**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 Poly urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal) , EPA I CR Number 2027.06, OMB Control Number 2060

- 0516. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Flexible Poly urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM ) were proposed on August 8, 2001 (66 FR 41729), promulgated on April 14, 2003 (68 FR 18062), and most

- recentl y amended on April 20 , 2006

. This subpart applies to each existing, new, or reconstructed affected source at facilities engaged in flexible poly urethane foam fabrication. For the purpose of the rule, flexible poly

urethane foam fabrication is further divided into the following two sub categories: 1) loop slitter adhesive use and ; 2) flame lamination. New facilities include those that commenced construction, modification , or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart MMMMM

. In general, all NESHAP standards require initial notification report s, performance tests, and periodic reports b y 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 the 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 repor

ts, 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. Over the next three ye ars, approximately 1 7 respondents per ye ar will be subject to the se standard s , an d 1 additional respondent per year will become subject to the se same standard s . All existing respondents are flame lamination source s. EPA anticipates that all new respondents will also be flame lamination sources. No loop slitter facilities are currentl y subject . EPA does not expect any

loop slitter facilities to become subject to the regulation over the three

- year ICR period

. The term “Affected Publ ic” applies to flexible poly urethane foam fabrication facilities , all of which are both publicly

- owned and

- operated . The Affected Public burden may be found2

below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Flexible Poly urethane Foam Fabri cation (40 CFR Part 63, Subpart MMMMM) (Renewal) . The burden to the Federal Government burden is attributed entirel y to work performed b y either F ederal employees or government contractors, and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Flexible Poly urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal)

. The Office of Management and Budget (OMB) approved the currentl y active I CR without any

“Terms of Clearance.”
**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. Inaddition, S ection 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 , particulate matter (PM) emissions from flexible poly ureth ane foam fabrication facilities cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category

at 40 CFR Part 6 3, Subpart MMMMM. **2(b) Practica l Utility/Users of the Data**  The recordkeeping and reporting requirements in the standard ensures compliance with the applicable regulations which w ere 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 s 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 th e pollution control devices are properl y installed and operate d, that leaks are being detected and repaired, and that the standard s are being met. The performance test may also be observed. The require d 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 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 submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Pub lic Notice Required Pr** **ior 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 ( 79 FR 30117 ) o n May 27, 2014. 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 Integrated Compliance Information System (I CI S). I CI S is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. Industry trade associations and other interested parties were provided with an opportunity4

to comment on the burden associated with the standard when it was being developed and further amended, and the standard has been previously reviewed to determine the minimum information needed for compliance purposes. For the current renewal, EPA contacted both the Poly urethane Foam Association , at (865) 657

- 9840 , and the American Chemistry C ouncil (ACC) Center for the Poly urethanes Industry

(CPI) , at (202) 249

- 7000

. We did not receive comments from the consultation. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitte d in response to the f irst Federal Register n otice. **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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **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 years allow s EPA to establish the compliance history of a source , any pattern of non - compli ance , 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 none xistence 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, 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 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).
**3(g) Sensitive Questions**5

The reporting or recordkeeping requirements in the standard do not include sensitive questions. **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 United States Standard Indus trial Classification (SI C) code for the respondents affected b y the standards is 3086, which corresponds to the North American Industry

Classification System (NAI CS) co de 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 b y the NESHAP for Flexible Poly

urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM ). A source must make the following notifications :
**Notification s**  Initial notification s 63.8816( a) , 63.9(b ) Application for construction/reconstruction (note: new or reconstructed source s must instead submit this application in lieu of initial notifications ) 63.8816(c) , 63.9(b)(1)(iii) Notification of performance test 63.8816(d) , 63.7(b), 63.9(e) Notification of compliance status 63.8816(e

- h), 63.9(h)(2)(ii) A source must make the following reports:
**Reports** Initial and subsequent semiannual compliance report s (flame lamination sources onl y) 63.8818(b) Initial and subsequent annual compliance reports (l oop slitter sources only) 63.8818( c ) Startup , shutdown , and malfunction (SSM) report ( flame lamination sources onl y) 63.8818( i ) , 63.6(e)(3), 63.10(d)(5)6

A source must keep the following records: **Recordkeeping** Record of all notifications and reports 63.8820(a) Record of SSM, performance tests, operating parameters, and emissions deviations (flame lamination sources onl y) 63.8820(b ) Record of adhesives used, adhesives suppliers, and Method 311 tests (loop slitter sources onl y) 63.8820(c)

Five

- ye ar records retention 63.8822 (b), 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 associated with monitoring and recordke eping at a plant site. **(ii) Respondent Activities Respondent Activities**  Familiarization with the regulatory requirements. Perform initial performance test, Reference Metho d 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 inform ation. 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.7

**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, 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, inc luding performance test reports and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in Integrated Compliance Information System (I CI S) and ECHO. **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. P erformance 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 i dentification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is reported b y state and local governments in the IC IS Air database , which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y local and state regulatory agenci es, EPA regional offices , and EPA headquarters. EPA and its 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 years. **5(c) Small Entity Flexibility**  The majority

of respondents are large entities (i.e., large businesses) . However,8

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 to be the minimum requirements 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 Sched ule**  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 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 18, 900 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 $ 129

. 93 ($ 61.87 + 110%) Technical $ 103

. 97 ($ 49.51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 66 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, June9

2014 , “ 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 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 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 (O&M) 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, data recorder $997 1 $997 $1,674 17 $28, 458

**Total (rounded)**  **$997 $28,500**  Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding The total capital/startup costs for this I CR are $997. This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this I CR are $28, 500

. 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 $29, 500

. These are recordkeeping costs

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

are those costs asso ciated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the respondents, periodic inspection of sources of10

emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 10 1 , 000

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 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, Subp art 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, approximately 16 existing respondents will be subject to the se standard s . It is also estimated that one additional respondent per year will become subject. The overall average number of respondents, as shown in the table below, is 17 per year. The number of respondents is calculated using the following table that addresses the three ye ars co vered b y this ICR : **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

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 1 15 0 0 16 2 1 16 0 0 17 3 1 17 0 0 18 Average 1 16 0 0 17
1 New respondents include sources with constructed, reconstructed , and modified affected facilities

.11

C olumn D is subtracted to avoid double

- counting respondents

. As shown above, th e average Number of Respondents over the three

- ye ar period of this ICR i s 17

. 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 for construction/reconstruction 1 1 0 1
Notification of performance test 1 1 0 1 Notification of compliance status 1 1 0 1 Initial compliance report: Loop slitter sources 0 1 0 0 Flame lamination sources 1 1 0 1 Subsequent compliance reports: Loop slitter sources 0 1 0 0 Flame lamination sources 17 2 0 34 SSM report 17 10 0 170 Total 209 The number of Total Annual Responses i s 209

. The total annual labor costs are $ 1, 900 , 000

. 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 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** 12

The total annual labor hours are 18, 900 hours at a cost of $1,900,000

. 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)

. We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty

pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time re quired for technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to av erage 90 h ours per response . The total annual capital/startup and O&M costs to the regulated entity are $2 9 , 500

. 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 the next three years is estimated to b e 2,210 l abor hours at a cost o f $ 10 1 , 000 . See below Table 2 : Average Annual EPA Burden and Cost

– NESHAP for Flexible Poly urethane Foam Fabrication (40 CFR Part 63, Subpart MMMMM) (Renewal). We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty

pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records.13

**6(f) Reasons for Change in Burden** There is an increase in the total estimated respondent burden as currently identified in the OMB Inventory

of Approved Burdens. This burden increase is due to adjustments EPA has made to account for industry growth that has occurred since the ICR was last approved . EPA has also updated corresponding labor costs to reflect current rates referenced from the Bureau of Labor Statistics

. EPA has similarly adjusted the Agency

labor burden to reflect industry growth over the past three ye ars and has updated labor costs to reflect rates referenced from the Office of Perso nnel Management. There is an increase in the total annual O&M cost as compared to the previous I CR. The previous ICR’s estimate only reflected those costs associated with new sources. The resulting omission of O&M costs also incurred by existing sourc es resulted in a significant underestimation of the total cost. EPA has thus reconciled the noted discrepancy and increased the total annual O&M cost accordingl y. **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 b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This in cludes the time needed to review instructions; develop, 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 ways 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, 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, E PA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 2014

- 008 6. 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), WJC 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 telephone14

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 th e EPA Docket ID Number EPA

- HQ

- OECA

- 2014

- 0086 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.15

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

**– NESHAP for**  **Fl exible Polyurethane Foam Fabrication (40 CFR Part 63,**  **Subpart MMMMM) (Renewal)**

**Burden item A**  **B C**  **D E**  **F G**  **H Person** 
**** **hours per**  **occurrence Annual** 

**occurrence per**  **respondent Person** 
**- hours** 

**per respondent per year (AxB)**  **Respondent**

**per year a**  **Technical**

**hours per**  **year (CxD)**  **Managem ent** 

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

**hours per year**  **(Ex0.10) Annual** 

**cost ($)**  **b** 1. Familiarization with regulatory requirements 4 1 4 1 4 0.2 0.4 462.58 2. Gather information 4 1 4 17 68 3.4 6.8 7,863.89 3. Reports a. Initial notification 2 1 2 1 2 0.1 0.2 231.29 b. Application for construction/ reconstruction 2 1 2 1 2 0.1 0.2 231.29 c. Notification of performance test 2 1 2 1 2 0.1 0.2 231.29 d. Notification of compliance status 20 1 20 1 20 1 2 2,312.91 e. Initial compliance report i. Flame lamination facilities 8 1 8 1 8 0.4 0.8 925.16 ii. Loop slitter facilities 8 1 8 0 0 0 0 0 f. Annual compliance report c 2 1 2 0 0 0 0 0 g. Semiannual compliance report 4 2 8 17 136 6.8 13.6 15,727.79 h. SSM report d 2 10 20 17 340 17 34 39,319.47 **Reporting Subtotal 669**  **67,306** 3. Recordkeeping requirements a. Plan activities 10 1 10 1 10 0.5 1 1,156.46 b. Implement activities for flame lamination i. Record SSM 1 100 100 17 1,700 85 170 196,597.35 ii. Conduct performance test e 50 1 50 1 50 2.5 5 5,782.28 iii. Record CPMS measurements 2 300 600 17 10,200 510 1,020 1,179,584.1 iv. CPMS calibration and maintenance f 4 50 200 17 3,400 170 340 393,194.7 c. Implement activities for loop slitters i. Record adhesives used and suppliers 1 1 1 0 0 0 0 016

**Burden item A**  **B C**  **D E**  **F G**  **H Person** 
**** **hours per**  **occurrence Annual** 

**occurrence per**  **respondent Person** 
**- hours** 

**per respondent per year (AxB)**  **Respondent**

**per year a**  **Technical**

**hours per**  **year (CxD)**  **Managem ent** 

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

**hours per year**  **(Ex0.10) Annual** 

**cost ($)**  **b** ii. Conduct Method 311 test 4 1 4 0 0 0 0 0 d. Develop record system i. SSM plan 40 1 40 1 40 2 4 4,625.82 ii. CPMS maintenance plan 20 1 20 1 20 1 2 2,312.91 e. Time to train personnel i. CPMS acquisition and installation 20 1 20 1 20 1 2 2,312.91 ii. CPMS inspection and monitoring 4 1 4 1 4 0.2 0.4 462.58 f. Store, file, and maintain all records g 1 12 12 17 204 10.2 20.4 23,591.68 g. Retrieve records/reports h 1 12 12 17 204 10.2 20.4 23,591.68 **Recordkeeping Subtotal 18,229**  **1,833,212 TOTAL ANNUAL BURDEN AND COST (ROUNDED)**  **18, 900**  **1,900,000 TOTAL ANNUAL CAPITAL AND O&M COST (SEE SECTION 6(b)(iii))**  **29,500 GRAND TOTAL (LABOR, CAPITAL, AND O&M)**  **1, 9**  **30 ,**  **000** CPMS

- Continuous Parameter Monitoring System SSM

- Startup, Malfunction, or Startup **Note:** Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding

. **Assu mptions:**  a EPA estimates 16 existing sources will be subject to the standard. One additional new source (flame lamination) will become subject to the rule over the three

year period of this ICR. b This ICR uses the following labor rates: $103.97 (technical), $129 .93 (managerial), and $51.79 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation. ” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry. c Applies to loop slitter adh e sive facilities only. d EPA assumes each respondent will submit SSM reports ten times per year.
e EPA assumes this activity also includes w riting the site

- specific test plan. f EPA assumes each respondent will implement CPMS calibration and maintenance activities 50 times per year. g EPA assumes each respondent will file and maintain records on a mo nthly basis. h EPA assumes each respondent will retrieve records/reports 12 times per year.17

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

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

**Burden item A**  **B C**  **D E**  **F G**  **H**
**EPA person**  **** **h ours**  **per occurrence**  **Annual**

**occurrences per**  **respondent EPA** 

**perso n**  **- hours**  **per respondent per year**  **(AxB) Respondents** 

**per year a**  **Technical**

**hours per year**  **(CxD) Managem**  **ent**

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

**hours per year**  **(Ex0.10) Annual** 

**cost ($)**  **b** Revie w initial notification 4 1 4 1 4 0.2 0.4 209.36 Revie w application for construction/reconstruction 4 1 4 1 4 0.2 0.4 209.36
Revie w notification of performance test 4 1 4 1 4 0.2 0.4 209.36 Revie w notification of compliance status 20 1 20 1 20 1 2 1,046.8 Revie w initial compliance report Flame lamination facilities 20 1 20 1 20 1 2 1,046.8 Loop slitter facilities 2 1 2 0 0 0 0 0 Revie w annual compliance report c 1 1 1 0 0 0 0 0 Revie w semiannual compliance report 15 2 30 17 510 25.5 51 26,693.4 Revie w SSM report 8 10 80 17 1,360 68 136 71,182.4 **TOTAL ANNUAL BURDEN AND COST (ROUNDED) 2,210**  **10 1**  **, 000**  **Note:** Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding
**Assu mptions:**  a EPA estimates 16 existing sources will be subject to the standard. One additional new source (flame lamination) will become subject to the rule over the three

year period of this ICR. b This ICR uses the following labor rates: $46.67 (technical), $62.9 0 (managerial), and $25.25 (clerical). These rates are from the Office of Personnel Management (OPM), 2014 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.
c Applies to loop slitter adhesive facilities only.