SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Wet-formed Fiberglass Mat Production (40 CFR part 63, subpart
HHHH) (Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

	NESHAP for Wet-formed Fiberglass Mat Production (40 CFR part 63,
subpart HHHH) (Renewal)

	1(b)  Short Characterization/Abstract

	The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Wet-formed Fiberglass Mat Production were proposed on May 26, 2000
(65 FR 34251), and promulgated on April 11, 2002 (67 FR 17823).  These
standards apply to new and existing component processes at industrial
facilities that manufactured wet-formed fiberglass mat including
preparation of glass fibers, formation of fibers into a fiberglass mat,
saturation with urea-formaldehyde binder solution, curing and drying the
binder-coated fiberglass mat, cooling the mat, and trimming, cutting,
and packaging.  This information is being collected to assure compliance
with 40 CFR part 63, subpart HHHH.

	The monitoring, recordkeeping, and reporting requirements outlined in
these rules are similar to those required for other NESHAP regulations. 
Consistent with the NESHAP General Provisions (40 CFR part 63, subpart
A), respondents are required to submit initial notifications, conduct
performance tests, and submit semiannual reports.  They are also
required to maintain records of applicability determinations;
performance test results; exceedances; periods of startup, shutdown, or
malfunction; monitoring records; and all other information needed to
determined compliance with the applicable standard.

	An owner or operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
five years following the date of such measurements, maintenance reports,
and records.  Records and reports must be retained for a total of 5
years, two years on-site.  The files may be maintained on microfilm, on
a computer or floppy disks, on magnetic tape disks, or on microfiche. 
All reports are sent to the delegated state or local authority.  In the
event that there is no such delegated authority, the reports are sent
directly to the United States Environmental Protection Agency (EPA)
regional office.

	In the development of this Information Collection Request (ICR), we
reviewed the Office of Management and Budget (OMB) “Terms of
Clearance” (TOC) section on the active ICR.  There were no comments in
the TOC section.

	The Agency has determined that there are 14 existing respondents, i.e.,
formed fiberglass mat production facilities which are major sources of
hazardous air pollutants (HAPs) that are currently subject to NESHAP,
subpart HHHH, based on data obtained during the development of this
rule.  In addition, we have determined that there is an average of one
production line per facility.  Therefore, there are 14 respondents
subject to this NESHAP regulation.  No net growth in this industry is
expected over the three-year period. 

 

2.  Need for and Use of the Collection

	2(a)  Need/Authority for the Collection

	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 (HAP).  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/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, metal hazardous air pollutants from
component processes at industrial facilities manufacturing wet-formed
fiberglass mat cause or contribute to air pollution that may reasonably
be anticipated to endanger public health or welfare.  Therefore, the
NESHAP standards were promulgated for this source category at 40 CFR
part 63, subpart HHHH.

	2(b) Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations that were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings. 
Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

	The notifications required in the standard 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, leaks are being detected and repaired,
and the standard is being met.  The performance test may also be
observed.

	The required semiannual compliance certifications are used to determine
periods of excess emissions, identify problems at the facility, verify
operation and maintenance procedures and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

	The requested recordkeeping and reporting are required under 40 CFR
part 63, subpart HHHH.

	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 (70 FR 24020) on May 6, 2005.  No
comments were received on the burden published in the Federal Register.

	3(c) Consultations

	Upon review of the standard, information available on the Agency
databases, and consultation with the Office of Air, Quality Planning and
Standards, we have determined that the recordkeeping and reporting
requirements in the “Active” ICR are fully supported and necessary
to fulfill the requirements of the Clean Air Act (CAA).  Any pertinent
comments received since the last ICR renewal including those submitted
in response to the first federal register notice announcing the renewal
of this ICR, have been reviewed, and it has been determined that no
further consultations with industry are necessary to calculate the
burden for this renewal.  It should be noted that the respondents, the
industry trade associations including the Technical Association of the
Pulp and Paper Industry (TAPPI) and the Asphalt Roofing Manufacturers
Association (ARMA), and other interested parties were provided an
opportunity to comment on the burden associated with the standard as it
was being developed.

	3(d) Effects of Less Frequent Collection

	Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and that emission limitations are met.  If the information
required by these standards was collected less frequently, the
likelihood of detecting poor operation and maintenance of control
equipment and noncompliance would decrease.

	3(e) General Guidelines

	None of these reporting or recordkeeping requirements violate any of
the regulations established by OMB at 5 CFR part 1320, section 1320.5.

	These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
the part 70 permit program and the five-year statute of limitations on
which the permit program is based.  Also, the retention of records for
five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  EPA would be prevented from pursuing the worst
violators due to the destruction or nonexistence of records if records
were retained for less than five years.

	3(f) Confidentiality

	Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, chapter 1, part 2, subpart B -
Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902,
September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR
42251, September 20, 1978; 44 FR 17674, March 23, 1979).

	3(g) Sensitive Questions

	None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

	4(a) Respondents/SIC Codes

	The respondents to the recordkeeping and reporting requirements are
owners or operators of wet-formed fiberglass mat production, which
provides the substrate for several roofing products.  The Standard
Industrial Classification (SIC) Code for wet-formed fiberglass mat
production is classified under SIC code 3329325, a subset of SIC code
3329, Pressed and Blown Glass, Not Elsewhere Classified, which under the
new North American Industrial Classification System (NAICS) codes would
be NAIC code 327212, Non-woven Fabric Mills.

	4(b) Information Requested

		(i) Data Items

	All data in this ICR that are recorded and/or reported are required by
NESHAP for Wet-formed Fiberglass Mat Production (40 CFR part 63, subpart
HHHH).

	A source must make the following reports:

Notification Reports

Initial notification requirements	63.9(b)(1)

Notification of compliance status when a source becomes subject to the
standard	63.9(h), 63.3000(b)

Notification that source is subject to special compliance requirements,
if applicable	63.9(d)

Notification of performance test	63.7(b), 63.9(e)

Rescheduled of performance test	63.7(b)(2)

Demonstration of continuous monitoring system	63.9(g)

Change in information already provided	63.9(j)

Request for an extension of compliance with relevant standard	63.9(c)



Reports

Application for approval of the construction or reconstruction of a new
major affected source, or reconstruction of a major affected source
63.5(6)(d)

Performance test results	63.10(d)(2),

63.3000(d)

Startup, shutdown and malfunction plan	63.6(e)(3)

Periodic startup, shutdown and malfunction reports	63.10(d)(5)(i),
63.3000(e)

Progress reports for compliance extension (if applicable)	63.6(i)

Semiannual compliance reports 	63.3000(b)



	A source must keep the following records:

Recordkeeping

Startup, shutdown and malfunction plan	63.6(e)(3)

All reports and notifications	63.10(b)(1)

Records of startup, shutdown, and malfunction of process equipment
63.10(b)(2)(i), (iv), (v)

Records of malfunctions of air pollution control equipment
63.10(b)(2)(ii)

Any applicability determination that demonstrates why owner or operator
believes source is unaffected	63.10(b)(3)

Records of maintenance of air pollution control equipment
63.10(b)(2)(iii)

Records of flow monitoring system performance evaluations, malfunctions,
calibrations, and adjustments	63.10(b)(2)(vi), (vii), (viii), (ix), (x),
(xi), 63.10(c)

Documentation required for waiver of recordkeeping or reporting
requirements (if applicable)	63.10(b)(2)(xii)

Documentation of initial notifications	63.10(b)(2)(xiv)

Five-year retention of records	63.10(b)(1), 63.2999(a)



		(ii)  Respondent Activities

Respondent Activities

Read instructions.

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.



	Regulatory agencies, to the extent possible, are relying more on
automated techniques such as electronic submissions of reports, and are
improving their tracking systems and database systems to enhance the use
of these techniques.  However, electronic reporting systems are still
not widely used.  At this time, it is estimated that approximately 10
percent of the respondents use electronic reporting.

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.  Data and records maintained by the
respondents are tabulated and published for use in compliance and
enforcement programs.  The report of annual compliance tests is used for
problem identification, as a check on source operation and maintenance,
and for compliance determinations.

	Information contained in the reports is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS is EPA’s
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses the AFS for tracking air pollution compliance and
enforcement by local and state regulatory agencies, EPA headquarters and
EPA regional offices.  EPA and its delegated Authorities can edit,
store, retrieve and analyze the data.

	The records required by this regulation must be retained by the
owner/operator for five years.

	5(c) Small Entity Flexibility

	Two of the 14 existing facilities subject to this NESHAP are classified
as small businesses under the Small Business Administration definition
(750 or fewer company employees).  However, the impact on small
businesses was accounted for in the regulation development.  Because
most of the monitoring and recordkeeping requirements in the final rule
are necessary to insure proper operation of emission control equipment,
plants will need to collect the information for their own records to
show compliance with the emission standards.  Thus, EPA does not expect
that any affected source, including small businesses, will experience
adverse impacts due to the reporting and recordkeeping requirements of
this rule.

	5(d) Collection Schedule

	The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Respondent Burden and Cost:
NESHAP for Wet-formed Fiberglass Mat Production (40 CFR part 63, subpart
HHHH) (Renewal).

6.  Estimating the Burden and Cost of the Collection

	Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

	The Agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB Control Number.

	6(a)  Estimating Respondent Burden

	The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 1,966
hours.  These hours are based on Agency studies and background documents
from the development of the regulation, Agency knowledge and experience
with the NESHAP program, the previously approved ICR, and any comments
received.

	6(b)  Estimating Respondent Costs

		(i)  Estimating Labor Costs 

	This ICR uses the following labor rates: 

		Managerial	$97.46   ($46.41 + 110%)

		Technical	$83.71   ($39.86 + 110%)

		Clerical	$42.55   ($20.26 + 110%)

	These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, “Table 2. Civilian Workers, by
occupational and industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

		(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

	The only types of industry costs associated with the information
collection activity in the regulations are labor costs.  There are no
capital/startup or operation and maintenance costs.  The capital/startup
costs are one-time costs when a facility becomes subject to the
regulation.  This is based on the assumptions that all existing sources
are in compliance with initial rule requirements and there will be no
new lines constructed over the three-year period of this ICR.  The
annual operation and maintenance costs are the ongoing costs to maintain
the continuous emission monitors and other costs such as photocopying
and postage.  We are not attributing to industry any O&M costs as a
result of this rule because the use of flow and temperature monitors at
thermal oxidizers are necessary to determine whether these are operating
properly.  

		(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

	There are no average annual costs to industry for capital/startup and
operation and maintenance associated with continuous monitoring
equipment over the next three years of the ICR due to the assumptions
discussed above.  This is shown on the OMB 83-I form in section 14 as
follows: block 4(a), Total annualized capital/startup costs; block
14(b), Total annual costs (O&M); 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 labor costs associated with analysis
of the reported information.  Respondents will bear the cost through
permit fees, for daily performance tests conducted at the plant by a
certified observer provided by the State enforcement agency.  EPA's
overall compliance and enforcement program includes activities such as
the examination of records maintained by the respondents, periodic
inspection of sources of emissions, and the publication and distribution
of collected information.

	The average annual Agency cost during the three years of the ICR is
estimated to be $21,760 (rounded).  This cost is based on the average
hourly labor rate as follows:

		Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

		Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

		Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2005
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Annual Burden and Cost
to the Federal/State Government: NESHAP for Wet-formed Fiberglass Mat
Production (40 CFR part 63, subpart HHHH) (Renewal).

	6(d)  Estimating the Respondent Universe and Total Burden and Costs

	Based on our research for this ICR, we have determined that there are
approximately 14 respondents subject to the regulation.  We have further
assumed that there will be no new lines constructed in the next three
years; therefore, there will be no new respondents.

	The number of respondents is calculated using the following table which
addresses the three years covered by this ICR.



Number of Respondents

	Respondents That Submit Reports	Respondents That Do Not Submit Any
Reports

	Year	(A)

Number of New Respondents 1	(B)

Number of Existing Respondents	(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	(D)

Number of Existing Respondents That Are Also New Respondents	(E)

Number of Respondents

(E=A+B+C-D)

1	0	14	0	0	14

2	0	14	0	0	14

3	0	14	0	0	14

Average	0	14	0	0	14

	1 New respondents include sources with constructed, reconstructed and
modified affected facilities.

	To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 14.  This number appears on the OMB 83-I form in block
13(a), Number of respondents.

	The number of Total Annual Responses is 32, as described below.  This
number is shown on the OMB 83-I form in block 13(b), Total annual
responses.

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	(E)

Total Annual Responses

E=(BxC)+D

Initial Notifications	0	5	0	0

Performance test reports	0	1	0	0

Semiannual compliance reports	14	2	0	28

Startup, shutdown and malfunction reports	2	2	0	4

Total



32



	The Total Hours Requested is shown on the OMB 83-I form in block 13(c).
 The total annual labor costs are 1,966.  The annual labor costs are not
shown on the OMB 83-I form.  Details regarding these estimates may be
found in Table 1. Annual Respondent Burden and Cost: NESHAP for
Wet-formed Fiberglass Mat Production (40 CFR part 63, subpart HHHH)
(Renewal), attached.

	There are no annualized capital/startup and O&M costs to the regulated
entities subject to the regulation.  This number is shown on the OMB
83-I form in block 14(c), Total annualized cost requested.  The cost
calculations are detailed in Section 6(b) (iii), Capital/Startup vs.
Operation and Maintenance (O&M) Costs.

	The average annual Agency burden and cost over next three years is
estimated to be 501 labor hours at a cost of $20,270 (rounded).  See
Table 2. Annual Agency Burden and Cost: NESHAP for Wet-formed Fiberglass
Mat Production (40 CFR part 63, subpart HHHH) (Renewal).

	6(e)  Bottom Line Burden Hours and Cost Tables

	The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

		(i)  Respondent Tally

	The Total Hours Requested is shown on the OMB 83-I form in block 13(c).
 The total annual labor costs are $158,672.  The annual labor costs are
not shown on the OMB 83-I form.  Details regarding these estimates may
be found in Table 1. Annual Respondent Burden and Cost: NESHAP for
Wet-formed Fiberglass Mat Production (40 CFR part 63, subpart HHHH)
(Renewal), attached.

	There are no annualized capital/startup and O&M costs to the regulated
entities.  This number is shown on the OMB 83-I form in block 14(c),
Total annualized cost requested.  The cost calculations are detailed in
Section 6(b) (iii), Capital/Startup vs. Operation and Maintenance (O&M)
Costs.

		(ii)  The Agency Tally

	The average annual Agency burden and cost over next three years is
estimated to be 501 labor hours at a cost of $20,270.  See Table 2.
Annual Agency Burden and Cost: NESHAP for Wet-formed Fiberglass Mat
Production (40 CFR part 63, subpart HHHH) (Renewal), attached.

	6(f)  Reasons for Change in Burden

	The decrease in labor burden to industry from the most recently
approved ICR from 2,983 hours to 1,966 hours is due to adjustments.  The
decrease in burden from the most recently approved ICR is due to the
assumptions that existing sources are in compliance with the initial
rule requirements, and that there will be no new lines constructed over
the three-year period of this ICR.

	The total annualized capital and operations and maintenance costs
decreased from $2,000 to $0 due to the lack of capital/startup costs
associated with new sources purchasing continuous emission monitoring
equipment.  In addition, we have determined that any operation and
maintenance (O&M) costs associated with the use of flow and temperature
monitors at thermal oxidizers cannot be attributed to this standard
because these monitors are standard equipment in oxidizers used to
determine whether these are operating properly.

	The Federal government burden significantly decreased (from 3,227 hours
to 501 hours) due to the deletion of burden and costs associated with
the review of initial reports, inspection activities, and litigation
costs.  The inspection category includes travel costs and labor burden
associated with inspections, which are activities that are exempt under
the Paperwork Reduction Act.  Litigation costs are associated with the
rule development processes which have been completed.

	There was also an increase in labor rates for both industry and the
Federal government; however, it did not offset the reduction in labor
burden due to all the assumptions stated above.

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 61 (rounded) 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-2005-0048, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  www.regulations.gov  , or in
person viewing at the Enforcement and Compliance Docket and Information
Center in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301
Constitution Ave., NW, Washington, DC.  The EPA Docket Center Public
Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday,
excluding legal holidays.  The telephone number for the Reading Room is
(202) 566-1744, and the telephone number for the Enforcement and
Compliance Docket and Information Center Docket is (202) 566-1752.  An
electronic version of the public docket is available at
www.regulations.gov.  T+his site can be used to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the Docket ID Number identified above.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2005-0048 and OMB Control Number 2060-0496 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 Respondent Burden and Cost:  NESHAP for Wet-formed
Fiberglass Mat Production (40 CFR part 63, subpart HHHH) (Renewal)

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per 	year

(Ex0.1)	

(H)

Cost, $  b



1.  Applications	N/A







	

2.  Survey and Studies	N/A







	

3.  Acquisition, Installation,         and Utilization of  Technology
and  Systems	N/A	

	

	

	

	

	

	





4.  Reporting Requirements











  A.  Read instructions	1	1	1	0	0.0	0.0	0.0	$0.00



  B.  Required activities:











    i.  Initial Performance tests:  c    	

200	

1	

200	

0	

0.0	

0.0	

0.0	

$0.00



    ii.  Repeat of performance test	

200	

1	

200	

0	

0.0	

0.0	

0.0	

$0.00



    iii.  Monitoring of operations         and equipment:  d	

Included in 5E









    iv.  Operation, maintenance,          monitoring plan	

40	

1	

40	

0	

0.0	

0.0	

0.0	

$0.00



    v.  Startup, shutdown,                    malfunction plan	

40	

1	

40	

0	

0.0	

0.0	

0.0	

$0.00



  D.  Gather Existing Information	Included in 4B and 5E









  E.  Write report   a, c 











    i.  Notification of compliance        status 	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



    ii.  Notification of actual                startup	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



    iii.  Notification of                         construction/
reconstruction   a	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



    iv.  Notification of                         performance test 	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



    v.  Notification of actual                startup	

2	

1	

2	

0	

0.0	

0.0	

0.0	

$0.00



    vi.  Reports of performance           test results	

4	

1	

4	

0	

0.0	

0.0	

0.0	

$0.00



    vii.  Report of monitoring              exceedances  e      	

16	

2	

32	

11.2	

358.4	

17.9	

35.8	

$33,270.18



    viii.  Report of no excess               emission  e	

8	

2	

16	

2.8	

44.8	

2.2	

4.5	

$4,155.24



    ix.  Startup, shutdown,           

    malfunction report   f	

8	

2	

16	

2	

32	

1.6	

3.2	

$2,970.82



5.  Recordkeeping Requirements











  A.  Read instructions	Included in 4A









  B.  Plan activities	Included in 4B









  C.  Implement activities	Included in 4B









  D.  Develop record system	

N/A









  E.  Time to enter and transmit all   information required by the rule
g	

1.75	

52	

91	

14	

1,274	

63.7	

127.4	

$118,275.61



  F.  Time to train personnel	

N/A	

	

	

	

	

	

	





  G. Time for audits	

N/A	

	

	











TOTAL LABOR  BURDEN AND COST  	

	

	

	

	

1,709.2	

85.5	

170.9	

$158,671.85



TOTAL LABOR HOURS (Rounded)	

	

	

	

	

1,966	

$158,672



Assumptions:

a  There are an estimated 14 respondents (i.e., wet-formed fiberglass
mat production facilities), 13 with one production line and one with two
lines, which are subject to this standard.  We have assumed that there
will be no new lines constructed over the three year period of this ICR.


b This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, “Table 2.Civilian Workers, 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.

c We have assumed that all sources are in compliance with initial rule
requirements including the initial performance test.  The rule requires
a performance test every five years since the initial test was
conducted; however, this requirement would not be applicable for this
ICR renewal.  We have estimated that each performance test will take
approximately 21 hours to complete it since sources will be using EPA
Method 316 to measure formaldehyde and applicable test methods specified
in the NESHAP to determine resin free-formaldehyde content and the
loss-on-ignition of the fiberglass mat.  In addition, we have assumed
that it will take approximately 200 hours to conduct the pretest survey,
equipment calibration, and sample analysis and report preparation for a
total of 221 hours per performance test.   We have further assumed that
20 percent of the performance tests fail and will have to be repeated.

d  Monitoring of operations include: 1) monitoring operating parameters
for control equipment (i.e., thermal oxidizer or other control
equipment); 2) urea-formaldehyde (UF) resin solids application rate; 3)
resin-free formaldehyde content; 4) loss-on-ignition; 5) UF-to-latex
ratio in the binder; 6) weight of the final mat product per roofing
square; and 7) average nonwoven wet-formed fiberglass mat production
rate (roofing square per hour).

e We have assumed that approximately 80 percent of the 14 respondents
(or 11.2) will report no excess emissions twice a year and approximately
20 percent (or 2.8) will report no excess emissions twice a year.  

f We have assumed that 2 of the 14 facilities will have a startup,
shutdown or malfunction (SSM) that is not managed according to the SSM
plan.

g We have assumed it takes each source approximately 1.75 hours per week
to record and transmit the information and that a year will consist of
52 weeks.

Table 2.  Annual Agency Burden and Cost: 

NESHAP for Wet-formed Fiberglass Mat Production (40 CFR part 63, subpart
HHHH) (Renewal)

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

per year

	

(C)

EPA person-

hours per

plant per

year

(C=AxB)	

(D)

Plants

per

year  a

	

(E)

Technical

person-hours

per year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)

	

(G)

Clerical

person-

hours per

year

(Ex0.1)

	

(H)

Cost, $ b



Initial  Notifications: applicability, performance test, compliance
status   a 	

2	

3	

6	

0	

0	

0	

0	

$0.00



Review reports of excess emissions   c	

16	

2	

32	

11.2	

358.4	

17.9	

35.8	

 $16,692.84 



Review reports of no excess 

emissions   c	

8	

2	

16	

2.8	

44.8	

2.24	

4.5	

$2,086.61



Review of startup, shutdown, malfunction report  d	

8	

2	

16	

2 ADVANCE \u2 i ADVANCE \d2 	

32	

1.60	

3.2	

$1,490.43



Subtotal Burden and Cost	

	

	

	

	

435.2	

21.8	

43.5	

$20,269.88



TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	

501	

$20,270



Assumptions:

a   There are an estimated 14 respondents (i.e., wet-formed fiberglass
mat production facilities), 13 with one production line and one with two
lines, which are subject to this standard.  We have assumed that all
sources are in compliance with initial rule requirements and that there
will be no new lines constructed over the three year period of this ICR.
b   This cost is based on the following labor rates which incorporates
a 1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $22.50 (GS-6, Step 3, $14.06 x 1.6).  These rates are from the
Office of Personnel Management (OPM) “2005 General Schedule” which
excludes locality rates of pay.  

c   We have assumed that approximately 80 percent of the 14 respondents
(or 11.2) will report no excess emissions twice a year and approximately
20 percent (or 2.8) will report no excess emissions twice a year.  

d   We have assumed that two of 14 respondents per year will have a
startup, shutdown, or malfunction occurrence that is not managed
according to the plan.

  

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