### 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

Manufac ture 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 commenc ed 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 r eports. 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 not ifications, 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 U nited 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.

T he 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 t he 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

### 2

Statistics. Agency assumptions were updated using the Offic e 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 Cos t

– 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) insta ll, 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

Admin istrator 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 publ ic 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 req uires 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 th e affected facilities. The subject standards are achieved by the capture of formaldehyde, methanol, and phenol using

### 3

scrubbers or other compliance options and/or leak detection and repair procedures.

The notifications required in the applicable regulatio ns 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, re cordkeeping, 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 suff icient 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 h ave 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 imp lement 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 IC R 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 Agenc y’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.

### 4

During a previous renewal of this ICR, industry trade associations and other interested parties were provided an opportunity to comment on the b urden 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 recordke eping 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 P art 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 v iolators 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, s ubpart 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 report ing or recordkeeping requirements contain sensitive questions.

### 5

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 resi ns 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

des cription.

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)

Notif ication 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)

### 6

Reports for 40 CFR Part 63, Subpart OOO

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 deter mining 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 se tting 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 perc ent of the respondents use electronic reporting.

### 7

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate compliance monitoring system (CMS) for pH, flow, temperature, or specific gravity, or or ganic 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 repo rts 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 Methodo logy, 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 facil ity 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

### 8

compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance

determination s.

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

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 b urdens are expressed under standardized headings believed to be consistent with the 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

en tities, 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 t o 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 contro l 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 entitie s.

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 O OO) (Renewal)

.

6. Estimating the Burden and Cost of the Collection

### 9

concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collec tion 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 i ndustry 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, Agen cy 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 c olumn 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 th e 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 st andards

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 maintenanc e costs are the ongoing costs to maintain the monitors 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)

### 10

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

Li quid 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 w ith 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 accou nt 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

- N ESHAP 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.

### 11

Number of respondents is calculated using the following table which addresses the three years covered by this IC R.

Number of Respondents

Year (A)

Number of New

Respondents (B)

Number of

Existing Respondent

s (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

R espondents (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 t otal 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 Res ponses 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.

### 12

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 burde n 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 t he 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 co llection 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

Numb ers 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

### 13

system , select “search,” then k ey 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: Ann ual 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 Responden t

per year Hours per Respondent

Per Year (C=AxB) Number of Respondents

per Year c 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

Trainin g 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 19 2 384 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) reporting i 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:

### 15

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 increase d by 110 percent.
b. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical h ours. c. We have assume that there are 40 affected sources with no new, modified or reconstructed facility exp ected 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 assum e 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 co mponents and two have more than 500 components. The typical affected source has four reactor batch process vents, three non

- reac tor batch process vents, and no affected storage vessels or heat exchange systems.

### 16

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) No tification 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 chan ge 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 t echnical 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/h tm.

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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 o ver 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 t imes per year to review the periodic reports of compliance status.