**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Flexible Polyur ethane Foam Fabrication (40 CFR**  **P art 63,**  **S ubpart**  **MMMMM) (Renewal)** 
**1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Flexible Poly urethane Foam Fabrication (40 CFR P art 63, S ubpart MMMMM) (Renewal), EPA I CR 2027. 05 , OMB Control Number 2060

- 0516 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for F lexible Poly urethane Foam Fabrication were proposed on August 8, 2001 (66 FR 41729), and promulgated on April 14, 2003 (68 FR 18062). These regulations apply to each existing, new, or reconstructed source at facilities engaged in flexible poly urethane foam fabrication. For the purpose of the rule, flexible poly urethane foam fabrication is further divided in the following two subcategories: 1) loop slitter adhesive use ; and 2) flame lamination. This information is being collected to assure compliance with 40 CFR part 63, subpart MMMMM. In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of an y startup, shutdown, or malfunction in the operation of an affected facility, or an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, mainten ance 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facility

at each plant site, and each plant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, an average of 14 res pondents per ye ar will be subject to the standard, and one additional respondent per year will become subject to the standard . All of the existing respondents are flame lamination sourc es, with an anticipation of one additional respondent per year over the three ye ars of this ICR. There is no loop slitter facility that would be subject to the regulation. The Office of Management and Budget (OMB) approved the current Information2

Collection Request (I CR) without any “Terms of Clearance.” The respondents to this ICR (the “Affected Public) are publicl y owned and operated flexible poly

urethane foam fabrication facilities . None of the facilities are owned by either state, local and tribal agencies or the Federal government. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

**–** NESHAP for Flexible Poly urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal). The burden to the “Federal Government” is attributed entirel y to work perform ed b y F ederal employees and/ or government contractors . T his burden is calculated below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Flexible Poly urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal).
**2. Need for and Use of t he Collection**  **2(a) Need/Authority for the Collection** The EPA is charged under section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissi ons is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, particulate matter emissions from facilitie s in flexible poly urethane foam fabrication cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for the source category

at 40 CFR part 63, subpart MMMMM. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.3

Performance tests are required in order to determine an affected facility ’s initial capability to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installe d and operated, that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the fac ility , verify operation/maintenance procedures and for compliance determinations.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 63, subpart MMMMM. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has ad opted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists.
**3 (b) Public Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 76 FR 26900 ) on May 9 , 2011 . No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency

has consulted industry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard is the Online Tracking Information Sy stem ( OTIS ) , which is operated and maintained b y EPA’s Office of Compliance. OTI S is EPA’s database for the collection, maintenance, and retrieval of all compliance data.4

Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this I CR , we contacted : 1) the Poly urethane Foam Association , at ( 865 ) 657

- 9840 ; and 2) Flexible Foam Products, Inc. at (423) 689

- 6911

. EPA did not receive any comments from the consultations. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the First Federal Register Notice. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that f acilities 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 emissio n limitations are met. If the information required by these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines**
T h ese reporting or recordkeeping requirements do not violate any of the regulations promulgated by

OMB at 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least fiv e 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 P art 70 permit program and the five

- ye ar statute of limitations on which the per mit program is based. The retention of records for five years allow s EPA to establish the compliance history of a source , an y pattern of non - compliance , and to determin e the appropriate level of enforcement action. EPA has found that the most flagrant vio lators have violations extending beyond the five years. Inaddition, EPA would be prevented from pursuing the violators due to either the destruction or nonexistence of essential records. **3(f) Confidentiality** Any information submitted to the Agency fo r which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, c hapter 1, p art 2, s ubpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 3999 , September 8, 1978; 43 FR 42251, September 2 8 , 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
T he reporting or recordkeeping requirements in the standard do not include sensitive questions.5

**4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are flexible poly urethane foam fabrication facilities. The U

. S

. Standard Industrial Classification (SI C) code for the respondents affected by the standards is SIC 3086, which corresponds to the North American Industry

Classification Sy stem (NAICS) code 326150 for “Urethane and Other Foam Products (ex cept Poly styrene) Manufacturing.” **4(b) Information Requested**

**(i) Data Items** In this ICR, all the data that is recorded or reported is required b y NESHAP for Flexible Poly urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM). A source must make the following reports:
**Notifications** Initial notification 63.9 (b), 63.8816(b) Notification of construction/reconstruction 63.9(b)(1)(iii), 63.8816.(c) Notification of performance test 63.9(e), 63.8816(d) Notification of compliance status 63.9(h)(2)(ii), 63.8816(e) **Reports** First compliance report 63.8818(b)(1) Semiannual compliance report 63.8818(b)(3) Annual compliance report 63.8818(c) Startup/Shutdown/Malfunction (SSM) report 63.10(d)(5)(i), 63.8818(f)(1) A source must make the following reports: **Recordkeeping** Record of startup, shutdown, and malfunctions 63.10(b)(1), 63.8820(a) Records are required to be retained for five years 63.10(b)(2) Electronic Reporting At the present, respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must evaluate the data, this internal automation has significantly reduced the burden associated with monitoring and recordkeeping at the plant site

.6

Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respon dent Activities**  Read instructions. Perform initial performance test, Reference Method 311 test, and repeat performance tests if necessary
. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the inf ormation. Currently , sources are using automated monitoring equipment that provides parameter data in an automated way (e.g. continuous parameter monitoring s ys tem) . Although personnel at the sources still need to evaluate the data, this type of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA conducts the follow ing activities in connection with the acquisition, analy sis, storage, and distribution of the required information :
**Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem ( OTI S).7

**5(b) Collection Methodology and Managem ent**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source’s initial capability to compl y with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs . The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In for mation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS 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 OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and it s delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** The majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes 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 Poly urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

.8

The Agency

may not conduct or sponsor, and a person is not re quired 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 requirem ents is estimated to be 15,601 (Total Labor Hours from Table 1 below ). These hours are based on Agency studies and background documents from the development of this regulation, Agency

knowledge and experience with the NESHAP program, the previousl y approv ed ICR, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $121.42 ($57.82 + 110%) Technical $99.14 ($47.21 + 110%) Clerical $49.81 ($23.27 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 20 11 , “Table 2 : Civilian Workers, by occupational and industry group.” The rates are from c olumn 1, “Total C ompensation.” The rates have been increas ed b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated with the information collection activitie s in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associat ed with continuous monitoring. Th e capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**  **Capital/Startup vs. Operation and Maintenance (O&M) Costs** (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F) Differential pressure, pH, liquid flow rate, $997 1 $997 $1,674 1 $1,6749 **Capital/Startup vs. Operation and Maintenance (O&M) Costs** data recorder The total capital/startup costs for this I CR are $997. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $1,674. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $ 2,671

. These are recordkeeping costs. **6(c) Estimating Agency Burden and Cost**  The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by th e respondents, periodic inspection of sources of emission, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 82,501

. This cost is based on the average ho url y labor rate as follows: Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%) Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%) These rates are from the Office of Personnel Management (OPM) , 2011 General Schedule , which excludes locality rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost − NESHAP for Flexible Poly

urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approxi mately 1 3 existing respondents will be subject to the standard. It is estimated that one additional respondent per year will become subject. The overall average number of respondents, as shown in the table below , is 14 per year. The number of respondents is calculated using the following table which addresses the three ye ars covered b y this I CR.10 **Number of Respondents** Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A)

Number of New Respondents (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records but Do Not Submit Reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 1 12 0 0 13 2 1 13 0 0 14 3 1 14 0 0 15 Average 1 13 0 0 14 To avoid double

- counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 14

. The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E)

Total Annual Responses E=(BxC)+D

Initial notification 1 1 0 1 Application of construction 1 1 0 1 Notification of performance test 1 1 0 1 Notification of compliance status 1 1 0 1 First compliance report 1 1 0 1 Semiannual compliance report 14 2 0 28 SSM report 14 10 0 140 Total 1 73 The number of Total Annual Responses is 1 73

. The total annual labor costs are $1,494,882 . Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost − NESHAP for Flexible Poly urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal). **6(e) Bottom Line Burden Hours Burden and Cost Tables** The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below.11 **(i) Respondent Tally** The total annual labor hours are 15,601 at a cost of $1,494,882 . Details regarding these estimates may

be found below in Table 1 : Annual Respondent Burden an d Cost − NESHAP for Flexible Poly

urethane Foam Fabrication (40 CFR Part 63, S ubpart MMMMM) (Renewal )

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 9 0 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $ 2,671 . The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 1,831 labor hours at a cost of $ 82,501 . See below Table 2 : Average Annual EPA Burden and Cost − NESHAP for Flexible Poly urethane Foam Fabrication (40 CFR Part 63, Subpart M MMMM) (Renewal)

. **6(f) Reasons for Change in Burden** There is an increase in burden hours for both the respondents and the Agency in this ICR compared to the previous I CR. This is because there are, on average, 3 more existing units subject to this st andard due to a growth in the respondent universe during the past three ye ars
. There is a lso an increase in the total labor and Agency costs as currentl y identified in the OMB Inventory

of Approved Burdens. The change in cost estimates reflects an incre ase in respondent numbers (described above) and updated labors rates available from the Bureau of Labor Statistics. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 9 0 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; devel op, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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, a12

collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for t his I CR under Docket ID Number EPA

- HQ

- OECA

- 2011

- 0255

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are al so available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52 . Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2011

- 0255 and OMB Control Number 2060

- 0516 in any correspondence.
**Part B of the Supporting Statement**  This part is not applicable because no statistical methods were used in collecting this information.**Table 1:**  **A nnual**  **Respondent Burden**  **and Cost** 

**– NESHAP**  **for Flexible**  **Polyurethane Foam**  **Fabrication (40**  **CFR Part**  **63,**

**Subpart MMMMM) (Renewal)** 

**Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per**  **year (Ex0.1)**  **(H)**

**Cost, $ b** 

1. Read instructions c 4 1 4 1 4 0.2 0.4 $ 440.77 2. Gather information c 4 1 4 14 56 2. 8 5.6 $ 6,170.82 3. Reports i. Initial notification c 2 1 2 1 2 0.1 0.2 $ 220.39 ii. Application for construction for new sources c 2 1 2 1 2 0.1 0.2 $ 220.39 iii. Notification of performance test c, d 2 1 2 1 2 0.1 0.2 $ 220.39 iv. Notification of compliance status c 20 1 20 1 20 1 2 $ 2,203.87 v. First compliance report c 8 1 8 1 8 0.4 0.8 $ 881.55 vi. Semiannual compliance report d 4 2 8 14 112 5.6 11.2 $ 12,341.65 vii. Annual compliance report e 2 1 2 0 0 0 0 $0 viii. SSM report f 2 10 20 14 280 14 28 $ 30,854.12 **Subtotal for Reporting Requirements 55**  **8.9** 4. Recordkeeping requirements a. Plan activities c 10 1 10 1 10 0.5 1 $ 1,101.93 b. Implement activities for f lame l amination i. Record SSM 1 100 100 14 1, 4 00 70 1 40 $ 154,270.62 ii. Conduct performance test c , g 50 1 50 1 50 2.5 5 $ 5,509.6 7 iii. Record CPMS measurements 2 300 600 14 8,400 420 840 $ 925,623.72 iv. CPMS calibration and maintenance h 4 50 200 14 2,800 140 280 $ 308,541.24
c. Im plement activities for l oop sitters14

**Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per**  **year (Ex0.1)**  **(H)**

**Cost, $ b** 

i. Record adhesives used and suppliers 1 1 1 0 0 0 0 $0
ii. Conduct Method 311 test 4 1 4 0 0 0 0 $0 d. Develop record system i. SSM plan c, d 40 1 40 1 40 2 4 $ 4,407.73 ii. Continuous parameter mo nitoring system (CPMS) maintenance plan c, d 20 1 20 1 20 1 2 $ 2,203.87

e. Time to train personnel i. CPMS acquisition and installation c , d 20 1 20 1 20 1 2 $ 2,203.87 ii. CPMS inspection and
mo nitoring c , d 4 1 4 1 4 0.2 0.4 $ 440.77 f. Store, file, and maintain all records i 1 12 12 14 168 8.4 16.8 $ 18,512.47 g. Retrieve records/reports j 1 12 12 14 168 8.4 16.0 $ 18,512.47 **Subtotal for Recordkeeping Requirements 15,042**  **13,566 678.3**  **1,356.6 TOTAL LABOR BURDEN AND COST**  **(rounded) 15,601**  **$1, 494,882** 

**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to the rule will be 14 . There will be one additional new source (flame lamination) that will become subject to the rule over the three

- year period of this ICR. b This ICR uses the following labor rates: $ 121.42 per hour for Executive, Administrative, and Managerial labor; $ 99 .14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 , “ Table 2. Civilian Workers, by o ccupational and industry group. ” The rates are from column 1, “ Total C om pensation. ” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.15

c This is a one

- time activity for each new facility. d We have assumed that this applies only to flame lamination facilities. e We have assumed that this applies to facilities that use loop slitter adhesive. f We have assumed that it will take each respondent two hours ten time per year to complete SSM reports. g We have assumed that this will also include writing site

- specific test plan. h We have assumed that it will take each respondent four hours 50 times per year to implement the CPMS calibration and maintenance activity. i We have assumed that it will take each respondent 1 hour twelve times per year to store, file and maintain records. j We have assumed that it will take each respondent 1 hour twelve times per year to retrieve records/reports.**Table 2:**  **A verage**  **Annual EPA**  **Burden and**  **C ost** 
**− NESHAP**  **for Flexible**  **Polyurethane Foam**  **Fabrication (40**  **CFR Part**  **63,**

**Subpart MMMMM) (Renewal)** 

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person hours per**  **plant per year**  **(C=AxB) (D)** 

**Plants per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

1. Review

initial notification c 4 1 4 1 4 0.2 0.4 $ 207.29 2. Review

application for construction c 4 1 4 1 4 0.2 0.4 $ 207.29
3. Review

notification of compliance status c 20 1 20 1 20 1 2 $ 1,036.45
4. Review

initial compliance report c , d 2 1 2 0 0 0 0 $0
5. Review

initial compliance report c , e 20 1 20 1 20 1 2 $ 1,036.45
6. Review

notification of performance test c , d 4 1 4 1 4 0.2 0.4 $ 207.29
7. Review

annual compliance report d 1 1 1 0 0 0 0 $0
8. Review

semiannual compliance report e 15 2 30 14 420 21 42 $ 21,765.41 9. Review startup, shutdown, malfunction report e 8 10 80 14 1 , 120 56 112 $ 58,041.09

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

**Assu mptions:**  a We have assumed that the average number of respondents subject to the rule will be 14 . There are nine flame lamination facilities that are currently subject to the regulation and it is estimated that one additional respondent per year will be subject to the requirements over the three

- year period of this ICR. There are no loop slitters th at are considered major sources that would be subject to the rule.17

b This cost is based on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $62.27 (GS

- 1 3, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS

- 12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS

- 6, Step3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “ 20 11 General Schedule ” which excludes locality rates of pay
. c This is a one

- time activity performed once per facility. d We have assumed that this applies to facilities that use loop slitter adhesive. e We have assumed that this applies only to flame lamination facilities.