SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY

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

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 2027.05, 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 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.  

	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 U. S. 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).

	Over the next three years, an average of 14 respondents per year will be subject to the standard, and one additional respondent per year will become subject to the standard.  All of    the existing 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.  

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

	The respondents to this ICR (the "Affected Public) are publicly owned and operated flexible polyurethane foam fabrication facilities.  None of the facilities are owned by either state, local and tribal agencies or the Federal government.  The burden to the "Affected Public" may be found below in Table 1: Annual Respondent Burden and Cost  -  NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal). The burden to the "Federal Government" is attributed entirely to work performed by Federal employees and/or government contractors. This burden is calculated below in Table 2: Average Annual EPA Burden and Cost  -  NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (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.  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: 

            (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, 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 (76 FR 26900) on May 9, 2011.  No comments were received on the burden published in the Federal Register.

	3(c) Consultations

      The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years.  The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard is the Online Tracking Information System (OTIS), which is operated and maintained by EPA's Office of Compliance.  OTIS is EPA's database for the collection, maintenance, and retrieval of all compliance data.  
      
      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.  In developing this ICR, we contacted: 1) the Polyurethane Foam Association, at (865) 657-9840; and 2) Flexible Foam Products, Inc. at (423) 689-6911.  EPA did not receive any comments from       the consultations. 
      	
      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.  

      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 proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

	3(e) General Guidelines

	These reporting or recordkeeping requirements do not violate any of the regulations promulgated 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 allows EPA to establish the compliance history of a source, any pattern of non-compliance, and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond the five years.  In addition, EPA would be prevented from pursuing the violators due to either the destruction or nonexistence of essential records.

	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 (CBI) (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

	The reporting or recordkeeping requirements in the standard do not include sensitive questions.
4.  The Respondents and the Information Requested

	4(a) Respondents/SIC Codes

	The respondents to the recordkeeping and reporting requirements are flexible polyurethane foam fabrication facilities. The U. S. Standard Industrial Classification (SIC) code 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

		(i)  Data Items

      In this ICR, all the data that is recorded or reported is required by NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM).

	A source must make the following reports:

                                 Notifications
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)
	
                                    Reports
First compliance report
63.8818(b)(1)
Semiannual compliance report
63.8818(b)(3)
Annual compliance report
63.8818(c)
Startup/Shutdown/Malfunction (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 in an automated way (e.g. continuous parameter monitoring system).  Although personnel at the sources still 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 Online Tracking Information System (OTIS).


5(b) Collection Methodology and Management

	Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated.  Performance test reports are used by the Agency to discern a source's initial capability to comply with the emission standard.  Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

	Information contained in the reports is entered into OTIS which is operated and maintained by EPA's Office of Compliance.  OTIS 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 OTIS 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

	The 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.  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 below in Table 1: Annual Respondent Burden and Cost − 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.  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 15,601 (Total Labor Hours from Table 1 below).  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 	$121.42   ($57.82 + 110%)
      Technical	$99.14   ($47.21 + 110%)
      Clerical	$49.81   ($23.27 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, "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 both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring.  The capital/startup costs are one-time costs when a facility becomes subject to the regulation.  The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

            (iii) 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. These are recordkeeping costs. 
--------------------------------------------------------------------------------

	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 $82,501.  

      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), 2011 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. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost − 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 13 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 14 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
                                      12
                                       0
                                       0
                                      13
                                       2
                                       1
                                      13
                                       0
                                       0
                                      14
                                       3
                                       1
                                      14
                                       0
                                       0
                                      15
Average
                                       1
                                      13
                                       0
                                       0
                                      14

	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 14.
 
      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
                                      14
                                       2
                                       0
                                      28
SSM report
                                      14
                                      10
                                       0
                                      140

                                       
                                       
                                     Total
                                      173

	The number of Total Annual Responses is 173.

	The total annual labor costs are $1,494,882. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost − NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal).

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 hours are 15,601 at a cost of $1,494,882.  Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost − NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal).

      Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 90 hours per response.

	The total annual capital/startup and O&M costs to the regulated entity are $2,671.  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 1,831 labor hours at a cost of $82,501.  See below Table 2: Average Annual EPA Burden and Cost − NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal).
	
	6(f) Reasons for Change in Burden

      There is an increase in burden hours for both the respondents and the Agency in this   ICR compared to the previous ICR.  This is because there are, on average, 3 more existing units subject to this standard due to a growth in the respondent universe during the past three years. 
      
      There is also an increase in the total labor and Agency costs as currently identified in the OMB Inventory of Approved Burdens.  The change in cost estimates reflects an increase in respondent numbers (described above) and updated labors rates available from the Bureau of Labor Statistics. 

	6(g) Burden Statement

      The annual public reporting and recordkeeping burden for this collection of information is estimated to average 90 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-2011-0255.  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) 566-1752.  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-2011-0255 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.   Read instructions [c]
                                       4
                                       1
                                       4
                                       1
                                       4
                                      0.2
                                      0.4
                                                                        $440.77
2.   Gather information [c]
                                       4
                                       1
                                       4
                                      14
                                      56
                                      2.8
                                      5.6
                                                                      $6,170.82
3.   Reports
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
      i.  Initial notification  [c]
                                       2
                                       1
                                       2
                                       1
                                       2
                                      0.1
                                      0.2
                                                                        $220.39
     ii.  Application for construction 
          for new sources [c]
                                       2
                                       1
                                       2
                                       1
                                       2
                                      0.1
                                      0.2
                                                                        $220.39
    iii. Notification of performance
          test [c, d]
                                       2
                                       1
                                       2
                                       1
                                       2
                                      0.1
                                      0.2
                                                                        $220.39
    iv.  Notification of compliance
          status [c]
                                      20
                                       1
                                      20
                                       1
                                      20
                                       1
                                       2
                                                                      $2,203.87
     v.  First compliance report [c]
                                       8
                                       1
                                       8
                                       1
                                       8
                                      0.4
                                      0.8
                                                                        $881.55
    vi.  Semiannual compliance report [d]
                                       4
                                       2
                                       8
                                      14
                                      112
                                      5.6
                                     11.2
                                                                     $12,341.65
   vii.  Annual compliance report [e]
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                                                             $0
  viii.  SSM report [f]  
                                       2
                                      10
                                      20
                                      14
                                      280
                                      14
                                      28
                                                                     $30,854.12
Subtotal for Reporting Requirements
                                       
                                       
                                       
                                       
                                     558.9
                                                                               
4.  Recordkeeping requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
    a.  Plan activities [c]
                                      10
                                       1
                                      10
                                       1
                                      10
                                      0.5
                                       1
                                                                      $1,101.93
    b.  Implement activities for flame
         lamination
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
     i.  Record SSM
                                       1
                                      100
                                      100
                                      14
                                     1,400
                                      70
                                      140
                                                                    $154,270.62
    ii.  Conduct performance test [c], [g]
                                      50
                                       1
                                      50
                                       1
                                      50
                                      2.5
                                       5
                                                                      $5,509.67
   iii.  Record CPMS measurements
                                       2
                                      300
                                      600
                                      14
                                     8,400
                                      420
                                      840
                                                                    $925,623.72
   iv.  CPMS calibration and
         maintenance [h]
                                       4
                                      50
                                      200
                                      14
                                     2,800
                                      140
                                      280
                                                                    $308,541.24
    c.  Implement activities for loop sitters                                   
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
       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
                                                                      $4,407.73
      ii.  Continuous parameter 
           monitoring system (CPMS)
           maintenance plan [c, d]
                                      20
                                       1
                                      20
                                       1
                                      20
                                       1
                                       2
                                                                      $2,203.87
    e.  Time to train personnel

                                       
                                       
                                       
                                       
                                       
                                       
                                                                               
       i.  CPMS acquisition and 
            installation [c][, d]
                                      20
                                       1
                                      20
                                       1
                                      20
                                       1
                                       2
                                                                      $2,203.87
      ii.  CPMS inspection and
           monitoring [c][, d]
                                       4
                                       1
                                       4
                                       1
                                       4
                                      0.2
                                      0.4
                                                                        $440.77
    f.  Store, file, and maintain all 
         records [i]
                                       1
                                       
                                      12
                                      12
                                      14
                                      168
                                      8.4
                                     16.8
                                                                     $18,512.47
    g.  Retrieve records/reports [j]
                                       1
                                      12
                                      12
                                      14
                                      168
                                      8.4
                                     16.0
                                                                     $18,512.47
Subtotal for Recordkeeping Requirements
                                       
                                       
                                       
                                       
                                                                               
                                    15,042
                                                                               
                                                                               

                                       
                                       
                                       
                                       
                                    13,566
                                     678.3
                                                                        1,356.6
                                                                               
TOTAL LABOR BURDEN AND COST (rounded)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                    15,601
                                                                     $1,494,882

Assumptions:
[a]  We have assumed that the average number of respondents that will be subject to the rule will be 14. 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: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 per hour for Clerical labor.  These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, "Table 2. Civilian Workers, by occupational and industry 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 new facility.
[d]  We have assumed that this applies only to flame lamination facilities.
[e]  We have assumed that this applies to facilities that use loop slitter adhesive.
[f]  We have assumed that it will take each respondent two hours ten time per year to complete SSM reports.
[g]  We have assumed that this will also include writing site-specific test plan.
[h]  We have assumed that it will take each respondent four hours 50 times per year to implement the CPMS calibration and maintenance activity.
i  We have assumed that it will take each respondent 1 hour twelve times per year to store, file and maintain records.
[j]  We have assumed that it will take each respondent 1 hour twelve times per year to retrieve records/reports.

Table 2:  Average Annual EPA Burden and Cost −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
                                                                        $207.29
2.   Review application for                   construction [c]
                                       4
                                       
                                       1
                                       
                                       4
                                       
                                       1
                                       
                                       4
                                       
                                      0.2
                                       
                                      0.4
                                       
                                                                        $207.29
                                                                               
3.   Review notification of                    compliance status [c]
                                      20
                                       1
                                      20
                                       1
                                      20
                                       1
                                       2
                                                                      $1,036.45
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
                                                                      $1,036.45
6.   Review notification of                    performance test [c][, d]
                                       4
                                       1
                                       4
                                       1
                                       4
                                      0.2
                                      0.4
                                                                        $207.29
7.   Review annual compliance             report [d]
                                       1
                                       
                                       1
                                       
                                       1
                                       
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                       0
                                       
                                                                             $0
                                                                               
8.   Review semiannual                         compliance report [e]
                                      15
                                       
                                       2
                                       
                                      30
                                       
                                      14
                                       
                                      420
                                       
                                      21
                                      42
                                       
                                                                     $21,765.41
                                                                               
9.  Review startup, shutdown,             malfunction report [e]
                                       8
                                       
                                      10
                                       
                                      80
                                       
                                      14
                                       
                                     1,120
                                       
                                      56
                                       
                                      112
                                       
                                                                     $58,041.09
                                                                               

TOTAL ANNUAL BURDEN AND COST (rounded)
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                     1,831
                                                                               
                                                                        $82,501

Assumptions:
a  We have assumed that the average number of respondents subject to the rule will be 14. 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 $62.27 (GS-13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS-6, Step3, $15.63 x 1.6).  These rates are from the Office of Personnel Management (OPM) "2011 General Schedule" which excludes locality rates of pay.
[c]  This is a one-time activity performed once per facility.
    [d]  We have assumed that this applies to facilities that use loop slitter adhesive.
    [e]  We have assumed that this applies only to flame lamination facilities.  
 
