SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY

NSPS/NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR
part 60, subpart PPP and 40 CFR part 63, subpart NNN)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NSPS/NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR
part 60, subpart PPP and 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 New
Source Performance Standards (NSPS) and National Emission Standards for
Hazardous Air Pollutants (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 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 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 they 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.

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 appropriate 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).

	OMB approved the currently active ICR without any “Terms of
Clearance.”

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 also 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 (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 hazardous air
pollutant (HAP) emissions from wool 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 its own similar standards to
implement the Federal standards, a copy of the report submitted to the
State, or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

3(b)  Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register at 71 FR 35652 on June 21, 2006. 
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) in preparation of the currently “Active” ICR was
used as the primary source for determining the number of affected
sources subject to these standards.

	Industry trade associations and other interested parties were provided
an opportunity to comment on the burden associated with the standard as
it was being developed and the standard has been previously reviewed to
determine the minimum information needed for compliance purposes.

It is our policy to carefully review any comments received since the
last ICR renewal including those submitted in response to the first
Federal Register notice, and to respond appropriately.

 

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 violates 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

None of the reporting or recordkeeping requirements contains 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.  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)

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:

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 two 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 levels 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

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 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

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.  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

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 rates 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 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

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/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup 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/Startup Cost for One Respondent	(C)

Number of New Respondents	(D)

Total Capital/Startup 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)

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 costs associated with either 40 CFR part 60,
subpart PPP, or 40 CFR part 63, subpart NNN.

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.

	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.

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 currently are 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.

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 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).

	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.

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 $1,110,551.  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.  These costs are detailed in section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the
respondents appear in 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	1,110,551	635	24,578	0	488,500



6(f)  Reasons for Change in Burden

	There is no change in the labor hours or cost in this ICR compared to
the previous ICR.  This is due to two considerations.  First, the
regulations have not changed over the past three years and are not
anticipated to change over the next three years.  Secondly, the growth
rate for the industry is low, negative or non-existent, so there is no
significant change in the overall burden. 

	Since there are no changes in the regulatory requirements and there is
no significant industry growth, the labor hours and cost figures in the
previous ICR are used in this ICR and there is no change in burden to
industry.

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 valid OMB
Control Number.  The OMB Control Numbers for EPA’s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

	To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OECA-2006-0420.   An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents also
are available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., NW, Washington, DC.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
docket center is (202) 566-1752.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2006-0420 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.

TABLE 1:	ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS







	NSPS FOR WOOL FIBERGLASS INSULATION MANUFACTURING (40 CFR PART 60,
SUBPART PPP)















 	REPORTING/RECORDKEEPING REQUIREMENT	Hours/ Occurrence     (A)
Occurrences/ Year              (B)	Hours/Year (C=A*B)            (C)
Respondents/Year                  (D)	Hours/Year        (E=C*D)       
(E)	Costs/Year         (F)

1.	APPLICATIONS	N/A	N/A	N/A	N/A	N/A	N/A

2.	SURVEY AND STUDIES	N/A	N/A	N/A	N/A	N/A	N/A

3.	REPORTING REQUIREMENTS	 	 	 	 	 	 

 	a.	Read Instructions	1	1	1	0	0	$0.00

 	b.	Required Activities	 	 	 	 	 	 

 	 	 	Initial Performance Tests	72	1	72	0	0	$0.00

 	 	 	Repeat of Performance Tests	72	0.2	14.4	0	0	$0.00

 	c.	Create Information	 	------------------------Included in
3b----------------------------	 	 	 	 

 	d.	Gather Existing Information	 	------------------------Included in
3b----------------------------	 	 	 	 

 	e.	Write Report	 	 	 	 	 	 

 	 	 	Notification of Construction/Reconstruction	2	1	2	0	0	$0.00

 	 	 	Notification of Actual Startup	2	1	2	0	0	$0.00

 	 	 	Notification of Physical or Operational Change	2	1	2	0	0	$0.00

 	 	 	Notification of Initial Performance Test	2	1	2	0	0	$0.00

 	 	 	Report of Performance Test	 	------------------------Included
in 3b----------------------------	 	 	 	 

 	 	 	Semiannual Exceedance Report	4	2	8	32	256	$15,784.96

4.	RECORDKEEPING REQUIREMENTS	 	 	 	 	 	 

 	a.	Read Instructions	 	------------------------Included in
3a----------------------------	 	 	 	 

 	b.	Plan Activities	 	------------------------Included in
3b----------------------------	 	 	 	 

 	c.	Implement Activities	 	------------------------Included in
3b----------------------------	 	 	 	 

 	d.	Develop Record System	N/A	N/A	N/A	N/A	N/A	N/A

 	e.	Time to Enter Information	 	 	 	 	 	 

 	 	 	Record of Operating Parameters and Emissions	0.25	250	62.5	32
2,000	$123,320.00

 	 	 	Records of Startups, Shutdowns, Malfunctions	1	1	1	32	32
$1,973.12

 	f.	Train Personnel	N/A	N/A	N/A	N/A	N/A	N/A

 	g.	Audits	N/A	N/A	N/A	N/A	N/A	N/A

 	 	 	 	 	 	 	 	 	 

 	TOTAL ANNUAL BURDEN	 	 	 	 	2,288	$141,078

 	 	 	 	 	 	 	 	 	(rounded)















Assumptions	 	 







	Number of affected facilities	32	 







	Number of new facilities (per year)	0	 







	Time required to read instructions (hours)	1	 







	Time required to complete performance test (hours)	72	 







	Rate of failed performance tests	20%	 







	Time required to prepare semiannual report (hours)	4	 







	Time required to record operating parameters           (hours)	0.25	 







	Number of days operating per year	250	 







	Time required to record startups, shutdowns, malfunctions etc. (hours)
1	 







	Number of startups, shutdowns, malfuctions, etc.    (per year)	1	 







	Time required for notification preparation (hours)	2	 







	Technicial labor rate 	$61.66	 







	 	 





	

TABLE 2:	ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS	 	 
 	 	 	 

 

	NESHAP FOR WOOL FIBERGLASS MANUFACTURING PLANTS (40 CFR PART 63,
SUBPART NNN)



 

 











 

 	REPORTING/RECORDKEEPING REQUIREMENTS	Hours/ Occurrence     (A)
Occurrences/Year              (B)	Hours/Yr    (C=A*B)            (C)
Respdts/Year                       (D)	Technical Hours/Year (E)	Managmt
Hours/Year    (E*0.05)	Admin     Hours/Yr.   (E*0.1)	Hours/Year     (F)
Costs/Year                  (G)

1.	APPLICATIONS	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

2.	SURVEY AND STUDIES	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

3.	REPORTING REQUIREMENTS	 	 	 	 	 	 	 	 	 

 	a.	Read Instructions	1	1	1	0	0	0	0	0	$0.00

 	b.	Required Activities	 	 	 	 	 	 	 	 	 

 	 	 	Initial Performance Tests	980	1	980	0	0	0	0	0	$0.00

 	 	 	Repeat of Performance Tests	980	0.2	196	0	0	0	0	0	$0.00

 	 	 	Operations, Maintenance, Monitoring Plan	40	1	40	0	0	0	0	0
$0.00

 	 	 	Startup, Shutdown, and Malfunction Plan	40	1	40	0	0	0	0	0	$0.00

 	c.	Create Information	 	------------------------Included in
3b----------------------------	 	 	 	 	 	 	 

 	d.	Gather Existing Information	 	------------------------Included in
3b----------------------------	 	 	 	 	 	 	 

 	e.	Write Report	 	 	 	 	 	 	 	 	 

 	 	 	Notification of Applicability	2	1	2	0	0	0	0	0	$0.00

 	 	 	Notification of Construction/Reconstruction	2	1	2	0	0	0	0	0
$0.00

 	 	 	Notification of Actual Startup	2	1	2	0	0	0	0	0	$0.00

 	 	 	Notification of Special Compliance Requirements	2	1	2	0	0	0	0	0
$0.00

 	 	 	Notification of Initial Performance Test	2	1	2	0	0	0	0	0	$0.00

 	 	 	Notification of Compliance Status	2	1	2	0	0	0	0	0	$0.00

 	 	 	Request for Extension of Compliance, Adjustments to Time
Periods, and Changes in Information	2	1	2	0	0	0	0	0	$0.00

 	 	 	Report of Performance Test	 	------------------------Included
in 3b----------------------------	 	 	 	 	 	 	 

 	 	 	Excess Emissions Report	16	2	32	5.8	185.6	9.28	18.56	213.44
$12,991.26

 	 	 	Report of No Excess Emissions	1	2	2	23.2	46.4	2.32	4.64	53.36
$3,247.81

 	 	 	Quality Improvement Plan	40	1	40	0	0	0	0	0	$0.00

 	 	 	Startup, Shutdown, and Malfunction Report	8	2	16	2.9	46.4	2.32
4.64	53.36	$3,247.81

4.	RECORDKEEPING REQUIREMENTS	 	 	 	 	 	 	 	 	 

 	a.	Read Instructions	 	------------------------Included in
3a----------------------------	 	 	 	 	 	 	 

 	b.	Plan Activities	 	------------------------Included in
3b----------------------------	 	 	 	 	 	 	 

 	c.	Implement Activities	 	------------------------Included in
3b----------------------------	 	 	 	 	 	 	 

 	d.	Develop Record System	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

 	 	 	 	 	 	 	 	 	 	 	 	 

 	REPORTING/RECORDKEEPING REQUIREMENT	Hours/Occurence     (A)
Occurences/Year              (B)	Hours/Year    (C=A*B)            (C)
Respondents/Year                     (D)	Technical Hours/Year (E)
Management Hours/Year    (E*0.05)	Admin.      Hours/Yr.   (E*0.1)
Hours/Year     (F)	Costs/Year                 (G)

 	e.	Time to Enter Information	 	 	 	 	 	 	 	 	 

 	 	 	Record of Operating Parameters and Emissions	9	52	468	29	13,572
678.6	1,357.2	15,607.8	$949,985.71

 	f.	Train Personnel	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

 	g.	Audits	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

 	 	 	 	 	 	 	 	 	 	 	 	 

 	TOTAL ANNUAL BURDEN	 	 	 	 	13,850	693	1,385	15,928	$969,473

 	 	 	 	 	 	 	 	 	 	 	(rounded)	(rounded)



	Assumptions	 	 	 









	Number of affected plants	 	29	 









	Number of new plants (per year)	 	0	 









	Time required to read instructions (hours)	 	1	 









	Time required to complete performance test (hours)	 	980	 









	Rate of failed performance tests	 	20%	 









	Time required to prepare the Operation, Maintain, Monitoring Plan
(hours)	 	40	 









	Time required to prepare the Startup, Shutdown, and Malfunction Plan
(hours)	 	40	 









	Time required to prepare the Quality Improvement Plan (hours)	 	40	 









	Time required to record info required by standard (hours/week)	 	9	 









	Percent of plants required to submit startup, shutdown, malfuction
reports (per year)	 	10%	 









	Time required to prepare the Excess Emission Reports (hours)	 	16	 









	Percent of plants preparing Excess Emissions Reports 	 	20%	 









	Time required to prepare No Excess Emissions Reports (hours)	 	1	 









	Percent of plants preparing No Excess Emissions Reports	 	80%	 









	Time required for Startup, Shutdown, and Malfunction Reports	 	8	 









	Estimated number of requests for extension/adjustments to time
periods/changes in info (hours)	 	1	 









	Time required for notification preparation/requests for
extensions/adjustments to time periods/changes in info(hours)	 	2	 









	Management labor rate	 	$89.94	 









	Technical labor rate 	 	$61.66	 









	Administrative labor rate	 	$38.39	 









TABLE 3:	AVERAGE ANNUAL EPA RESOURCE REQUIREMENT







	NSPS FOR WOOL FIBERGLASS INSULATION MANUFACTURING (40 CFR PART 60,
SUBPART PPP)











	REPORTING/RECORDKEEPING REQUIREMENT	EPA Hours/Occurrence         (A)
Occurrences/Plant/Year       (B)	EPA Hours/   Year (C=A*B)  (C)
Plants/Year       (D)	EPA Hours/ Year (E=C*D)        (E)

INITIAL PERFORMANCE TESTS	 	 	 	 	 

 	New or Modified Facility	24	1	24	0	0

REPEAT PERFORMANCE TEST	 	 	 	 	 

 	New or Modified Facility	24	0.2	4.8	0	0

REPORT REVIEW	 	 	 	 	 

 	New or Modified Facility	 	 	 	 	 

 	 	Notification of Construction/Reconstruction	2	1	2	0	0

 	 	Notification of Actual Startup	1	1	1	0	0

 	 	Notification of Physical or Operational Change	2	1	2	0	0

 	 	Notification of Initial Performance Test	1	1.2	1.2	0	0

 	 	Review Performance Test Results	8	1.2	9.6	0	0

 	 	Review Semiannual Exceedance/No Exceedance Reports	2	2	4	32	128

TOTAL ANNUAL HOURS	 	 	 	 	128

 	 	 	 	 	 	 	 

TOTAL ANNUAL BURDEN	$5,055	 	 	 	 

 	 	 	(rounded)	 	 	 	 





























	Assumptions	 	 





	Number of new plants	0	 





	Number of existing plants	32	 





	Rate of failed performance tests	20%	 





	Time required to participate with performance test (per plant)	24	 





	Time require to review construction notification (hours)	2	 





	Time required to review startup and initial test notifications (hours)
1	 





	Time required to review performance test results (hours)	8	 





	Time required to review existing plant emission reports (hours)	2	 





	EPA labor rate	$39.49	 





	Percentage of new plant visits	100%	 





	 	 







TABLE 4:	AVERAGE ANNUAL EPA RESOURCE REQUIREMENT









	NESHAP FOR WOOL FIBERGLASS MANUFACTURING PLANTS (40 CFR PART 63,
SUBPART NNN)















	REPORTING/RECORDKEEPING REQUIREMENT	EPA Hours/ Occurrence      (A)
Occurrences/ Plant/Year       (B)	EPA Hours/   Year (C=A*B)     (C)
Plants/Year       (D)	Technical Hours/Year (E)	Management Hours/Year   
(E*0.05)	Admin.     Hours/Year   (E*0.1)	Total            Hours/ Year   
 (E=C*D)          (F)

INITIAL PERFORMANCE TESTS	 	 	 	 	 	 	 	 

 	New or Modified Facility	40	1	40	0	0	0	0	0

REPEAT PERFORMANCE TEST	 	 	 	 	 	 	 	 

 	New or Modified Facility	40	0.2	8	0	0	0	0	0

REPORT REVIEW	 	 	 	 	 	 	 	 

 	New or Modified Facility	 	 	 	 	 	 	 	 

 	 	Notification of Applicability	2	1	2	0	0	0	0	0

 	 	Notification of Construction/Reconstruction	2	1	2	0	0	0	0	0

 	 	Notification of Actual Startup	2	1	2	0	0	0	0	0

 	 	Notification of Special Compliance Requirements	1	1	1	0	0	0	0	0

 	 	Notification of Initial Performance Test	2	1	2	0	0	0	0	0

 	 	Notification of Compliance Status	2	1	2	0	0	0	0	0

 	 	Request for Extension of Compliance, Adjustments to Time Periods,
and Changes in Information	2	1	2	0	0	0	0	0

 	 	Quality Improvement Plan	40	1	40	0	0	0	0	0

 	 	Operations Maintenance and Monitoring Plan	40	1	40	0	0	0	0	0

 	 	Startup, Shutdown, and Malfunction Plan	40	1	40	0	0	0	0	0

 	 	Report of Performance Test	40	1	40	0	0	0	0	0

 	 	Excess Emissions Reports	20	2	40	5.8	232	11.6	23.2	267

 	 	Report of No Excess Emissions	2	2	4	23.2	92.8	4.64	9.28	107

 	 	Startup, Shutdown, and Malfunction Reports	20	2	40	2.9	116	5.8
11.6	133

TOTAL ANNUAL HOURS	 	 	 	 	 	 	440.8	22.04	44.08	507

TOTAL ANNUAL BURDEN	 	 	$19,523	(rounded)	 	 	 	 	 	 















Assumptions	 	 









Number of new plants	0	 









Number of existing plants	29	 









Rate of failed performance tests	20%	 









Time required to participate with performance test (per plant)	40	 









Time require to review notifications (hours)	2	 









Time required to review plans (hours)	40	 









Time required to review performance test results (hours)	40	 









Time required to review reports (e.g., excess emissions, startup,
shutdown, and malfunctions) (hours)	20	 









Percent of plants required to submit startup, shutdown, and malfunction
reports (per year)	10%	 









Percent of facilities required to prepare excess emissions reports	20%
 









Percent of facilities required to prepare no excess emissions reports
80%	 









Estimated number of extensions, adjustments to time periods, etc. (per
year)	1	 









EPA management labor rate	$53.22	 









EPA technical labor rate	$39.49	 









EPA administrative labor rate	$21.38	 









 	 







	

 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. 

 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.

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