SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

MMMMM) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

(Renewal), EPA ICR 2027.05, OMB Control Number 2060-0516

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Flexible 

Polyurethane Foam Fabrication were proposed on August 8, 2001 (66 FR 41729), and 

promulgated on April 14, 2003 (68 FR 18062). These regulations apply to each existing, new, 

or reconstructed source at facilities engaged in flexible polyurethane foam fabrication. For the 

purpose of the rule, flexible polyurethane foam fabrication is further divided in the following 

two subcategories: 1) loop slitter adhesive use; and 2) flame lamination. This information is 

being collected to assure compliance with 40 CFR part 63, subpart MMMMM.

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

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in 

the operation of an affected facility, or any period during which the monitoring system is 

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

and are required of all affected facilities subject to NESHAP. 

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

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

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

In the event that there is no such delegated authority, the reports are sent directly to the U. S.

Environmental Protection Agency (EPA) regional office.

Based on our consultations with industry representatives, there is an average of one 

affected facility at each plant site, and each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, an average of 14 respondents per year will be subject to the 

standard, and one additional respondent per year will become subject to the standard. All of 

the existing respondents are flame lamination sources, with an anticipation of one additional 

respondent per year over the three years of this ICR. There is no loop slitter facility that would 

be subject to the regulation. 

The Office of Management and Budget (OMB) approved the current Information 
2

Collection Request (ICR) without any “Terms of Clearance.”

The respondents to this ICR (the “Affected Public) are publicly owned and operated 

flexible polyurethane foam fabrication facilities. None of the facilities are owned by either state, 

local and tribal agencies or the Federal government. The burden to the “Affected Public” may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Flexible 

Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal). The burden to 

the “Federal Government” is attributed entirely to work performed by Federal employees and/or 

government contractors. This burden is calculated below in Table 2: Average Annual EPA 

Burden and Cost – NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, 

Subpart MMMMM) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

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

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

of this Act to: 

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

In the Administrator's judgment, particulate matter emissions from facilities in flexible 

polyurethane foam fabrication cause or contribute to air pollution that may reasonably be 

anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated 

for the source category at 40 CFR part 63, subpart MMMMM.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.
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 properly 

installed and operated, that leaks are being detected and repaired, and that the standards are 

being met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

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

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

MMMMM.

3(a) Non-duplication

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

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

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

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

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

duplication exists.

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

An announcement of a public comment period for the renewal of this ICR was published 

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

burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard is the Online Tracking Information System (OTIS), which is operated 

and maintained by EPA’s Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of all compliance data. 
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 ICR, we contacted: 1) the Polyurethane Foam Association, at (865) 657-9840; and 2) 

Flexible Foam Products, Inc. at (423) 689-6911. EPA did not receive any comments from 

the consultations. 

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the First Federal Register Notice. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB at 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. The EPA believes that the five-year records retention requirement is consistent 

with the Part 70 permit program and the five-year statute of limitations on which the permit 

program is based. The retention of records for five years allows EPA to establish the compliance 

history of a source, any pattern of non-compliance, and to determine the appropriate level of 

enforcement action. EPA has found that the most flagrant violators have violations extending 

beyond the five years. In addition, EPA would be prevented from pursuing the violators due to 

either the destruction or nonexistence of essential records.

3(f) Confidentiality

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

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 3999, September 8, 1978; 43 FR 42251, September 28, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.
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4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are flexible 

polyurethane foam fabrication facilities. The U. S. Standard Industrial Classification (SIC) code

for the respondents affected by the standards is SIC 3086, which corresponds to the North 

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

Products (except Polystyrene) Manufacturing.”

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NESHAP for Flexible 

Polyurethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM).

A source must make the following reports:

Notifications

Initial notification 63.9(b), 63.8816(b)

Notification of construction/reconstruction 63.9(b)(1)(iii), 63.8816.(c)

Notification of performance test 63.9(e), 63.8816(d)

Notification of compliance status 63.9(h)(2)(ii), 63.8816(e)

Reports

First compliance report 63.8818(b)(1)

Semiannual compliance report 63.8818(b)(3)

Annual compliance report 63.8818(c)

Startup/Shutdown/Malfunction (SSM) report 63.10(d)(5)(i), 63.8818(f)(1)

A source must make the following reports:

Recordkeeping 

Record of startup, shutdown, and malfunctions 63.10(b)(1), 63.8820(a)

Records are required to be retained for five years 63.10(b)(2)

Electronic Reporting

At the present, respondents are using monitoring equipment that automatically records 

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

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

the plant site.
6

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Perform initial performance test, Reference Method 311 test, and repeat performance tests if 

necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.

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

providing information.

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

Transmit, or otherwise disclose the information.

Currently, sources are using automated monitoring equipment that provides parameter 

data in an automated way (e.g. continuous parameter monitoring system). Although personnel at 

the sources still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping.

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

Management

5(a) Agency Activities

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

storage, and distribution of the required information:

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

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

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).
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5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard. Data and records maintained by the respondents are tabulated and

published for use in compliance and enforcement programs. The semiannual reports are used for 

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

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, 

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five 

years.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these requirements the 

minimum needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost − NESHAP for Flexible 

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

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory. 
8

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

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 15,601 (Total Labor Hours from Table 1 below). 

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

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

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.42 ($57.82 + 110%)

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.27 + 110%)

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

September 2011, “Table 2: Civilian Workers, by occupational and industry group.” The rates are 

from column 1, “Total Compensation.” The rates have been increased by 110 percent to account 

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

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

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

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

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

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

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

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total 

O&M,

(E X F)

Differential 

pressure, pH, 

liquid flow rate,

$997 1 $997 $1,674 1 $1,674
9

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

data recorder

The total capital/startup costs for this ICR are $997. This is the total of column D in the 

above table.

The total operation and maintenance (O&M) costs for this ICR are $1,674. This is the 

total of column G.

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $2,671. These are recordkeeping 

costs. 

6(c) Estimating Agency Burden and Cost

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

information. EPA's overall compliance and enforcement program includes activities such as the 

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

emission, and the publication and distribution of collected information.

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

$82,501. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%)

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2011 General

Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to 

account for the benefit packages available to government employees. Details upon which this 

estimate is based appear below in Table 2: Average Annual EPA Burden and Cost − NESHAP 

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

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

Based on our research for this ICR, on average over the next three years, approximately

13 existing respondents will be subject to the standard. It is estimated that one additional 

respondent per year will become subject. The overall average number of respondents, as shown 

in the table below, is 14 per year.

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

three years covered by this ICR.
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Number of Respondents

Respondents That Submit 

Reports

Respondents That Do 

Not Submit Any 

Reports

Year

(A)

Number of 

New

Respondents

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents That 

Keep Records but Do 

Not Submit Reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 1 12 0 0 13

2 1 13 0 0 14

3 1 14 0 0 15

Average 1 13 0 0 14

To avoid double-counting respondents, column D is subtracted. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 14.

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number 

of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports

(E)

Total Annual 

Responses 

E=(BxC)+D

Initial notification 1 1 0 1

Application of construction 1 1 0 1

Notification of performance test 1 1 0 1

Notification of compliance status 1 1 0 1

First compliance report 1 1 0 1

Semiannual compliance report 14 2 0 28

SSM report 14 10 0 140

Total 173

The number of Total Annual Responses is 173.

The total annual labor costs are $1,494,882. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost − NESHAP for Flexible 

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

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

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below.
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(i) Respondent Tally

The total annual labor hours are 15,601 at a cost of $1,494,882. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost − NESHAP for 

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

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 90 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $2,671. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally

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

1,831 labor hours at a cost of $82,501. See below Table 2: Average Annual EPA Burden and 

Cost − NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, Subpart 

MMMMM) (Renewal).

6(f) Reasons for Change in Burden

There is an increase in burden hours for both the respondents and the Agency in this 

ICR compared to the previous ICR. This is because there are, on average, 3 more existing units 

subject to this standard due to a growth in the respondent universe during the past three years. 

There is also an increase in the total labor and Agency costs as currently identified in the 

OMB Inventory of Approved Burdens. The change in cost estimates reflects an increase in 

respondent numbers (described above) and updated labors rates available from the Bureau of 

Labor Statistics. 

6(g) Burden Statement

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

is estimated to average 90 hours per response. Burden means the total time, effort, or financial 

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

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

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

sources; complete and review the collection of information; and transmit or otherwise disclose

the information. 

An agency may not conduct or sponsor, and a person is not required to respond to, a 
12

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

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

burden estimates, and any suggested methods for minimizing respondent burden, including the 

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

Docket ID Number EPA-HQ-OECA-2011-0255. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

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

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

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

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

Number EPA-HQ-OECA-2011-0255 and OMB Control Number 2060-0516 in any

correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
Table 1: Annual Respondent Burden and Cost – NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, 

Subpart MMMMM) (Renewal)

Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year 

a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

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 f2 10 20 14 280 14 28 $30,854.12

Subtotal for Reporting Requirements 558.9

4. Recordkeeping requirements

 a. Plan activities c 10 1 10 1 10 0.5 1 $1,101.93

 b. Implement activities for flame

 lamination

 i. Record SSM 1 100 100 14 1,400 70 140 $154,270.62

 ii. Conduct performance test c, g 50 1 50 1 50 2.5 5 $5,509.67

 iii. Record CPMS measurements 2 300 600 14 8,400 420 840 $925,623.72

 iv. CPMS calibration and

 maintenance h

4 50 200 14 2,800 140 280 $308,541.24

 c. Implement activities for loop sitters 
14

Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year 

a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

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 

 monitoring system (CPMS)

 maintenance plan c, d

20 1 20 1 20 1 2 $2,203.87

 e. Time to train personnel

 i. CPMS acquisition and 

 installation c, d

20 1 20 1 20 1 2 $2,203.87

 ii. CPMS inspection and

 monitoring c, d

4 1 4 1 4 0.2 0.4 $440.77

 f. Store, file, and maintain all 

 records i

1 12 12 14 168 8.4 16.8 $18,512.47

 g. Retrieve records/reports j1 12 12 14 168 8.4 16.0 $18,512.47

Subtotal for Recordkeeping Requirements 15,042

13,566 678.3 1,356.6

TOTAL LABOR BURDEN AND COST 

(rounded)

15,601 $1,494,882

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to the rule will be 14. There will be one additional new source (flame lamination) that 

will become subject to the rule over the three-year period of this ICR. 

b

 This ICR uses the following labor rates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81 per 

hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011, “Table 2. Civilian Workers, by 

occupational and industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages 

available to those employed by private industry.
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: Average Annual EPA Burden and Cost −NESHAP for Flexible Polyurethane Foam Fabrication (40 CFR Part 63, 

Subpart MMMMM) (Renewal)

Activity

(A)

EPA 

personhours 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

personhours

per year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

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

2. Review application for 

construction c

4 1 4 1 4 0.2 0.4 $207.29

3. Review notification of 

compliance status c

20 1 20 1 20 1 2 $1,036.45

4. Review initial compliance 

report c, d

2 1 2 0 0 0 0 $0

5. Review initial compliance 

report c, e

20 1 20 1 20 1 2 $1,036.45

6. Review notification of 

performance test c, d

4 1 4 1 4 0.2 0.4 $207.29

7. Review annual compliance 

report d

1 1 1 0 0 0 0 $0

8. Review semiannual 

compliance report e

15 2 30 14 420 21 42 $21,765.41

9. Review startup, shutdown, 

malfunction report e

8 10 80 14 1,120 56 112 $58,041.09

TOTAL ANNUAL BURDEN 

AND COST (rounded)

1,831 $82,501

Assumptions:

a We have assumed that the average number of respondents subject to the rule will be 14. There are nine flame lamination facilities that are currently subject to 

the regulation and it is estimated that one additional respondent per year will be subject to the requirements over the three-year period of this ICR. There are no 

loop slitters that are considered major sources that would be subject to the rule. 
17

b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 

Managerial rate of $62.27 (GS-13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS-6, Step3, $15.63 

x 1.6). These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.

c

 This is a one-time activity performed once per facility.

 

d

 We have assumed that this applies to facilities that use loop slitter adhesive.

 

e

 We have assumed that this applies only to flame lamination facilities.