SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Flexible
Polyurethane
Foam
Production
(
40
CFR
part
63,
subpart
III)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Flexible
Polyurethane
Foam
Production
(
40
CFR
part
63,
subpart
III)

1(
b)
Short
Characterization/
Abstract
The
Maximum
Achievable
Control
Technology
(
MACT)
standards
for
Flexible
Polyurethane
Foam
Production,
published
at
40
CFR
part
63,
subpart
III,
were
proposed
on
December
27,
1996
and
promulgated
on
October
7,
1998.
These
standards
apply
to
owners
or
operators
of
new
and
existing
facilities
that
engage
in
the
manufacture
of
flexible
polyurethane
foam
products
which
emit
hazardous
air
pollutants
(
HAPs).
This
includes
facilities
making
slabstock
flexible
polyurethane
foam
("
slabstock
foam"),
rebond
flexible
polyurethane
foam
("
rebond
foam"),
and/
or
molded
flexible
polyurethane
foam
("
molded
foam").

In
general,
all
MACT
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
of
flexible
polyurethane
foam
production
facilities
to
which
this
rule
is
applicable
must
choose
one
of
the
compliance
options
described
in
the
standard
or
reduce
HAP
emissions
to
below
the
compliance
level.
Specifically,
the
rule
requirements
for
slabstock
foam
producers
include
an
initial
notification,
notification
of
compliance
status,
semiannual
reports
and
annual
compliance
certifications.
In
addition,
respondents
are
required
to
submit
a
pre­
compliance
report
that
describes
the
HAP
compliance
procedures,
and
recordkeeping
procedures.
Those
electing
to
comply
with
the
slabstock
foam
emission
limitation
using
recovery
devices
must
measure
and
record
emissions
as
specified
in
Section
63.1297
of
the
rule.
The
rule
requirements
for
molded
and
rebond
foam
producers
include
a
notification
of
compliance
status
report
and
an
annual
compliance
certification.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
MACT.

Any
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.
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.
The
TOC
section
stated:
2
This
ICR
is
approved
for
three
years.
OMB
is
concerned,
however,
that
EPA
may
not
have
accurately
estimated
the
non­
labor
costs
reported
in
block
14
of
Form
83­
I.
As
soon
as
practicable,
EPA
should
review
the
non­
labor
costs
associated
with
the
collection,
and
revise,
as
appropriate,
its
cost
burden
estimate
to
reflect
any
financial
costs
associated
with
the
collection,
including
costs
associated
with
monitoring,
reporting,
and
record
storage.

It
has
been
determined
that
the
non­
labor
costs,
reported
on
the
OMB
83­
I
form
in
block
14,
are
zero.
The
continuous
parameter
monitoring
equipment
used
by
facilities
affected
by
this
regulation
is
used
to
maintain
a
high
level
of
operational
efficiency
and
would
have
been
installed
and
maintained
with
or
without
regulation.
Therefore,
there
are
no
capital/
startup
or
Operation
and
Maintenance
(
O&
M)
costs
associated
with
this
regulation.

Approximately
132
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
no
new
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
The
number
of
sources
and
the
assumptions
made
in
determining
the
industry
burden
associated
with
this
ICR
were
based
on
information
gathered
from
EPA's
Air
Facility
System
(
AFS)
database
through
the
Online
Tracking
Information
System
(
OTIS);
consultation
with
the
Agency's
contact
for
the
development
of
this
rule
at
the
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS);
consultation
with
the
Polyurethane
Foam
Association;
and
the
review
of
information
available
on
the
active
ICR.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
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.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
this
Act
to:

(
A)
Establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
3
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
hazardous
air
pollutants
(
HAPs)
from
flexible
polyurethane
foam
production
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
MACT
standards
were
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
III.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAPs
from
hazardous
air
pollutants
(
HAPs)
from
flexible
polyurethane
foam
production
facilities
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emission
of
HAPs
from
flexible
polyurethane
foam
production
facilities
are
the
result
of
operation
of
each
slabstock
production
line,
each
storage
vessel,
equipment
cleaning,
or
from
leaking
equipment
(
e.
g.,
transfer
pumps,
connectors,
valves,
etc.).
The
subject
standards
are
achieved
by
the
capture
of
HAP
emissions
using
vapor
recovery
systems
or
carbon
adsorption
systems
and
leak
detection
and
repair
procedures.
The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
leaks
are
being
detected
and
repaired,
and
the
regulations
are
being
met.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
MACT
standards
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
III.

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
their
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.
4
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
on
May
19,
2003,
at
68
FR
27059.
No
comments
were
received
on
the
burden
published
on
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
several
sources
were
used
to
obtain
updated
information
on
the
number
of
sources
and
on
the
assumptions
made
to
determine
the
industry
burden
associated
with
MACT
subpart
III
over
the
next
three
years.
As
discussed
in
Section
1(
b),
the
number
of
sources
was
estimated
by
conducting
queries
on
the
EPA's
AFS
database
through
OTIS.
In
the
development
of
this
ICR,
the
originator
consulted
with
OAQPS
rule
development
staff
including
Dave
Svendsgaard
and
Warren
Johnson,
industry
websites
and
the
Polyurethane
Foam
Association.

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
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
affected
facilities
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five­
year
records
retention
requirement
is
consistent
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
5
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
and
NAICS
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
owners
or
operators
of
flexible
polyurethane
foam
production
facilities.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
United
States
Standard
Industrial
Classification)
Code
3086
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
326150
for
Urethane
and
Other
Foam
Product
(
except
Polystyrene)
Manufacturing.

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Flexible
Polyurethane
Foam
Production
(
40
CFR
part
63,
subpart
III).

A
source
must
make
the
following
reports:

Notification
Reports
Citation
Initial
Notification
63.1306(
a)

Application
for
Approval
of
Construction
or
Reconstruction
63.1306(
b)

Pre­
compliance
Report
63.1306(
c)

Notification
of
Compliance
Status
63.1306(
d)

Notification
of
Special
Compliance
Requirements
63.9(
d)

Change
in
Selected
Emission
Limitation/
Compliance
Method
63.1306(
f)(
1)&(
2)

Request
for
Extension
of
Compliance,
Adjustments
to
Time
Periods,
and
Changes
in
Information
63.9(
c),
63.9(
i),
63.9(
j)
6
Reports
Citation
Semiannual
Compliance
Reports
63.1306(
e)

Annual
Compliance
Certification
63.1306(
g)

A
source
must
keep
the
following
records:

Recordkeeping
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2)

All
reports
and
notifications
63.10(
b)

Record
of
applicability
63.10(
a)

Slabstock
sources
shall
maintain
storage
vessel
records,
equipment
leaks
record,
HAP
auxilliary
blowing
unit
(
ABA)
records
for
emission
point
specific
limitations
or
source­
wide
limitations,
records
of
product
data
sheet
for
HAP
cleaners,
and
if
using
a
recovery
device,
the
records
of
the
recovered
HAP
ABA
recordkeeping
program,
the
monitoring
device's
Quality
Assurance
(
QA)
data,
parameter
monitoring,
and
the
HAP
ABA
recovered.
63.1307(
a­
f)

Molded/
rebond
foam
sources
shall
maintain
records
of
product
data
sheets
for
each
compound
other
than
diisocyanates
used
to
flush
the
mixhead
and
associated
piping
during
periods
of
startup
or
maintenance,
and
the
product
data
sheets
for
each
mold
release
agent
used
that
has
HAPs.
63.1307(
g­
h)

Records
are
required
to
be
retained
for
five
years,
however,
only
the
data
of
the
most
recent
two
years
must
be
kept
on­
site
63.10(
b)(
1)

Electronic
Reporting
Presently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
flow
rate
monitoring
and
pump
revolution
per
minute
monitoring.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
estimated
that
approximately
10
percent
of
the
respondents
use
electronic
reporting.
7
(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Slabstock
foam
sources
shall
install,
calibrate,
maintain,
and
operate
Continuous
Monitoring
System
(
CMS)
for
flow
rate
or
pump
revolutions
to
continuously
monitor
the
amount
of
polyol
added
and
for
HAP
ABA.

Performance
tests
are
not
required
by
MACT,
subpart
III.
However,
sources
are
required
to
use
Reference
Method
18
of
Part
60
for
HAP
concentration;
Method
25A
of
Part
60
for
organic
compounds
measurements;
Method
21
of
Part
60
for
equipment
leaks;
and
American
Society
for
Testing
and
Materials
(
ASTM)
method
D3574­
91,
Standard
Test
methods
for
Flexible
Cellular
Materials­
Slab,
Bonded,
and
Molded.

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.

Presently
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
flow
rate
monitors;
however,
personnel
at
the
facility
still
need
to
evaluate
the
data.
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
Agencies.
It
is
estimated
that
approximately
10
percent
of
the
respondents
use
electronic
reporting.
8
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
semiannual
reports
and
annual
compliance
certifications
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
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.

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

5(
c)
Small
Entity
Flexibility
There
is
a
distribution
of
business
sizes.
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
9
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

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
Flexible
Polyurethane
Foam
Production
(
40
CFR
part
63,
subpart
III).

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
under
the
MACT
standards,
subpart
III,
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
9,047
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
MACT
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:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
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.
10
1
Bag
leak
detectors
for
VOCs
compounds
at
pumps,
valves,
connectors,
pressure­
relief
valves,
and
openended
lines
is
required
for
slabstock
foam
sources
complying
with
the
emission
point
specific
limitation
option.
However,
we
have
assumed
that
all
slabstock
foam
producers
are
meeting
the
source­
wide
emission
limit
and
control
diisocynate
emissions
monitoring,
recordkeeping
and
reporting
requirements.
Therefore,
there
would
be
no
burden
associated
with
this
type
of
monitoring.

2
Although
the
rule
requires
continues
parameter
monitoring
for
slabstock
foam
producers
(
e.
g.,
monitors
for
pump
revolutions
and
flow
rate),
we
have
not
accounted
for
any
O&
M
costs
in
the
ICR
since
the
OAQPS
determined
that
these
sources
had
already
the
required
monitors
when
the
rule
became
effective
and
the
O&
M
costs
can
not
be
attributed
to
these
standards.
In
addition,
even
when
we
have
assumed
that
there
will
be
six
(
6)
existing
sources
per
year
conducting
modifications,
these
sources
would
not
need
to
installed
new
monitoring
equipment
and
will
not
incur
in
additional
costs.
Managerial
$
93.04
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
only
costs
to
the
regulated
industry
resulting
from
information
collection
activities
required
by
the
subject
standards
are
labor
costs.
The
capital/
startup
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor(
s)
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital
/
Startup
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Start
up
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

Volatile
organic
compound
(
VOC)
Equipment
leak
detectors
1
$
29,786
0
$
0
$
5,250
0
$
0
Flow
rate
or
pump
revolutions
monitors
as
applicable
2
$
3,000
0
$
0
$
500
0
$
0
11
There
are
no
total
capital/
startup
costs
for
this
ICR
since
we
have
assumed
that
no
new
sources
will
become
subject
to
these
standards
and
that
the
existing
sources
conducting
modifications
will
not
be
purchasing
new
monitoring
equipment.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

There
are
no
operation
and
maintenance
costs
for
this
ICR
since
sources
electing
to
comply
with
the
source­
wide
emission
limit
and
are
not
using
bag
leak
detectors
and
the
monitoring
parameter
monitors
were
already
being
used
in
their
operations
prior
to
promulgation
of
this
rule,
as
discussed
on
footnotes
1
and
2
of
the
above
table.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
Therefore,
there
is
no
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR.
This
cost
is
shown
on
the
OMB
83­
I
form
in
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
those
costs
associated
with
analysis
of
the
reported
information.
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
$
18,689.
This
cost
is
based
on
the
average
hourly
labor
rates
below:

Managerial
$
53.22
(
GS­
13,
Step
5,
$
33.26
x
1.6)
Technical
$
39.49
(
GS­
12,
Step
1,
$
24.68
x
1.6)
Clerical
$
21.38
(
GS­
6,
Step
3,
$
13.36
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Burden
and
Cost
for
the
Federal
Government:
NESHAP
for
Flexible
Polyurethane
Foam
Production
(
40
CFR
part
63,
subpart
III),
attached.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
132
existing
sources
(
i.
e.,
59
slabstock
foam
producers
and
73
molded/
rebond
foam
producers)
are
currently
subject
to
the
standard.
It
is
estimated
that
no
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
12
However,
it
is
estimated
that
six
existing
sources
will
be
modifying/
reconstructing
its
operations
and
will
have
new
affected
facilities.

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

Number
of
Respondents
*

Year
(
A)
Number
of
New
Respondents
That
Submit
Reports
(
B)
Number
of
Existing
Respondents
That
Submit
Reports
(
C)
Number
of
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
6
132
0
6
132
2
6
132
0
6
132
3
6
132
0
6
132
Average
6
132
0
6
132
*
"
New
respondents"
are
defined
for
this
calculation
as
sources
that
recently
became
subject
to
the
rule
and
existing
sources
that
have
modified/
reconstructed
their
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
132.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:

Total
Annual
Responses
(
A)
Number
of
New
Respondents
(
B)
Number
of
Reports
for
New
Sources
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
AxB)+(
CxD)+
F
6
3
59
(
slabstock)
2
0
209
73
(
molded/
rebond)
1
13
*
"
New
respondents"
are
defined
for
this
calculation
as
sources
that
recently
became
subject
to
the
rule
and
existing
sources
that
have
modified/
reconstructed
their
facilities.
There
are
59
existing
slabstock
foam
producers
and
73
existing
molded/
rebond
foam
producers.

The
number
of
Total
Annual
Responses
is
209.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
572,300.
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
Flexible
Polyurethane
Foam
Production
(
40
CFR
part
63,
subpart
III),
attached.

Note
that
there
are
no
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
that
can
be
attributed
to
this
rule.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
appear
below
or
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
43
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
adjustment
increase
in
burden
is
due
to
the
omission
of
the
burden
associated
with
annual
compliance
certifications
in
the
active
ICR
which
was
corrected
in
its
renewal.
The
slabstock
foam
producers
are
complying
with
the
annual
compliance
certification
requirement
concurrently
with
the
semiannual
reports,
and,
therefore,
do
have
an
additional
burden
associated
with
it.
However,
the
molded/
rebond
foam
producers
only
have
the
annual
compliance
certification
reporting
requirement,
and
its
burden
must
be
accounted
for
in
the
ICR
separately.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
43
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
14
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
OECA­
2003­
0037,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
N.
W.,
Washington,
D.
C.
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
is
(
202)
566­
1514.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
to
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,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0037
and
OMB
control
number
2060­
0357
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1.
Annual
Respondent
Burden
and
Cost:

NESHAP
for
Flexible
Polyurethane
Foam
Production
(
40
CFR
part
63,
subpart
III)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
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
6
6
0.3
0.6
$
436.50
B.
Required
activities:

Monitoring
of
emissions
and
operations
c&
d
i.
Slabstock
sources
­
Metering
pump
calibrations
­
Storage
tank
measurements
measurements
4
2
8
59
472
23.6
47.2
$
34,337.76
1
12
12
59
708
35.4
70.8
$
51,506.65
ii.
Molded/
rebond
sources
Included
in
5E
C.
Create
Information
Included
in
4B
and
5E
16
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
D.
Gather
Existing
Information
Included
in
4B
and
5E
E.
Write
report
Initial
Notification
e
2
1
2
0
0
0
0
$
0.00
Notification
of
modification/

reconstruction
a
2
1
2
6
12
0.6
1.2
$
872.99
Precompliance
Report
4
1
4
6
24
1.2
2.4
$
1,745.99
Notification
of
compliance
status:
a
i.
Molded/
rebond
foam
producers
ii.
Slabstock
foam
producers
4
1
4
3
12
0.6
1.2
$
872.99
16
1
16
3
48
2.4
4.8
$
3,491.98
Semiannual
reports
f
4
2
8
59
472
23.6
47.2
$
34,337.76
Annual
compliance
g
certifications
2
1
2
73
146
7.3
14.6
$
10,621.43
Notification
of
special
compliance
requirements
h
2
1
2
0
0
0
0
$
0.00
Request
for
extension
of
compliance,
adjustments
to
the
time
periods,
and
changes
in
information
i
2
1
2
1
2
0.1
0.2
$
145.50
17
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
Change
in
selected
compliance
method
or
emission
limit
j
1
1
1
1
1
0.05
0.1
$
72.75
Progress
report
for
extensions
4
2
8
1
8
0.4
0.8
$
582.00
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
40
1
40
0
0
0
0
$
0.00
E.
Time
to
enter
and
transmit
k
information:
records
of
monitoring
and
operations:

i.
Molded/
rebond
foam
producers
ii.
Slabstock
foam
producers
4
1
4
73
292
14.6
29.2
$
21,242.85
8
12
96
59
5,664
283.2
566.4
$
412,053.17
F.
Time
to
train
personnel
40
1
40
0
0
0
0
$
0.00
G.
Time
for
audits
N/
A
TOTAL
LABOR
BURDEN
AND
COST
(
Rounded)
7,867
393
787
$
572,300
18
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)
Cost,$
b
COMBINED
LABOR
HOURS
9,047
Assumptions:

a
We
have
assumed
that
are
approximately
59
existing
slabstock
foam
producers
and
73
existing
rebond/
molded
foam
producers
for
a
total
of
132
existing
foam
producers
(
i.
e.,
sources)
that
are
major
sources
and
subject
to
the
NESHAP
subpart
III.
We
have
further
assumed
that
there
will
be
no
new
foam
producers
commencing
operations
over
the
period
of
this
ICR.
However,
we
have
assumed
that
6
existing
sources
(
3
slabstock
foam
producers
and
3
molded/
rebound
foam
producers)
a
year
will
be
conducting
some
type
of
modification
but
they
will
continue
to
meet
compliance
requirements
while
the
reconstruction/
modification
application
is
under
review.
Therefore,
the
average
number
of
respondents
per
year
for
this
ICR
is
estimated
to
be
132.

b
This
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group".
The
rates
are
from
column
1,
"
Total
compensation."
These
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
slabstock
foam
producers
are
meeting
the
source­
wide
emission
limit
and
control
diisocynate
emissions
monitoring,
recordkeeping
and
reporting
requirements.
Molded/
rebond
foam
producers
are
required
to
eliminate
the
use
of
HAP
or
HAP­
based
materials,
cleaners
or
agents
and
only
have
recordkeeping
and
reporting
requirements.

d
Sources
are
required
to
use
Method
21
of
Appendix
A
of
part
63
for
equipment
leaks;
Standard
Methods
for
Flexible
Cellular
Materials
for
determining
foam
properties,
ASTM
D3574­
91;
Method
18
of
part
60
for
HAPs
concentration;
and
Method
25A
of
40
CFR
part
60
for
organic
compounds.

e
We
have
assumed
that
all
existing
sources
are
in
compliance
with
the
initial
rule
requirements.

f
Slabstock
foam
producers
(
i.
e.,
59
sources)
are
required
to
submit
semiannual
reports.

g
All
sources
are
required
to
submit
compliance
certifications
annually.
However,
we
have
assumed
that
all
of
the
existing
molded
foam
producers
sources
that
are
major
sources
are
collocated
at
slabstock
foam
production
sites,
and
therefore,
there
wouldn't
be
an
additional
burden
since
they
would
be
meeting
this
requirement
concurrently
with
the
semiannual
compliance
status
reports.

h
We
have
determined
that
there
will
be
no
sources
submitting
a
special
compliance
report
for
this
ICR
since
the
compliance
date
for
this
rule
has
passed.

Owners
or
operators
of
an
affected
source
for
which
reconstruction
occurs
after
the
proposal
date
of
the
subject
rule
under
40
CFR
part
63
and
before
the
promulgation
of
such
rule
or
before
the
proposal
date
of
a
relevant
standard
established
pursuant
to
section
of
112(
f)
of
the
Clean
Air
Act,
is
required
to
submit
this
report,
as
described
in
section
63.6(
b)(
3)
and
(
4)
of
the
General
Provisions
of
part
63.

i
This
notification
is
required
when
an
owner
or
operator
request
approval
of
an
extension
of
a
time
period
or
postmark
deadline,
according
to
section
63.9(
i)
of
the
General
Provisions
under
part
63.

j
We
have
assumed
that
one
existing
source
will
be
changing
its
compliance
period
from
monthly
rolling
to
annual
rolling
or
viceversa.
19
k
The
types
of
records
include:
storage
vessel
records;
equipment
leaks
records;
HAP
ABA
records
for
point­
specific
and
source­
wide
limitations
for
both
rolling
annual
compliance
and
monthly
compliance
alternative
records;
recovery
devices
records,
and
maintain
proper
product
data
sheets.
20
Table
2.
Annual
Burden
and
Cost
for
The
Federal
Government:

NESHAP
for
Flexible
Polyurethane
Foam
Production
(
40
CFR
part
63,
subpart
III)

Activity
(
A)
EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)
EPA
personhours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost,
$
b
Initial
Notification
c
2
1
2
0
0
0
0
$
0.00
Notification
of
reconstruction/

modification
2
1
2
6
12
0.6
1.2
$
531.43
Precompliance
Report
2
1
2
6
12
0.6
1.2
$
531.43
Notification
of
special
compliance
requirements
d
2
1
2
0
0
0
0
$
0.00
Notification
of
compliance
status
2
1
2
6
12
0.6
1.2
$
531.43
Semiannual
reports
e
2
2
4
59
236
11.8
23.6
$
10,451.50
Annual
compliance
certifications
f
2
1
2
73
146
7.3
14.6
$
6,465.76
Change
in
selected
compliance
method
or
emission
limit
g
2
1
2
1
2
0.1
0.2
$
88.57
21
Activity
(
A)
EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)
EPA
personhours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost,
$
b
Progress
report
for
extensions,
adjustments
to
time
periods,
and
changes
in
Information
g
2
1
2
1
2
0.1
0.2
$
88.57
Subtotal
(
Rounded)
422
21.1
42
$
18,689
Travel
Expenses
d
(
1
person
x
1
plant/
yr
x
2
days/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
1
round
trips/
yr)
=
$
500.00
TOTAL
ANNUAL
COST
(
rounded)
TOTAL
ANNUAL
COST
=
$
18,689
+
$
500=
$
19,189
Assumptions:

a
We
have
assumed
that
there
are
approximately
59
existing
slabstock
foam
producers
and
73
existing
rebond/
molded
foam
producers
for
a
total
of
132
sources.

We
have
further
assumed
that
about
6
existing
sources
a
year
will
be
conducting
some
type
of
modification
at
its
facility
and
that
there
will
be
no
new
sources
over
the
period
of
this
ICR
Therefore,
the
average
number
of
respondents
per
year
is
estimated
to
be
132.
These
rates
are
from
the
Office
of
Planning
and
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.

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
$
53.22
(
GS­
13,
Step
5,
$
33.26
x
1.6),
Technical
rate
of
$
39.49
(
GS­
12,
Step
1,
$
24.68
x
1.6),
and
Clerical
rate
of
$
21.38
(
GS­
6,
Step
3,

$
13.36
x
1.6)

c
Assumes
that
all
existing
sources
are
in
compliance
with
the
initial
rule
requirements.

d
We
have
determined
that
there
will
be
no
sources
submitting
a
special
compliance
report
for
this
ICR
since
the
compliance
date
for
this
rule
has
passed.

e
Slabstock
foam
producers
(
i.
e.,
59
sources)
are
required
to
submit
semiannual
reports.

f
All
sources
(
132)
are
required
to
submit
annual
compliance
certifications.
However,
we
have
assumed
that
slabstock
sources
will
be
complying
with
this
requirement
concurrently
when
submitting
semiannual
reports.
Molded
foam
producers
would
still
need
to
meet
this
requirement
separately.

g
We
have
assumed
that
one
existing
source
will
be
changing
its
compliance
period
from
monthly
rolling
to
annual
rolling
or
viceversa
Assumes
that
facilities
seeking
to
reconstruct
will
continue
to
meet
compliance
requirements
while
application
is
under
review.

N/
A
=
Not
applicable.
