SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63,
Subpart MMMMM) 

1.  Identification of the Information Collection

	1(a) Title of the Information Collection

NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR part 63,
subpart 

MMMMM) (Renewal), EPA ICR 2027.04, OMB Control Number 2060-0516

	1(b) Short Characterization/Abstract	

	The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Flexible Polyurethane Foam Fabrication were proposed on August 8,
2001 (66 FR 41729), and promulgated on April 14, 2003 (68 FR 18062). 
These regulations apply to each existing, new, or reconstructed affected
source at facilities engaged in flexible polyurethane foam fabrication. 
For the purpose of the rule, flexible polyurethane foam fabrication is
further divided in the following two subcategories: 1) loop slitter
adhesive use, and 2) flame lamination.  This information is being
collected to assure compliance with 40 CFR part 63, subpart MMMMM.

	In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports by the owners/operators of the
affected facilities.  They 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
affected facilities subject to NESHAP.  An annual summary report is also
required.

	Any owner/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.

	Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site, and each plant site
has only one respondent (i.e., the owner/operator of the plant site).

	An average of 11 respondents will be subject to the regulation over the
period covered by this ICR.  It is estimated that one additional
respondent per year will become subject to the regulation in the next
three years.  Flexible polyurethane foam fabrication is divided into two
subcategories: 1) loop slitter adhesive use, and 2) flame lamination. 
All of the nine respondents are flame lamination sources, with an
anticipation of one additional respondent per year over the 

three years of this ICR.  There is no loop slitter facility that would
be subject to the regulation.  Over the next three years, the average
number of respondents will be eleven.  

	The Office of Management and Budget (OMB) approved the current
Information Collection Request (ICR) without any “Terms of
Clearance.”

	The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost – NESHAP for Flexible Polyurethane Foam
Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal), attached. 

                       The burden to the “Federal Government” is
attributed entirely to work performed by federal employees or government
contractors; this burden may be found in Table 2: Average Annual EPA
Burden – NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR
Part 63, Subpart MMMMM) (Renewal), attached. 

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/operator subject to any requirement of this Act to: 

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, particulate matter emissions from
facilities in flexible polyurethane foam fabrication cause or contribute
to air pollution that may reasonably be anticipated to endanger public
health or welfare.  Therefore, the NESHAP were promulgated for the
source category at 40 CFR part 63, subpart MMMMM.

	

2(b) Practical Utility/Users of the Data

	The recordkeeping and reporting requirements in the standard ensure
compliance with the applicable regulations which were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

	The notifications required in the standard 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, that leaks are being detected and
repaired, and that the standards are being met.  The performance test
may also be observed.

	The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Non-duplication, Consultations, and Other Collection Criteria

	The requested recordkeeping and reporting are required under 40 CFR
part 63, subpart MMMMM.

	3(a) Non-duplication

	If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its 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

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (73 FR 31088) on May 30, 2008.  No
comments were received on the burden published in the Federal Register.

	3(c) Consultations

	For the information collection, we previously referenced the most
recent ICR, consulted 

with the preparer of the active ICR, and used other resources to obtain
the most recent data available.  Information available from the United
States Census Bureau, the Air Facility System 

(AFS), and websites covering flexible polyurethane foam fabrication was
also reviewed.  

	

It is our policy to respond after a thorough review of comments received
since the last ICR renewal as well as those submitted in response to the
First Federal Register Notice.  In this case, no comments were received.

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 that 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 the respondents 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.  The
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.  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.  In addition, 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,
September 1, 1976; amended by 43 FR 3999, September 8, 1978; 43 FR
42251, September 28, 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 to the recordkeeping and reporting requirements are
flexible 

for the respondents affected by the standards is SIC 3086, which
corresponds to the North American Industry Classification System (NAICS)
code 326150 for “Urethane and Other Foam Products (except Polystyrene)
Manufacturing.”

4(b) Information Requested

	These reporting or recordkeeping requirements do not violate any of the
regulations that OMB established under 5 CFR part 1320, section 1320.5.

		(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR part 63,
subpart MMMMM).

	A source must make the following reports:

Notifications	Standard Citation by Sections

Initial notification	63.9(b), 63.8816(b)

Notification of construction/reconstruction	63.9(b)(1)(iii), 63.8816.(c)

Notification of performance test	63.9(e), 63.8816(d)

Notification of compliance status	63.9(h)(2)(ii), 63.8816(e)

First compliance report	63.8818(b)(1)

Semiannual compliance report	63.8818(b)(3)

Annual compliance report	63.8818(c)

SSM report	63.10(d)(5)(i), 63.8818(f)(1)



	A source must make the following reports:

Recordkeeping 

Record of startup, shutdown, and malfunctions	63.10(b)(1), 63.8820(a)

Records are required to be retained for five years	63.10(b)(2)



Electronic Reporting

	At the present, respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must evaluate the data, this internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at the plant site.

	Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

		(ii)  Respondent Activities	

Respondent Activities

Read instructions.

Perform initial performance test, Reference Method 311 test, 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.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.



	Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the sources need to
evaluate the data, this type of monitoring equipment has significantly
reduced the burden associated with monitoring and recordkeeping.

5.  The Information Collected: Agency Activities, Collection
Methodology, and Information Management

	5(a) Agency Activities

	EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information:

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

Review notifications and reports, including performance test reports,
and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).



5(b) Collection Methodology and Management

	Following notification of startup, the reviewing authority might
inspect the source to determine whether the pollution control devices
are properly installed and operated.  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

	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
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses the AFS for tracking air pollution compliance and
enforcement by local and state regulatory agencies, EPA regional offices
and EPA headquarters.  EPA and its delegated Authorities can edit,
store, retrieve and analyze the data.

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

	5(c) Small Entity Flexibility

	A majority of the respondents are large entities (i.e., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  The number of small entities affected by this rule could
not be determined, based on review of the promulgated rule notice in the
Federal Register and a search of publicly available current data
sources.  

Due to technical considerations involving the process operations and the
types of control equipment employed, the recordkeeping and reporting
requirements are the same for both small and large entities.  The Agency
considers these requirements the minimum needed to ensure compliance
and, therefore, cannot reduce them further for small entities.  To the
extent that larger businesses can use economies of scale to reduce their
burden, the overall burden will be reduced.

	5(d) Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM)
(Renewal).

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(a)  Estimating Respondent Burden

	The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 12,303
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of this
regulation, Agency knowledge and experience with the NESHAP program, the
previously approved ICR, and any comments received.

	6(b)  Estimating Respondent Costs

		(i)  Estimating Labor Costs 

 

	This ICR uses the following labor rates: 

		Managerial	$97.46   ($46.41 + 110%)

		Technical	$83.71   ($39.86 + 110%)

		Clerical	$42.55   ($20.26 + 110%)

	These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, “Table 2: Civilian Workers, by
Occupational and Industry group.”  The rates are from column 1,
“Total Compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

		(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

	The type of industry costs associated with the information collection
activities in the subject standard are 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 and
other costs such as photocopying and postage.

Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs



(A)

Continuous Monitoring Device	

(B)

Capital/Startup Cost for One Respondent	

(C)

Number of New Respondents	

(D)

Total Capital/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)



Differential pressure, pH, liquid flow rate, data recorder	

$997	

1	

$997	

$1,674	

1	

$1,674



The total capital/startup costs for this ICR are $997.  This is the
total of column D in the above table. 

The total operation and maintenance (O&M) costs for this ICR are $1,674.
 This is the total of column G.

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 $2,671.

	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
emission, and the publication and distribution of collected information.

	The average annual Agency cost during the three years of the ICR is
estimated to be $58,836.  This cost is based on the average hourly labor
rate as follows:

		Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

		Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

		Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2005
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Burden, NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part
63, Subpart MMMMM) (Renewal).

	

6(d) Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, on average over the next three
years, approximately 11 existing respondents will be subject to the
standard.  It is estimated that one additional respondent per year will
become subject.  The overall average number of respondents, as shown in
the table below is 11 per year.

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

Number of Respondents



	

Respondents That Submit Reports	

Respondents That Do Not Submit Any Reports	





Year	

(A)

Number of New Respondents	

(B)

Number of Existing Respondents	

(C)

Number of Existing 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	1	9	0	0	10

2	1	10	0	0	11

3	1	11	0	0	12

Average	1	10	0	0	11



	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 11.

 

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

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	

(E)

Total Annual Responses 

E=(BxC)+D

Initial notification	1	1	0	1

Application of construction	1	1	0	1

Notification of performance test	1	1	0	1

Notification of compliance status	1	1	0	1

First compliance report	1	1	0	1

Semiannual compliance report	11	2	0	22

SSM report	11	10	0	110



	Total	137



	The number of Total Annual Responses is 137.

6(e) Bottom Line Burden Hours Burden and Cost Tables

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

		

(i) Respondent Tally

	The total annual labor costs are $1,002,163.  Details regarding these
estimates may be found in Table 1: Annual Respondent Burden and Cost,
NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR part 63,
subpart MMMMM) (Renewal), attached.  Furthermore, the annual public
reporting and recordkeeping burden for this collection of information is
estimated to average 89 hours per response.

	The total annual capital/startup and O&M costs to the regulated entity
are $3,000.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

		(ii) The Agency Tally

	The average annual Agency burden and cost over next three years is
estimated to be 1,451 labor hours at a cost of $58,836.  See Table 2:
Annual Agency Burden and Cost, NESHAP for Flexible Polyurethane Foam
Fabrication (40 CFR part 63, subpart MMMMM) (Renewal), attached.

	

	6(f) Reasons for Change in Burden

There is no change in the labor hours or cost to the respondents in this
ICR compared to the previous ICR.  This is due to two considerations. 
First, the regulations have not changed over the past three years and
are not anticipated to change over the next three years.  Secondly, the
growth rate for respondents is very low, negative, or non-existent. 
Therefore, the labor hours and cost figures in the previous ICR reflect
the current burden to the respondents and are reiterated in this ICR. 
Apparent differences of less than 500 hours are attributable to
rounding; in previous years, hours were rounded to the nearest thousand;
this ICR presents more exact figures.

	6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 89 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete 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
EPA-HQ-OECA-2008-0371.  An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the 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 in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 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
docket center is (202) 566-1927.  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
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2008-0371 and OMB Control Number 2060-0516 in any
correspondence.

Part B of the Supporting Statement

	This part is not applicable because no statistical methods were used in
collecting this information.



Table 1:  Annual Respondent Burden and Cost – NESHAP for Flexible
Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal)

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours

per year

(Ex0.05)	

(G)

Clerical

person-

hours per 	year

(Ex0.1)	

(H)

Cost, $  b

1.  Reporting Requirements









    a.  Read instructions c	4	1	4	1	4	0.2	0.4	  $371.35

    b.  Gather information c	4	1	4	11	44	2.2	4.4	$4,084.87

    c.  Reports









      i.  Initial notification  c	2	1	2	1	2	0.1	0.2	$185.68

     ii.  Application for construction                  for new sources
c	2	1	2	1	2	0.1	0.2	$185.68

    iii. Notification of performance

          test c, d	2	1	2	1	2	0.1	0.2	$185.68

    iv.  Notification of compliance

          status c	20	1	20	1	20	1	2	$1,856.76

     v.  First compliance report c	8	1	8	1	8	0.4	0.8	$742.70

    vi.  Semiannual compliance report d	4	2	8	11	88	4.4	8.8	$8,169.74

   vii.  Annual compliance report e	2	1	2	0	0	0	0	$0

  viii.  SSM report   	2	10	20	11	220	11	22	$29,424.36

SUBTOTAL Reporting



	448.5	$45,206.82

4.  Recordkeeping requirements









    a.  Plan activities c	10	1	10	1	10	0.5	1	$928.38

    b.  Implement activities for Flame              Lamination









     i.  Record SSM	1	100	100	11	1,100	55	110	 $102,121.80

    ii.  Conduct performance test c, f	50	1	50	1	50	2.5	5	$4,641.90

   iii.  Record CPMS measurements	2	300	600	11	6,600	330	660	$612,712.80

   iv.  CPMS calibration and                            maintenance	4	50
200	11	2,200	110	220	$204,243.60

    c.  Implement activities for Loop                Slitters









       i.  Record adhesives used and 

           suppliers	1	1	1	0	0	0	0	$0

      ii.  Conduct Method 311 test 	4	1	4	0	0	0	0	$0

    d.  Develop record system









       i.  SSM plan c, d	40	1	40	1	40	2	4	$3,713.52

      ii.  Continuous parameter                            monitoring
system (CPMS)                   maintenance plan c, d	20	1	20	1	20	1	2
$1,856.76

    e.  Time to train personnel









       i.  CPMS acquisition and                           installation
c, d	20	1	20	1	20	1	2	$1,856.76

      ii.  CPMS inspection and                            monitoring c,
d	4	1	4	1	4	0.2	0.4	$371.35

     f.  Store, file, and maintain all 

         records	1

	12	12	11	132	6.6	13.2	$12,254.62

    g.  Retrieve records/reports	1	12	12	11	132	6.6	13.2	$12,254.62

SUBTOTAL Recordkeeping



	11,854.2	$956,956.11



Subtotals Labor Burden and Cost  	

	

	

	

	

10,698	

534.9	

1,069.8	

$1,002,162.93



TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	

12,303	

$1,002,163



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 11. There will be one additional new source
(flame lamination) that will become subject to the rule over the
three-year period of this ICR. 

b  This ICR uses the following labor rates: $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, “Table 2. Civilian Workers, by 

Occupational and Iindustry group.”  The rates are from column 1,
“Total Compensation.”  The rates have been increased by 110% to
account for the benefit packages available to those employed by private
industry.

c  This is a one-time activity for each facility.

d  This applies to flame lamination facilities.

e  This applies to loop slitter adhesive use facilities.

f  It also includes writing site-specific test plan.Table 2:  Average
Annual EPA Burden - NESHAP for Flexible Polyurethane Foam Fabrication
(40 CFR Part 63, Subpart MMMMM) (Renewal)

	Activity	(A)

EPA person-

hours per

occurrence	(B)

No. of

occurrences

per plant

 per year	(C)

EPA person

hours per

plant  per year

(C=AxB)	(D)

Plants per year  a	(E)

Technical

person-hours

per year

(E=CxD)	(F)

Management

person-hours

per year

(Ex0.05)

	(G)

Clerical

person-

hours per year

(Ex0.1)	(H)

Cost, $ b

1.   Review initial notification c	4	1	4	1	4	0.2	0.4	   $186.48

2.   Review application for                   construction c	4

	1

	4

	1

	4

	0.2

	0.4

	$186.48



3.   Review notification of                    compliance status c	20	1
20	1	20	1	2	$932.42

4.   Review initial compliance              report c, d	2

	1

	2

	0

	0

	0

	0

	$0



5.   Review initial compliance              report c, e	20	1	20	1	20	1	2
$932.42

6.   Review notification of                    performance test c, d	4	1
4	1	4	0.2	0.4	$186.48

7.   Review annual compliance             report d	1

	1

	1

	0

	0

	0

	0

	$0



8.   Review semiannual                         compliance report e	15

	2

	30

	11

	330

	16.5	33

	$15,384.93



9.  Review startup, shutdown,             malfunction report e	8

	10

	80

	11

	880

	44

	88

	$41,026.48





TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	1,451	

$58,836



Assumptions:

a  We have assumed that the average number of respondents subject to the
rule will be 11. There are nine flame lamination facilities that are
currently subject to the regulation and it is estimated that one
additional respondent per year will be subject to the requirements over
the three-year period of this ICR.  There are no loop slitters that are
considered major sources that would be subject to the rule.   

b  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $22.50 (GS-6, Step 3, $14.06 x 1.6).  These rates are from the
Office of Personnel Management (OPM) “2005 General Schedule” which
excludes locality rates of pay.

c  This is a one-time activity performed once per facility.

    d  This applies only to loop slitter adhesive use facilities.

    e  This applies only to flame lamination facilities.  

  

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