116
The
number
of
total
respondents
for
both
40
CFR
part
60,
subpart
PPP
and
40
CFR
part
63,
subpart
NNN
is
61.
This
number
is
the
sum
of
column
A
and
column
C
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period
(
i.
e.,
the
total
of
the
number
of
new
respondents
over
the
three­
year
period
divided
by
three
years).
It
is
shown
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
number
of
Total
Annual
Responses
for
both
40
CFR
part
60,
subpart
PPP
and
40
CFR
part
63,
subpart
NNN
is
180.
This
is
the
number
in
column
E
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table
above.
It
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
total
annual
labor
costs
for
40
CFR
part
60,
subpart
PPP
is
$
141,078.
The
total
annual
labor
costs
for
40
CFR
part
63,
subpart
NNN
is
$
969,473.
The
total
annual
labor
costs
for
both
standards
are
equal
to
$
1,110,553.
This
number
is
not
shown
on
the
OMB
83­
I
form.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NSPS
for
Wool
Fiberglass
Insulation
Manufacturing
Plants
(
40
CFR
part
60,
subpart
PPP)
and
Table
2:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Wool
Fiberglass
Manufacturing
Plants
(
40
CFR
part
63,
subpart
NNN).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
488,500.
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.
16
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
the
attached
tables
1
thru
4.
A
summary
of
the
bottom
line
burden
hours
and
cost
appears
below.

Industry
Burden
Agency
Burden
Capital
Costs
O&
M
Costs
Hours
Dollars
Hours
Dollars
Dollars
Dollars
40
CFR
Part
60,
Subpart
PPP
2,288
141,078
128
5,055
0
478,500
40
CFR
Part
63,
Subpart
NNN
15,928
969,473
507
19,523
0
10,000
Total
18,216
1,110,553
635
24,578
0
488,500
6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
adjustment
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
the
fact
that
all
performance
testing
under
40
CFR
part
63,
subpart
NNN
was
conducted
before
the
June
14,
2002
compliance
dates,
three
years
from
the
promulgation
of
the
standards.
Thus,
all
performance
testing,
which
makes
up
a
significant
portion
of
the
burden
associated
with
40
CFR
subpart
NNN,
occurred
during
the
previously
approved
ICR
time
period.
Existing
sources
subject
to
40
CFR
part
63,
subpart
NNN
should
only
have
to
meet
the
recordkeeping
and
reporting
requirements
of
the
standard
for
this
ICR
period.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
101
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
17
for
EPA's
regulations
are
listed
in
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
0057,
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
Avenue,
N.
W.,
Washington,
D.
C.
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
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1514.
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.
Once
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,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
(
OECA­
2003­
0057)
and
OMB
Control
Number
(
2060­
0114)
in
any
correspondence.

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