SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for the Manufacture of Amino/Phenolic Resins (40CFR Part 63,
Subpart OOO) (Renewal)

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) (Renewal), EPA ICR Number 1869.06, OMB Control Number
2060-0434

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the Manufacture of Amino/Phenolic Resins were proposed on December
14, 1998, and promulgated on January 20, 2000.  These standards apply to
existing 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 owners or operators 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 40 sources are currently subject to the regulation, and it
is estimated that no additional sources are expected to become subject
to the standard in the next three years.

The Office of Management and Budget (OMB) approve the currently active
Information Collection Request (ICR) with the following “Terms of
Clearance": 

The burden and cost assumptions and calculations for the respondents and
the agency should be updated in the next renewal.

EPA has addressed each item of concern in the TOC by updating respondent
assumptions using September 2009 labor rates from the United States
Department of Labor, Bureau of Labor Statistics.  Agency assumptions
were updated using the Office of Personnel Management (OPM), 2010
General Schedule for Agency labor.  Respondent and Agency cost
assumptions are provided in Sections 6(b)(i) and 6(c).

The burden to the “Affected Public” may be found below in Table 1:
Annual Respondent Burden and Cost – NESHAP for the Manufacture of
Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO) (Renewal).  The
burden to the “Federal government” is attributed entirely to work
performed by Federal employees or government contractors; this burden
may be found below in Table 2: Average Annual EPA Burden - NESHAP for
the Manufacture of Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO)
(Renewal).

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 (HAPs). 
These standards are applicable to new or existing sources of HAPs 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, HAP emissions from manufacture of
amino/phenolic resins cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP was promulgated for this source category at 40 CFR
part 63, subpart OOO.

2(b)  Practical Utility/Users of the Data

The control of emissions of pollutants 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 affected 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, that leaks are being detected and
repaired, and that the regulations are being met.  The semiannual
reports are used for problem identification, as a check on source
operation and maintenance, and for compliance determinations.

The information generated by the (monitoring, recordkeeping and
reporting) requirement 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 the applicable regulations, as required by the Clean Air
Act.  The information collected from recordkeeping and reporting
requirements is also used for targeting inspections, and is of
sufficient quality to be used as evidence in court.

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

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

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 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

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (74 FR 32583) on July 8, 2009.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

The primary source of information as reported by industry, in compliance
with the recordkeeping and reporting provisions in the standard, is the
Air Facility System (AFS) which is operated and maintained by the EPA
Office of Compliance.  AFS is the Agency’s database for the
collection, maintenance, and retrieval of all compliance data.  The
growth rate for the industry is based on our consultations with the
Agency’s internal industry experts.  In consultation with the
Agency’s industry experts and the AFS databases, we have determined
that there has been no growth in the number of respondents since the
last ICR.

	During a previous renewal of this ICR, industry trade associations and
other interested parties were provided an opportunity to comment on the
burden associated with the standard as it was being developed and the
standard has been previously reviewed to determine the minimum
information needed for compliance purposes.  It is our policy to review
any comments received since the last ICR renewal and to respond
appropriately.  This review includes 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 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

The required information has been determined not to be confidential. 
However, any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, chapter 1, part 2, subpart B -
Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
owners and operators of amino/phenolic resins manufacturing operations. 
The United States Standard Industrial Classification (SIC) code for the
respondents affected by the standard, which corresponds to the North
American Industry Classification System (NAICS) code, are listed below
for source description.

Manufacture of Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO)	SIC
Code	NAICS Code

Plastics Material and Resin Manufacturing	2821	325211



4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by
National Emission Standards for Hazardous Air Pollutants for the
Manufacture of Amino/Phenolic Resins (40 CFR part 63, subpart OOO).

A source must make the following reports:

Reports for 40 CFR Part 63, Subpart OOO

Notification of intent to construct or reconstruct	63.05, 63.1417(d)

Notification and report of construction date	63.05, 63.1400(j)

Notification of anticipated startup	63.05, 63.1400(j)

Actual startup notification 	63.05, 63.1400(j)

Notification of modification	63.05, 63.1400(j)

Notification and report of performance tests and results	63.07 (b),
63.1417(e)

Pre-compliance report	63.1417(d)

Notification and report of compliance status	63.1417(e)

Periodic reports (semiannual) including statement of compliance (if no
exceedances occurred), daily, hatch 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	63.1416(f)(2)

Develop startup, shutdown, malfunction plan	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 re-designated 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 for 40 CFR Part 63, Subpart T

Five-year retention of records	63.1416(a)

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

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)



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 percent 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 tests 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.

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

Adjust existing ways to comply with any previously applicable
instructions and requirements. 

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 operational.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard, and note the operating conditions under which
compliance was achieved.  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 the EPA Office of Compliance.  AFS is the EPA
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 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

A majority of the affected facilities are primarily small entities
(e.g., small businesses).  According to the Final Rule (65 FR 3276): 

We have determined that, of the twenty affected firms, only six are
small businesses . . . .  Although this final rule will not have a
significant economic impact on a substantial number of small entities,
EPA nonetheless has tried to reduce the impact of this rule on small
entities.  In order to minimize the impact of the rule for leaking
equipment, we have exempted firms producing less than 881 tpy (800
Mg/yr) from complying with the requirements to have a leak detection and
repair program.

Therefore, this ICR estimates approximately 30 percent of respondents,
or 12 of the 40 respondents, may be small entities.  Due to technical
considerations involving the process operations and the type 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.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown below in Table 1: Annual Respondent Burden and
Cost - NESHAP for the Manufacture of Amino/Phenolic Resins (40 CFR part
63, subpart OOO) (Renewal).

6.  Estimating the Burden and Cost of the Collection

Table 1 document 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.  Wherever 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 24,044
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the 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	$114.49 ($54.52 + 110%)   

Technical	$98.20 ($46.76 + 110%)

Clerical	$48.53 ($23.11 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, September 2009, “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

	This section covers the costs associated with all types of continuous
monitoring equipment (e.g., continuous emission monitoring system (CEMS)
and continuous parameter monitors).  The types of industry cost
associated with the information collection activities 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 cost when a facility becomes subject
to the regulation.  The annual operation and maintenance costs are the
ongoing costs to maintain the monitors 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)

pH Monitor	$1,000 	0	0	$300	40	$12,000

Liquid Flow Monitor	$500	0	0	$100	40	$4,000



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

The total operation and maintenance (O&M) costs for this ICR are
$16,000.  This is the total of column G.

The average annual cost for capital/startup and operation and
maintenance cost to industry over the next three years of the ICR is
estimated to be $16,000.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 $19,071.  

This cost is based on the average hourly labor rate as follows:

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2010
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  [These rates can be obtained from
the OPM web site: http//www.opm.gov/oca/payrates/index/htm.]  Details
upon which this estimate is based appear below in Table 2: Average
Annual EPA Burden - NESHAP for the Manufacture of Amino/Phenolic Resins
(40 CFR Part 63, Subpart OOO) (Renewal).

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 no additional 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 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	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 40.

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

Respondent Universe and Number of Responses Per Year

Regulation Citation	(A)

Average Number of New Respondents per Year	(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 =

(AxB)+(CxD)+F

40 CFR part 63, subpart OOO	0	5	40	2.05	0	82



The number of total respondents is 40.  This represents the number of
existing sources plus the number of new sources averaged over the
three-year period (i.e., the total of the number of new respondents over
the three-year period divided by three years).

The number of Total Annual Responses is 82.  This is the number in
column E of the Respondent Universe and Number of Responses per Year
table above.

The total annual labor costs are $2,274,320.  Details regarding these
estimates may be found below in Table 1. Annual Respondent Burden and
Cost, NESHAP for the Manufacture of Amino/Phenolic Resins (40 CFR part
63, subpart OOO) (Renewal).

Note that the total annual capital and O&M costs to the regulated entity
are $16,000.  These costs are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

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

The bottom line burden hours and cost tables for both the Agency and the
respondents are attached.  The annual public reporting and recordkeeping
burden for this collection of information are estimated to average 293
hours per response.

6(f)  Reasons for Change in Burden

There is no change in the respondent labor hours in this ICR compared to
the previous ICR.  This is due to two considerations: 1) the regulations
have not changed over the past three years and are not anticipated to
change over the next three years; and 2) the growth rate for the
respondents is very low, negative or non-existent.  Therefore, the labor
hours in the previous ICR reflect the current burden to the respondents
and are reiterated in this ICR.

The increase in cost to Respondents and the Agency is due to labor rate
adjustments to reflect the most recent available estimates.  

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 293 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-2009-0397, which is available for on line viewing at
www.regulations.gov, or in person viewing at the Enforcement and
Compliance Docket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W.,
Washington, D.C.  The EPA Docket Center Public Reading Room is open from
8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.
 The telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Enforcement and Compliance Docket and
Information Center is (202) 566-1752.  An electronic version of the
public docket is available online at www.regulations.gov.  This site can
be used 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, N.W.,
Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OECA-2009-0397 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.

Table 1:  Annual Respondent Burden and Cost – NESHAP for the
Manufacture of Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO) 
(Renewal)













Burden item	(A)	(B)	(C)	(D)	(E)	(F)	(G)	(H)	(I)

	Respondent Hours Per Occurrence	Number of Occurrences per Respondent
per year	Hours per Respondent Per Year (C=AxB)	Number of Respondents per
Yearc	Technical Hours Per Year @$98.20	Managerial Hours Per Year
@$114.49 (E x 0.05)	Clerical Hours per Year @ $48.53 (E x 0.1)	Total
Hours per Year	Total Cost Per Year a

	 	 	 	 	 	 	 	 	 

1.  Applications	N/A	 	 	 	 	 	 	 	 

2.  Survey and Studies	N/A	 	 	 	 	 	 	 	 

3.  Reporting Requirements	 	 	 	 	 	 	 	 	 

Read instructions d	16	1	16	40	640	32	64	736	$69,617.60 

Plan activities	8	1	8	40	320	16	32	368	$34,808.80 

Training 	16	1	16	40	640	32	64	736	$69,617.60 

Create, test and research development e, f	320	1	320	2	640	32	64	736
$69,617.60 

Gather, monitor and inspect information	208	1	208	40	8,320	416	832	9568
$905,028.80 

Process, compile and review	48	2	96	40	3,840	192	384	4416	$417,705.60 

Complete reports g	40	2	80	40	3,200	160	320	3680	$348,088.00 

Record/disclose information	16	2	32	40	1,280	64	128	1472	$139,235.20 

Store, file, maintain information h	4	2	8	40	320	16	32	368	$34,808.80 

Leak detection and repair (LDAR) reportingi	60	1	60	25	1,500	75	150	1725
$163,166.25 

Subtotal Reporting	 	 	 	 	 	 	 	23,805	$2,251,694 

4. Recordkeeping Requirements	 	 	 	 	 	 	 	 	 

Leak detection and repair (LDAR) recordkeeping j	104	1	104	2	208	10.4
20.8	239	$22,625.72 

Subtotal Recordkeeping	 	 	 	 	 	 	 	239	$22,626

TOTAL LABOR BURDEN AND COST (rounded)	 	 	 	 	 	 	 	24,044
$2,274,320 











	Assumptions:









	a.  We assume a technical labor rate of $98.20, managerial rate
$114.49, and clerical rate of $48.53 from the United States Department
of Labor, Bureau of Labor Statistics, March 2009, “Table 2. Civilian
Workers, by Occupational and Industry group.”  The rates are from
column 1: Total compensation.  The wage rate obtained from the table has
been increased by 110 percent.

b.  This ICR assumes that Managerial hours are 5 percent of Technical
hours, and Clerical hours are 10 percent of Technical hours.

c.  We have assume that there are 40 affected sources with no new,
modified or reconstructed facility expected to be constructed over the
next three years.

d.  We assume that it will take 16 hours for each respondent to read
instructions.

e.  Initial performance testing was assumed to take 280 technical hours
(1 test leader for two weeks and 5 feet crew for one week), with an
additional 40 hours for the establishment of parameter monitoring levels
for a total of 320 respondent hours per occurrence.

f.  We assume that 5 percent of the initial tests will be repeated
during each successive year. 

g.  We assume that it will take each respondent 40 hours two times per
year to complete reports (semiannual reporting).

h.  We assume that it will take 4 hours two times per year to gather
monitoring information and maintain monitoring equipment. 

i.  We assume that there are 27 affected sources that will be required
to comply with the equipment leaks LDAR program; 25 have less than 500
components and two 

have more than 500 components.  The typical affected source has four
reactor batch process vents, three non-reactor batch process vents, and
no affected storage vessels or heat exchange systems.





Table 2:  Average Annual EPA Burden - NESHAP for the Manufacture of
Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO) (Renewal)









Activity	(A)	(B)	(C)	(D)	(E)	(F) a

	Person-hours per Activity	Number of activities per Year	Technical
person-hours per Year

$46.21/hr

 (C=AxB) c	Managerial person-hours per Year

$62.27/hr

 (D=Cx0.05)b	Clerical person-hours per Year

$25.01/hr

 (E=Cx0.1)b	EPA Cost  Per Year

	 	 	 	 	 	 

Initial performance test	N/A	 	 	 	 	 

Repeat performance test d	20	2	40	2	4	$2,072.98 

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 e	4	2	8	0.4	0.8	$414.60 

    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	 	 	 	 	 

     j)  Pre-compliance report	N/A	 	 	 	 	 

    k)  Storage vessel initial compliance demonstration	N/A	 	 	 	 
 

     l)  Periodic reports of compliance status f	4	80	320	16	32
$16,583.84 

Subtotals Labor Burden and cost	 	 	368	18.4	36.8	$19,071.42 

TOTAL ANNUAL BURDEN AND COST (rounded)	 	 	423	$19,071 









Assumptions:







a.  We assume a technical labor rate of $46.21, managerial rate $62.27,
and clerical rate of $25.01 from the United States Department of Labor. 
These rates are from the Office of Personnel Management (OPM), 2010
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  These rates can be obtained from the
OPM web site, http//www.opm.gov/oca/payrates/index/htm.

b.  This ICR assumes that Managerial hours are 5 percent of Technical
hours, and Clerical hours are 10 percent of Technical hours.

c.  We assume that there are 40 affected sources with no new, modified
or reconstructed facility expected to be constructed over the next three
years.

d.  We assume that it would take 20 hours two times per year for
respondents to complete repeat performance test.

e.  We assume that it will take four hours two times per year to review
the notification of performance test report.

f.  We assume that it will take 4 hours 80 times per year to review the
periodic reports of compliance status.



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