1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
the
Manufacture
of
Amino/
Phenolic
Resins
(
40
CFR
part
63,
subpart
OOO)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
the
Manufacture
of
Amino/
Phenolic
Resins
(
40
CFR
part
63,
subpart
OOO)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
amino/
phenolic
resins
published
at
40
CFR
part
63,
subpart
OOO
were
proposed
on
December
14,
1998
and
promulgated
on
January
20,
2000.
These
regulations
apply
to
existing
facilities
and
new
facilities
that
engage
in
the
manufacture
of
amino/
phenolic
resins.
New
facilities
include
those
that
commenced
construction
or
reconstruction
after
the
date
of
the
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
63,
subpart
OOO.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance
and
are
required
of
all
sources
subject
to
NESHAP.

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.

Approximately
forty
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
an
additional
zero
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.

The
active
(
previous)
Information
Collection
Request
(
ICR)
had
the
following
Terms
of
Clearance
(
TOC):

This
collection
is
approved.
OMB
understands
that
respondents
to
this
collection
are
seeking
legal
review
of
the
rule
associated
with
this
collection.
OMB
reminds
EPA
that
if
adjudication
or
settlement
of
legal
petitions
filed
by
respondents
or
other
interested
2
parties
results
in
a
modification
of
the
regulation
as
it
relates
to
the
approved
collection,
EPA
will
need
to
submit
an
ICR
containing
the
proposed
amendments
to
the
collection
to
OMB
for
approval.
Separately,
OMB
notes
that
EPA
has
not
properly
accounted
for
capital
and/
or
O&
M
costs
associated
with
the
monitoring
that
is
required
for
the
collection.
These
costs
should
be
included
in
EPA's
cost
estimate
for
the
collection.
As
soon
as
practicable,
EPA
should
submit
to
OMB
an
amendment
to
the
cost
estimate
for
the
collection
that
includes
a
line­
item
accounting
of
these
costs.

EPA
has
addressed
each
item
of
concern
in
the
TOC
by
examining
the
status
of
respondents'
request
for
legal
review
of
the
rule
associated
with
this
collection,
and
by
separately
accounting
for
capital
and/
or
O&
M
costs
associated
with
the
monitoring
that
is
required
for
the
collection.
The
respondents
did
not
pursue
their
request
for
legal
review
and,
therefore,
no
modification
of
the
regulation
as
it
relates
to
the
approved
collection
occurred.
Capital
and/
or
O&
M
costs
associated
with
the
monitoring
that
is
required
for
the
collection
are
now
separately
accounted
for
in
Section
6(
b)(
2)(
iii)
of
the
Supporting
Statement,
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

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
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
hazardous
air
pollutant
(
HAP)
emissions
from
3
amino/
phenolic
resins
manufacturing
operations
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP
for
this
source
category
were
promulgated
at
40
CFR
part
63,
subpart
OOO.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAP
from
amino/
phenolic
resins
manufacturing
operations
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
formaldehyde,
methanol,
and
phenol
from
amino/
phenolic
resins
manufacturing
operations
are
the
result
of
operation
of
the
facilities.
The
subject
standards
are
achieved
by
the
capture
of
formaldehyde,
methanol,
and
phenol
using
scrubbers
or
other
compliance
options
and/
or
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
and
the
regulations
are
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
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
NESHAP
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
these
standards,
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
recordkeeping
and
reporting
requested
is
required
under
40
CFR
part
63,
subpart
OOO.

3(
a)
Nonduplication
If
the
subject
standards
have
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
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.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
4
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
(
68
FR
68372)
on
December
8,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS)
conducted
a
review
and
discussions
with
industry
during
development
of
the
rule.
Results
from
that
activity
were
used
in
preparation
of
this
ICR.

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
with
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
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
5
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
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
owners
or
operators
of
amino/
phenolic
resins
manufacturing
operations.

Standard
SIC
Codes
NAICS
Codes
40
CFR
part
63,
subpart
OOO
2821
325211
(
Plastics
Material
and
Resin
Manufacturing)

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
OOO.

A
source
must
make
the
following
reports:

Notification
Reports
Notification
of
intent
to
construct
or
reconstruct
63.5,
63.1417(
d)

Notification
and
report
of
construction
date
63.5,
63.1400(
j)

Notification
of
anticipated
startup
63.5,
63.1400(
j)

Actual
startup
notification
63.5,
63.1400(
j)

Notification
of
modification
63.5,
63.1400(
j)

Notification
and
report
of
performance
tests
and
results
63.7(
b),
63.1417(
e)

Precompliance
report
63.1417(
d)
6
Notification
Reports
Notification
and
report
of
compliance
status
63.1417(
e)

Periodic
reports
(
semiannual)
including
statement
of
compliance
(
if
no
exceedances
occurred),
daily,
batch
cycle,
and
block
average
monitoring
data
for
any
periods
where
exceedances
or
excursions
occur,
periods
of
monitoring
system
downtime
63.1417(
f)

Quarterly
reports
upon
request
of
the
Administrator
63.1417(
f)(
12)

Develop
startup,
shutdown,
malfunction
plan,
submit
reports
63.6(
e)(
3),
63.10(
d)(
5),
63.1417(
g)

Notification
of
storage
vessel
inspection
63.1417(
h)(
1)

Site­
specific
test
plan
63.1417(
h)(
2)

Notification
of
planned
performance
test
63.1417(
h)(
3)

Notification
of
change
in
primary
product
63.1417(
h)(
4),
63.1400(
g)(
7),
(
8)

Notification
of
added
emission
points
63.1417(
h)(
5)

Notification
that
a
small
control
device
has
been
redesignated
as
a
large
control
device
63.1417(
h)(
6)

Notification
of
process
change
63.1417(
h)(
7)

A
source
must
keep
the
following
records:

Recordkeeping
Five­
year
retention
of
records
63.1416(
a)

Records
of
monitored
values,
maintenance,
startup,
shutdown,
malfunction
63.6,
63.1416(
b)

Monitoring
records
63.1416(
c)

Batch
process
vent
records
63.1416(
d)

Aggregate
batch
vent
stream
records
63.1416(
e)

Continuous
process
vent
records
63.1416(
f)

Other
records
or
documentation
63.1416(
g)

Reduced
recordkeeping
program
63.1416(
h)
7
Above
requirements
include
documentation
of
control
device
performance,
design
evaluation,
performance
test,
values
measured
by
continuous
monitoring
systems,
monitoring
system
calibrations
and
maintenance,
periods
of
monitoring
system
failure/
shutdown
Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
inlet
and
outlet
concentrations
when
determining
percent
efficiency.
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%
of
the
respondents
use
electronic
reporting.

ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
compliance
monitoring
system
(
CMS)
for
pH,
flow,
temperature,
or
specific
gravity,
or
organic
monitoring
device
for
control
options
as
applicable.

Perform
initial
performance
test,
Reference
Method
1,
1A,
2,
2A,
2C,
2D,
3,
4,
18,
308,
316,
or
320
as
applicable,
and
repeat
performance
tests
if
necessary.

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.
8
Respondent
Activities
Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

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,
excess
emissions
reports,
startup,
shutdown,
malfunction
plan,
and
quality
control
plan
for
CMS
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.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
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
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
more
than
100,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
9
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
Eleven
of
the
forty
affected
facilities
in
this
source
category
are
owned
by
small
businesses
as
defined
by
the
Small
Business
Administration
(
SBA).
The
Agency
does
not
expect
that
any
amino/
phenolic
resins
production
facilities,
including
the
small
businesses,
would
experience
more
than
minimal
adverse
impacts
related
to
the
cost
of
the
required
reporting
and
recordkeeping.

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
the
Manufacture
of
Amino/
Phenolic
Resins
(
40
CFR
part
63,
subpart
OOO).

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
for
the
subpart
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.
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
for
the
subpart
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.
10
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
to
be
24,044
hours
(
Total
Burden
from
Table
1).
These
hours
are
based
on
Agency
review
and
discussions
with
the
industry
during
development
of
the
rule,
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
and
the
previously
approved
ICR.

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.

Managerial
$
93.09
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
This
section
covers
the
costs
associated
with
all
types
of
continuous
monitoring
equipment
(
e.
g.,
compliance
emission
monitoring
system
(
CEMS)
and
continuous
parameter
monitors).
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
subject
standards
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
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.
Operating
and
Maintenance
(
O&
M)
Costs
11
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs
(
A)
Continuou
s
Monitoring
Device
(
B)
Capital/
Startup
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startup
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)

pH
Monitor
$
1,000
0
0
$
300
40
$
12,000
Liquid
Flow
Monitor
$
500
0
0
$
100
40
$
4,000
The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
0.
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.

The
total
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
are
$
16,000.
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
annualized
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
16,000.
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.
The
continuous
monitoring
costs
that
are
included
in
this
section
consist
only
of
those
capital/
start­
up
and
O&
M
costs
that
a
source
incurs
as
a
result
of
the
standard.
Some
continuous
monitoring
costs
may
not
be
included
in
this
section.
For
instance,
if
a
particular
industry
typically
utilizes
a
control
device
that
must
have
a
continuous
monitor
(
e.
g.,
temperature,
pressure
drop,
etc.)
to
function
properly,
and
the
recordation
of
additional
measurements
beyond
the
minimum
are
required
by
the
standard,
then
there
is
no
capital/
startup
or
O&
M
cost,
but
there
is
a
labor
cost
to
record
the
additional
readings.
Such
a
cost
would
not
appear
in
this
section,
but
in
the
industry
burden
Section
6(
d)
below.

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
$
16,281
[
see
Table
2
in
Section
6(
e)].
This
cost
is
based
upon
the
following
labor
breakdown:
12
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
Agency
Burden
and
Cost,
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
there
are
approximately
forty
existing
sources
currently
subject
to
the
standard.
It
is
estimated
that
an
additional
zero
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.

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
(
B)
Number
of
Existing
Respondents
(
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
0
40
0
0
40
2
0
40
0
0
40
3
0
40
0
0
40
Average
0
40
0
0
40
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
forty.
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:
13
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
0
5
40
2.1
0
82
1
Weighted
Average.
See
Table
1
for
details.

The
number
of
Total
Annual
Responses
is
82
(
rounded).
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
$
1,521,017.
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.

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
16,281.
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
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
appear
below.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
293
(
rounded)
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
adjustment
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
a
reduction
in
annual
burden
because
the
initial
compliance
activities
have
been
completed
and
there
are
no
new
sources.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
293
(
rounded)
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;
14
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
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
0153,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Enforcement
and
Compliance
Docket
and
Information
Center
Docket
is
(
202)
566­
1752.
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,
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,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0153
and
OMB
Control
Number
2060­
0434
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
the
Manufacture
of
Amino/
Phenolic
Resins
(
40
CFR
part
63,
subpart
OOO)

Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Person­
hrs.

per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person­
hrs.

per
year
$
64.13/
hr
(
E=
C*
D)
(
F)
Management
person­
hrs.
per
year
$
93.09/
hr
(
F=
E*
0.05)
(
G)
Clerical
person­
hrs.

per
year
$
39.65
(
G=
E*
0.1)
(
H)

Annual
costs
in
Dollars
Read
Rule
and
Instructions
16
1
16
40
640
32
64
$
46,559.68
Plan
Activities
8
1
8
40
320
16
32
$
23,279.84
Training
16
1
16
40
640
32
64
$
46,559.68
Create,
Test,
and
Research
and
Development
320d
1
320
2
640
32
64
$
46,559.68
Gather
Information,
Monitor,

and
Inspect
208
1
208
40
8,320
416
832
$
605,275.84
Process/
Compile
and
Review
48
2
96
40
3,840
192
384
$
279,358.08
Complete
Reports
40
2
80
40
3,200
160
320
$
232,798.40
Record/
Disclose
16
2
32
40
1,280
64
128
$
93,119.36
Store/
File/
Maintain
4c
2
8
40
320
16
32
$
23,279.84
LDAR
Reporting
and
Recordkeeping
60a
104b
1
1
60
104
25
2
1,708
85
171
$
124,226.84
Total
Burden
(
hrs)
and
Costs
20,908
1,045
2,091
$
1,521,017
(
rounded)

24,044
Table
2:
Annual
Agency
Burden
and
Cost
NESHAP
for
the
Manufacture
of
Amino/
Phenolic
Resins
(
40
CFR
part
63,
subpart
OOO)

16
Assumptions:

(
a)
Less
than
500
components
(
b)
Greater
than
500
components
(
c)
There
are
27
affected
sources
that
will
be
required
to
comply
with
the
equipment
leaks
LDAR
program;
25
have
less
than
500
components
and
2
have
more
than
500
components.
The
typical
affected
source
has
4
reactor
batch
process
vents,
3
nonreactor
batch
process
vents,
and
no
affected
storage
vessels
or
heat
exchange
systems.

(
d)
Initial
performance
testing
was
assumed
to
take
280
technical
hours
(
1
test
leader
for
two
weeks
and
5
test
crew
for
one
week).
An
additional
40
hours
were
assumed
for
the
establishment
of
parameter
monitoring
levels.
Five
percent
of
the
initial
tests
will
be
repeated
during
each
successive
year.

(
d)
Four
hours
per
week
were
estimated
for
gathering
monitoring
information
and
maintaining
monitoring
equipment.

Burden
Item
(
A)

Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
$
39.49/
hr
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
$
53.22/
hr
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
$
21.38/
hr
(
E=
C*
0.1)
(
F)

Annual
costs
in
Dollars
Initial
performance
test
N/
A
Repeat
performance
test
20
2
40
2
4
$
1,771.56
Report
review
a)
notification
of
construction/

reconstruction
N/
A
b)
notification
of
anticipated
startup
N/
A
c)
notification
of
actual
startup
N/
A
d)
notification
of
modification
N/
A
e)
notification
of
compliance
status
N/
A
f)
notification
of
performance
test
4
2
8
0.4
1
$
337.30
g)
notification
of
process
change
N/
A
h)
notification
of
inspection
of
storage
vessel
N/
A
i)
notification
of
change
in
primary
product
N/
A
17
j)
precompliance
report
N/
A
k)
storage
vessel
initial
compliance
demonstration
N/
A
l)
periodic
reports
of
compliance
status
4
80
320
16
32
$
14,172.48
Total
Burden
(
hrs)
and
Costs
368
18
37
$
16,281
(
rounded)

423
