STANDARD
FORM
83­
I
SUPPORTING
STATEMENT
FOR
OMB
REVIEW
OF
ICR
No.
2027.02
INFORMATION
COLLECTION
REQUEST
FOR
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
FROM
FLEXIBLE
POLYURETHANE
FOAM
FABRICATION
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NORTH
CAROLINA
27711
January
10,
2003
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
The
title
of
this
collection
is
"
Recordkeeping
and
Reporting
Requirements
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Flexible
Polyurethane
Foam
Fabrication."
This
is
a
new
information
collection
request
(
ICR),
and
the
tracking
number
is
EPA
ICR
No.
2027.02.

1(
b)
Short
Characterization/
Abstract
This
ICR
was
prepared
for
a
U.
S.
Environmental
Protection
Agency
(
EPA)
final
rulemaking
developed
under
authority
of
section
112
of
the
Clean
Air
Act
(
CAA).
The
final
rule
amends
title
40,
chapter
I,
part
63
of
the
Code
of
Federal
Regulations
(
CFR)
with
subpart
MMMMM
­­
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Flexible
Polyurethane
Foam
Fabrication.
(
Hereafter,
this
subpart
is
referred
to
as
the
"
foam
fabrication
NESHAP.")
The
foam
fabrication
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutants
(
HAPs).
A
major
source
of
HAP
is
one
that
has
the
potential
to
emit,
considering
controls
(
in
place
under
a
federally
enforceable
agreement),
10
tons
or
more
of
any
one
HAP
or
25
tons
or
more
of
total
HAPs
per
year.
Respondents
are
owners
or
operators
of
affected
sources
regulated
under
the
foam
fabrication
NESHAP.
All
existing
major
sources
must
be
in
compliance
with
the
requirements
of
the
foam
fabrication
NESHAP
within
one
year
of
the
effective
date
(
promulgation
date)
of
standards
for
an
affected
source.
All
new
or
reconstructed
affected
sources
must
be
in
compliance
with
the
requirements
of
the
foam
fabrication
NESHAP
on
the
date
of
startup
or
the
effective
date,
whichever
is
later.

For
the
purposes
of
this
rule,
flexible
polyurethane
foam
fabrication
is
further
divided
into
the
following
two
subcategories:
(
1)
loop
slitter
adhesive
use
and
(
2)
flame
lamination.

According
to
the
available
information,
the
foam
fabrication
industry
consists
of
an
estimated
61
existing
nationwide
facilities.
This
includes
40
loop
slitter
facilities
and
21
flame
lamination
facilities.
Of
these
facilities,
eight
flame
lamination
facilities
are
considered
to
be
potential
major
sources
and
may
be
subject
to
the
requirements
under
the
foam
fabrication
NESHAP.
In
the
first
three
years
after
the
effective
date
(
promulgation
date),
we
anticipate
that
three
new
flame
lamination
sources
will
be
constructed
and
two
loop
slitters
facilities
will
be
constructed
or
2
reconstructed.
Of
these,
one
flame
lamination
facility
may
be
a
major
source
and,
if
so,
would
be
subject
to
requirements
for
new
and
reconstructed
sources
in
the
foam
fabrication
NESHAP.

Table
1
provides
a
summary
of
the
facilities
in
the
foam
fabrication
industry
and
their
assumed
status
under
the
foam
fabrication
NESHAP.

TABLE
1.
NUMBER
OF
FOAM
FABRICATION
FACILITIES
Loop
slitters
Flame
Lamination
Existing
facilities
40
21
Existing
major
sources
0
8
New
facilities
(
assumed)
2
3
New
major
sources
(
assumed)
0
1
Facilities
subject
to
rule
0
9a
a
No
emission
limit
or
other
MIRR
requirements
are
required
for
existing
flame
lamination
sources,
so
only
the
one
new
potential
major
source
would
be
subject
to
the
emissions
limit
and
MIRR
requirements
of
the
rule.
The
other
eight
major
sources
would
only
be
subject
to
a
one­
time
initial
notification
requirement.

The
period
considered
in
the
initial
ICR
and
throughout
this
supporting
statement
is
the
first
three
years
following
promulgation
of
the
foam
fabrication
NESHAP.
For
the
purposes
of
calculating
the
reporting
and
recordkeeping
burden
over
this
period,
we
made
the
following
assumptions
based
on
available
information.
We
assumed
that
all
existing
and
new
major
sources
will
read
the
rule.
For
existing
flame
lamination
facilities,
there
are
no
emission
limits
or
monitoring,
inspection,
reporting,
and
recordkeeping
(
MIRR)
requirements
except
for
submission
of
an
initial
notification.
Therefore,
we
assumed
that
the
eight
existing
flame
lamination
facilities
will
submit
an
initial
notification
and
will
not
perform
any
other
MIRR
activities.
Finally,
we
assumed
that
one
new
flame
lamination
facility
will
perform
all
activities
necessary
to
comply
with
the
emission
limit
and
MIRR
requirements
for
new
flame
lamination
sources.

We
estimate
that
the
total
MIRR
costs
for
new
and
existing
sources
during
the
first
three
years
after
promulgation
of
the
foam
fabrication
NESHAP
are
$
162,371.
Of
the
estimated
total
MIRR
costs,
$
154,399
is
labor
dollars
for
the
first
three
years
and
$
7,972
is
capital
and
operation
and
maintenance
for
the
first
three
years.
The
annual
costs
for
each
of
the
first
three
years
after
promulgation
are
not
expected
to
be
equal
and
are
expected
to
differ
from
costs
in
subsequent
years,
because
existing
major
sources
will
likely
phase
in
their
compliance
activities
prior
to
their
3
compliance
date,
which
is
one
year
after
the
promulgation
date,
and
new
sources
may
be
constructed
in
subsequent
years.
See
section
6
for
more
details
on
cost
estimates.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
We
have
been
directed
by
section
112
of
the
CAA
to
regulate
the
emissions
of
HAP
from
stationary
sources.
The
flexible
polyurethane
foam
fabrication
operations
source
category
contains
major
sources
of
HAP
emissions
and
is
included
on
our
list
of
categories
scheduled
for
regulation.
The
HAP
identified
as
being
emitted
from
foam
fabrication
sources
are
methylene
chloride
(
MeCl
2),
hydrochloric
acid
(
HCl),
hydrogen
cyanide
(
HCN)
and
toluene
diisocyanate
(
TDI).

Section
114
of
the
CAA
gives
us
authority
to
collect
data
and
information
necessary
to
enforce
standards
established
under
section
112
of
the
CAA.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
(
1)
identify
existing
and
new
sources
subject
to
the
foam
fabrication
NESHAP
and
(
2)
ensure
that
the
requirements
specified
for
an
affected
source
subject
to
the
foam
fabrication
NESHAP,
which
are
based
on
maximum
achievable
control
technology
(
MACT),
are
being
achieved.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
our
enforcement
personnel
to
(
1)
identify
existing
and
new
HAP
emission
points
subject
to
the
foam
fabrication
NESHAP,
(
2)
ensure
that
MACT
is
being
properly
applied,
and
(
3)
ensure
that
control
equipment
is
being
properly
operated
and
maintained
on
a
continuous
basis
to
reduce
HAP
emissions
from
foam
fabrication
sources.

Records
and
reports
are
necessary
to
enable
us
to
identify
facilities
subject
to
the
foam
fabrication
NESHAP
that
may
not
be
in
compliance.
Based
on
reported
information,
we
can
decide
whether
to
inspect
a
facility
and
which
records
or
processes
to
inspect.
The
records
that
facilities
maintain
must
indicate
to
us
whether
facility
personnel
are
operating
and
maintaining
control
equipment
properly.
4
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
A
search
of
our
existing
standards
and
ongoing
ICRs
revealed
some
overlap
in
information
gathering
efforts
between
the
foam
fabrication
NESHAP
and
a
federal
rule,
specifically
the
Occupational
Safety
and
Health
Administration's
(
OSHA)
Occupational
Exposure
to
Methylene
Chloride
rule
(
62FR1494).
Certain
reports
required
by
OSHA
may
duplicate
information
required
by
the
standard.
In
such
cases,
a
copy
of
the
report
submitted
to
OSHA
may
be
sent
in
lieu
of,
or
as
a
part
of,
the
report
required
by
the
standards.
We
have
minimized
the
overlap
by
requiring
minimal
reporting
from
loop
slitter
sources.
The
OSHA
rule
does
not
apply
to
flame
lamination
sources.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
This
section
does
not
apply
since
public
notice
was
given
as
part
of
the
proposal
process
for
the
foam
fabrication
NESHAP.

3(
c)
Consultations
OMB
regulations
require
periodic
consultation
with
respondents
and
data
users
such
as
members
of
industry
as
well
as
State
and
local
governments.
We
consulted
with
numerous
representatives
of
companies
involved
with
foam
fabrication
throughout
the
NESHAP
development
process.
Table
2
presents
a
list
of
the
names,
affiliations,
and
telephone
numbers
of
several
of
the
people
we
consulted
during
the
final
rule
development.

Public
comments
on
the
foam
fabrication
NESHAP
were
solicited
by
the
proposal
notice.

The
EPA
received
a
total
of
eight
letters
commenting
on
the
proposed
standard.
The
comments
were
summarized
and
addressed
in
the
EPA
document
"
Background
Information
Document
for
Promulgation
of
National
Emissions
Standards
for
Hazardous
Air
Pollutant
(
NESHAP):
Flexible
Polyurethane
Foam
Fabrication
Summary
of
Public
Comments
and
Responses."
Changes
made
to
the
rule
as
a
result
of
addressing
these
comments
did
not
affect
the
estimate
of
burden
for
the
standard.
5
TABLE
2.
FLEXIBLE
POLYURETHANE
FOAM
FABRICATION
CONSULTATIONS
Name
Affiliation
Telephone
Number
Curt
Baker
Ohio
Decorative
Products
(
423)
689­
6911
Donnie
Skinner
Hickory
Springs
(
919)
672­
3383
Charles
Johnson
Carpenter
Co.
(
804)
233­
0606
Randy
Rains
Guilford
Fabricators
(
336)
434­
3163
Lou
Peters
Polyurethane
Foam
Association
(
973)
633­
9044
Tom
Burghardt
Foamex
International
(
610)
859­
3010
Mark
Anstey
Shawmut
Mills
(
508)
588­
3300
Chester
Ellis
Collins
&
Aikman
Corp.
(
252)
753­
7495
3(
d)
Effects
of
Less
Frequent
Collection
If
the
requirement
for
the
designated
representatives
of
owners
and
operators
of
affected
sources
to
submit
compliance
demonstrations
of
relevant
information
were
collected
less
frequently,
we
would
not
be
reasonably
assured
that
a
source
is
in
compliance
with
the
NESHAP.

In
addition,
our
authority
to
take
administrative
action
would
be
significantly
reduced.

3(
e)
General
Guidelines
The
foam
fabrication
NESHAP
would
require
owners
or
operators
of
an
affected
source
to
retain
records
for
5
years,
which
exceeds
the
3­
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.6.
The
5­
year
retention
period
is
consistent
with
the
subpart
A
General
Provisions
of
40
CFR
part
63
and
the
retention
requirement
in
the
operating
permit
program
under
Title
V
of
the
CAA.
All
subsequent
general
guidelines
have
been
followed
and
do
not
violate
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.6.

3(
f)
Confidentiality
All
information
submitted
to
us
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
our
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
subpart
B,

Confidentiality
of
Business
Information.
See
40
CFR;
41
FR
36902,
September
1,
1976;

amended
by
43
FR
3999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,
March
23,
1979.
Even
where
we
have
determined
that
data
received
in
response
to
an
ICR
is
eligible
for
confidential
treatment
under
40
CFR
Part
2,
subpart
B,
we
may
nonetheless
disclose
the
information
if
it
is
"
relevant
in
any
proceeding"
under
the
statute
[
42
U.
S.
C.
7414
6
(
C);
40
CFR
2.301
(
g)].
The
information
collection
complies
with
the
Privacy
Act
of
1974
and
Office
of
Management
and
Budget
(
OMB)
Circular
108.

3(
g)
Sensitive
Questions
Information
that
will
be
reported
consists
of
emissions
data
and
other
information
that
are
not
expected
to
be
of
a
sensitive
nature.
Therefore,
this
section
is
not
applicable.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
and
NAICS
Codes
Respondents
are
owners
or
operators
of
all
existing
and
new
HAP­
emitting
affected
sources
in
the
flexible
polyurethane
foam
fabrication
operations
source
category.
The
source
category
and
affected
sources
regulated
by
the
foam
fabrication
NESHAP
are
classified
under
the
Standard
Industrial
Classification
(
SIC)
code
3086,
"
Plastic
Foam
Products."
The
corresponding
North
American
Industrial
Classification
System
(
NAICS)
code
is
32615,
"
Urethane
and
Other
Foam
Product
(
except
Polystyrene)
Manufacturing."

4(
b)
Information
Requested
The
final
standards
are
based
on
material
substitution
or
add­
on
control
devices
to
reduce
HAP
emissions.
In
order
to
demonstrate
compliance
with
the
standards,
facilities
may
use
continuous
parameter
monitoring
systems
(
CPMS)
for
control
devices,
or
recordkeeping
for
compliant
materials
(
i.
e.,
adhesives).
The
burden
and
cost
estimates
presented
below
assume
the
use
of
CPMS
or
recordkeeping
to
demonstrate
compliance.

4(
b)(
i)
Data
items,
including
recordkeeping
requirements
New
flame
lamination
major
sources
and
new
and
existing
loop
slitter
major
sources
are
also
required
to
submit
the
following
notifications:
(
1)
initial
notification,
(
2)
notification
of
compliance
status,
and
(
3)
notification
of
intent
to
conduct
a
performance
test
(
flame
lamination
only).

All
affected
major
sources
(
including
those
for
which
there
are
no
emission
limits
in
the
rule)
with
an
initial
startup
date
before
the
proposal
date
of
the
standards
must
submit
a
one­
time
initial
notification
not
later
than
120
days
after
the
effective
date
of
the
foam
fabrication
NESHAP.
A
new
or
reconstructed
major
source
with
an
initial
startup
date
on
or
after
the
proposal
date
of
the
standards
must
submit
the
application
for
construction
or
reconstruction
in
lieu
of
the
initial
notification.
The
application
is
required
to
contain
information
on
the
air
pollution
control
that
will
be
used
for
each
potential
HAP
emission
point.
The
information
in
the
7
application
for
construction
or
reconstruction
will
enable
enforcement
personnel
to
identify
the
number
of
sources
subject
to,
or
already
in
compliance
with,
the
standards.

The
due
date
for
the
notification
of
compliance
status
is
dependent
upon
whether
a
performance
test
is
required.
For
affected
loop
slitter
sources
subject
to
standards
under
the
foam
fabrication
NESHAP,
a
performance
test
is
not
required
and
the
notification
of
compliance
status
must
be
submitted
within
60
days
of
the
compliance
date
(
one
year
from
the
date
of
promulgation
of
the
final
rule).
For
affected
flame
lamination
sources
subject
to
standards
under
the
foam
fabrication
NESHAP,
a
performance
test
is
required
and
the
notification
of
compliance
status
must
be
submitted
before
the
close
of
business
on
the
60th
calendar
day
following
the
completion
of
the
performance
test,
which
must
be
conducted
within
180
calendar
days
after
the
compliance
date.

Sources
required
to
conduct
a
performance
test
to
demonstrate
compliance
must
submit
a
notification
of
intent
to
conduct
a
performance
test
at
least
60
calendar
days
before
the
performance
test
is
scheduled
to
begin.

Affected
sources
subject
to
standards
under
the
foam
fabrication
NESHAP
must
submit
ongoing
compliance
reports.
The
first
compliance
report
is
due
on
January
31
or
July
31,

whichever
date
follows
the
end
of
the
first
calendar
half
after
the
compliance
date.
Compliance
reports
subsequent
to
the
first
compliance
report
must
be
submitted
semiannually
for
flame
lamination
sources
and
annually
for
loop
slitter
sources.
Each
compliance
report
would
have
to
be
signed
by
a
responsible
company
official
who
certifies
its
truth,
accuracy,
and
completeness
and
certifies
that
the
affected
source
has
complied
with
the
relevant
standards.
Affected
sources
are
required
to
include
in
the
report
information
on
deviations
from
emissions
limitations.
For
affected
loop
slitter
sources,
a
list
of
adhesives
used
and
a
statement
certifying
that
they
meet
the
emission
limitation
would
additionally
be
included.
For
affected
flame
lamination
sources,
the
report
must
additionally
include
information
on
startups,
shutdowns
and
malfunctions
that
were
consistent
with
the
startup,
shutdown
and
malfunction
plan.
The
semiannual
compliance
report
must
be
submitted
within
30
days
after
the
end
of
each
calendar
half.

The
foam
fabrication
NESHAP
requires
owners
or
operators
of
affected
flame
lamination
sources
subject
to
standards
under
the
foam
fabrication
NESHAP
to
develop
startup,
shutdown,

and
malfunction
plans
(
SSMP)
to
document
procedures
that
will
be
taken
in
the
case
of
any
of
these
events.
The
SSMP
must
be
prepared
by
the
affected
source's
compliance
date.
If
a
startup,
8
shutdown
or
malfunction
occurs
that
is
not
consistent
with
the
SSMP,
the
affected
source
is
required
to
submit
a
startup,
shutdown
and
malfunction
report
by
fax
or
telephone
within
two
working
days
after
starting
actions
inconsistent
with
the
SSMP
and
by
letter
within
seven
working
days
after
the
end
of
the
event.

Affected
sources
subject
to
the
foam
fabrication
NESHAP
are
required
to
maintain
records
of
the
following:
1)
a
copy
of
each
notification
and
report
submitted,
and
documentation
supporting
each
notification
and
report
submitted;
2)
records
related
to
startup,
shutdown,
and
malfunction
(
for
flame
lamination
sources);
3)
records
of
performance
tests
(
for
flame
lamination
sources);
4)
records
of
operating
parameter
values
(
for
flame
lamination
sources);
5)
records
of
all
deviations
from
emission
limitations
(
for
flame
lamination
sources);
6)
list
of
adhesives
used
and
the
manufacturer
or
supplier
of
each
(
for
loop
slitter
sources);
and
7)
record
of
Method
311
or
alternative
approved
method
(
for
loop
slitter
sources).

New
flame
lamination
sources
are
required
to
develop
a
site­
specific
performance
evaluation
test
plan
prior
to
conducting
a
performance
test.
The
test
plan
must
be
submitted
to
the
Administrator
only
if
requested
by
us.
They
must
also
develop
a
site­
specific
monitoring
plan.

The
foam
fabrication
NESHAP
requires
owners
or
operators
of
an
affected
source
to
retain
records
for
5
years.
Records
must
be
maintained
on­
site
for
at
least
2
years
after
the
date
of
each
occurrence,
measurement,
maintenance,
corrective
action,
report,
or
record.
Records
may
be
kept
offsite
for
the
remaining
3
years
but
must
be
made
readily
available
upon
request.

4(
b)(
ii)
Respondent
activities
The
activities
that
we
assumed
would
be
performed
by
respondents
to
meet
the
requirements
of
the
foam
fabrication
NESHAP
for
each
of
the
first
three
years
are
presented
in
Tables
3a
through
3c
for
existing
sources
and
in
Tables
3d
through
3f
for
new
sources.
We
have
assumed
that
one
new
flame
lamination
facility
will
be
constructed
during
each
year
after
promulgation,
with
only
the
facility
constructed
during
the
first
year
being
a
potential
major
source
and
becoming
subject
to
the
rule,
and
that
two
new
loop
slitter
facilities
will
be
constructed
or
reconstructed,
one
during
each
of
the
first
two
years
after
promulgation,
neither
of
which
will
be
a
major
source.
We
have
assumed
that
all
of
the
new
and
existing
major
affected
sources
will
read
the
rule.

In
the
first
year,
we
have
assumed
that
all
major
sources
will
submit
an
initial
notification
and
the
one
new
flame
lamination
facility
will
startup,
install
control
and
monitoring
equipment,
9
conduct
a
performance
test
and
submit
the
first
compliance
report.
The
cost
of
the
control
equipment
is
not
included
in
this
ICR
because
it
is
not
purchased
for
the
purpose
of
satisfying
the
reporting
or
recordkeeping
requirements.
In
the
second
and
third
years,
we
have
assumed
that
the
one
new
facility
will
continue
to
submit
semiannual
compliance
reports.
The
labor
hour
and
cost
burden
of
respondent
MIRR
activities
and
capital
and
operation
and
maintenance
(
O&
M)

costs
over
the
first
three
years
is
summarized
in
Table
4.

5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
A
list
of
our
activities
for
each
of
the
first
three
years
after
promulgation
of
the
foam
fabrication
NESHAP
is
provided
in
Tables
5a
through
5f.
Table
6
summarizes
the
estimated
labor
hours
and
costs
for
us
over
the
first
three
years.
These
tables
are
introduced
in
Section
6(
c)
of
this
ICR.

5(
b)
Collection
Methodology
and
Management
Information
contained
in
the
one­
time­
only
reports
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
our
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
Information
contained
in
the
periodic
reports
submitted
to
us
will
be
reviewed
for
accuracy
and
completeness.
Data
from
records
maintained
by
the
respondents
and
obtained
during
periodic
visits
by
our
personnel
will
be
tabulated
and
published
for
internal
use
in
compliance
and
enforcement
programs.

5(
c)
Small
Entity
Flexibility
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
on
our
part.
We
have
reduced
the
recordkeeping
and
reporting
requirement
respondent
burden
to
include
only
the
information
needed
by
us
to
determine
compliance
with
the
foam
fabrication
NESHAP.
The
foam
fabrication
NESHAP
is
applicable
only
to
major
sources.

By
definition,
a
small
business
is
any
business
that
is
independently
owned
and
operated
and
not
dominant
in
its
field
as
defined
by
the
Small
Business
Administration
(
SBA)
regulations
under
Section
3
of
the
Small
Business
Act.
For
the
purpose
of
assessing
the
impacts
of
the
proposed
foam
fabrication
NESHAP
on
small
entities,
a
small
entity
is
defined
based
on
definitions
provided
by
the
Small
Business
Administration
(
SBA).
Based
on
the
SBA
definitions,

there
are
no
small
entities
affected
by
any
of
the
final
NESHAP.
Therefore,
the
final
rule
will
not
10
have
a
significant
impact
on
a
substantial
number
of
small
entities,
and
small
business
considerations
do
not
apply.

5(
d)
Collection
Schedule
The
foam
fabrication
NESHAP
is
scheduled
for
promulgation
in
the
Federal
Register
in
February
2003.
Collection
of
data
will
begin
after
promulgation
of
the
standards.
The
schedule
for
reports
that
are
required
by
the
foam
fabrication
NESHAP
is
summarized
below.

The
initial
notification
for
existing
major
sources
is
due
no
later
than
120
days
after
the
promulgation
date.
For
sources
required
to
conduct
a
performance
test,
the
notification
of
intent
to
conduct
a
performance
test
must
be
submitted
at
least
60
days
before
the
performance
test
is
scheduled
to
begin.
The
notification
of
compliance
status
must
be
submitted
within
60
days
after
completing
a
performance
test,
if
required,
which
must
be
conducted
within
180
days
after
the
compliance
date,
or
within
60
days
of
the
compliance
date
if
no
performance
test
is
required.

Affected
major
sources
subject
to
standards
under
the
foam
fabrication
NESHAP
are
required
to
submit
compliance
reports.
The
first
compliance
report
is
due
on
January
31
or
July
31,
whichever
date
follows
the
end
of
the
first
calendar
half
after
the
compliance
date.
Compliance
reports
subsequent
to
the
first
compliance
report
must
be
submitted
semiannually
for
affected
flame
lamination
sources
and
annually
for
affected
loop
slitter
sources.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
The
annual
burden
for
respondent
activities
includes
labor
cost,
capital/
startup
cost,
and
operating
and
maintenance
(
O&
M)
cost.
Our
estimates
of
total
burden
for
respondents
for
each
of
the
first
three
years
after
promulgation
of
the
foam
fabrication
NESHAP
are
presented
in
Tables
3a
through
3f.

6(
b)
Estimating
Respondent
Costs
6(
b)(
i)
Estimating
labor
costs
The
estimates
of
annual
total
technical
labor
hours
per
source
and
the
annual
number
of
activities
per
respondent
listed
in
each
of
Tables
3a
through
3f
are
based
upon
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts
and
the
number
of
emission
points
in
each
source.
Activities
that
are
one­
time­
only
activities
are
identified
as
such
in
the
tables.
1
Memorandum.
Harris,
J.,
EC/
R
Incorporated
to
Friedman,
B.,
EC/
R
Incorporated.
CPMS
Cost
Estimates
for
Flame
Lamination.
February
6,
2001.
11
The
estimated
costs
of
the
activities
listed
in
Tables
3a
through
3f
were
based
on
data
from
the
U.
S.
Bureau
of
Labor
Statistics'
Internet
web
site
(
http://
www.
bls.
gov/
news.
release/
ecec.
t12.
htm),
Table
12,
accessed
November
29,
2000.
Labor
costs
were
divided
into
the
following
three
categories:
(
1)
technical,
(
2)
managerial,
and
(
3)
clerical.
Managerial
and
clerical
labor
hours
were
calculated
as
5
and
10
percent,
respectively,

of
each
technical
labor
hour
requirement.
In
addition,
the
labor
rates
were
multiplied
by
1.5
to
account
for
overhead
costs.
Therefore,
we
estimated
the
cost
of
technical
labor
for
foam
fabrication
to
be
$
42.89
per
hour
($
42.89/
hr),
the
cost
of
managerial
labor
to
be
$
65.19/
hr,
and
the
cost
of
clerical
labor
to
be
$
27.11/
hr.
These
estimates
included
fringe
benefits.
All
costs
are
in
March
2000
dollars.

6(
b)(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs
For
the
foam
fabrication
NESHAP,
affected
flame
lamination
sources
can
demonstrate
continuous
compliance
and
meet
reporting
and
recordkeeping
requirements
using
monitoring
devices.
Three
monitoring
devices
(
pH,
differential
pressure,
and
liquid
flow
rate),
along
with
a
data
recorder,
would
be
used
to
demonstrate
compliance.
The
total
estimated
installed
capital
cost
of
this
equipment
is
estimated
at
$
7,000
for
new
major
sources
($
2,000
per
monitor
and
$
1,000
for
the
data
recorder),
based
on
quotes
provided
by
equipment
manufacturers.
1
The
cost
of
add­
on
control
equipment
is
not
included
in
this
ICR
because
it
is
not
purchased
for
the
purpose
of
satisfying
the
reporting
and
recordkeeping
requirements.
See
Table
4
for
capital
cost
information.

The
total
annual
estimated
O&
M
costs
were
calculated
based
on
(
1)
operation
and
maintenance
costs
for
monitoring
equipment,
(
2)
the
estimated
postage
costs
for
annual
responses
associated
with
the
provisions
of
the
foam
fabrication
NESHAP
and
(
3)
the
performance
test
contracting
costs
required
of
flame
lamination
facilities
to
demonstrate
compliance
with
this
standard.
The
annual
O&
M
cost
for
operating
the
monitoring
equipment
is
estimated
at
10
percent
of
the
annualized
capital
cost,
or
$
100.
Postage
costs
are
for
submittal
to
regulatory
agencies
of
notifications
and
reports
required
by
the
rule.
Total
postage
costs
for
the
first
three
years
after
promulgation
were
estimated
at
$
87.84
per
respondent.
The
postage
rates
($
3.50
per
one­
pound
package
by
Priority
Mail,
and
$
0.34
per
one­
ounce
First­
Class
letter)
were
based
on
12
data
from
U.
S.
Postal
Services
Internet
web
site
(
http://
www.
usps.
com),
accessed
February
23,

2001.
The
per­
response
cost
of
performance
test
contracting
is
estimated,
based
on
information
provided
by
test
contractors,
to
be
$
4,550
for
the
tests
required
for
flame
lamination
facilities
and
$
1500
for
the
test
required
for
loop
slitter
facilities.
See
Table
4
for
O&
M
cost
information.

6(
b)(
iii)
Annualizing
Capital
Costs
The
total
installed
capital
cost
of
the
monitoring
equipment
at
new
sources
($
7,000)
was
multiplied
by
a
capital
recovery
factor
(
CRF)
of
0.1424,
using
an
interest
rate
of
7
percent
and
an
estimated
equipment
life
of
10
years,
to
calculate
the
annualized
capital
cost.
The
annualized
capital
cost
is
$
997.

6(
c)
Estimating
the
EPA's
Burden
and
Cost
Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
the
foam
fabrication
NESHAP,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
recordkeeping
and
reporting
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
CAA,
no
operational
costs
will
be
incurred
by
the
Federal
government.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
operated
and
maintained
by
our
OAQPS,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
affected
sources.
Periodic
inspections
are
part
of
our
overall
compliance
and
enforcement
program.
Therefore,
these
examinations
are
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information.
Labor
rates
and
associated
costs
are
based
on
the
2000
General
Schedule
(
GS)
base
annual
salary
data
from
Federal
Personnel
Guide
Internet
web
site
(
http://
www.
fedguide.
com/
baseannualsalaries99.
html),
accessed
November
29,
2000.
We
estimated
an
average
hourly
labor
cost
of
$
37.12
for
technical
staff,
$
61.35
for
managerial
staff,

and
$
18.83
for
administrative/
clerical
staff.
To
derive
hourly
estimates,
we
divided
annual
compensation
estimates
by
2,080,
which
is
the
number
of
hours
in
the
Federal
work
year.
We
then
multiplied
hourly
rates
by
the
standard
government
benefits
multiplication
factor
of
1.6
for
60
percent
overhead
expenses.
The
federal
burden
and
cost
are
detailed
in
Table
5a
through
5f
and
summarized
in
Table
6.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
13
To
calculate
the
total
burden
for
respondents,
we
estimated
the
number
of
respondents
(
the
respondent
universe)
to
complete
each
activity.
The
burden
for
each
activity
was
calculated
by
multiplying
the
per­
respondent
burden
per
activity
by
the
number
of
respondents.

The
respondent
universe
varies
among
the
activities
listed
in
Tables
3a
through
3f,
because
not
all
respondents
must
complete
each
activity.
The
total
burden
and
costs
are
summarized
in
Table
4.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
Tables
6(
e)(
i)
Respondent
tally
The
bottom
line
respondent
burden
hours
and
costs
are
summarized
in
Table
4.
The
estimated
total
nationwide
burden
for
existing
sources
in
the
first
three
years
after
promulgation
of
the
foam
fabrication
NESHAP
are
an
estimated
92
total
labor
hours
and
$
3,912.
The
burden
cost
estimate
includes
labor,
capital
and
O&
M
costs.
Because
we
anticipate
construction
in
the
near
future
of
one
new
major
source
subject
to
the
standards
under
the
foam
fabrication
NESHAP
and
four
new
sources
not
subject
to
the
standards,
our
estimated
burden
for
new
sources
is
3,542
total
labor
hours
and
$
158,459
for
the
first
three
years
after
promulgation.
The
total
estimated
annual
labor
hour
reporting
and
recordkeeping
burden
for
the
first
three
years
is
1,211
labor
hours.

The
total
estimated
annualized
capital
and
startup
costs
and
annual
operating
and
maintenance
(
O&
M)
costs
to
comply
with
the
proposed
standard
were
estimated
to
be
$
2,657
.

Table
4
includes
summarized
annualized
capital
and
startup
costs
and
annual
O&
M
costs.
The
total
annualized
capital
and
startup
costs
reflect
the
estimated
capital
costs
of
equipment
to
comply
with
MIRR
activities
associated
with
the
proposed
standards.
The
total
annual
O&
M
costs
reflect
costs
that
are
associated
with
the
MIRR
equipment
but
that
are
not
included
in
the
labor
hour
burden
estimate.

The
total
capital
and
O&
M
costs
for
existing
major
sources
are
estimated
to
be
$
3
for
the
first
three
years
after
promulgation.
For
new
major
sources,
capital
and
annual
O&
M
costs
are
estimated
to
be
$
7,969
for
the
first
three
years
after
promulgation.

6(
e)(
ii)
The
EPA
tally
The
bottom
line
Federal
government
burden
hours
and
costs
that
would
result
from
this
ICR
in
the
first
three
years
following
promulgation
of
the
foam
fabrication
NESHAP
are
14
presented
in
Tables
5a
through
5c
for
existing
major
sources
and
in
Tables
5d
through
5f
for
new
major
sources.
Estimated
hours
and
costs
for
existing
sources
are
37
total
labor
hours
and
$
1,346
for
the
first
three
years
after
promulgation.
Estimated
hours
and
costs
for
new
sources
are
423
total
labor
hours
and
$
15,482
for
the
first
three
years
after
promulgation.
Table
6
summarizes
the
Federal
government
burden
hours
and
costs
for
the
foam
fabrication
NESHAP
over
the
first
three
years.

6(
e)(
iii)
Variations
in
the
annual
bottom
line
Variations
in
the
annual
bottom
line
for
this
regulation
may
occur
over
the
three
years
following
promulgation
of
this
rule
because
(
1)
certain
one­
time
activities
would
typically
occur
prior
to
the
source's
compliance
date
and
(
2)
new
sources
may
be
constructed
or
reconstructed.

6(
f)
Reasons
for
Change
in
Burden
This
section
does
not
apply,
because
this
is
a
new
collection.

6(
g)
Burden
Statement
The
respondent
universe
consists
of
9
facilities,
although
8
of
these
facilities
would
only
be
subject
to
a
one­
time
initial
notification
requirement.
The
total
burden
hours
and
costs,

respectively,
for
this
collection
are
presented
in
Table
4.
We
have
assumed
that
one
new
major
source
flame
lamination
facility
will
startup
during
the
first
year
following
rule
promulgation
and
will
incur
startup
costs
associated
with
installing
monitoring
equipment.

The
total
three­
year
monitoring,
recordkeeping,
and
reporting
burden
for
this
collection
is
estimated
at
3,634
labor
hours,
and
the
annual
average
burden
is
1,211
labor
hours.
The
annualized
capital
costs
for
monitoring
equipment
is
estimated
to
be
$
997.
Annual
O&
M
costs
are
estimated
to
be
$
4,982
over
three
years,
averaging
$
1,661
per
year.
The
hour
burden
estimate
includes
time
to
read
the
rule,
write
and
submit
required
notifications
and
reports,
perform
recordkeeping
activities,
perform
performance
tests,
develop
plans
for
implementing
recordkeeping
requirements,
develop
record
systems,
train
personnel,
and
store,
file
and
retrieve
records.
The
cost
burden
estimate
includes
the
cost
of
labor
hours,
purchase
of
capital
equipment
necessary
to
generate
and
record
data
needed
to
meet
the
MIRR
requirements
in
the
rule,
postage
to
submit
notifications
and
reports,
and
performance
test
contractor
costs.

Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
140
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
15
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.

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
No.
OAR­
2002­
0080,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center,
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
Air
Docket
is
(
202)
566­
1742.
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.
Once
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
No.
(
OAR­
2002­
0080).
16
PART
B
OF
THE
SUPPORTING
STATEMENT
Not
applicable.
No
sampling
or
other
methods
are
used
to
select
respondents
because
all
owners
or
operators
of
facilities
subject
to
the
foam
fabrication
NESHAP
are
required
to
collect
information.
