1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
FOR
SOURCE
CATEGORIES
(
NESHAP)/
MAXIMUM
ACHIEVABLE
CONTROL
TECHNOLOGY
(
MACT):
SUBPART
DDD
MINERAL
WOOL
PRODUCTION
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP/
MACT
Subpart
DDD
­
National
Emission
Standards
for
Hazardous
Air
Pollutants/
Maximum
Achievable
Control
Technology
for
Mineral
Wool
Production.

1(
b)
Short
Characterization/
Abstract
The
NESHAP/
MACT
for
Wool
Fiberglass
Manufacturing
Plants
was
proposed
on
May
8,

1997
and
promulgated
on
June
1,
1999.
Potential
respondents
are
owners
or
operators
of
existing
mineral
wool
production
facilities.
The
proposed
rule
applies
to
each
cupola
and/
or
curing
oven
at
existing,
new,
or
reconstructed
mineral
wool
production
facilities.
Consistent
with
the
general
provision
of
NESHAP/
MACT
for
source
categories
(
40
CFR
Part
63,
Subpart
A),

respondents
would
not
include
the
owner
or
operator
of
any
facility
that
is
not
a
major
source.

General
requirements
applicable
to
all
NESHAP/
MACT
require
records
of
applicability
determinations;
test
results;
exceedances;
periods
of
startups,
shutdowns,
or
malfunctions;
1
There
are
9
mineral
wool
production
companies
operating
16
facilities
in
the
U.
S.
Three
of
these
16
facilities
are
area
sources
and
are
not
subject
to
this
standard.

2
monitoring
records;
and
all
other
information
needed
to
determine
compliance
with
the
applicable
standard.
Records
and
reports
must
be
retained
for
a
total
of
5
years
(
2
years
at
the
site;
the
remaining
3
years
of
records
may
be
retained
off
site).
The
files
may
be
maintained
on
microfilm,

on
a
computer
or
floppy
disks,
on
magnetic
tape
disks,
or
on
microfiche.

The
proposed
emission
limits
are
provided
in
Exhibit
1.

EXHIBIT
1
Source
Pollutant
Emission
Limit
Existing
Facilities
New
Facilities
Cupola
Particulate
Matter
(
PM)
0.05
kg/
Mg
(
0.10
lb/
ton)
of
melt.
0.05
kg/
Mg
(
0.10
lb/
ton)
of
melt.

Carbon
Monoxide
(
CO)
N/
A
0.05
kg/
Mg
(
0.10
lb/
ton)
of
melt
or
99
percent
CO
removal.

Curing
Oven
Formaldehyde
0.03
kg/
Mg
(
0.06
lb/
ton)
of
melt.
0.03
kg/
Mg
(
0.06
lb/
ton)
of
melt
or
80
percent
formaldehyde
removal.

Approximately
13
facilities
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
new
facilities
will
become
subject
to
the
standard
over
the
next
three
years.
1
The
estimated
annual
cost
burden
of
NESHAP/
MACT
Subpart
DDD
on
the
mineral
wool
production
industry
will
be
$
311,953
(
See
Exhibit
8).

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
3
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
hazardous
air
pollutants
(
HAPs)
from
Mineral
Wool
Production
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP/
MACT
were
promulgated
for
this
source
category
at
40
CFR
Part
(
60,61,63)
DDD
.
4
2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
particulates
and
HAPs
from
Mineral
Wool
Production
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
particulates
and
HAPs
from
Mineral
Wool
Production
are
the
result
of
operation
of
the
cupola
and
curing
ovens.
The
proposed
standards
rely
on
a
fabric
filter
for
metal
HAPs
control
for
affected
cupolas
and
a
thermal
incinerator
for
formaldehyde
and
phenol
control
for
affected
curing
ovens.
The
proposed
standards
for
new
sources
rely
on
a
thermal
incinerator
for
carbonyl
sulfide
(
COS)
control,
in
addition
to
a
fabric
filter
for
metal
HAPs
control,
for
cupolas
and
a
thermal
incinerator
for
formaldehyde
and
phenol
control
for
curing
ovens.
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,

leaks
are
being
detected
and
repaired,
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.

Subpart
DDD
would
require
respondents
to
install
fabric
filter
bag
leak
detection
systems
and
then
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.

The
proposed
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
would
be
considered
a
5
violation
of
the
applicable
emission
standard.
Additionally,
all
respondents
would
be
required
to
continuously
monitor
and
record
the
cupola
production
(
melt)
rate
and
respondents
with
affected
curing
ovens
would
be
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.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63
Subpart
DDD.

3(
a)
Nonduplication
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.
6
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
March
31,
2000.

3(
c)
Consultations
No
comments
were
received
on
the
notice
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
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
7
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
of
the
recordkeeping
and
reporting
requirements
for
NESHAP/
MACT
Subpart
DDD
are
mineral
wool
production
plants.
They
are
listed
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
63
Subpart
DDD.
A
source
subject
to
NESHAP/
MACT
Subpart
DDD
must
comply
with
the
notification,
monitoring,
and
recordkeeping
requirements
listed
in
the
following
exhibits.

EXHIBIT
2
8
NESHAP/
MACT
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)

EXHIBIT
3
NESHAP/
MACT
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)

Semi­
annual
Excess
Emissions
Report
63.10(
e)(
3),
63.1193
(
e)

Semi­
annual
No
Excess
Emissions
Report
63.10(
e)(
3),
63.1193
(
f)

EXHIBIT
4
9
NESHAP/
MACT
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
microfishe.
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)

EXHIBIT
5
Respondent
Activities
for
NESHAP/
MACT
Subpart
DDD
Read
instructions.

All
monitoring
systems
and
equipment
must
be
installed,
operational,
and
properly
calibrated
before
the
performance
test.
Respondent
Activities
for
NESHAP/
MACT
Subpart
DDD
10
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.

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
63
Subpart
DDD:
11
EXHIBIT
6
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
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
NESHAP/
MACT
Subpart
DDD
must
be
retained
by
the
owner
or
12
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
The
impact
on
small
businesses
was
accounted
for
in
the
regulation
development.
The
requirements
reflect
the
burden
on
small
businesses.
Even
though,
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,

therefore,
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Table
2.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
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
§
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.
2
The
wage
rate
has
been
loaded
by
adding
110%
overhead.

13
6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
for
NESHAP/
MACT
Subpart
DDD
is
estimated
at
5,779
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
NESHAP/
MACT
program,
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,

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.
2
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
capital
and
O&
M
costs
for
NESHAP/
MACT
Subpart
DDD
are
associated
with
baghouse
leak
detection
monitoring
on
28
cupolas
that
operate
at
the
13
mineral
wool
production
facilities.
It
is
assumed
that
no
additional
equipment
is
needed
to
meet
the
monitoring
requirements
for
the
curing
ovens.
The
capital
cost
of
each
baghouse
leak
detection
system
is
estimated
at
$
14,900.
The
capital/
startup
costs
are
one
time
costs
when
a
facility
becomes
subject
3
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."

4
This
average
is
based
on
the
estimate
that
two­
thirds,
or
approximately
9
facilities,
will
come
into
compliance
during
this
ICR
time
period.

5
This
average
is
based
on
the
estimate
that
approximately
11
facilities
that
will
be
operating
mid­
way
through
this
ICR
period.

14
to
the
standard.
Operation
and
maintenance
(
O&
M)
costs
for
baghouse
leak
detection
monitoring
are
estimated
at
$
500
per
baghouse
per
year.

(
iii)
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Exhibits
7
provides
a
summary
of
the
capital
and
O&
M
costs
associated
with
NESHAP/
MACT
Subpart
DDD.

EXHIBIT
7
NESHAP/
MACT
Subpart
DDD
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
Startup3
(
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
$
14,900
28
$
417,200
$
500
28
$
14,000
Average
Annual
Cost
$
96,2774
$
3,9495
Average
Annual
Cost
per
Facility
$
10,697
$
359
15
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
NESHAP/
MACT
Subpart
PPP
during
the
3
years
of
the
ICR
is
estimated
to
be
$
28,341.
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
The
estimated
number
of
respondents
subject
to
NESHAP/
MACT
Subpart
DDD
is
13.
We
estimate
that
the
total
annual
burden
hours
associated
with
this
standard
is
approximately
5,799
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
Table
2
attached.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
Exhibits
8
provides
a
summary
of
the
estimated
overall
cost
burden
of
NESHAP/
MACT
Subpart
DDD
on
the
mineral
wool
production
industry
and
EPA
for
the
next
three
years.
For
a
detailed
breakdown
of
the
costs,
see
Tables
1
and
2
attached.
6
NAIMA
was
an
active
participant
in
developing
this
standard
and
also
assisted
in
preparing
the
first
ICR
for
this
standard.

16
EXHIBIT
8
NESHAP/
MACT
Subpart
DDD
Summary
of
the
Estimated
Overall
Burden
Year
Industry
Burden
(
Hours)
Industry
Cost
($)
EPA
Burden
(
Hours)
EPA
Cost
($)

First
Year
6,117
$
330,216
1,026
$
37,321
Second
Year
7,405
$
399,720
1,084
$
39,316
Third
Year
3,815
$
205,924
242
$
8,386
Total
17,337
$
935,860
2,352
$
85,023
Annual
Average
5,779
$
311,953
784
$
28,341
The
overall
annual
cost
burden
associated
with
this
standard
on
the
mineral
wool
production
industry
is
estimated
at
$
311,953.
The
average
annual
Agency
burden
associated
with
this
two
standard
is
estimated
at
$
28,341.

6(
f)
Reasons
for
Change
in
Burden
The
primary
source
used
to
estimate
the
number
of
facilities
subject
to
NESHAP/
MACT
Subpart
DDD
was
the
North
American
Insulation
Manufacturers
Association
(
NAIMA)
6.
The
change
in
burden
from
the
most
recently
approved
ICR
for
NESHAP/
MACT
Subpart
DDD
reflects
an
decrease
in
the
number
of
affected
facilities
from
14
to
13.
This
slight
decrease
is
the
result
of
ongoing
efforts
to
consolidate
the
industry.
7
The
previous
ICR
for
NESHAP/
MACT
Subpart
DDD
was
approved
on
7/
31/
97
and
covers
the
first
three
years
following
promulgation
of
the
standard;
June
1,
1999
thru
June
2,
2002.
However,
since
the
previous
ICR
expires
on
July
31,
2000,
this
ICR
will
overlap
the
previous
ICR
for
approximately
two
years,
covering
August
2000
thru
August,
2003.

17
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.
Although
there
was
a
slight
decrease
in
the
number
of
facilities
subject
to
this
standand,
the
change
in
labor
rate
is
the
primary
reason
for
the
increased
annual
cost
burden
on
industry
subject
to
NESHAP/
MACT
Subpart
DDD
from
$
196,206
to
$
311,953.

We
expect
existing
facilities
to
continue
to
come
into
compliance
with
NESHAP/
MACT
Subpart
DDD
during
the
first
two
years
of
this
ICR
in
an
effort
to
meet
the
June
2,
2002
compliance
date.
However,
in
the
third
year
of
this
ICR,
we
expect
all
existing
facilities
to
be
in
compliance
with
this
NESHAP/
MACT
and
thus
expect
a
decrease
in
the
overall
burden
on
the
industry
(
see
Table
2
(
a
­
c)).
7
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
18
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
U.
S.
Environmental
Protection
Agency,

Collection
Strategies
Division
(
Mail
Code
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
1799.02
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.
