Burden Calculation Table

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Overview

Summary
Table 1
Table 2
Capital O&M
Responses
Respondents
Test Cost Inputs

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Sheet 1: Summary

ICR Summary Information
Hours per Response	117
Number of Respondents	9
Total Estimated Burden Hours	2,440
Total Estimated Costs	$368,000
Annualized Capital O&M	$75,400
Total Annual Responses	20.8
Form Number	Not Applicable

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Sheet 2: Table 1

Table 1: Annual Respondent Burden and Cost – NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD) (Renewal)
					123.94	157.61	62.52
Burden Items	(A) Person hours per occurrence	(B) Occurrences per respondent per year	(C) Person hours per respondent per year (AxB)	(D) Respondents per year a	(E) Technical person hours per year (CxD)	(F) Managerial person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost per year, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements c
A. Familiarization with the regulatory requirements	4	1	4	9	36	1.8	3.6	$4,970.61
B. Required Activities
Initial performance test d	490	1	490	0	0	0	0	$0
Repeat performance test d, e	490	0.2	98	0	0	0	0	$0
Operations, maintenance, and monitoring plan f	40	1	40	0	0	0	0	$0
C. Create Information	See 3B
D. Gather Existing Information	See 3B
E. Write Reports
Notification of applicability g	2	1	2	0	0	0	0	$0
Notification of construction/ reconstruction g	2	1	2	0	0	0	0	$0
Notification of actual startup g	2	1	2	0	0	0	0	$0
Notification of special compliance requirements g	2	1	2	0	0	0	0	$0
Notification of initial performance test g	2	1	2	0	0	0	0	$0
Notification of compliance status g	2	1	2	0	0	0	0	$0
Request for extension of compliance adjustment to time periods, and changes in information g	2	1	2	0	0	0	0	$0
Report of performance test	See 3B
Excess emissions report h	16	2	32	1.8	57.6	2.88	5.76	$7,952.98
Report of no excess emission i	8	2	16	7.2	115.2	5.76	11.52	$15,905.95
Quality improvement plan j	40	1	40	1	40	2	4	$5,523
Subtotal for Reporting					286			$34,352.44
4. Recordkeeping Requirements
A. Familiarization with the regulatory requirements	See 3A
B. Plan Activities	See 3E
C. Implement Activities	See 3E
D. Develop Record System	See 3E
E. Time to Enter Information
Records of operating parameters and emissions k	4	52	208	9	1872	93.6	187.2	$258,471.72
F. Time to transmit or disclose information l	0.25	2	0.5	9	4.5	0.225	0.45	$621.33
G. Time to Train Personnel	N/A
H. Time for Audits	N/A
Subtotal for Recordkeeping					2,158			$259,093.05
Total Labor Burden and Cost (rounded) m					2,440			$293,000		117	hr per resp
Capital and O&M Cost (see Section 6(b)(iii)): m								$75,400
TOTAL COST: m								$368,000
Assumptions:
a We have assumed that the average number of respondents potentially subject to this rule is 9. There will be no additional new sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $147.40 for Managerial, $117.92 for Technical, and $57.02 for Clerical. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “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.
c We have assumed that it will take each respondent 4 hours to familiarize with the regulatory requirements.
d We have assumed that it will take 490 hours for each new respondent to complete an initial performance test based on the following: (1.56 cupolas plus 0.67 bonded lines = 2.23 sources per plant; 2.23 sources per plant x 130 hours per source +200 hours for calibration, retesting, sample analysis, etc) for a total of 490 hours.
e We have assumed that 20% of respondents will have to repeat performance test due to failure.
f We have assumed that each of the respondents will take 40 hours to prepare the operation, maintenance, and monitoring plan.
g We have assumed that each of the respondents will take 2 hours to write reports.
h We have assumed that 20% of respondents will each take 16 hours two times per year to write excess emission reports.
i We have assumed that 80% of respondents will take 8 hours two times per year to complete the report for no excess emissions.
j We have assumed that 10% of facilities are required to prepare a quality improvement plan each year.
k We have assumed that each respondent will take 4 hours 52 times per year to enter information.
l We have assumed that it will take each respondent 15 minutes (0.25 hours) two times per year to transmit of disclose information.
m Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 2

Table 2: Average Annual EPA Burden and Cost – NESHAP for Mineral Wool Production (40 CFR Part 63, Subpart DDD) (Renewal)
					52.37	70.56	28.34
Activity	(A) EPA Hours per occurrence	(B) Number of occurrences per Year	(C) EPA Hours per Year (AxB)	(D) Plants per Year a	(E) Technical Hours per Year (CxD)	(F) Managerial Hours per Year (Ex0.05)	(G) Clerical Hours per Year (Ex0.10)	(H) Total cost per year, $ b
Initial performance tests
New or modified facility	40	1	40	0	0	0	0	$0
Repeat performance tests
A. Familiarization with the regulatory requirements c	40	0.2	8	0	0	0	0	$0
Report review
Notification of applicability	2	1		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, adjustment to time periods, and changes in information	2	1	2	0	0	0	0	$0
Quality improvement plan d	40	1	40	1	40	2	4	$2,349
Operations, maintenance, and monitoring plan	40	1	40	0	0	0	0	$0
Report of performance test	40	1	40	0	0	0	0	$0
Excess emissions report e	20	2	40	1.8	72	3.6	7.2	$4,228.70
Report of no excess emissions f	2	2	4	7.2	28.8	1.44	2.88	$1,691.48
Review compliance test reports for COS for cupolas and formaldehyde, phenol, and methanol for collection/curing operations g	8	1	8	9	72	3.6	7.2	$4,228.70
Total Labor Burden and Cost (rounded) h					245			$12,500
Assumptions:
a We have assumed that the average number of respondents potentially subject to this rule is 9. There will be no additional new sources over the three-year period of this ICR.
b This ICR uses the following labor rates: $70.56 (GS-13, Step 5, $44.10 + 60%) for Managerial, $52.37 (GS-12, Step 1, $32.73 + 60%) for Technical, and $28.34 (GS-6, Step 3, $17.71 + 60%) for Clerical. These rates are from the Office of Personnel Management (OPM), 2022 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c We have assumed that 20% of respondents will fail the performance test.
d We have assumed that it will take 40 hours to review the quality improvement plan report.
e We have assumed that 20% of respondents will submit the excess emissions report and it will take 20 hours to review.
f We have assumed that 80% of respondents will submit the report of no excess emissions and it will take take 2 hours to review.
g Assumes Agency will review all of the annual reports - including the new COS, phenol, and methanol emissions testing.
h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Capital O&M

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M,
						(E X F)
Baghouse Leak Detection a, b	$27,738	0	$0	$931	9	$8,377
COS Testing b, c	$0	0	$0	$4,207	9	$37,867
HCl/HF Testing b, c	$0	0	$0	$1,267	9	$11,401
Phenol, methanol, formaldehyde testing b, c	$0	0	$0	$1,968	9	$17,712
Total d			$0			$75,400
a Capital/Startup and O&M costs for baghouse leak detection are estimated as follows: $14,900 capital/startup cost per cupola x 1.56 cupolas per facility; and $500 O&M per cupola x 1.56 cupolas per facility. These costs were adjusted from 2006 $ to 2020 $ using the CEPCI Index.
b We have assumed there are an average of 1.56 cupolas and 0.67 bonded lines per respondent.
c Test costs are based on the estimates from EPA-HQ-OAR-2010-1041-0171 adjusted from 2011 to 2020 $ using the CEPCI Index. We have assumed that the previously estimated cost to test for phenol/methanol after adjustment to the 2020 $ year is representative of the cost to test for phenol/methanol/formaldehyde. Based on EPA's experience with the NESHAP program and recent cost estimates for similar source categories, we assume that these estimates are reasonable for testing for all three of these pollutants.
d Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
			Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses
Information Collection Activity	Number of Respondents	Number of Responses		E=(BxC)+D
Notification of applicability	0	1	0	0
Notification of construction/reconstruction	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of special compliance requirements	0	1	0	0
Notification of initial performance test	0	1	0	0
Notification of compliance status	0	1	0	0
Excess emissions report	1.8	2	0	3.6
Report of no excess emissions	7.2	2	0	14.4
Performance test results for COS, HCl/HG, formaldehyde, phenol, and methanol 1	9	0.2	0	1.8
Quality improvement plan	1	1	0	1
			Total	20.8
1 Performance tests must be completed once every five years (1 report of performance test results/5 years = 0.2 reports per year per respondent).

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Sheet 6: Respondents

Number of Respondents
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	0	9	0	0	9
2	0	9	0	0	9
3	0	9	0	0	9
Average	0	9	0	0	9

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Sheet 7: Test Cost Inputs

1. Original Costs from EPA-HQ-OAR-2010-1041-0171
		Cupolasa			Combined Collection/Curing
		#	Annualized	Annualized	# Bonded	Annualized
		Cupolas	(New) COS	(New) HCl/HF	Lines	(New) Testing
Facility	Location		Testing Costb	Testing Costb		Costc	Total Facility Incremental Annualized (New) Costs
Industrial Insulation Group (IIG)	Phenix City, AL	1	2,800	800	1	3,000	$6,600
Thermafiber	Wabash IN	2	5,200	1,600	1	3,000	$9,800
USG	Red Wing, MN	2	5,200	1,600	0	0	$6,800
Interiors
USG	Walworth, WI	1	2,800	800	0	0	$3,600
Interiors
Amerrock Products	Nolanville, TX	2	5,200	1,600	0	0	$6,800
Isolatek Int’l	Huntington, IN	2	5,200	1,600	0	0	$6,800
Rock Wool Mfg	Leeds, AL	1	2,800	800	1	3,000	$6,600
Roxul USA	Byhalia, MS	2	5,200	1,600	2	5,400	$12,200
SubTotal		13	$34,400	$10,400	5	$14,400	$59,200
a – 8 of the 13 cupolas currently have (or will have) incineration/afterburner controls. None of the facilities are expected to have any additional equipment or material cost impacts to meet the proposed emission limits.
b – Cupola testing costs reflect incremental (new) costs for COS, HF, and HCl testing; current test requirements for PM not included.
c – Collection/curing costs reflect incremental costs for phenol and methanol testing; current test requirements for formaldehyde not included.
2. Updates for ICR Renewal 1799.11
Facility a	Location	# Cupolas b	Annualized COS Testing Cost c	Annualized HCl/HF Testing Cost c	# Bonded Lines b	Annualized Methanol/Phenol/Formaldehyde Testing Cost c	Total Facility Annualized Costs
Johns Manville (IIG)	Phenix City, AL	1	$2,850	$814	1	3,054	$6,718
Thermafiber (Owens Corning)	Wabash IN	2	$5,293	$1,629	1	3,054	$9,976
USG Interiors	Red Wing, MN	2	$5,293	$1,629	0	0	$6,922
USG Interiors	Walworth, WI	1	$2,850	$814	0	0	$3,665
American Rockwool	Nolanville, TX	2	$5,293	$1,629	0	0	$6,922
Isolatek	Huntington, IN	2	$5,293	$1,629	0	0	$6,922
Roxul USA	Byhalia, MS	2	$5,293	$1,629	2	5,497	$12,419
Rockwool (formerly Roxul)	Kearneysville, WV	1	$2,850	$814	1	3,054	$6,718
Thermafiber (Owens Corning)	Joplin, MO	1	$2,850	$814	1	3,054	$6,718
	Total	14	$37,867	$11,401	6	$17,712	$66,980
	Annual Average for One Respondent	1.56	$4,207	$1,267	0.67	$1,968	$7,442
a The revised facility list was provided by the North American Insulation Manufacturers Association (NAIMA). The American Rockwool facility in TX is not operating but is expected to come back online within the next year; therefore, it is included in the average number of respondents per year (9 respondents) for the three-year period covered by this ICR. We have assumed that repairs made at the facility do not meet the definition of a reconstructed source.
b We have assumed that the number of cupolas and bonded lines have not changed for existing facilities. We have assumed that the two facilities added to the list since the 2015 RTR each have 1 cupola and 1 bonded line.
c Costs per test are based on the estimates from EPA-HQ-OAR-2010-1041-0171 adjusted from 2011 to 2020 $ using the CEPCI Index. We have assumed that the previously estimated cost to test for phenol/methanol after adjustment to the 2020 $ year is representative of the cost to test for phenol/methanol/formaldehyde. Based on EPA's experience with the NESHAP program and recent cost estimates for similar source categories, we assume that these estimates are reasonable for testing for all three of these pollutants.