SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

(Revised)

1. Identification of the Information Collection

1(a) Title of the Information Collection

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Manufacture of 

Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO) (Revised), EPA ICR Number 1869.09, 

OMB Control Number 2060-0434. 

1(b) Short Characterization/Abstract

The amendments to this ICR are a result of the review of the existing NESHAP for the 

Manufacture of Amino/Phenolic Resins (40 CFR part 63, Subpart OOO) as required by the 

Clean Air Act. The NESHAP published at 40 CFR part 63, subpart OOO were proposed on 

December 14, 1998, and promulgated on January 20, 2000. The current rulemaking applies to 

hazardous air pollutant (HAP) emissions from facilities involved in the manufacture of 

amino/phenolic resins (APR). This information is being collected to assure compliance with 40 

CFR part 63, subpart OOO. Organic HAP emissions are the pollutants regulated under this 

subpart.

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

periodic reports by the owners/operators of the affected facilities. These notifications, reports, 

and records are essential in determining compliance, and are required of all affected facilities 

subject to NESHAP. Semiannual summary reports are also required.

The rulemaking amends title 40, chapter I, part 63 subpart OOO to include emission 

sources for which standards were not previously developed. The amendments also add 

requirements to monitor each pressure relief device (PRD) that releases to the atmosphere using 

a device or system that is capable of identifying and recording the time and duration of each 
2

pressure release and of notifying operators that a pressure release has occurred. Information 

related to these new provisions is required to be submitted in the semi-annual reports required by 

the existing NESHAP. We believe that the number of affected facilities under this subpart will 

remain constant for this source category. The overall change in burden found in this ICR reflect 

the provision changes, an update in the cost of labor, and corrections to the number of affected 

facilities found in EPA ICR number 1869.09.

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

without any “Terms of Clearance.” The overall change in burden found in this ICR reflect the 

provision changes, an update in the cost of labor, and corrections to the number of affected 

facilities found in EPA ICR number 1869.09.

The period considered in this ICR and throughout this supporting statement is the first 

three years following the promulgation of the amended Manufacture of Amino/Phenolic Resins 

NESHAP. The estimates of the size of the regulated universe are based on data from the National 

Emissions Inventory (NEI) database. There is an annual average of 19 respondents that will be 

subject to the regulations, except only three facilities have continuous process vents that will 

require emission controls. Due to the nature of the industry, it is estimated that no additional 

sources will become subject to the standard over the next three years. 

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 (HAP). These standards are applicable to new or existing sources of 

HAP 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 
3

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

In the Administrator's judgment, HAP emissions from the manufacture of amino/phenolic 

resins cause or contribute to air pollution that may reasonably be anticipated to endanger public 

health or welfare. Therefore, the NESHAP standards were promulgated for this source category 

at 40 CFR part 63, subpart OOO.

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. In 

addition, the collected information is 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 tests, 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 ensure that 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, 
4

identify problems at the facility, verify operation/maintenance procedures, 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 NESHAP 

continues to operate the control equipment in compliance with the regulation.

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

3(a) Non-duplication

A search of EPA’s existing standards and ongoing ICR’s revealed no duplication of 

information gathering efforts. However, certain reports required by State or local agencies may 

duplicate information required by this NESHAP. In these cases, 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 amendments to 40 CFR part 63, subpart OOO for the APR source 

category. Comments were solicited on the proposal package and the proposed ICR. Comments 

were received regarding the proposed amendments, but no comments were received regarding 

the ICR.

3(c) Consultations

Over the next three years, an average of 19 facilities per year will be subject to the 

standard (except only three facilities have continuous process vents that will require emission 

controls), with no additional sources per year becoming subject to the standard. In estimating the 

affected number of sources and the growth rate of the amino/phenolic resins manufacturing 

industry subject to this standard, we referenced the most recent ICR, and used other resources to 

obtain the most recent data available. We reviewed information available from the Online 

Tracking Information System (OTIS) which is the primary source of information regarding the 

number of existing sources. OTIS data was used in conjunction with industry consultation to 

verify the number of sources and the industry growth rate. 
5

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 are consistent with 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. 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. Without the five-year record retention, EPA would be prevented from pursuing the 

violators due to 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 (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.
6

4. The Respondents and the Information Requested

4(a) Respondents

The respondents affected by the amendments to 40 CFR part 63, subpart OOO are 

facilities that manufacture amino/phenolic resins. The United States Standard Industrial 

Classification (SIC) codes, which correspond to the North American Industry Classification 

System (NAICS) codes, could be found in the following table:

Manufacture of Amino/Phenolic Resins (40 CFR part 63, 

subpart OOO)

SIC Codes

NAICS 

Codes

Plastics Material and Resin Manufacturing 2821 325211

4(b) Information Requested

None of these reporting and 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 63.5, 63.1417(d)

Notification and report of construction date 63.5, 63.1400(j)

Notification of anticipated startup 63.5, 63.1400(j)

Actual startup notification 63.5, 63.1400(j)

Notification of modification 63.5, 63.1400(j)

Notification and report of performance test and results 63.7(b), 63.1417(e)

Pre-compliance report 63.1417(d)
7

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)

Malfunction reports 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 OOO

Five-year retention of records 63.1416(a)

Malfunction records 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

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 
8

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

Install, calibrate, maintain, and operate compliance monitoring system (CMS) for pH, flow, 

temperature, or specific gravity, or organic monitoring device for control options as applicable

Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 3, 4, 18, 308, 316, 

or 320 tests as applicable and repeat performance tests if necessary

Write the notifications and reports listed above

Enter information required to be recorded above

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information

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

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

Transmit, or otherwise disclose the information

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

Management

5(a) Agency Activities

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

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

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

affirmative defense reports, and quality control plan for CMS required to be submitted by 

industry.
9

Agency Activities

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, and note the operating conditions under which compliance was 

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

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into 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. 

Both 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 impact on small entities was taken into consideration during the development of the 

regulation. Due to technical considerations involving the process operations and the type of 

control equipment employed, the recordkeeping and reporting requirements are the same for both 

small and large entities. The Agency considers these requirements the minimum needed to 

ensure compliance and, therefore, cannot reduce them further for small entities. 

5(d) Collection Schedule
10

The specific frequency for each information collection activity within this request is 

shown below in Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping 

Requirements for the NESHAP for the Manufacture of Amino/Phenolic Resins (40 CFR Part 63, 

Subpart OOO) (Revised).

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 20,033 (Total Labor Hours from Table 1). These 

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

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

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Technical $54.66 ($26.03 + 110%)

Managerial $115.96 ($55.22 + 110%)

Clerical $38.14 ($18.16 + 110%)

These labor rates are based on the May 2012 National Occupational Employment and Wage 

Estimates for the United States, occupational codes 51-8091 for chemical plant and system 
11

operators (technical), 11-1021 for general and operations managers (managerial) and 43-6010 for 

secretaries and administrative assistants (clerical). 

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

The type of industry costs associated with the information collection activities in the 

subject standard are labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor and other costs such as photocopying and postage.

As part of the amendments to the APR NESHAP, facility owners or operators are 

required to monitor each PRD that releases to the atmosphere using a device or system that is 

capable of identifying and recording the time and duration of each pressure release and of 

notifying operators that a release has occurred. For purposes of estimating the costs of this 

requirement, we assumed that operators would install electronic indicators on each PRD in 

organic HAP service that vents to the atmosphere. The cost of each monitoring system depends 

on the number of PRDs at the facilities. The total cost for these capital expenditures for the 19

facilities in the APR source category is estimated to be $416,000. For continuous process vents, 

facility owners or operators would also be required to install controls to reduce HAP emissions 

to 1.9 pounds of organic HAP per pound of resin produced. The capital costs associated with this 

requirement, assuming carbon adsorption systems would be used to comply with this emissions 

limit, are estimated to be $3.6 million for the three facilities in the APR source category that 

would need to install and operate emissions control systems for these process vents. There are 

also revised standards for storage vessels at existing facilities. However, our data indicate that all 

storage vessels subject to the final standards are already in compliance, and no capital or annual 

costs are expected.

Annualized costs are calculated by multiplying the capital recovery factor by the capital 

cost. The capital recovery factor is 0.142 based on an interest rate of 7 percent and an assumed 

equipment life of 10 years. The total annualized capital cost for the PRD monitors and 

continuous process vents requirements for the APR source category is $912,524. 
12

The annual operation and maintenance costs are the ongoing costs to maintain monitors 

and other costs such as photocopying and postage. Based on a previous ICR for the Pesticide 

Active Ingredient source category, which estimated the annual O&M costs to be $1,450 per 

source in 2011 dollars, inflating this number from 2011 dollars to 2013 dollars gives $1,505 per 

source. The total annual O&M cost for the 19 facilities in the APR source category is $28,595.

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

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

(A)

Item

(B)

Capital/

Startup Cost 

for One 

Respondent

(C)

Number of 

Respondentsa

(D)

Total 

Capital/

Startup Cost 

(B X C) 

(E)

Annual Costs 

for One 

Respondent 

(F)

Number of 

Respondents 

a 

(G)

Total 

Annual 

Cost

(E X F)

O&M $0 0 $0 $1,505 19 $28,595

Continuous process 

vents control 

systems

$1,206,621b 3 $3,619,865 $287,408b 3 $862,225

Monitoring 

equipment (PRD) $21,919 19 $416,461 $3,121 19 $59,299

Total $4,036,326 $950,119

a We assume that there are 19 facilities in the Amino/Phenolic Resins category, however only 3 facilities are 

expected to install and operate emissions controls for continuous process vents.

b Average cost for one facility.

The total capital/startup costs for this ICR are $4,036,326. This is the total of column D 

in the above table. The total annualized capital costs and operation and maintenance (O&M) 

costs for this ICR are $950,119 and are shown in column G.

6(c) Estimating Agency Burden and Cost

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

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

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

emissions; and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be 

$17,206.
13

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), 2013 General 

Schedule, which excludes locality rates of pay (http://www.opm.gov/policy-data-oversight/payleave/salaries-wages/2013/general-schedule/2013-gs-hourlyovertime-rates-by-grade-and-step/). 

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 for the NESHAP for the Manufacture of Amino/Phenolic Resins (40 CFR Part 63, 

Subpart OOO) (Revised).

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

The number of respondents was updated based on the NEI database, which was used 

during the analysis to determine the MACT and information from the industry. The number of 

respondents is calculated using the following table which addresses the 3 years covered by this 

ICR. Over the three year period of this ICR, we expect 19 existing facilities to be respondents. 

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

YEAR

(A) (B) (C) (D) (E)

Number of 

New 

Respondents

Number 

Existing 

Respondents

Number of Existing 

Respondents That Keep 

Records But Do Not 

Submit Reports

Number of Existing 

Respondents That 

Are Also New 

Respondents

Number of 

Respondents 

(E=A+B+C-D)

1 0 19 0 0 19

2 0 19 0 0 19

3 0 19 0 0 19

Avg 0 19 0 0 19

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 19.
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)

Initial notification and performance tests 2 1 0 2

Malfunction reports 19 2 0 38

Semiannual periodic report 19 2 0 38

Other reports 19 2 0 38

Total Number of Annual Responses 116

The number of Total Annual Responses is 116.

The total annual labor costs are $1,119,104 for 20,033 labor hours. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost of 

Reporting and Recordkeeping Requirements for the NESHAP for the Manufacture of 

Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO) (Revised).

6(e) Bottom Line Burden Hours Burden Hours 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 20,033. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping 

Requirements for the NESHAP for the Manufacture of Amino/Phenolic Resins (40 CFR Part 63, 

Subpart OOO) (Revised). Furthermore, the annual public reporting and recordkeeping burden for 

this collection of information is estimated to average 173 hours per response. The total annual 

capital/startup and Operation and Maintenance (O&M) costs to the regulated entities are 

$950,119.
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(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 382

labor hours at a cost of $17,206. See below Table 2: Average Annual EPA Burden for the 

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

(Revised).

6(f) Reasons for Change in Burden

The rulemaking amends title 40, chapter I, part 63 subpart OOO to include emission 

sources for which standards were not previously developed and requirements to monitor PRDs. 

Burden changes associated with these amendments result from new recordkeeping and reporting 

requirements associated with the PRD monitoring requirements. In addition, we estimate that 

three facilities will be subject to recordkeeping, reporting and monitoring requirements 

associated with the control of certain continuous process vents. In addition, the number of 

affected facilities is estimated to be 19, which is a decrease from the previous estimate of 37. The 

overall change in burden found in this ICR reflect the provision changes, an update in the cost of 

labor, and corrections to errors found in EPA ICR number 1869.09. 

6(g) Burden Statement

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

is estimated to average 173 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, disclose or provide information to 

or for a Federal agency. This includes the time needed to review instructions; to 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; to adjust the existing ways to comply with any previously applicable instructions 

and requirements; to train personnel to be able to respond to a collection of information; to 

search data sources; to complete and review the collection of information; and to 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 
16

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-OAR-2012-0133. 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 

content of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search” than 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 Avenue, N.W., 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 Enforcement and Compliance Docket and Information Center Docket 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, N.W., Washington, DC 20503, Attention: 

Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2012-0133

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.
17

Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements for the NESHAP for the 

Manufacture of Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO) (Revised)

Burden item

Person 

hours per 

occurrencea

No. of 

occurrences 

per 

respondent 

per yearb

Person hours 

per 

respondent 

per year 

(C=AxB)

Respondents 

per yeara

Technical 

person- hours 

per year 

(E=CxD)

Management 

person hours 

per year 

(Ex0.05)

Clerical 

person 

hours per 

year 

(Ex0.1)

Total Cost 

Per yearc 

($)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

 A. Read rule and instructions 16 1 16 19 304 15 30 $19,539 

 B. Plan activities 8 1 8 19 152 8 15 $9,769 

 C. Training 16 1 16 19 304 15 30 $19,539 

 D. Create information d 320 1 320 1 320 16 32 $20,567 

 E. Gather existing information 208 1 208 19 3,952 198 395 $254,003 

 F. Write Report

 a. Pre-compliance report 20 1 20 0 0 0 0 $0 

 b. Notification of compliance status 20 1 20 0 0 0 0 $0 

 c. Semiannual summary report 40 2 80 19 1,520 76 152 $97,693 

 d. Reports of malfunctions 20 2 40 19 760 38 76 $48,847 

 e. Other reports 8 2 16 19 304 15 30 $19,539 

Subtotal for Reporting Requirements 8,758 $489,496 

5 Recordkeeping requirements

 A. Read instructions 8 1 8 19 152 8 15 $9,769 

 B. Plan activities 8 1 8 19 152 8 15 $9,255 

 C. Implement activities

 a. Malfunction records 6 2 12 19 228 11 23 $14,654 

 b. Monitoring records 24 2 48 19 912 46 91 $58,616 

 c. Batch process vent records 24 2 48 19 912 46 91 $58,616 

 d. Aggregate batch vent stream 

records 24 2 48 19 912 46 91 $58,616 
18

 e. Leak detection and repair records 24 2 48 19 912 46 91 $58,616 

 f. Other records and documentation 24 2 48 19 912 46 91 $58,616 

 D. Develop record system

 a. Record/disclose information 16 2 32 19 608 30 61 $39,077 

 b. Store, file, and maintain 

information 4 2 8 19 152 8 15 $9,769 

 E. Time to enter information

 a. Malfunction records 4 2 8 19 152 8 15 $9,769 

 b. Monitoring records 4 2 8 19 152 8 15 $9,769 

 c. Batch process vent records 4 2 8 19 152 8 15 $9,769 

 d. Aggregate batch vent records 4 2 8 19 152 8 15 $9,769 

 e. Other records and documentation 8 2 16 19 304 15 30 $19,539 

 F. Time to train personnel

 a. Control equipment inspect and 

monitor 40 2 80 19 1,520 76 152 $97,693 

 b. Leak detection and repair 40 2 80 19 1,520 76 152 $97,693 

 G. Time for audits N/A

Subtotal for Recordkeeping 

Requirements 11,275 $629,608 

TOTAL LABOR BURDEN AND 

COST (rounded) 20,033 $1,119,104 

N/A = Not applicable

a Estimate of burden for each activity, technical hours only. 

b Estimate based on average facilities. 

c Costs are rounded and based on the following hourly rates: Technical at $54.66, Management at $115.96, and Clerical at $38.14. 

d Assumes 5% of the performance tests will be repeated during each successive year. Assumed to be 280 technical hours for testing and an additional 40 hours for 

establishment of parameter monitoring levels for a total of 320 respondent hours per occurrence.
19

Table 2: Average Annual EPA Burden for the NESHAP for 

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

Burden Item

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

EPA personhours per

occurrence

No. of

occurrences

per plant

per year

EPA personhours per

plant per

year

(C=AxB)

Plant

s

per

year

Technical

person-hours

per year

(E=CxD)

Management

person-hours

per year

(Ex0.05)

Clerical

personhours per

year

(Ex0.1)

Cost,$ (a)

Initial performance test N/A

Repeat performance test 20 1 20 1 20 1 2 $1,036

REPORT REVIEW

Notification of construction/reconstruction N/A

Notification of anticipated startup N/A

Notification of actual startup N/A

Notification of modification N/A

Notification of compliance status N/A

Notification of performance test 4 1 4 2 8 0.4 0.8 $415

Notification of process change N/A

Notification of inspection of storage vessel N/A

Notification of change in primary product N/A

Pre-compliance report N/A

Storage vessel initial compliance demonstration N/A

Semiannual summary report 4 2 8 19 152 7.6 15.2 $7,877

Reports of malfunctions 2 2 4 19 76 3.8 7.6 $3,939

Other reports 2 2 4 19 76 3.8 7.6 $3,939

TOTAL ANNUAL EPA BURDEN AND COST (Rounded) 382 $17,206 

(a) Agency labor rates are from the Office of Personnel Management (OPM) 2013 General Schedule which excludes locality rates of pay. Salary Table 2013-GS. Labor 

rates are inflated to reflect average locality pay increase from base rates. Available at http://www.opm.gov/policy-data-oversight/pay-leave/salarieswages/2013/general-schedule/2013-gs-hourlyovertime-rates-by-grade-and-step/