Burden Calculation Tables

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Overview

Summary
Table 1a
Table 1b
Table 2a
Table 2b
Capital O&M
Responses
Respondents

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Sheet 1: Summary

ICR Summary Information
Hours per Response 40 CFR Part 60, Subpart PPP	42
Hours per Response 40 CFR Part 63, Subpart NNN	285
Number of Respondents	38
Total Estimated Burden Hours	5,580
Total Estimated Costs	$1,250,000
Annualized Capital O&M	$585,000
Total Annual Responses	76

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Sheet 2: Table 1a

Table 1a: Annual Respondent Burden and Cost – NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP) (Renewal)
					123.94	157.61	62.52
Burden Items	(A) Hours per Occurrence	(B) Occurrences per Year	(C) Hours per Year (C=AxB)	(D) Respondents per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c	1	1	1	32.33	32.33	1.62	3.23	$4,464.34
B. Required activities
Initial performance tests d	72	1	72	0.33	24.00	1.20	2.40	$3,314
Repeat performance tests e	72	0.2	14.4	0.07	0.96	0.05	0.10	$133
C. Create information
D. Gather existing information
E. Write Report
Notification of construction/reconstruction f	2	1	2	0.33	0.67	0.03	0.07	$92
Notification of actual startup f	2	1	2	0.33	0.67	0.03	0.07	$92
Notification of physical or operational change f	2	1	2	0	0.00	0.00	0.00	$0
Notification of initial performance test f	2	1	2	0.33	0.67	0.03	0.07	$92
Report of performance test	See 3B
Semiannual exceedance report g	4	2	8	32.33	258.67	12.93	25.87	$35,714.75
Subtotal for Reporting Requirements					366			$43,902
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
40 CFR Part 60, Subpart PPP
Records of operating parameters and emissions h, i	0.25	250	62.5	32.33	2,021	101.04	202.08	$279,022
Records of startups, shutdowns, and malfunctions j	1	1	1	32.33	32.33	1.62	3.23	$4,464.34
F. Train Personnel	N/A
G. Audits	N/A
Subtotal for Recordkeeping Requirements					2,361			$283,486
TOTAL LABOR BURDEN AND COST (rounded) k					2,730			$327,000		2,730
TOTAL CAPITAL AND O&M COSTS (rounded) k								$533,445
GRAND TOTAL (rounded) k								$860,000		42	hours per response
Assumptions:
a We have assumed that there are approximately 32 respondents, with 1 additional new or reconstructed source becoming subject to the rule in the next three years (an average of 0.33 new respondents per year).
b This ICR uses the following labor rates: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We have assumed that all existing respondents will each take one hour to re-familiarize with the regulatory requirements each year.
d We assume that it will take each respondent 72 hours to complete initial performance tests.
e We assume that 20 percent of respondents will have to repeat the initial performance tests due to failures.
f We assume that each respondent will take two hours to prepare notification reports.
g We assume that each respondent will take four hours to prepare semiannual report.
h We assume that 0.25 hours is required to record operating parameters.
i We assume that each respondent will enter operating parameters and emissions records 250 days per year.
j We assume that it will take one hour per year for each respondent to record startups, shutdowns, malfunctions.etc.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Table 1b

Table 1b: Annual Respondent Burden and Cost – NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN) (Renewal)
					123.94	157.61	62.52
Burden Items	(A) Hours per Occurrence	(B) Occurrences per Year	(C) Hours per Year (C=AxB)	(D) Respondents per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with regulatory requirements c	1	1	1	5	5	0.25	0.5	$690.36
B. Required activities
Initial performance tests d	980	1	980	0	0	0	0	$0
Repeat initial performance tests e	980	0.2	196	0	0	0	0	$0
Operations, maintenance, and monitoring plan f	40	1	40	0	0	0	0	$0
C. Create information	8	1	8	5	40	2	4	$5,522.90
D. Gather existing information
E. Write Report
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, adjustments to time periods, and changes in information g, h	2	1	2	0	0	0	0	$0
Report of performance test	See 3B
Excess emissions report h, n	16	2	32	1	32.0	1.6	3.2	$4,418.32
Report of no excess emissions n, l	1	2	2	4	8	0.4	0.8	$1,104.58
Quality improvement plan m	40	1	40	0	0	0	0	$0
Subtotal for Reporting Requirements					98			$11,736
4. Recordkeeping Requirements
A. Familiarize with regulatory requirements c	See 3A
B. Plan activities	See 3B
C. Implement activities	See 3B
D. Develop record system	N/A
E. Time to enter information
Records of operating parameters and emissions n	9	52	468	5	2,340	117	234	$323,089.65
F. Train Personnel	N/A
G. Audits	N/A
H. Time to transmit or disclose information o	8	1	8	6.5	52	3	5.2	$7,179.77						143	hours per response
Subtotal for Recordkeeping Requirements					2,751			$330,269
TOTAL LABOR BURDEN AND COST (rounded) p					2,850			$342,000		2,850
TOTAL CAPITAL AND O&M COSTS (rounded) p								$47,000
GRAND TOTAL (rounded) o								$389,000		285	hours per response
Assumptions:
a We have assumed that there are approximately 5 respondents, with no new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: $157.61 per hour for Executive, Administrative, and Managerial labor; $123.94 per hour for Technical labor, and $62.52 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2021, “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 varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees.
c We have assumed that all existing respondents will each take one hour to re-familiarize with the regulatory requirements each year.
d We assume that it will take each respondent 980 hours to complete initial performance tests.
e We assume that 20 percent of respondents will have to repeat the initial performance tests due to failures.
f We assume that each respondent will take 40 hours to prepare the operations, maintenance, and monitoring plan.
g We assume that it will take each respondent two hours to prepare each of the notifications.
h We assume that it will take each respondent one hour to write the extension of compliance; adjustments to time periods, and changes in information reports.
i We assume that it will take each respondent 16 hours to prepare excess emissions reports.
j We assume that 20 percent of respondents are required to prepare excess emissions reports.
k We assume that each respondent will take one hour to prepare no excess emissions reports.
l We assume that 80 percent of respondents will submit the no excess emissions reports.
m We assume that 40 percent of respondents are required to prepare the quality improvement plan.
n We assume that it will take each respondent nine hours each week to record records of operating parameters and emissions.
o It is assumed there are approximately 6.5 flame attenuation lines for which respondents are required to transmit information. The 2015 RTR assumed the burden for 13 flame attenuation lines at 2 facilities, and this ICR assumes these estimates decreased proportionally with the number of sources.
p Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 4: Table 2a

Table 2a: Average Annual EPA Burden and Cost – NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP) (Renewal)
					52.37	70.56	28.34
Burden Items	(A) EPA Hours per Occurrence	(B) Occurrences per Year	(C) EPA Hours per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, $ b
1. Initial performance tests
A. New or modified plant c	24	1	24	0.33	8	0.4	0.8	$470
2. Repeat performance tests			0
A. New or modified plant c, d	24	0.2	4.8	0.07	0.32	0.016	0.032	$19
3. Report Review
A. New or modified plant
Notification of construction/reconstruction	2	1	2	0.33	0.67	0.03	0.07	$39
Notification of actual startup	1	1	1	0.33	0.33	0.02	0.03	$20
Notification of physical or operational change	2	1	2	0	0.00	0.00	0.00	$0
Notification of initial performance test	1	1.2	1.2	0.33	0.40	0.02	0.04	$23
Review performance test results e	8	1.2	9.6	0.33	3.20	0.16	0.32	$188
Review semiannual exceedance/no exceedance reports f	2	2	4	32.33	129.33	6.47	12.93	$7,596.01
TOTAL COST (rounded) g					164			$8,350		164	228
											$11,600
Assumptions:
a We have assumed that there are approximately 32 respondents, with 1 additional new or reconstructed source becoming subject to the rule in the next three years (an average of 0.33 new respondents per year).
b This ICR uses the following labor rates: $70.56 per hour for Managerial labor; $52.37 per hour for Technical labor, and $28.34 per hour for Clerical labor. 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% to account for the benefit packages available to government employees.
c We have assumed that it will take 24 hours to observe the performance testing for each new plant.
d We assume that 20 percent of new or modified plants will have to repeat performance test due to failures.
e We assume that EPA will take 8 hours 1.2 times per year to review the performance test results reports for each new or modified plant.
f We have assumed that EPA will take two hours two times per year per plant to review the semiannual exceedance/no exceedance reports.
g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 5: Table 2b

Table 2b: Average Annual EPA Burden and Cost – NESHAP for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 63, Subpart NNN) (Renewal)
					52.37	70.56	28.34
Burden Items	(A) EPA Hours per Occurrence	(B) Occurrences per Year	(C) EPA Hours per Year (C=AxB)	(D) Plants per Year a	(E) Technical Hours per Year (E=CxD)	(F) Managerial Hours per Year (F=Ex0.05)	(G) Clerical Hours per Year (G=Ex0.1)	(H) Cost, $ b
1. Initial performance tests
A. New or modified plant c	40	1	40	0	0	0	0	$0
2. Repeat performance tests
A. New or modified plant c, d	40	0.2	8	0	0	0	0	$0
3. Report Review
A. New or modified plant
Notification of applicability e	2	1	2	0	0	0	0	$0
Notification of construction/reconstruction e	2	1	2	0	0	0	0	$0
Notification of actual startup e	2	1	2	0	0	0	0	$0
Notification of special compliance requirements e	1	1	1	0	0	0	0	$0
Notification of initial performance test e	2	1	2	0	0	0	0	$0
Notification of compliance status e	2	1	2	0	0	0	0	$0
Request for extension of compliance, adjustments to time periods, and changes in information f	2	1	2	0	0	0	0	$0
Report of initial performance test	40	1	40	0	0	0	0	$0
Excess emissions report g	20	2	40	1	40	2.0	4	$2,349.28
Report of no excess emissions h	2	2	4	4	16	0.8	1.6	$939.71
Quality improvement plan i	40	1	40	0	0	0	0	$0
Operations, maintenance, and monitoring plan i	40	1	40	0	0	0	0	$0
TOTAL COST (rounded) j					64			$3,290		64
Assumptions:
a We have assumed that there are approximately 5 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years.
b This ICR uses the following labor rates: $70.56 per hour for Managerial labor; $52.37 per hour for Technical labor, and $28.34 per hour for Clerical labor. 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% to account for the benefit packages available to government employees.
c We have assumed that it will take 40 hours to observe the performance testing for each new plant.
d We assume that 20 percent of new or modified plants will have to repeat performance test due to failures.
e We assume that EPA will take two hour once per year to review the notification reports for each new or modified plant.
f We assume that EPA will take two hours once per year to review the request for each new or modified plant.
g We assume that 20 percent of plants will submit excess emissions reports twice per year.
h We assume that 80 percent of plants will submit the no excess emissions report twice per year.
i We assume that it will take 40 hours once per year to review plans.
j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 6: 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 a	Total O&M, (E X F)
NSPS for Wool Fiberglass Insulation Manufacturing Plants (40 CFR Part 60, Subpart PPP)
Particulate Matter Monitoring	$15,000	0.33	$4,950	$16,500	32.33	$533,445
NESHAP for Wool Fiberglass Manufacturing Plants (40 CFR Part 63, Subpart NNN)
Baghouse Leak Detection	$9,100	0	$0	$500	3.5	$1,750
Furnace Temperature Monitoring	$1,500	0	$0	$0	2.5	$0
Formaldehyde Emission Monitoring	$15,000	0	$0	$0	8.5	$0
Chromium Compound Testingb	$0	0	$0	$10,000	4	$40,000
Phenol, Methanol and Formaldehyde Testingc	$0	0	$0	$800	6.5	$5,200
Total (rounded) d			$5,000			$580,445		$585,445
a In order to calculate O&M costs for 40 CFR Part 63, Subpart NNN, the estimates provided in column F were not based on the number of respondents but, instead, based on the total number of continuous monitoring devices that exist within the industry; some respondents may have more than one continuous monitoring device located at their facility. We assumed the number of continuous monitoring devices decreased proportionally with the number of sources.
b It is assumed there are approximately 4 gas-fired furnaces at 3 facilities. Chromium compound testing is required annually with an estimated cost of $10,000 per test. The 2015 Residual Risk and Technology Review (RTR) assumed 8 gas-fired furnaces at 5 facilities, and this ICR assumes these estimates decreased proportionally with the number of sources.
c It is assumed that one facility has approximately 6.5 flame attenuation lines. Phenol, methanol, and formaldehyde testing is required once every 5 years with an estimated cost of $4,000 per test. ($4,000 per test x (1 test / 5 years) = $800/yr). The 2015 RTR assumed 13 flame attenuation lines at 2 facilities, and this ICR assumes these estimates decreased proportionally with the number of sources.
d Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding.

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Sheet 7: Responses

Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of Respondents	Number of Responses	Number of Existing Respondents That Keep Records But Do Not Submit Reports	Total Annual Responses E=(BxC)+D
40 CFR Part 60, Subpart PPP
Notification of construction/reconstruction	0.33	1	0	0.33
Notification of actual startup	0.33	1	0	0.33
Notification of physical or operational change	0	1	0	0
Notification of initial performance test	0.33	1.2	0	0.40
Semiannual Exceedance Report	32.33	2	0	64.67
40 CFR Part 63, Subpart NNN
Excess or No Excess Emissions Reports	5	2	0	10
			Total (rounded)	76

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Sheet 8: Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents a	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	1	37	0	0	38
2	0	38	0	0	38
3	0	38	0	0	38
Average	0.33	37.67	0	0	38
a New respondents include sources with constructed and reconstructed affected facilities. We anticipate 1 additional new or reconstructed source becoming subject to the rule in the next three years (an average of 0.33 new respondents per year).