1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NESHAP
SUBPART
III
NATIONAL
EMISSION
STANDARDS
FOR
AIR
POLLUTANTS
FOR
SOURCE
CATEGORIES:
FLEXIBLE
POLYURETHANE
FOAM
PRODUCTION
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP
Subpart
III
­
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Flexible
Polyurethane
Foam
Production.

1(
b)
Short
Characterization/
Abstract
The
Maximum
Achievable
Control
Technology
(
MACT)
for
Flexible
Polyurethane
Foam
Production
was
proposed
on
December
27,
1996
and
promulgated
on
October
7,
1998.
This
standard
applies
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").

Owners
or
operators
of
flexible
polyurethane
foam
production
facilities
to
which
this
2
standard
is
applicable
must
choose
one
of
the
compliance
options
described
in
the
standard
or
reduce
HAP
emissions
to
below
the
compliance
level.
For
slabstock
foam
producers,
these
requirements
include
an
initial
notification,
notification
of
compliance
status,
and
semiannual
reports
thereafter.
In
addition,
respondents
are
required
to
submit
a
pre­
compliance
report
that
describes
the
HAP
compliance
procedures,
and
recordkeeping
procedures.
Respondents
electing
to
comply
with
the
slabstock
foam
emission
limitation
using
recovery
devices
must
measure
and
record
emissions
as
specified
in
§
63.1297
of
the
final
rule.
Molded
and
rebond
foam
producers
have
only
to
submit
a
notification
of
compliance
status
report.

If
the
owner
or
operator
identifies
any
deviations
resulting
from
a
known
cause
for
which
no
federally­
approved
or
promulgated
exemption
from
an
emission
limitation
or
standard
applies,

the
compliance
report
will
also
include
all
records
that
the
source
is
required
to
maintain
that
pertain
to
the
periods
during
which
such
deviation
occurred,
as
well
as
the
following:
the
magnitude
of
each
deviation;
the
reason
for
each
deviation;
a
description
of
the
corrective
action
taken
for
each
deviation,
including
actions
taken
to
minimize
each
deviation
and
action
taken
to
prevent
recurrence;
and
a
copy
of
all
quality
assurance
activities
performed
on
any
element
of
the
monitoring
protocol.

Owners
or
operators
of
slabstock
flexible
polyurethane
foam
production
facilities
must
maintain
a
copy
of
all
HAP
usage
records
onsite
for
a
minimum
of
five
years.
All
reports
are
to
be
submitted
upon
request
to
EPA
or
the
enforcement
authority
by
EPA.
The
information
is
used
to
determine
whether
or
not
all
sources
subject
to
the
NESHAP
are
achieving
the
standards.

There
are
approximately
132
facilities
that
comprise
the
source
category
required
to
meet
the
applicability
criteria
defined
in
this
rule.
It
is
estimated
that
no
new
facilities
will
become
3
subject
to
the
standard
over
the
next
three
years.
However,
it
is
estimated
that
approximately
six
(
6)
existing
facilities
will
undergo
reconstruction
or
modification
each
year
over
the
next
three
years.
Based
on
this
information,
the
annual
cost
burden
of
this
ICR
on
the
flexible
polyurethane
foam
production
industry
we
be
$
362,184.

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
will
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that:

.
.
.
the
Administrator
may
require
any
person
who
owns
or
operates
any
emission
source
.

.
.
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
methods
at
such
locations,
at
such
intervals,
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
114(
a)(
3);
and
(
G)

provide
such
other
information
as
the
Administrator
may
reasonably
require.
.
.

In
the
Administrator's
judgment,
HAP
emissions
from
flexible
polyurethane
foam
production
facilities
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
4
endanger
public
health
or
welfare.
Therefore,
a
MACT
standard
was
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
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.).

This
standard
relies
on
the
capture
of
HAPs
by
control
equipment
such
as
vapor
recovery
systems
or
carbon
adsorption
systems.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and
the
standard
is
being
met.
Compliance
reports
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved
and
may
be
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63
Subpart
III.

If
the
standard
has
not
been
delegated,
the
information
is
sent
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
Local
Agency.
If
a
5
State
or
Local
Agency
has
adopted
their
own
similar
regulation
to
implement
the
Federal
Regulation,
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
Standard.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
April
18,
2000.

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
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
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
63
Subpart
III
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
6
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,

September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
63
Subpart
III
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
requirements
of
this
subpart
apply
to
the
owner
or
operator
of
flexible
polyurethane
foam
production
facilities.
They
are
listed
under
SIC
Code
3086.
The
government
is
in
the
process
of
adopting
the
new
North
American
Industrial
Classification
System
(
NAICS).
The
NAICS
code
for
this
industry
is
32615.
7
4(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63
Subpart
III.
A
source
subject
to
this
MACT
must
comply
with
the
notification,
monitoring,
and
recordkeeping
requirements
listed
in
the
following
four
exhibits.

Exhibit
1:
Notification
Reports
Initial
Notification
63.9
(
b)
40
CFR
63
Subpart
A
Application
for
Approval
of
Construction
or
Reconstruction
63.1306
(
b)

Precompliance
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)

Exhibit
2:
Monitoring
Reports
Semiannual
Compliance
Reports
63.1306
(
e)

Annual
Compliance
Certification
63.1306(
g)
8
Exhibit
3:
Recordkeeping
General
recordkeeping
requirements
(
e.
g.,
startups,
shutdowns,
and
malfunctions
including
process
equipment,
air
pollution
control
equipment,
maintenance
performed,
and
actions
taken
outside
the
scope
of
the
existing
plans)
63.10
40
CFR
63
Subpart
A
Storage
Vessels
63.1307(
a)

Equipment
Leaks
63.1307(
b)

HAP
ABA
Records
63.1307(
c)

HAP
ABA
­
Recovery
System
Monitoring
63.1303(
d)

Vapor
Return
Line
Records
63.1303(
f)

Maintain
product
data
sheets
for
equipment
cleaners
and
mold
release
agents.
63.1303
(
e),
(
g),
(
h)

Exhibit
4:
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
continuous
monitoring
system
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.
9
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
information
required
under
40
CFR
Part
63
Subpart
III:

Agency
Activities
Review
notifications
and
reports,
including
precompliance
reports
and
semiannual
compliance
status
reports,
required
to
be
submitted
by
industry
Audit
facility
records
Input,
analyze,
and
maintain
data
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
database
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
compliance
reports
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
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
more
than
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
10
Offices
and
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
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutant.
The
requirements
reflect
the
burden
on
small
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
Although
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Table
2.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
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.
1
The
wage
rate
has
been
loaded
by
adding
110%
overhead.

11
Responses
to
this
information
collection
are
mandatory
(
40
CFR
§
63.1290).
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
at
6,400
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
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
labor
rates
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rate
is
from
column
1:
Total
Compensation.
1
The
following
table
provides
a
summary
of
these
rates
for
management,
technical,
and
clerical
staff.

Labor
Rates
Management
$
73.93
Technical
$
54.94
Clerical
$
34.42
12
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
capital
and
operations
and
maintenance
costs
for
this
standard
are
associated
with
the
cost
of
new
equipment
that
reduces
HAP
emissions.
However,
it
is
reasonable
to
assume
that
all
slabstock
foam
production
sources
will
elect
the
source­
wide
emission
limitation,
which
requires
no
startup,
capital,
or
operation
and
maintenance
costs
paid
outside
of
the
company.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Monitoring
device
start
up
cost
($)
annual
O&
M
costs
($)

Continuous
Monitoring
$
0
$
0
Control
Devices
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.

Publication
and
distribution
of
the
information
are
part
of
the
AIRS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.
The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
11,649.
This
cost
is
based
on
a
federal
government
employee
salary
at
the
GS­
10
Step
1
grade
plus
110%

overhead
which
is
equal
to
$
34.69
per
hour.
13
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
40
CFR
Part
63
Subpart
III
is
132.
It
is
estimated
that
no
new
sources
will
become
subject
to
the
rule
over
the
next
three
years.
The
estimated
total
average
annual
labor
cost
associated
with
this
MACT
is
$
362,184.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Burden
of
Reporting
and
Recordkeeping
Requirements,
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Flexible
Polyurethane
Foam
Production
­
MACT
Subpart
III.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
The
table
below
provides
a
summary
of
the
estimated
overall
burden
to
the
flexible
polyurethane
foam
production
industry
and
EPA
for
the
next
three
years.
For
a
detailed
breakdown
of
the
costs,
see
Tables
1
and
2
attached.

Summary
of
the
Estimated
Overall
Burden
Year
Industry
Burden
(
Hours)
Industry
Cost
($)
EPA
Burden
(
Hours)
EPA
Cost
($)

First
Year
628
$
35,533
345
$
11,968
Second
Year
9,691
$
548,417
340
$
11,808
Third
Year
8,881
$
502,601
322
$
11,170
Total
19,200
$
1,086,551
1,007
$
34,946
Annual
Average
6,400
$
362,184
336
$
11,649
2
EC/
R
Inc.
supported
EPA
during
the
development
of
this
MACT
standard.

3
EC/
R
indicated
that
some
facilities
have
substituted
liquid
CO2
for
methylene
chloride
in
their
foam
production
process.

4
We
estimate
that
half
of
the
reconstruction
projects
planned
for
the
next
three
years
will
substitute
for
regulated
chemicals
under
this
standard
or
will
embrace
new
technologies
that
will
exempt
them
from
this
rule.
In
addition,
we
estimate
that
three
of
these
reconstructed
facilities
will
be
slabstock
foam
facilities
and
the
other
three
will
be
rebond
or
molded
foam
facilities.

14
6(
f)
Reasons
for
Change
in
Burden
Two
primary
sources
were
used
to
estimate
the
number
of
facilities
subject
to
this
MACT
standard,
the
Polyurethane
Foam
Association
and
EC/
R
Inc2.
In
addition,
initial
notification
responses
from
slabstock
and
molded/
rebond
polyurethane
foam
production
facilities,
using
EPA's
MACTRAX
database,
provided
additional
information
on
the
universe
of
facilities
potentially
subject
to
this
standard.
The
change
in
burden
from
the
most
recently
approved
ICR
reflects
a
25%
decrease
in
the
number
of
affected
facilities
from
176
to
132.
This
decrease
is
due
to
a
consolidation
of
the
industry
and
the
use
of
more
"
environmentally­
friendly"
substitutes
for
the
HAPs
regulated
under
this
standard.
3
In
addition,
we
expect
technological
advances
to
further
reduce
the
use
of
regulated
HAPs
at
facilities
manufacturing
flexible
polyurethane
foam.

In
addition
to
a
decrease
in
the
number
of
facilities
subject
to
this
rule,
we
also
estimate
that
no
new
facilities
will
commence
construction
over
the
next
three
years.
However,
we
estimate
that
approximately
six
(
6)
facilities
will
undergo
some
type
of
reconstruction
each
year
over
the
next
three
years.
4
This
estimate
represents
decrease
in
growth
from
the
previous
ICR
from
4
new
facilities
per
year
to
no
new
facilities
per
year
and
a
reduction
in
reconstruction
from
17
facilities
per
year
to
6
facilities
per
year.
This
decrease
in
growth
is
also
the
result
of
using
more
"
environmental­
friendly"
chemical
substitutes
in
conjunction
with
new
technologies.
5
We
are
assuming
that
most
facilities
will
comply
just
before
the
deadline.

6
Initial
notifications
are
required
within
120
days
after
the
promulgated
date
of
the
standard
(
§
63.9(
b)(
2)).

7
Facilities
are
required
to
come
into
compliance
with
this
standard
within
three
years
of
the
promulgated
date
(
§
63.1291(
a))

8
Precompliance
reports
must
be
submitted
no
later
than
12
months
before
the
compliance
date
(
§
63.1306(
c)).

15
The
previous
ICR
for
this
MACT
standard
included
costs
associated
with
the
submission
of
startup,
shutdowns,
and
malfunction
reports
that
are
not
required
by
the
rule.
The
costs
associated
with
these
reports
have
been
removed
from
this
ICR.

The
formula
used
to
calculate
labor
rates
on
the
previous
ICR
has
been
replaced
by
1999
rates
identified
by
the
Bureau
of
Labor
Statistics.
This
change
in
labor
rate
is
a
significant
contributor
to
the
hourly
cost
burden
increase
on
each
individual
facility
from
the
previous
ICR.

The
previous
ICR
assumed
that
all
of
the
facilities
regulated
under
this
standard
would
come
under
compliance
in
the
first
year
after
promulgation.
However,
this
assumption
is
flawed
because
the
facilities
subject
to
this
rule
have
three
years
following
promulgation
to
come
into
compliance
with
this
standard.
In
addition,
several
provisions
within
the
standard
have
specific
compliance
deadlines
that
will
determine
a
facility's
compliance
schedule.
The
table
below
provides
a
rough
schedule
of
the
deadlines
for
certain
provisions
of
the
standard.
5
Anticipated
Compliance
Schedule
Initial
Notification6
2/
7/
99
Compliance
Date7
10/
8/
01
Pre­
compliance
Reports8
10/
8/
00
Anticipated
Compliance
Schedule
9
Notifications
of
compliance
status
must
be
submitted
no
later
than
180
days
after
the
compliance
date
(
§
63.1306(
d)).

10
The
first
semiannual
report
must
be
submitted
no
later
than
240
days
after
submission
of
the
notification
of
compliance
(
§
63.1306(
e)).

11
The
previous
ICR
for
this
standard
was
approved
on
1/
31/
97
and
covers
the
first
three
years
following
promulgation;
October
7,
1998
thru
October
7,
2001.
However,
since
the
previous
ICR
expires
on
April
30,
2000,
this
ICR
will
overlap
the
previous
ICR
for
the
first
17
months,
covering
May
1,
2000
thru
May
1,
2003.

16
Notification
of
Compliance
Status9
4/
8/
02
Semi­
Annual
Report10
12/
8/
02
As
a
result
of
this
schedule,
the
annual
burden
on
facilities
subject
to
this
standard
will
vary
over
the
next
three
years.
Tables
2a­
2c
summarize
the
estimated
burden
on
the
flexible
polyurethane
foam
production
industry
for
each
year.
11
In
the
first
year,
each
facility
subject
to
the
standard
will
be
required
to
submit
a
precompliance
report.
In
addition,
facilities
planning
to
undergo
reconstruction
will
be
required
to
submit
applications
for
approval.
In
the
second
year,

each
facility
subject
to
this
standard
will
submit
notifications
of
compliance
status.
With
the
compliance
deadline
(
October
8,
2001)
occurring
in
the
second
year
of
this
ICR,
facilities
will
also
be
required
to
initiate
monitoring
and
recordkeeping
requirements
as
required
by
the
standard.
In
the
third
year,
slabstock
foam
facilities
will
begin
submitting
semiannual
reports.
Monitoring
and
recordkeeping
will
continue
through
the
third
year
for
existing
facilities
subject
to
this
standard.

We
are
assuming
that
all
training
was
conducted
within
the
first
two
years
following
promulgation
as
was
assumed
in
the
previous
ICR;
therefore
no
training
burden
is
estimated
for
17
the
next
three
years.
In
addition,
we
anticipate
that
only
1%
of
the
facilities
subject
to
this
rule
will
request
special
compliance
requirements,
changes
in
selected
emissions
limits
or
compliance
methods,
or
request
an
extension
of
compliance.

6(
g)
Burden
Statement
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
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave,
N.
W.,

Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1783.02
and
OMB
control
number
2060­
0357
in
any
18
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
