**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Flexible Polyurethane Foam Product (40 CFR**  **Pa rt 63, Subpart III)**  **(Renewal )**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Flexible Poly urethane Foam Product (40 CFR Part 63, Subpart III) (Renewal) , EPA I CR Number 1783.06 , OMB Control Number 2060

- 0357 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Flexible Poly ure thane Foam Product were proposed on December 27, 1996 and promulgated on October 7, 1998. These regulations apply to new and existing facilities that engage in the manufacture of flexible poly

urethane foam products that are a major source of hazardous air pollutants (HAPs). This includes facilities making slabstock flexible poly urethane foam (slabstock foam), rebond flexible poly

urethane foam (rebond foam), and/or molded flexible poly urethane foam (molded foam). New facilities include those that commence d construction or reconstruction after the date of proposal. This information is being collected to assure c ompliance with 40 CFR Part 63, Subpart III

. 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 sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP

. Any owner/operato r 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 loc al 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. Over the next three ye ars, an average of 132 respondents per ye ar will be subject to the standard , and no new additional respondents per year will become subject to the standard

. The Office of Management and Budget approved the currently active ICR without any

“ Terms of Clearance ”. The “Affected Public” are publicly owned and operated b y flexible poly urethane foam production 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 Product (40 CFR2

Part 63, Subpart III) (Renewal). The burden to the Federal Government is attributed entirel y to work performed b y either F ederal employees or government contractor s and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Flexible Poly urethane Foam Product (40 CFR Part 63, Subpart III) (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 Admini strator may reasonabl y require. In the Administrator’ s judgment , HAP emissions from flexible poly urethane foam production facilities cause or contribute to air pollution that may reasonably

be antic ipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR P art 63, S ubpart III

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure co mpliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also 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 test a record of the operating parameters under whi ch compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.3

The notifications required in the standard are used to inform either 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 installed and operated, leaks are being detected and repaired , and the standard is 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 III

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y 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 adopted its own similar standards to implement the Federal standards, a cop y of the report submitt ed to the state or local agency can be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment p eriod for the renewal of this I CR was published in the Federal Register ( 77 FR 63813 ) on October 17, 2012

. 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 pro visions 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. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. 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 and the standard has been previousl y reviewed to determine the minimum information needed for compliance purposes. In developing this I CR, we contact ed : 1) the Polyurethane Foam Association , at (865) 657

- 9840 ; and 2) the Spray

Pol yurethane Foam Alliance , at (800) 523

- 6154.4

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 f irst Federal Register n otice. In this case, no comments were received

. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required b y these standards was collected less f requentl y, 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 b y OMB under 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

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

- ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars allow s EPA t o 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 five years. In addition, 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 (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1 979). **3(g) Sensitive Questions** The 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 owners or operators of flexible poly

urethane foam production facilities . The United States Standard Industrial Classification ( SI C ) code for the respondents affected by the standards is S IC 3086 , which corresponds to the North American Industry Classification Sy stem (NAICS ) code 326150 for Urethane and Other Foam Product (except Polysty rene) Manufacturing. **4(b) Information Requested (i) Data Items**  In this ICR , all the data that is recorded or reported is required b y the NESHAP for Flexible Poly urethane Foam Product (40 CFR Part 63, Subpart III). A source must make the following reports:
**Notification s**  Initial notification 63.1306(a) Application for approval of construction or reconstruction 63.1306(b) Pre

- compliance report 63.1306(c) Notification of compliance status 63.1306(d) Change in selected emission limitation/compliance method 63.1306(f)(1)&(2) Request for extension of compliance, adjustments to time periods, and changes in information 63.9(c), 63.9(i), 63.9(j)
**Reports** Semiannual compliance reports 63.1306(e) Annual compliance certification 63.1306(g) A source must keep the following records: **Recordkeeping** Startups, shutdowns, malfunctions, periods where the continuous monitoring sy stem is inoperative 63.10(b)(2) All reports and notifications 63.10(b)6

**Recordkeeping** Record of applicability 63.10(a) Slabstock sources shall maintain storage vessel records, equipment leaks record, HAP auxiliary blowing unit (ABA) record s for emission point specific limitations or source

- wide limitations, records of product data sheet for HAP cleaners, and if using a recovery device, the records of the recovered HAP ABA recordkeeping program, the monitoring device ’ s Quality Assurance (QA) data, parameter monitoring, and the HAP ABA recovered. 63.1307(a

- f)

Molded/rebond foam sources shall maintain records of product data sheets for each compound other than diisocyanates used to flush the mixhead and associated piping during periods of star tup or maintenance, and the product data sheets for each mold release agent used that has HAPs. 63.1307(g

- h)

Records are required to be retained for five years; however, onl y the data of the most recent two years must be kept on

- site 63.10(b)(1)
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 asso ciated with monitoring and recordkeeping at a plant site. 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 Respondent Activities**  Read instructions. Slabstock foam sources shall install, calibrate, maintain, and operate Continuous Monitoring Sy stem (CMS) for flow rate or pump revolutions to monitor continuously the amount of polyol added and for HAP ABA. Performance t ests are not required by MACT, S ubpart III. However, sources are required to use Reference Metho d 18 of part 60 for HAP concentration; Method 25A of part 60 for organic compounds measurements; Method 21 of part 60 for equipment leaks; and American Society for Testing and Materials (ASTM) method D3574

- 91, Standard Test methods for Flexible Cellular Materials

- Slab, Bonded, and Molded.7

**Respondent Activities** 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. Adjust the existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently , sources are using monitoring equipment that provides parameter data in an automated way

( e.g., flow rate monitoring and pump revolution per minute monitoring) . Although personnel at the source still need to evaluate the data, this ty pe of mo nitoring 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 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, anal yz e, and maintain data in the Online Tracking Information System (OTI S). **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 properl y installed and operated. Data and records maintained b y the respondents are tabulated and publis hed for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check8

on source operation and maintenance, and for compliance determinations. In formation contained in the reports is entered into OT IS 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 anal yz e 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** There is a distribution of business sizes. EPA estimates that approximately 59 percent of currentl y affected facilities, or 77 facilities, may be small entities (i.e., small businesses). During this renewal, the proposed and final rules were reviewed to estimate the number of small entities potentially

affected. According to the Proposed Rule (61 FR 68406): Due to insufficient data on the ownership of plants in the flexible poly urethane foam industry , an anal ys is of each parent company in the industry was not feasible. Consequently , the EPA used data collected in the section 114 survey to evaluate the impact on small businesses based on model facilities. That analy sis indicates that there is a total of approximately 121 businesses (31 slabstock, 90 mo lded) that are affected by the proposed regulation, of which approximately

71 are small busines ses (18 slabstock, 53 molded). Given the results of the analy sis and the use of worst

- case assumptions in the closure anal ys is, the EPA believes that the affect of the proposed regulation on sm all businesses will be minimal. 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 in below Table 1: Annual Respondent Burden and Cost

– NESHAP for Flexible Poly urethane Foam Product (40 CFR Part 63, S ubpart III) (Renewal).9

**6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicab le 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. 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 requirement s is estimated to b e 9,047 hours ( Total Labor Hours from Table 1 below). 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 I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 p ercent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. There are no capital/startup or operation and maintenance costs.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** The only type of industry costs associated with the information collection activity in the10

regulations is labor costs. There are no capital/startup or operation and maintenance costs. We estimate that $29,786 is required to purchase each leak detector and $5,250 is required for annual operation and maintenance of the detecto r. However, we have also assumed that no new sources will become subject to these standards and that the existing sources conducting modifications will not be purchasing new monitoring equipment. Additionally, sources are electing to compl y with the source - wide emission limit and are not using bag leak detectors, and the monitors were already in place prior to promulgation of this rule. **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 the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected inf ormation. The average annual Agency cost during the three years of the ICR is estimated to be $ 21, 870

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 2 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 emplo ye es . Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Flexible Poly urethane Foam Product (40 CFR Part 63, S ubpart III) (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, approximately 132 existing respondents will be subject to the standard. It is estimated that no additional respo ndents per year will become subject. The overall average number of respondents, as shown in the table below , is 132 per ye ar . The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.11

**Number of Respondents** 

Year (A) Number of Ne w Respondents 1 (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 6 132 0 6 132 2 6 132 0 6 132 3 6 132 0 6 132 Average 6 132 0 6 132 1 New respondent include sources with constructed, reconstructed and modified affected facilities. We assume that 6 of the existing sources will reconstruct or modify their facility. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three year period of this I CR is 132. 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

Notification of modification / reconstruction 1 6 1 0 6

Pre

- compliance report 1 6 1 0 6 Notification of compliance status 1 6 1 0 6 Semiannual reports 2 59 2 0 118 Annual compliance certification2 73 1 0 73 Total 209 1 New respondents are defined for this calculation as sources that recently became subject to the rule and existing sources that have modified/reconstructed their facilities. 2 There are 59 existing slabstock foam producers and 73 existing molded/rebond foam producers which total 132 respondents. The number of Total Annual Responses is 209. The total annual labor costs are $ 87 4 , 812

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

– NESHAP for Flexible Poly urethane Foam12

Product (40 CFR Part 63, Subpart III) (Renewal)

. **6(e) Bottom Line 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 below , respectively , and summarized below. **(i) Respondent Tally** The total annual labor hours are 9,047 hours at a cost of $87 4 , 812

. Details regarding these estimates may

be found below in Table 1. Annual Respondent Burden and Cost

– NESHAP for Flex ible Poly

urethane Foam Product (40 CFR Part 63, Subpart III) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 43 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $0

. 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 485 labor hours at a cost of $ 21,870 . See Table 2: Average Annual EPA Burden and Co st

– NESHAP for Fle xible Poly

urethane Foam Product (40 CFR Part 63, Subpart III) (Renewal). **6(f) Reasons for Change in Burden** There is no change in the labor hours in this I CR compared to the previous ICR. This is due to two considerations : 1) the regulations have not changed over the past three years and are not anticipated to change over the next three years ; and 2) the growth rate for the industry is very low, negative or non

- existent. Therefore, the labor hours in the previous ICR reflect the current burden and are reiterated in this ICR. There is an increase in total labor costs to the respondents and the Agency due to an increase in labor rate s . The increase is not due to any program changes. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 43 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; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying13

information, processing and maintaining information, and disclosing and prov iding information; adjust the existing way s to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information ; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA 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 I CR under Docket ID Number EPA

- HQ

- OECA

- 2012

- 0668. 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 o f 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 also available for public viewing at the Enforcement and Compliance Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The E PA 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 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

- 2012

- 0668 and OMB Control Number 2060

- 0357 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.14

**Table 1**  **: Annual Respondent Burden and Cost** 

**– NESHAP for Flex**  **ible Polyurethane Foam Product (40 CFR Part 63,**  **Subpart III) (Renewal)**  **A B**  **C D**  **E F**  **G H** 

**Burden Items Person**  **Hours per Occurrence**  **No, of**

**o ccurrences**  **per respondent**  **per y ear**  **Person**

**h ours**  **per respondent**  **per year (C = A x B)**  **Respondents**

**p er year**  **a Technical** 

**person h**  **ours per year**  **(E=CxD) Managerial** 

**person hours per**  **year (Ex0.05)**  **Clerical**

**person hours**  **per year**  **(Ex0.1) Total** 

**Costs per year**  **( $**  **) b** 
1. Applications N/A $0 2. Survey and s tudies N/A $0 **3 .**  Reporting Requirements A. Read Instructions 1 1 1 6 6 0.3 0.6 $ 668.12 B. Required Activities i. Monitoring of emissions o perations c, d Slabstock Sources Metering p ump calculations 4 2 8 59 472 23.6 47.2 $ 52,558.62 Storage tank measurements 1 12 12 59 708 35.4 70.8 $ 78,837.92 ii. Molded/Rebond Sources Included in 4 E C. Create Information Included in 3 B and 4 E D. Gather Existing Information Included in 3 B and 4 E E. Write Report Initial notification e 2 1 2 0 0 0 0 $ 0 Notification of modification/ r econstruction a 2 1 2 6 12 0.6 1.2 $ 1,336.24 Pre

- com pliance Report 4 1 4 6 24 1.2 2.4 $ 2,672.47 Notification of Compliance s tatus a i. Stablestock f

oam producers 16 1 16 3 48 2.4 4.8 $ 5,344.94 ii. Molded/r ebond f

oam p roducers 4 1 4 3 12 0.6 1.2 $ 1,336.24 Semiannual r eports f 4 2 8 59 472 23.6 47.2 $ 52,558.62 Annual c om

pliance c ertifications g 2 1 2 73 146 7.3 14.6 $ 16,257.5415

Notification of special c om pliance r equirements h 2 1 2 0 0 0 0 $ 0 Request for e xtension of c o mp liance, a djustments to the time p eriods, and c hanges in i nformation i 2 1 2 1 2 0.1 0.2 $ 22.71 Change in s elected com

pliance method or emission limit j 1 1 1 1 1 0.05 0.1 $ 111.35 Progress r eport for extensions 4 2 8 1 8 0.4 0.8 $ 890.82 **Subtotal for Reporting**  **Requirements 2,198**  **$ 211,5**  **9 3**  **. 42**  4 . Recordkeeping Requirements A. Read i nstructions Included in 3 A B. Plan a ctivities Included in 3 B C. Implement a ctivities Included in 3 B D. Develop r ecord s ystem 40 1 40 0 0 0 0 $ 0 E. Time to e nter and transit information: records of monitoring and o perations k Slabstock f

oam p roducers 8 12 96 59 5,664 283.2 566.4 $ 630,703.39 Molded/r ebond f

oam producers 4 1 4 73 292 14.6 29.2 $ 32,515.08 F. Train p ersonnel 40 1 40 0 0 0 0 $ 0 G. Audits N/A $0 **Subtotal for Recordkeeping**  **Requirements 6,849**  **$ 663,218.47**  **TOTAL ANNUAL BURDEN**  **and COST (rounded)**  **9,047 $**  **87 4**  **, 812**  Assumptions: a) We have assumed that there are approximately 59 existing slabstock foam producers and 73 existing rebond/molded foam producers for a total of 132 existing foam producers (i.e., respondents) that are major sources and subject to the NESHAP subpart III. We have further assumed that there will be no new foam producers commencing operation s over the period of this ICR

. However, we have assumed that 6 existing respondents (3 slabstock foam producers and 3 molded/rebound foam producers) a year will be conducting some type of modification but they will continue to meet compliance requirements while the reconstruction/modification application is under review. Therefore, the average number of respondents per year for this ICR is estimated to be 132. b) This ICR uses the following labor rates: Managerial $1 21.44 ($5 7.83 + 110%); Technical $ 100.2 3 ($ 47.73 + 110%); and Clerical $ 50.51 ($ 24.05 + 110%)

. These rates are from the United States Department of Labor, Burea u of Labor Statistics, March 2012 , 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. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.16

c) We have assumed that all slabstock foam producers are meeting the source

- wide emission limit and control diisocyanate emissions monitoring, recordkeeping and reporting requirements. Molded/rebond foam producers are required to eliminate the use of HAP or HAP

- based materials, cleaners or agents and only have recordkeeping and reporting requirements. d) Sources are required to use Method 21 of Appendix A of part 63 for equipment leaks; Standard Methods for Flexible Cellular Materials for determining foam properties, ASTM D3574

- 91; Method 18 of part 60 for HAP concentration; and Method 25A of 40 CFR part 60 for organic compounds. e) We have assumed that all existing sources are in compliance with the initial rule requirements. f) Slabst ock foam producers (i.e., 59 respondents) are required to submit semiannual reports. g) All sources are required to submit compliance certifications annually. However, we have assumed that all of the existing mol ded foam producer sources that are major so urces are collocated at slabstock foam production sites, and therefore, there won't be an additional reporting burden due to meeting this requirement concurrently with the semiannual compliance status reports. h) We have determined that there will be no so urces submitting a special compliance report for this ICR since the compliance date for this rule has passed. Owners or operators of an affected source for which reconstruction occurs after the proposal date of the subject rule under 40 CFR part 63 and be fore the promulgation of such rule or before the proposal date of a relevant standard established pursuant to section of 112(f) of the Clean Air Act, is require d to submit this report, as described in section 63.6(b)(3) and (4) of the General Provisions of part 63. i) This notification is required when an owner or operator request s approval of an extension of a time period or postmark deadline, according to section 63.9(i) of the General Provisions under part 63. j) We have assumed that one existing sourc e will be changing its compliance period from monthly rolling to annual rolling or vice

- versa. k) The types of records include: storage vessel records; equipment leak records; HAP ABA records for point

- specific and source

- wide limitations for both rolling annual compliance and monthly compliance alternative records; recovery device records, and proper maintenance of product data sheets. N/A = Not applicable17

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for Flex**  **ible Polyurethane Foam Product (40 CFR**  **Pa rt 63,**  **Subpart III) (Renewal) (A)**  **(B) (C)**  **(D) (E)**  **(F) (G)**  **(H)**

**Activity EPA**  **Hours/ Occurrence**  **Occurrences/**

**Plant/Year EPA** 

**Hours/Year** **(C=A*B)** **Plants/**

**Year a**  **Technical**

**Hours/Year** **(C*D)** **Managerial**

**Hours/Year** **(E*0.05)** **Clerical**

**Hours/Year** **(E*0.10)** **Total**

**Costs/Year ($)**  **b** Initial Notification c 2 1 2 0 0 0 0 $ 0 Notification of Reconstruction/ Modification 2 1 2 6 12 0.6 1.2 $ 621.89 Pre

- compliance Report 2 1 2 6 12 0.6 1.2 $ 621.89 Notification of Special Compliance Requirements d 2 1 2 0 0 0 0 $0 Notification of Compliance Status d 2 1 2 6 12 0.6 1.2 $ 621.89 Semiannual Reports e 2 2 4 59 236 11.8 23.6 $ 12,230.58 Annual Compliance Certifications f 2 1 2 73 146 7.3 14.6 $ 7,566.38 Change in Selected Compliance Method or Emission Limit g 2 1 2 1 2 0.1 0.2 $ 103.65 Progress Report for Extensions, Adjustments to Time Periods, and Changes in Information g 2 1 2 1 2 0.1 0.2 $ 103.65

**TOTAL ANNUAL BURDEN 485**  **$ 21,8**  **70**

Assumptions: a) We have assumed that there are approximately 59 existing slabstock foam producers and 73 existing rebond/molded foam producers for a total of 132 respondents. We have further assumed that about 6 existing respondents a year will be conducting some type of modification at its facility and that there will be no n ew sources over the period of this ICR. Therefore, the average number of respondents per year is estimated to be 132

. b) This ICR uses the following labor rates: Managerial $6 2

. 27 (GS

- 13, Step 5, $38. 92 + 60%); Technical $ 46

. 21 (GS

- 12, Step 1, $28. 88 + 60%); and Clerical $2 5.01 (GS

- 6, Step 3, $15. 63 + 60%)

. These rates are from the OPM, 20 13 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. This ICR assumes that Clerical hours are 10 percent of Technical hours and Managerial hours are 5 percent of Technical hours.18

c) We have assumed that all existing sources are in compl iance with the initial rule requirements. In addition, we have assumed that facilities seeking to reconstruct will continue to meet compliance requirements while application is under review. d) We have determined that there will be no sources submitting a special compliance report for this ICR since the compliance date for this rule has passed. e) Slabstock foam producers (i.e., 59 sources) are required to submit semiannual reports. f) All respondents (i.e., 132 foam producers) are required to submit annual compliance certifications. However, we have assumed that slabstock sources will be complying with this requirement concurrently when submitting semiannual reports. Molded foam producers would still need to meet this requirement separately. g) We have a ssumed that one existing source will be changing its compliance period from monthly rolling to annual.