2481ss01

SUPPORTING STATEMENT

NESHAP for Gas-Fired Melting Furnaces Located at Wool Fiberglass Manufacturing Area Sources (40 CFR part 63, subpart NN) (Proposed Rule)

PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection.

NESHAP for Gas-Fired Melting Furnaces Located at Wool Fiberglass Manufacturing Area Sources (40 CFR part 63, subpart NN), EPA ICR number is 2481.01, OMB Control Number 2060-NEW

(b) Short Characterization.

This ICR covers information collection requirements in the proposed NESHAP for Wool Fiberglass Manufacturing Area Sources (40 CFR part 63, subpart NN).

The potential respondents are owners or operators of any existing, new, or reconstructed Wool Fiberglass Manufacturing facilities. Per the applicability section of subpart NN, only the gas-fired glass-melting furnaces at a Wool Fiberglass Manufacturing facility, and that is located at a plant site that is an area source as defined in 40 CFR part 63.2. There are an estimated 30 facilities currently producing Wool Fiberglass, but because the industry is moving away from phenol-formaldehyde binders, we estimate that 20 facilities are currently area sources of HAP emissions on the compliance date for the final area source NESHAP. We estimate that 5 current facilities with 8 gas-fired glass-melting furnaces will be subject to the area source requirements. We also estimate that some additional major source facilities with gas-fired furnaces will become area sources in the next few years and will be subject to the area source requirements. However, we are not including any costs for those new facilities (based on potential reclassification as area sources) to avoid double counting costs since those facilities will be complying with the major source rule requirements

The proposed amendments would require specific emission limits for PM (surrogate for HAP metals) and chromium compounds from gas-fired glass-melting furnaces. The proposed emission limits for chromium compounds can be met by installing add-on air pollution control equipment such as a sodium hydroxide scrubber, or changing the brick refractories in the glass-melting furnaces. The proposed PM emission limit is currently being met by all facilities. The proposed requirements are explained further in the following paragraphs.

The information collection requirements associated with the proposed area source NESHAP are listed in Attachment 1.

2. Need For and Use of the Collection

(a) Need/Authority for the Collection.

Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP for both major and area sources of HAP that are listed for regulation under CAA section 112(c). A major source is a stationary source that emits or has the potential to emit more than 10 tons per year (tpy) of any single HAP or more than 25 tpy of any combination of HAP. An area source is a stationary source that is not a major source (i.e., an area source does not emit and does not have the potential to emit more than 10 tpy of any single HAP and more than 25 tpy of any combination of HAP). For major sources, these technology-based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, energy requirements, and non-air quality health and environmental impacts) and are commonly referred to as maximum achievable control technology (MACT) standards. Section 112(d)(6) requires EPA to review these technology-based standards and to revise them “as necessary (taking into account developments in practices, processes, and control technologies)” no less frequently than every 8 years. In addition, section 112(f) of the CAA requires EPA to determine for source categories subject to certain CAA section 112(d) standards whether the emissions limitations provide an ample margin of safety to protect public health. For MACT standards for HAP “classified as a known, probable, or possible human carcinogen" that "do not reduce lifetime excess cancer risks to the individual most exposed to emissions from a source in the category or subcategory to less than 1-in-1 million,” EPA must promulgate residual risk standards for the source category (or subcategory) as necessary to provide an ample margin of safety to protect public health. In doing so, EPA may adopt standards equal to existing MACT standards, if EPA determines that the existing standards are sufficiently protective. EPA must also adopt more stringent standards, if necessary, to prevent an adverse environmental effect, but must consider cost, energy, safety, and other relevant factors in doing so.

Certain records and reports are necessary for the Administrator to confirm the compliance status of sources subject to NESHAP, identify any new or reconstructed sources subject to the standards, and confirm that the standards are being achieved on a continuous basis. These recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and 40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

(b) Use/Users of the Data.

The information will be used by the delegated authority (State agency, or Regional Administrator if there is no delegated State agency) to ensure that the standards and other requirements are being achieved. Based on review of the recorded information at the site and the reported information, the delegated permitting authority can identify facilities that may not be in compliance and decide which facilities, records, or processes may need inspection.

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.

A computer search of EPA’s ongoing ICRs revealed no duplication of information-gathering efforts.

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

The preamble to the proposed rule provided public notice of this ICR.

(c) Consultations.

The proposed amendments were developed in consultation with individual companies, State agencies, and trade associations. The non-EPA persons consulted on the information collection activities are identified in Table 1.

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES

Contact	Organization	Telephone No.
Angus Crane	North American Insulation Manufacturers Association	703-684-0084
Mike Pettis	Owens Corning	740-827-7087
Carlos Davis	CertainTeed Corporation	913-342-6624
Steve Aldridge	Knauf Insulation	317-398-4434
Jeffrey Tarde	Johns Manville	303-978-2161

(d) Effects of Less Frequent Collection.

If the relevant information was collected less frequently, the delegated permitting authority (State or EPA) will not be reasonably assured that a facility is in compliance with the standards.

(e) General Guidelines.

None of the guidelines in 5 CFR 1320.6 are being exceeded.

(f) Confidentiality.

All 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 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).

(g) Sensitive Questions.

This section is not applicable because this ICR does not involve matters of a sensitive nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes.

Potential respondents under subpart NN are owners or operators of any existing or new facility engaged in Wool Fiberglass Manufacturing operations. Wool Fiberglass Manufacturing facilities are primarily classified under NAICS code 327993, Mineral Wool Manufacturing.

There are an estimated 5 facilities that would be subject to the proposed area source NESHAP. There are currently 8 gas-fired glass-melting furnaces at these 5 facilities and 3 of those furnaces would require additional controls to meet the proposed chromium compound emission limit. We are not aware of any new Wool Fiberglass Manufacturing facilities being constructed; however, we do expect most, if not all of the remaining major source facilities to convert to non-HAP binders and become area sources. However, we are not including any costs for new area sources during the 3­year period of this ICR to avoid double counting costs associated with the major source rule (subpart NNN) proposed amendments.

(b) Information Requested.

(i) Data Items, Including Recordkeeping Requirements. Attachment 1, Information Requirements, summarizes the data items, including recordkeeping and reporting requirements, for the Wool Fiberglass Manufacturing source category.

(ii) Respondent Activities. The respondent activities that will be required by the proposed Wool Fiberglass Manufacturing NESHAP for area sources are identified in Table 2 and are introduced in section 6(a).

5. The Information Collected–Agency Activities, Collection Methodology, and Information Management

(a) Agency Activities.

The Agency activities associated with the proposed area source Wool Fiberglass Manufacturing NESHAP are provided in Table 3 and are introduced in section 6(c).

(b) Collection Methodology and Management.

Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs of the delegated permitting authority. EPA is the permitting authority until the State agency is delegated authority to implement the final amendments to the rule. Therefore, information contained in any report submitted to the Regional Administrator will be 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 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 regional offices and EPA headquarters. EPA and its delegated authorities can edit, store, retrieve and analyze the data.

(c) Small Entity Flexibility.

The Small Business Administration defines a small entity engaging in Wool Fiberglass Manufacturing operations as a firm having no more than 500 employees. There are three companies operating the five Wool Fiberglass Manufacturing facilities that are expected to be affected by this rule and none of the three companies are small businesses. The proposed area source NESHAP would not result in significant adverse impacts on any of the small entities. The proposed area source NESAHP would create new requirements for compliance testing for existing sources and associated notification requirements, recordkeeping, and reporting requirements.

(d) Collection Schedule.

The specific frequency for each information collection activity within this request is shown in Table 2 for the Wool Fiberglass Manufacturing Source Category.

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

The annual burden estimates for the proposed Wool Fiberglass Manufacturing NESHAP for Area Sources are shown in Table 2. These numbers were derived from estimates based on EPA’s experience with other standards. As discussed previously, there are no burden estimates provided for new sources during the 3­year period of this ICR to avoid double counting costs associated with the major source rule (subpart NNN) proposed amendments.

(b) Estimating Respondent Costs.

The information collection activities for the proposed Wool Fiberglass Manufacturing NESHAP for Area Sources are presented in Table 2. Because the data are already collected by respondents as part of normal operations, no respondent development costs are associated with the information collection activities.

(i) Estimating Labor Costs. Labor rates and associated costs are based on Bureau of Labor Statistics (BLS) data. Technical, management, and clerical average hourly rates for private industry workers were taken from the United States Department of Labor, Bureau of Labor Statistics, Occupational Employment and Wages, May 2011 available at http://www.bls.gov/oes/current/naics4_327200.htm. Wages for technical labor are based on "Glass and Glass Product Manufacturing – architectural and engineering," with a total compensation of $38.54/hour. Wages for management labor are taken from "Glass and Glass Product Manufacturing – management, business, and financial," with a total compensation of $58.29/hour. Wages for clerical labor are based on "Glass and Glass Product Manufacturing – production, planning, and expediting clerks," with a total compensation of $21.11/hour. These rates represent salaries plus fringe benefits and do not include the cost of overhead. An overhead rate of 110 percent is used to account for these costs. The fully-burdened hourly wage rates used to represent respondent labor costs are: technical at $80.93 /hour, management at $122.41 /hour, and clerical at $44.33 /hour.

(ii) Estimating Capital and Operations and Maintenance (O&M) Costs. No capital costs or O & M costs are associated with the information collection requirements of the proposed area source Wool Fiberglass Manufacturing NESHAP. The proposed area source rule would require affected facilities to purchase new monitoring systems and conduct new performance testing.

(iii) Annualizing Capital Costs. No capital costs associated with the information collection requirements of the proposed area source Wool Fiberglass Manufacturing NESHAP.

(c) Estimating Agency Burden and Cost.

Because the information collection requirements were developed as an incidental part of standards development, no costs can be attributed to the development of the information collection requirements. Because reporting and recordkeeping requirements on the part of the respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the part 63 NESHAP General Provisions, no operational costs will be incurred by the Federal Government. Publication and distribution of the information are part of the Compliance Data System, with the result that no Federal costs can be directly attributed to the ICR. Examination of records to be maintained by the respondents will occur incidentally as part of the periodic inspection of sources that is part of EPA’s overall compliance and enforcement program, and, therefore, is not attributable to the ICR. The only costs that the Federal government will incur are user costs associated with the analysis of the reported information, as presented in Table 3.

The Agency labor rates are from the Office of Personnel Management (OPM) 2010 General Schedule, which excludes locality rates of pay. These rates can be obtained from Salary Table 2010-GS available on the OPM website, http://www.opm.gov/oca/12tables/pdf/gs_h.pdf. The government employee labor rates are $15.63/hour for clerical (GS-6, Step 3), $28.88 for technical (GS-12, Step 1), and $38.92/hr for management (GS-13, Step 5). These rates were increased by 60 percent to include fringe benefits and overhead. The fully-burdened wage rates used to represent Agency labor costs are: clerical at $25.01/hour; technical at $46.21/hour, and management at $62.27/hour.

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

There are an estimated 30 existing facilities that are currently manufacturing wool fiberglass in the United States. However, industry is eliminating phenol-formaldehyde binders from their bonded products and we estimate that there will be five existing facilities subject to the proposed area source requirements during the next 3 years. Consequently, the average number of wool fiberglass respondents during the 3-year period of this ICR is 5 facilities / 3 = 1.67.

For the proposed Wool Fiberglass Manufacturing NESHAP for Area Sources, the components of the total annual burden attributable to this ICR include reading the area source NESHAP; conducting the performance testing to demonstrate compliance with the proposed PM and chromium compounds emission limits; reporting the results of those emissions tests; and complying with all other monitoring, recordkeeping and reporting activities for the NESHAP.

(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent tally. The bottom line respondent burden hours and costs, presented in Table 2 are calculated by adding person-hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column. The average annual burden for the recordkeeping and reporting requirements in the proposed area source NESHAP (subpart NN) for the five existing facilities with gas-fired furnaces that are subject to the Wool Fiberglass Manufacturing NESHAP for Area Sources is 77 person-hours, with an annual average cost of $32,808. No capital costs would be expected for the proposed rule requirements.

(ii) The Agency tally. The average annual Federal Government cost is $695 for 15 hours for the proposed subpart NN requirements. The bottom line Agency burden hours and costs presented in Table 3 are calculated by adding person-hours per year down each column for technical, managerial, and clerical staff, and by adding down the cost column.

(iii) Variations in the annual bottom line. This section does not apply since no significant variation is anticipated.

(f) Reasons for Change in Burden.

This is a new ICR, covering information collection requirements in the proposed NESHAP for Wool Fiberglass Manufacturing Area Sources (40 CFR part 63, subpart NN).

(g) Burden Statement

The average annual respondent burden for the proposed Wool Fiberglass Manufacturing NESHAP for Area Sources is estimated at 15 hours per facility.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9.

To comment on the Agency’s need for this information the accuracy of the provided burden estimates, and any suggestions for minimizing respondent burden, including through the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OAR-2010-1042 which is available for online viewing at http://www.regulations.gov, or in person viewing at the Air and Radiation 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 Air Docket is (202) 566-1742. An electronic version of the public docket is available at http://www.regulations.gov. This 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 17^th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID Number (EPA-HQ-OAR-2010-1042) and OMB Control Number (2060-NEW) in any correspondence.

PART B

This section is not applicable because statistical methods are not used in data collection associated with the proposed rule.

TABLE 2. ANNUAL RESPONDENT BURDEN AND COST -- WOOL FIBERGLASS MANUFACTURING NESHAP AREA SOURCES

Burden item	(A) Person-hours per occurrence	(B) No. of occurrences per respondent	(C) Person-hours per respondent (C=A*B)	(D) Respondents per year	(E) Technical person-hours per year (E=C*D)	(F) Management person-hours per year (E*0.05)	(G) Clerical person-hours per year (E*0.1)	(H) Costa, $
1. Applications	N/A
2. Surveys and Studies	N/A
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A
4. Reporting Requirements
A. Read instructionsb	4	1	8	1.67	13.4	0.7	1.3	$1,216
B. Required activitiesc (compliance testing)	$16,000	1		1.67				$26,720
C. Create informationd	8	2	16	1.67	26.7	1.3	2.7	$2,440
D. Gather existing information	N/A
E. Write report	8	1	8	1.67	13.4	0.7	1.3	$1,216
5. Recordkeeping Requirements
A. Read instructions	See 4A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information	See 4C
F. Time to train personnel	N/A
G. Time to adjust existing ways to comply with previously applicable requirements	N/A
H. Time to transmit or disclose information	8	1	8	1.67	13.4	0.7	1.3	$1,216
I. Time for audits	N/A
TOTAL LABOR BURDEN AND COST (SALARY)					66.9	3.4	6.6	$32,808
TOTAL NUMBER OF ANNUAL RESPONSES	5
ANNUAL CAPITAL COSTSd
TOTAL ANNUALIZED COSTS								$32,808

N/A = not applicable.

^a This ICR uses the following labor rates: $122.41 for managerial labor, $80.93 for technical labor, and $44.33 for clerical labor. These rates are based on the U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment and Wages, May 2011.

^b An estimated 5 existing facilities and no new facilities (5 total) are expected to have gas-fired furnaces and be subject to subpart NN; the average number expected to read the rule during the 3-yr compliance period is 5 / 3 = 1.67.

^c The average facility cost for PM and Cr compound testing was calculated to be: (8 gas-fired furnaces) x ($10,000 per test) = $80,000 / 5 facilities = $16,000.

^d There would be no capital costs associated with the reporting and recordkeeping requirements of the proposed area source NESHAP.

3. ANNUAL BURDEN AND COST TO THE AGENCY ---- WOOL FIBERGLASS MANUFACTURING NESHAP AREA SOURCES

Burden item	(A) Person-hours per occurrence	(B) Occurrences per respondent	(C) EPA person-hours/year (C=A*B)	(D) Facilities per year	(E) Technical person-hours/year (E=C*D)	(F) Management person-hours/year (F=0.05*E)	(G) Clerical person-hours/year (G=0.1*E)	(H) Costa, $
Report Review:
Review compliance test reports for PM and Cr compounds for gas-fired furnaces	8	1	8	1.67	13.4	0.7	1.3	$695
TOTAL BURDEN AND COST								$695

^a This ICR uses the following average hourly labor rates: $62.27 for managerial (GS-13, Step 5), $46.21 (GS-12, Step 1) for technical, and $25.01 (GS-6, Step 3) for clerical. These rates are from the Office of Personnel Management (OPM) 2011 General Schedule, which excludes locality rates of pay.

ATTACHMENT 1. INFORMATION REQUIREMENTS ---- WOOL FIBERGLASS MANUFACTURING NESHAP AREA SOURCES

Requirement	Citation for existing sources	Citation for new sources	General Provisions citation
PM and Cr compound limit for gas-fired glass-melting furnaces	§ 63.882(a)(1)(iii)	§ 63.882(a)(1)(iii)
Notifications	§ 63.886(a)	§ 63.886(a)	N/A
Plans
Operation and Maintenance Plan	N/A	N/A	N/A
Records
Monitoring/inspection information	§ 63.883	§ 63.883	N/A
Reports	§ 63.886(b) and (c)	§ 63.886(b) and (c)	40 CFR 63.10(e)

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