SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Flexible Polyurethane Foam Product (40 CFR Part 63, Subpart III) 

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Flexible Polyurethane Foam Production (40 CFR Part 63, Subpart III) 

EPA ICR Number 1783.08; OMB Control Number 2060-0357

1(b) Short Characterization/Abstract

This ICR covers information collection requirements in the proposed rulemaking that 

amends title 40, Chapter I, part 63 of the Code of Federal Regulations (CFR) Subpart III, 

National Emissions Standards for Hazardous Air Pollutants: Flexible Polyurethane Foam 

Production. These standards apply to owners or operators of new and existing facilities that 

engage in the manufacture of flexible polyurethane foam products which emit hazardous air 

pollutants (HAPs). This includes facilities making slabstock flexible polyurethane foam 

(slabstock foam), rebond flexible polyurethane foam (rebond foam), and/or molded flexible 

polyurethane foam (molded foam).

In general, all MACT standards require initial notifications, performance tests, and 

periodic reports. Owners or operators of flexible polyurethane foam production facilities to 

which this rule is applicable must choose one of the compliance options described in the standard 

or reduce HAP emissions to below the compliance level. Specifically, the rule requirements for 

slabstock foam producers include an initial notification, notification of compliance status, 

semiannual reports and annual compliance certifications. The rule requirements for molded and 

rebond foam producers include a notification of compliance status report and an annual 

compliance certification. These notifications, reports, and records are essential in determining 

compliance, and are required of all sources subject to MACT.

Any owner or operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

This ICR covers information collection requirements in the final rulemaking that amend

title 40, chapter I, part 63 of the Code of Federal Regulations (CFR) Subpart III National 

Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production, 

hereafter, this subpart is referred to as the "FPUF NESHAP." There are approximately 12 

respondents currently subject to the regulation, and it is estimated that no new respondents per 

year will become subject to the regulation in the next three years.
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The proposed amendments require that slabstock foam production facilities use no HAP 

or HAP-based material as an auxiliary blowing agent (ABA) or for equipment cleaning. To 

ensure compliance with this requirement, facility owners or operators are required to maintain a 

statement that the facility is in compliance, and records indicating HAP content of ABAs and 

equipment cleaners.

Existing major sources subject to these requirements will be required to comply with the 

new proposed requirements prohibiting the use of HAP ABAs in this action no later than 90 days 

after the effective date of the final rule, and the remainder of the requirements upon the effective 

date of the standards. All new or reconstructed affected sources must be in compliance with the 

existing and new requirements of the FPUF NESHAP on the date of startup or the effective date, 

whichever is later.

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent 

Burden and Cost: NESHAP for Flexible Polyurethane Foam Product (40 CFR part 63, subpart 

III). 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 Flexible Polyurethane Foam Product (40 CFR part 63, 

subpart III).

There are no capital/startup or Operation and Maintenance (O&M) costs associated with 

this regulation. The continuous parameter monitoring equipment used by facilities affected by 

this regulation are used to maintain a high level of operational efficiency and would have been 

installed and maintained with or without regulation. Details on this estimate can be found in 

Section 6(b)(iii) of this report.

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”

The cost of labor has been updated using the United States Department of Labor, Bureau 

of Labor Statistics, December 2009 - January 2011 (average reference date July 2010) Table 4

labor rates for the respondent labor costs, and the Office of Personnel Management (OPM) 2013 

General Schedule for the Agency labor costs.

Eleven of the 12 facilities in the United States, which are respondents to this ICR, are 

publicly owned and operated by flexible polyurethane foam production facilities. One of the 

facilities is owned by the Federal government. None of the facilities is owned by either state, 

local or tribal agencies.

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 
3

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner or operator subject to any 

requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may 

reasonably require.

In the Administrator's judgment, hazardous air pollutants (HAP) emissions from flexible 

polyurethane foam production facilities either cause or contribute to air pollution that may 

reasonably be anticipated to endanger public health or welfare. Therefore, the MACT standards 

were promulgated for this source category at 40 CFR part 63, subpart III.

2(b) Practical Utility/Users of the Data

The control of emissions from HAP emissions from flexible polyurethane foam 

production facilities requires not only the installation of properly designed equipment, but also 

the operation and maintenance of that equipment. Emissions of HAP from flexible polyurethane 

foam production facilities are the result of operation of each slabstock production line, each 

storage vessel, equipment cleaning, or from leaking equipment (e.g., transfer pumps, connectors, 

valves, etc.). The subject standards are achieved by the capture of HAP emissions using vapor 

recovery systems or carbon adsorption systems and leak detection and repair procedures.

The notifications required in the applicable regulations are used to inform the Agency or 

delegated authority when a source becomes subject to the requirements of the regulations. The 

reviewing authority may then inspect the source to check if the pollution control devices are 

properly installed and operated, leaks are being detected and repaired, and 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 requirements 

described in this ICR is used by the Agency to ensure that facilities affected by the MACT 

standards continue to operate the control equipment in compliance with the regulation. Adequate 

monitoring, recordkeeping, and reporting are necessary to ensure compliance with the applicable 

regulations, as required by the Clean Air Act. The information collected from recordkeeping and 

reporting requirements is also used for targeting inspections, and is of sufficient quality to be 

used as evidence in court.
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3. Non-duplication, Consultations, and Other Collection Criteria

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

III.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state 

or local agency. If a state or local agency has adopted their own similar standards to implement 

the Federal standards, a copy of the report submitted to the state or local agency can be sent to 

the Administrator in lieu of the report required by the Federal standards. Therefore, no 

duplication exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

This ICR is related to proposed amendments to the FPUF NESHAP. Comments will be 

solicited on the proposal package and the proposed ICR.

3(c) Consultations

Upon review of the standard, information available and the data, the Agency has

determined the recordkeeping and reporting requirements in the “Active” ICR is fully supported

and necessary to fulfill the requirements of the Clean Air Act (CAA). It has been determined that 

no further consultations with industry are necessary to calculate the burden associated with the 

amendments to the FPUF NESHAP.

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

None of these reporting or recordkeeping requirements violate any of the regulations 

established by OMB at 5 CFR part 1320, section 1320.5. These standards require the respondents 

to maintain all records, including reports and notifications for at least five years. This is 

consistent with the General Provisions as applied to the standards. The EPA believes that the 

five-year records retention requirement is consistent with the Part 70 permit program and the 

five-year statute of limitations on which the permit program is based. The retention of records for 

five years allows the EPA to establish the compliance history of a source, any pattern of noncompliance and to determine the appropriate level of enforcement action. The EPA has found 
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that the most flagrant violators have violations extending beyond the five years. In addition, the 

EPA would be prevented from pursuing the violators due to the destruction or nonexistence of 

essential records.

3(f) Confidentiality

All information submitted to the Agency for which a claim of confidentiality is made will 

be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart 

B--Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 

17674, March 23, 1979).

3(g) Sensitive Questions

This section is not applicable because this ICR does not involve matters of a sensitive 

nature.

4. The Respondents and the Information Requested

4(a) Respondents/SIC and NAICS Codes

Potential respondents under Subpart III are owners or operators of any existing or new 

Flexible Polyurethane Foam manufacturing facility that is a major source of HAP emissions. The 

source category and affected sources regulated by the FPUF NESHAP are classified under 

United States Standard Industrial Classification (SIC) code 3086 which corresponds to the North 

American Industry Classification System (NAICS) code 326150 for Urethane and Other Foam 

Product (except Polystyrene) Manufacturing.

The Flexible Polyurethane Foam Production source category is estimated to consist of 12

existing facilities nationwide. No new major sources are projected during the 3-year period of 

this ICR.

4(b) Information Requested

(i) Data Items

All data in this ICR that is recorded and/or reported is required by National Emissions 

Standards for Hazardous Air Pollutants (NESHAP) for Flexible Polyurethane Foam Production 

(40 CFR part 63, subpart III).

A source must make the following reports:

Notification Reports Citation

Initial notification 63.1306(a)

Application for approval of construction or reconstruction 63.1306(b)
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Notification Reports Citation

Notification of compliance status 63.1306(c)

Request for extension of compliance, adjustments to time periods, and 

changes in information

63.9(c), 63.9(i), 

63.9(j)

Malfunction reports 63.1306(f)

Reports Citation

Semiannual compliance reports 63.1306(d)

Annual compliance certification 63.1306(e)

A source must keep the following records:

Recordkeeping Citation

Startups, shutdowns, malfunctions 63.10(b)(2) 

All reports and notifications 63.10(b)

Record of applicability 63.10(a)

Slabstock sources shall maintain storage vessel records, equipment leak 

records, and product data sheets showing HAP content in ABA and

equipment cleaners, 

63.1307(a-e)

Molded/rebond foam sources shall maintain records of product data sheets for 

each compound other than diisocyanates used to flush the mixhead and 

associated piping during periods of startup or maintenance, and the product 

data sheets showing HAP content in mold release agents.

63.1307(f-g)

Records are required to be retained for five years; however, only the data of 

the most recent two years must be kept on-site

63.10(b)(1)

Electronic Reporting

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way, e.g., flow rate monitoring and pump revolution per minute monitoring. Although 

personnel at the source still need to evaluate the data, this type of monitoring equipment has 

significantly reduced the burden associated with monitoring and recordkeeping. In addition, 

some regulatory agencies are setting up electronic reporting systems to allow sources to report 

electronically which is reducing the reporting burden. However, electronic reporting systems are 

still not widely used by the regulatory agencies. It is estimated that approximately 10 percent of 

the respondents use electronic reporting.
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(ii) Respondent Activities

Respondent Activities

Read instructions.

Performance tests are not required by MACT, subpart III. However, sources are required to 

use Method 25A of part 60 for organic compounds measurements; 

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.

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.

Transmit, or otherwise disclose the information.

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

Management

5(a) Agency Activities

The EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

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

5(b) Collection Methodology and Management

Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs of the delegated permitting authority. The semiannual 

reports are used for problem identification, as a check on source operation and maintenance, and 

for compliance determinations.

The EPA is the permitting authority until the state agency is delegated authority to 

implement the rule. Therefore, information contained in the reports submitted to the Regional 

Administrator will be entered into the Air Facility System (AFS), which is operated and 

maintained by the EPA’s Office of Compliance. The AFS is the EPA’s database for the 

collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial 
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and government-owned facilities. The EPA uses the AFS for tracking air pollution compliance 

and enforcement by local and state regulatory agencies, the EPA regional offices and the EPA 

headquarters. The EPA and its delegated authorities can edit, store, retrieve and analyze the data.

5(c) Small Entity Flexibility

During the RTR process, the proposed rule was reviewed to estimate the number of small 

entities potentially affected. Based on this analysis, EPA assumes that approximately 25 percent 

of currently affected facilities, or 3 facilities, may be small entities.

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 Production (40 CFR part 63, subpart III).

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 under the NESHAP subpart III standards, 

included in this ICR. The individual burdens are expressed under standardized headings believed 

to be consistent with the concept of burden under the Paperwork Reduction Act. Where 

appropriate, specific tasks and major assumptions have been identified. Responses to this

information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB control number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 884 hours, which is shown below in Table 1. These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously 

approved ICR, and any comments received.
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6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: $104.92 per hour for Executive, Administrative, 

and Managerial labor; $51.62 per hour for Technical labor, and $41.66 per hour for Clerical 

labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

December 2009 - January 2011 (average reference date July 2010), “Table 4. Full-time private 

industry workers: Mean and median hourly, weekly, and annual earnings and mean weekly and 

annual hours.” The rates are from column 1, “Mean Earnings.” The rates have been increased by 

110 percent to account for the benefit packages available to those employed by private industry.

Managerial $104.92 ($49.96 + 110%)

Technical $51.62 ($24.58 + 110%)

Clerical $41.66 ($19.84 + 110%)

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

The only costs to the regulated industry resulting from information collection activities 

required by the subject standards are labor costs. 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 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)

n/a $0 0 $0 $0 0 $0

There are no total capital/startup costs for this ICR since we have assumed that no new 

sources will become subject to these standards and that the existing sources conducting 

modifications will not be purchasing new monitoring equipment. This is the total of column D in 

the table above.

There are no operation and maintenance costs for this ICR since any parameter monitors 

were already being used in their operations prior to promulgation of this rule. This is the total of 

column G in the table above.

The total respondent costs have been calculated as the addition of the capital/startup 

costs, and the annual operation and maintenance costs. Therefore, there is no average annual cost 

for capital/startup and operation and maintenance costs to industry over the next three years of 

the ICR.
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6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. The EPA compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information.

The average annual cost to the Federal government during the three years of the ICR is 

estimated to be $3,234. This cost is based on the average hourly labor rates below:

Managerial $74.73 (GS-13, Step 5, $38.92 + 20% + 60%)

Technical $55.45 (GS-12, Step 1, $28.88 + 20% + 60%)

Clerical $30.01 (GS-6, Step 3, $15.63 +20% + 60%)

These rates are from the Office of Personnel Management (OPM) 2013 General Schedule, which 

excludes locality rates of pay. Labor rates are inflated 20% to reflect average locality pay 

increase from base rates and a further 60% to account for the benefit packages available to 

government employees. Details upon which this estimate is based appear below in Table 1: 

Average Annual Burden: NESHAP for Flexible Polyurethane Foam Product (40 CFR part 63, 

subpart III).

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

Based on our research for this ICR, approximately 12 existing respondents (i.e., 6 

slabstock foam producers and 6 molded/rebond foam producers) are currently subject to the 

standard. It is estimated that no respondents per year will become subject to the regulation in the 

next three years. However, it is estimated that one existing source will be 

modifying/reconstructing its operations and will have new affected facilities.

The number of respondents is calculated using the following table which addresses the 

three years covered by this ICR.

Number of Respondents*

Year (A)

Number of New 

Respondents 

That Submit 

Reports

(B)

Number of 

Existing 

Respondents 

That Submit 

Reports

(C)

Number of 

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 1 12

2 1 12 0 1 12

3 1 12 0 1 12

Average 1 12 0 1 12

* New respondents are defined for this calculation as sources that recently became subject to the rule and existing 

sources that have modified/reconstructed their facilities.
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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 12.

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

Total Annual Responses

(A)

Number of 

New 

Respondentsa

(B)

Number of 

Reports for 

New 

Sources

(C)

Number of 

Existing 

Respondentsb

(D)

Number of 

Reports for 

Existing 

Sources

(F)

Number of 

Respondents That 

Keep Records but 

Do Not Submit 

Reports

(E)

Total Annual 

Responses 

E=(AxB)+(CxD)+F

1 3

6 3

0 27

6 1

a New respondents are defined for this calculation as sources that recently became subject to the rule and existing 

sources that have modified/reconstructed their facilities.

b There are 6 existing slabstock foam producers and 6 existing molded/rebond foam producers which total 12 

respondents.

The number of Total Annual Responses is 27. The total annual labor costs are $77,312.

Details regarding these estimates may be found below in Table 1. Annual Respondent Burden 

and Cost: NESHAP for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III).

Note that there are no total annual capital/start up and operation and maintenance (O&M) 

costs to the regulated entity that can be attributed to this rule. These costs are detailed in Section 

6(b)(iii), Capital/Startup vs. Operation and Maintenance Costs.

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

The bottom line burden hours and cost tables for both the Agency and the respondents 

appear below or are attached. The annual public reporting and recordkeeping burden for this 

collection of information is estimated to average 33 hours per response.

6(f) Reasons for Change in Burden

The decrease in burden from the most recently approved ICR is due to adjustment in both 

the types of information which must be collected and the number of sources submitting the 

required information. Specifically, existing burden items related to HAP ABA are eliminated

under the proposed amendments and replaced with a recordkeeping requirement. The previous 

(active) ICR calculated burden based on 132 existing sources, no new sources, and six existing 

source that will be reconstructed; whereas this ICR calculates burden based on 12 existing 

sources and one existing source that will be reconstructed. The overall change in burden from the 

previous ICR is a decrease; primarily due to the large decrease in the number of affected sources 

since the last ICR calculated burden was estimated.
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6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 33 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 currently valid OMB control number. The OMB 

control numbers for the EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9.

To comment on the Agency’s need for this information the accuracy of the provided 

burden estimates, and any suggestions for minimizing respondent burden, including through the 

use of automated collection techniques, the EPA has established a public docket for this ICR 

under Docket ID No. EPA-HQ-OAR-2012-0510, which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation 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 Air Docket 

is (202) 566-1742. An electronic version of the public docket is available at 

http://www.regulations.gov. This site can be used to submit or view public comments, access the 

index listing of the contents of the public docket, and to access those documents in the public 

docket that are available electronically. When in the system, select “search,” then key in one of 

the Docket ID Numbers identified above. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID 

Number (EPA-HQ-OAR-2012-0510) in any correspondence.

Part B of the Supporting Statement

This section is not applicable because statistical methods are not used in data collection 

associated with the rule.
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TABLE 1. ANNUAL RESPONDENT BURDEN AND COST: NESHAP FOR FLEXIBLE POLYURETHANE FOAM PRODUCTION (40 CFR part 63, subpart III)

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

Technical Hours/ 

Occurrence

Occurrences/ 

Year

Hours/ Year 

(C=A*B)

Respondents/

Yeara

Technical 

Hours/Year 

(E=C*D)

Management 

Hours/Year 

(F=E*0.05)

Clerical 

Hours/Year 

(G=E*0.10)

Total 

Hours/Year 

(H=E+F+G)

Total Costs/ 

Yearb

1. Applications N/A N/A N/A N/A N/A N/A N/A N/A N/A

2. Survey and Studies N/A N/A N/A N/A N/A N/A N/A N/A N/A

3. Acquisition, Installation, & Utilization of Tech. & Systems N/A N/A N/A N/A N/A N/A N/A N/A N/A

4. Reporting Requirements

A. Read instructions 1.00 1.0 1.0 1.0 1.0 0.1 0.1 1.2 $ 61

B. Required activities

 Monitoring of Emissions Operations, Slabstock Facilities - 

Storage Tank Measurementsc 1.00 12.0 12.0 6.0 72.0 3.6 7.2 82.8 $ 4,394

C. Create information

D. Gather existing information

E. Write report

 Initial Notificationd 2.00 1.0 2.0 0.0 0.0 0.0 0.0 0.0 $ -

 Notification of Modification/Reconstructiona 2.00 1.0 2.0 1.0 6.0 0.3 0.6 6.9 $ 366

 Precompliance Report 4.00 1.0 4.0 1.0 2.0 0.1 0.2 2.3 $ 122

 Notification of Compliance Statusa 16.00 1.0 16.0 1.0 16.0 0.8 1.6 18.4 $ 976

 Semiannual Reportse 4.00 2.0 8.0 6.0 48.0 2.4 4.8 55.2 $ 2,929

 Annual Compliance Certifications 2.00 1.0 2.0 12.0 24.0 1.2 2.4 27.6 $ 1,465

Reporting Subtotal 32.00 20.00 47.00 28.00 169.00 8.45 16.90 194.35 $ 10,314

5. Recordkeeping Requirements

A. Read instructions

B. Plan activities

C. Implement activities

D. Develop record system 40.00 1.0 40.0 0.0 0.0 0.0 0.0 0.0 $ -

E. Time to enter information: Records of Monitoring and Operations

 Slabstock Facilities 8.00 12.0 96.0 6.0 576.0 28.8 57.6 662.4 $ 64,318

 Molded/Rebond Facilities 4.00 1.0 4.0 6.0 24.0 1.2 2.4 27.6 $ 2,680

F. Train personnel 40.00 1.0 40.0 0.0 0.0 0.0 0.0 0.0 $ -

I. Audits N/A N/A N/A N/A N/A N/A N/A N/A N/A

Recordkeeping Subtotal 92.00 15.00 180.00 12.00 600.00 30.00 60.00 690.0 $ 66,998

TOTAL ANNUAL NUMBER OF RESPONSESf 27.0

TOTAL ANNUAL BURDEN HOURS 769.0 38.5 76.9 884.4 884.4

TOTAL ANNUAL COST (SALARY) $ 77,312

INITIAL CAPITAL COSTS: $ -

ANNUALIZED CAPITAL COSTS: $ -

N/A = Not Applicable.

(c) Molded/rebond foam producers only have recordkeeping and reporting requirements.

(d) We have assumed that all existing sources are in compliance with the initial rule requirements.

(e) Only slabstock foam producers (i.e.,6 respondents) are required to submit semiannual reports.

(f) Total responses calculated by adding semiannual reports (6 sources * 2 responses), notification of modification/reconstruction (1 source * 1 response), precompliance report (1 source * 1 response), notification of 

compliance status (1 source * 1 response), and annual compliance certifications (12 sources * 1 response)

(a) We have assumed there are 6 existing slabstock foam producers and 6 existing molded/rebond foam producers for a total of 12 existing foam producers (i.e., respondents) that are major sources and subject ot 

the NESHAP subpart III. We have further assumed there will be no new foam producers commencing operations over the period of this ICR. However, we have assumed that 1 existing respondent a year will be 

conducting some type of modification but they will continue to meet compliance requirements while the reconstruction/modification application is under review. Therefore the average number of respondents per year 

for this ICR is estimated to be 12.

(b) This ICR uses the following labor rates: Managerial $104.92 ($49.96 + 110%); Technical $51.62 ($24.58 + 110%); and Clerical $41.66 ($19.84 + 110%). These rates are from the U.S.Department of Labor, 

Bureau of Labor Statistics, Occupational earnings tables: United States, December 2009 - January 2011 (average reference date July 2010) Table 4. Full-time private industry workers: Mean and median hourly, 

weekly, and annual earnings and mean weekly and annual hours. The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. This ICR assumes 

managerial hours are 5% of the technical hours and clerical hours are 10% of technical hours.

Included in 4A

Included in 4B

Included in 4B

Included in 4B and 5E

Included in 4B and 5E
14

TABLE 2. ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT OF THE FINAL STANDARDS

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

Activity

EPA Hours/ 

Occurrence

Occurrences/ 

Plant/Year

EPA Hours/ 

Year 

(C=AxB)

Plants/ 

Yeara

Technical 

Hours/Year 

(E=C*D)

Managerial 

Hours/Year 

(E*0.05)

Clerical 

Hours/Year 

(E*0.10)

Total 

Hours/Year 

(H=E+F+G)

Total Costs/ 

Yearb

Initial Notificationc 2 0 0 0 0.0 0.0 0.0 0.0 $0

Notification of Recontruction/Modifcation 2 1 2 1 2.0 0.1 0.2 2.3 $124

Notification of Special Compliance Requirementsd 2 1 2 0 0.0 0.0 0.0 0.0 $0

Notification of Compliance Statusd 2 1 2 1 2.0 0.1 0.2 2.3 $124

Semiannual Reportse 2 2 4 6 24.0 1.2 2.4 27.6 $1,492

Annual Compliance Certificationsf 2 1 2 12 24.0 1.2 2.4 27.6 $1,492

TOTAL ANNUAL BURDEN 52.0 2.6 5.2 59.8 $3,234

(a) We have assumed there are 6 existing slabstock foam producers and 6 existing molded/rebond foam producers for a total of 12 respondents. We have further assumed that one existing 

respondent a year will be conducting some type of modification at its facility and that there will be no new sources over the period of this ICR. Therefore, the average number of respondents per year 

is estimated to be 12. 

(b) This ICR uses the following labor rates: Managerial $74.73 (GS-13, Step 5, $38.92 +20% + 60%); Technical $55.45 (GS-12, Step 1, $28.88 + 20% + 60%); and Clerical $30.01 (GS-6, Step 3, 

$15.63 + 20% + 60%). These rates are from the Office of Personnel Management (OPM) 2013 General Schedule which excludes locality rates of pay. Salary Table 2013-GS. The rates have been 

increased by 20% to reflect average locality pay increase from base rates and a further 60% increase to account for the benefit packages available to government employees. This ICR assumes that 

Clerical hours are 10 percent of Technical hours and Managerial hours are 5 percent of Technical hours.

(c) We have assumed that all existing sources are in compliance with the initial rule requirements. In addition, we have assumed that facilities seeking to reconstruct will continue to meet 

compliance requirements while application is under review.

(d) We have determined there will be no sources submitting a special compliance report for this ICR since the compliance date for this rule has passed.

(e) Slabstock foam producers (i.e., 6 facilities) are required to submit semiannual reports.

(f) All respondents (i.e., 12 foam producers) are required to submit annual compliance certifications. However, we have assumed that slabstock facilities will be complying with this requirement 

concurrently when submitting semiannual reports. Molded/rebond foam producers would still need to meet this requirements separately.