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 Number 2027.06, OMB Control Number 2060-0516.

1(b) Short Characterization/Abstract

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

Polyurethane 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-recently 

amended on April 20, 2006. This subpart applies to each existing, new, or reconstructed affected 

source at facilities engaged in flexible polyurethane foam fabrication. For the purpose of the 

rule, flexible polyurethane foam fabrication is further divided into the following two 

subcategories: 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 reports, 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 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 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.

Over the next three years, approximately 17 respondents per year will be subject to these

standards, and 1 additional respondent per year will become subject to these same standards. All 

existing respondents are flame lamination sources. EPA anticipates that all new respondents will 

also be flame lamination sources. No loop slitter facilities are currently subject. EPA does not 

expect any loop slitter facilities to become subject to the regulation over the three-year ICR 

period.

The term “Affected Public” applies to flexible polyurethane foam fabrication facilities, 

all of which are both publicly-owned and -operated. The Affected Public burden may be found 
2

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 burden is attributed entirely to work performed by either Federal employees or 

government contractors, and may be found below in Table 2: Average Annual EPA Burden and 

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

MMMMM) (Renewal).

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

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. 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 (PM) emissions from flexible 

polyurethane 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 63, Subpart MMMMM.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensures 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 standards 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, 

duplication does not exist.

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 (79 FR 30117) on 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 (ICIS). ICIS 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 opportunity
4

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 Polyurethane 

Foam Association, at (865) 657-9840, and the American Chemistry Council (ACC) Center for 

the Polyurethanes 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 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 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-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 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 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 

polyurethane foam fabrication facilities. The United States Standard Industrial Classification 

(SIC) code for the respondents affected by the standards is 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 the NESHAP for 

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

A source must make the following notifications:

Notifications

Initial notifications

63.8816(a), 

63.9(b)

Application for construction/reconstruction (note: new or reconstructed 

sources 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 reports (flame lamination 

sources only)

63.8818(b)

Initial and subsequent annual compliance reports (loop slitter sources

only)

63.8818(c)

Startup, shutdown, and malfunction (SSM) report (flame lamination 

sources only)

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 only)

63.8820(b)

Record of adhesives used, adhesives suppliers, and Method 311 tests 

(loop slitter sources only)

63.8820(c)

Five-year 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 recordkeeping at 

a plant site. 

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements. 

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.
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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 Integrated Compliance Information System (ICIS) 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 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 reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS 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 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 types 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 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. 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 requirements is estimated to be 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 ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 
9

2014, “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 (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 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 $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 ICR 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 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 
10

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 

$101,000.

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

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. 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

16 existing respondents will be subject to these standards. 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 

years covered by this ICR: 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

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

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three-year period of this ICR is 17. 

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 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 is 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 

Polyurethane 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 Polyurethane 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 typical 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 typical 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 average 90 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $29,500. 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 be 

2,210 labor hours at a cost of $101,000. See below Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Flexible Polyurethane 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 typical 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 typical 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 years and has updated labor costs to reflect rates referenced from the Office 

of Personnel Management.

There is an increase in the total annual O&M cost as compared to the previous ICR. 

The previous ICR’s estimate only reflected those costs associated with new sources. The 

resulting omission of O&M costs also incurred by existing sources resulted in a significant 

underestimation of the total cost. EPA has thus reconciled the noted discrepancy and increased 

the total annual O&M cost accordingly.

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 

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 ICR under 

Docket ID Number EPA-HQ-OECA-2014-0086. 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 telephone 
14

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-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 Flexible Polyurethane Foam Fabrication (40 CFR Part 63, 

Subpart MMMMM) (Renewal)

Burden item

A B C D E F G H

Personhours

per 

occurrence

Annual 

occurrence

per 

respondent

Person-hours

per respondent

per year (AxB)

Respondent

per year a

Technical 

hours

per year 

(CxD)

Management 

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 c2 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 d2 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 e50 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 f4 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 0
16

Burden item

A B C D E F G H

Personhours

per 

occurrence

Annual 

occurrence

per 

respondent

Person-hours

per respondent

per year (AxB)

Respondent

per year a

Technical 

hours

per year 

(CxD)

Management 

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 g1 12 12 17 204 10.2 20.4 23,591.68

g. Retrieve records/reports h1 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) 1,930,000

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. 

Assumptions:

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 threeyear 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 adhesive facilities only.

d

 EPA assumes each respondent will submit SSM reports ten times per year.

e

 EPA assumes this activity also includes writing 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 monthly 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

personhours per 

occurrence

Annual 

occurrences

per 

respondent

EPA

person-hours

per respondent

per year

(AxB)

Respondents

per year a

Technical 

hours

per year

(CxD)

Management

hours 

per year

(Ex0.05)

Clerical 

hours

per year

(Ex0.10)

Annual 

cost

($) b

Review initial notification 4 1 4 1 4 0.2 0.4 209.36

Review application for 

construction/reconstruction

4 1 4 1 4 0.2 0.4 209.36

Review notification of performance test 4 1 4 1 4 0.2 0.4 209.36

Review notification of compliance status 20 1 20 1 20 1 2 1,046.8

Review 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

Review annual compliance report c1 1 1 0 0 0 0 0

Review semiannual compliance report 15 2 30 17 510 25.5 51 26,693.4

Review SSM report 8 10 80 17 1,360 68 136 71,182.4

TOTAL ANNUAL BURDEN AND COST (ROUNDED) 2,210 101,000

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding

Assumptions:

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 threeyear period of this ICR.

b

 This ICR uses the following labor rates: $46.67 (technical), $62.90 (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.