### SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for the Manufacture of Amino/Phenolic Resins (Revised)

1. Identification of the Information Collection

1(a) Title of the Information Collection

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Manufacture of

Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO) (Revised), EPA ICR Number 1869.08,

OMB Control Number 2060

- 0434.

1(b) Short Characterization/A bstract

The amendments to this ICR are a result of the review of the existing NESHAP for the

Manufacture of Amino/Phenolic Resins (40 CFR part 63, Subpart OOO) as required by the Clean

Air Act. The NESHAP published at 40 CFR part 63, subpart OOO were propo sed on December 14,

1998, and promulgated on January 20, 2000. The current proposed rulemaking applies to

hazardous air pollutant (HAP) emissions from facilities involved in the manufacture of

amino/phenolic resins (APR). This information is being collect ed to assure compliance with 40

CFR part 63, subpart OOO. Organic HAP emissions are the pollutants regulated under this

subpart.

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

periodic reports by the owners/operators of the affected facilities. These notifications, reports, and

records are essential in determining compliance, and are required of all affected facilities subject to

NESHAP. Semiannual summary reports are also required.

The proposed rulemaking would amen d title 40, chapter I, part 63 subpart OOO to include

emission sources for which standards were not previously developed. The proposed amendments

also add requirements to monitor each pressure relief device (PRD) that releases to the atmosphere

using a dev ice or system that is capable of identifying and recording the time and duration of each

pressure release and of notifying operators that a pressure release has occurred. Information

### 2

related to these new provisions is required to be submitted in the semi

- a nnual reports required by

the existing NESHAP. The proposed amendments also add provisions for facility owners or

operators to use if they wish to assert an affirmative defense to avoid civil penalties for

exceedances of the applicable standards that are c aused by a malfunction. If these provisions are

used, the owner or operator is required to meet certain criteria during the malfunction, notify the

Administrator of malfunctions that may cause an exceedance of the emissions standards, and

submit a report f

or the malfunction to the Administrator. We believe that the number of affected

facilities under this subpart will remain constant for this source category. The overall change in

burden found in this ICR reflect the provision changes, an update in the cost of labor, and

corrections to the number of affected facilities found in EPA ICR number 1869.08.

The Office of Management and Budget (OMB) approved the currently active ICR without

any “Terms of Clearance.” The overall change in burden found in this ICR re flect the provision

changes, an update in the cost of labor, and corrections to the number of affected facilities found in

EPA ICR number 1869.08.

The period considered in this ICR and throughout this supporting statement is the first

three years following the promulgation of the amended Manufacture of Amino/Phenolic Resins

NESHAP. The estimates of the size of the regulated universe are based on data from the National

Emissions Inventory (NEI) database. There is an annual average of 18 respondents that wil l be

subject to the regulations, except only two facilities have continuous process vents. Due to the

nature of the industry, it is estimated that no additional sources will become subject to the standard

over the next three years.

2. Need for and Use o f 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 pollut ants (HAP). These standards are applicable to new or existing sources of HAP

and shall require the maximum degree of emission reduction. In addition, section 114(a) states

that the Administrator may require any owner or operator subject to any requiremen t of this Act to:

### 3

(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 impra ctical; (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, HAP emissions from the manufacture of amino/phenolic

res ins cause or contribute to air pollution that may reasonably be anticipated to endanger public

health or welfare . Therefore, the NESHAP standards were promulgated for this source category at

40 CFR part 63, subpart OOO.

2(b) Practical Utility/Users of th e Data

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

applicable regulations which were promulgated in accordance with the Clean Air Act. In addition,

the collected information is 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 tim es. During the performance tests, a record of the operating

parameters under which compliance was achieved may be recorded and used to determine

compliance in place of a continuous emission monitor.

The notifications required in the standard are used to i nform 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 ensure that the pollution control devices are properly

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

### 4

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/mainte nance procedures, and for compliance

determinations.

The information generated by the monitoring, recordkeeping and reporting requirements

described in this ICR is used by the Agency to ensure that facilities affected by the NESHAP

continues to operate th e control equipment in compliance with the regulation.

3. Non

- duplication, Consultations, and Other Collection Criteria

3(a) Non

- duplication

A search of EPA’s existing standards and ongoing ICR’s revealed no duplication of

information gathering efforts. However, certain reports required by State or local agencies may

duplicate information required by this NESHAP. In these cases, a copy of the report submitted to

the State or local agency can be sent to the Administrator in lieu of the report required by the

Federal standards. Therefore, no duplication exists.

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

This ICR is related to proposed amendments to 40 CFR part 63, subpart OOO for the APR

source category. Comments will be solicited on the proposal package and the proposed ICR.

3(c) Consultations

Over the next three years, an average of 18 facilities per year will be subject to the standard

(except only two facilities have continuous process vents), with no additional sources per year

becom ing subject to the standard. In estimating the affected number of sources and the growth rate

of the amino/phenolic resins manufacturing industry subject to this standard, we referenced the

most recent ICR, and used other resources to obtain the most recen t data available. We reviewed

information available from the Online Tracking Information System (OTIS) which is the primary

source of information regarding the number of existing sources. OTIS data was used in

conjunction with industry consultation to veri fy the number of sources and the industry growth

### 5

rate.

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 informatio n 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 an d maintenance of control equipment and the possibility of

detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements are consistent with the regulations

established by OMB at 5 CFR part 1320, section 1 320.5.

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 retenti on requirement is consistent with the Part

70 permit program and the five

- year statute of limitations on which the permit program is based.

The retention of records for five years allows EPA to establish the compliance history of a source,

any pattern of non

- compliance, and to determine the appropriate level of enforcement action. EPA

has found that the most flagrant violators have violations extending beyond the five years. Without

the five

- year record retention, EPA would be prevented from pursuing the v iolators 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, cha pter 1, part 2, subpart B

-
Confidentiality of Business Information (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).

### 6

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents

The respondents affected by the amendments to 40 CFR part 63, subpart OOO are facilities

that manufacture amino/phenolic resins. The United States Standard Industrial Classification (SIC)

codes, which correspond to the North American Industry Classification System (NAICS) codes,

could be found in the following table:

Manufacture of Amino/Phenolic Resins (40 CF R part 63,

subpart OOO) SIC Codes NAICS

Codes

Plastics Material and Resin Manufacturing 2821 325211

4(b) Information Requested

None of these reporting and recordkeeping requirements violate any of the regulations

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

(i) Data Items

All data in this ICR that is recorded and/or reported is required by National Emission

Standards for Hazardous Air Pollutants for the Manufacture of Amino/Phenolic Resins (40 CFR

part 63, subpart OOO).

A source must make t he following reports:

Reports for 40 CFR part 63, subpart OOO

Notification of intent to construct or reconstruct 63.5, 63.1417(d)

Notification and report of construction date 63.5, 63.1400(j)

Notification of anticipated startup 63.5, 63.1400(j)

Actual startup notification 63.5, 63.1400(j)

### 7

Notification of modification 63.5, 63.1400(j)

Notification and report of performance test and results 63.7(b), 63.1417(e)

Pre

- compliance report 63.1417(d)

Notification and report of compliance status 63.1417(e)

Periodic reports (semiannual) including statement of compliance (if no exceedances occurred), daily, hatch cycle, and block average monitoring data for any periods where exceedances or excursions occur, periods of monitoring system downtime. 63.1417(f)

Qu arterly reports upon request of the Administrator 63.1416(f)(2)

Notification of storage vessel inspection 63.1417(h)(1)

Site

- specific test plan 63.1417(h)(2)

Notification of planned performance test 63.1417(h)(3)

Notification of change in primary product 63.1417(h)(4), 63.1400(g)(7

- 8)

Notification of added emission points 63.1417(h)(5)

Notification that a small control device has been re

- designated as a large control device 63.1417(h)(6)

Notification of process change 63.1417(h)(7)

Pressure rel ief device deviation report 63.1417(h)(8)

A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart OOO

Five

- year retention of records 63.1416(a)

Records of monitored values, maintenance, and malfunction

records 63.1416(b), 63.6

Monitoring records 63.1416(c)

Batch process vent records 63.1416(d)

Aggregate batch vent stream records 63.1416(e)

Continuous process vent records 63.1416(f)

Other records or documentation 63.1416(g)

Reduced recordkeeping program 63.1416(h)

### 8

Electronic Reporting

Currently, sources are using monitoring equipment that provides parameter data in an

automated way, e.g., leaks and spills of mercury. Although personnel at the source still need to

evaluate the data, this type of monitoring equipment has significantly reduced the burden

associated with monitoring and recordkeeping. However for this rule, we are only proposing

electronic reporting of performance tests.

(ii) Respondent Activities

Respondent Activities

Read instructions

Install, calibrate, maintain, and operate compliance monitoring system (CMS) for pH, flow, temperature, or specific gravity, or organic monitoring device for control options as applicable Perform initial performance test, Reference Method 1, 1A, 2, 2A, 2C, 2D, 3, 4, 18, 308, 316, or 320 tests as applicable 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 uti lizing 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 util ize technology and systems for the purpose of disclosing and providing information

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

Adjust existing ways to comply with any previously applicable instructions and requirements

Transmit, or otherwise disclose the information

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.

### 9

Agency Activities Observe initial performance tests and repeat performance tests if necessary. Review notifications and reports, including performance test reports, excess emissions reports,

affirmative defense reports, and quality control plan for CMS required to be submitted by industry. Audit facility records.

Maintain data in the CDX

5(b) Collection Methodology and Management

Information contained in the reports will be required to submit records electronically to

EPA’s Central DATA Exchange (CDX) using the Electronic Reporting Tool. The Central Data

Exchange (CDX) enables fast, efficient and more accurate environmental data su bmissions from

state and local governments, industry and tribes to the Environmental Protection Agency (EPA)

and participating program offices. EPA's CDX is the point of entry on the Environmental

Information Exchange Network (Exchange Network) for enviro nmental data submissions to the

Agency. CDX works with both EPA program offices looking for a way to better manage incoming

data, and stakeholders looking for a way to reduce burden from reporting requirements.

5(c) Small Entity Flexibility

The impact on small entities was taken into consideration during the development of the

regulation. Due to technical considerations involving the process operations and the type of

control equipment employed, the recordkeeping and reporting requirements are the same fo r 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.

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 of Reporting and Recordkeeping

Requirements for the Proposed NESHAP for the Manufacture of Amino/Phenolic Resins (40 CFR

Part 63, Subpart OOO) (Revised).

### 10

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 expr essed 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 mandat ory.

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 n ext three years from these recordkeeping

and reporting requirements is estimated to be 1,178 (Total Labor Hours from Table 1). These

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

regulation, Agency knowledge and ex perience 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: $54.66 per hour for technical labor, $115.96 per

hour for man agement labor, and $38.14 for clerical labor. The rates have already been increased by

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

These rates are from the May 2012 National Occupational Employment and W age Estimates

United States for Production Occupations ( http://www.bls.gov/oes/current/oes_nat.htm#51

- 0000).

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

The type of industry costs associated with the information collection activi ties in the

subject standard are 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 operati on and maintenance costs are the ongoing costs to

### 11

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

As part of the proposed amendments to the APR NESHAP, facility owners or operators are

required to monitor each PRD that releases to th e atmosphere using a device or system that is

capable of identifying and recording the time and duration of each pressure release and of

notifying operators that a release has occurred. For purposes of estimating the costs of this

requirement, we assumed t hat operators would install electronic indicators on each PRD in organic

HAP service that vents to the atmosphere. The cost of each monitoring system depends on the

number of PRDs at the facilities. The total cost for these capital expenditures for the 18 facilities in

the APR source category is estimated to be $394,542. For continuous process vents, facility

owners or operators would also be required to install controls to reduce HAP emissions by 85

percent. The capital costs associated with this requirem ent, assuming scrubbers would be used to

attain this emissions reduction, are estimated to be $1.1 million for the two facilities in the APR

source category that have these types of process vents. There are also proposed standards for

storage vessels at ex isting facilities. However, our data indicate that all storage vessels subject to

the proposed standards are already in compliance, and no capital or annual costs are expected.

Annualized costs are calculated by multiplying the capital recovery factor by the capital

cost. The capital recovery factor is 0.1098 based on an interest rate of 7 percent and an assumed

equipment life of 15 years. The total annualized capital cost for the PRD monitors and continuous

process vents requirements for the APR source ca tegory is $397,522.

The annual operation and maintenance costs are the ongoing costs to maintain monitors

and other costs such as photocopying and postage. Based on a previous ICR for the Pesticide

Active Ingredient source category, which estimated the annual O&M costs to be $1,450 per source

in 2011 dollars, inflating this number from 2011 dollars to 2013 dollars gives $1,505 per source.

The total annual O&M cost for the APR source category is $27,090.

### 12

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

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

(A)

Item (B)

Capital/ Startup Cost

for One Respondent (C)

Number of Respondents a (D)

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

Annual Costs

for One Respondent (F)

Number of Respondents

a (G)

Total

Annual

Cost (E X F)

O&M $0 0 $0 $1,505 18 $27,090

Continuous process

vents scrubber

systems $1,106,750 b 1 $1,106,750 $340,544 b 1 $340,544

pH Monitor $1,000 2 $2,000 $300 2 $600

Liquid flow monitor $500 2 $1,000 $100 2 $200

Monitoring equipment (PRD) $21,919 18 $394,542 $3,121 18 $56,178

Total $1,504,292 $424,612

a We assume that there are 18 facilities in the Amino/Phenolic Resins category, however only 2 facilities operate continuous process vents.

b Combined costs for both facilities.



### The total capital/startup costs for this ICR are $1,504,292. This is the total of column D in

the above table. The total annualized capital costs and operation and maintenance (O&M) costs for

this ICR are $424,612 and are shown in column G.

(iv) Affirmative Defense/Root Cause Analysis/Malfunction Costs.

The EPA’s estimate for an affirmative defense and root cause analysis in the table below is

based on general experience to calculate the time and effort required of a source to r eview relevant

data, interview plant employees, and reconstruct the events prior to a malfunction in order to

determine primary and contributing causes. The level of effort also includes time to produce and

retain the report in document form so that the so urce will have it available should EPA or state

enforcement agencies ever request to review it.

The labor rates used to estimate the costs for preparing an affirmative defense have been

increased by 110 percent to account for the benefit packages available to those employed by

### 13

private industry. These rates are from the May 2012 National Occupational Employment and

Wage Estimates United States for Production Occupations

( http://www.bls.gov/oes/current/oes_nat.htm#51

- 0000).

Personnel Number of

Personnel Time

Requirement (hours) Total

Hours Hourly Rate

($/hr) Total

Technical Personnel 3 6 18 $54.66 $984

Managerial Personnel 2 6 12 $111.96 $1,392

Total 5 30 $2,375



### 6(c) Estimating Agency Burden and Cost

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

information. The EPA 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 di stribution of collected information.

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

$15,443.

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

Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%)

Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2013 General Schedule,

which excludes locality rates of pay

(http://www.opm.gov/policy

- data

- oversight/pay

- le ave/salaries

- wages/2013/general

- schedule/201

3

- gs

- hourlyovertime

- rates

- by

- grade

- and

- step/). 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 for the Proposed NESHAP for the Manufacture of Amino/Phenolic Resins (40 CFR Part

63, Subpart OOO) (Revised)

.

### 14

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

The number of respondents was updated based on the NEI database, which was used

during the analysis to determine the MACT and information from the industry. The number of

respondents is calculated using the following table which addresses the 3 years cover ed by this

ICR. Over the three year period of this ICR, we expect 18 existing facilities to be respondents.

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

YEAR (A) (B) (C) (D) (E)

Number of New Respondents Number

Existing Respondents Number of

Existing Respondents That Keep

Records But Do

Not Submit Reports Number of

Existing Respondents

That Are Also

New Respondents Number of

Respondents (E=A+B+C

- D)

1 0 18 0 0 18

2 0 18 0 0 18

3 0 18 0 0 18

Avg 0 18 0 0 18



### To avoid double

- counting respondents, column D is subtracted. As shown above, the average

Number of Respondents over the three

- year period of this ICR is 18.

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)

Affirmative Defense 1 1 N/A 1

Semiannual periodic report 18 2 0 36
Total Number of Annual Responses 37



### The number of Total Annual Responses is 37.

The total annual labor costs are $66,522 for 1,178 labor hours. Details regarding these

estimates may be found below in Table 1: Annual Respondent Burden and Cost of Reporting and

### 15

Recordkeeping Requirements for the Proposed NESHAP for the Manufacture of Am ino/Phenolic

Resins (40 CFR Part 63, Subpart OOO) (Revised).

6(e) Bottom Line Burden Hours 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, respectivel y, and summarized below.

(i) Respondent Tally

The total annual labor hours are 1,178. Details regarding these estimates may be found

below in Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping

Requirements for the Proposed NESHAP for the Manufacture of Amino/Phenolic Resins (40 CFR

Part 63, Subpart OOO) (Revised)

. Furthermore, the annual public reporting and recordkeeping

burden for this collection of information is estimated to average 32 hours per response. The total

annual capit al/startup and Operation and Maintenance (O&M) costs to the regulated entity are

$424,6112.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 343

labor hours at a cost of $15,443. See below Table 2: Average Annual EPA Burden for the

Proposed NESHAP for the Manufacture of Amino/Phenolic Resins (40 CFR Part 63, Subpart

OOO) (Revised).

6(f) Reasons for Change in Burden

The proposed rulemaking would amend title 40, chapter I, part 63 subpart OOO to incl ude,

emission sources for which standards were not previously developed and requirements to monitor

PRDs . Burden changes associated with these proposed amendments would result from new

recordkeeping and reporting requirements associated with the PRD monito ring requirements and

affirmative defense provisions for all facilities subject to the APR MACT standards. In addition,

we estimate that two facilities will be subject to recordkeeping, reporting and monitoring

requirements associated with the control of c ertain continuous process vents. The overall change

### 16

in burden found in this ICR reflect the provision changes, an update in the cost of labor, and

corrections to errors found in EPA ICR number 1869.08.

The EPA also provides an adjustment to this ICR that estimates the costs of the notification,

recordkeeping and reporting requirements associated with the assertion of the affirmative defense.

The EPA’s estimate for the required notification, reports and records, including the root cause

analysis, associated with a single incident totals approximately $2,375 and is based on the time and

effort required of a source to review relevant data, interview plant employees, and document the

events surrounding a malfunction that has caused an exceedance of an emission limit. The estimate

also includes time to produce and retain the records and reports for submission to the EPA. For the

purpose of estimating the annual burden, the EPA is attributing a total of 3 instances of affirmative

defense over a 3 year period acros s all sources in the category. The EPA is using this frequency of

3 events in 3 years, because of the number of excess emission events reported by source operators,

only a small number would be expected to result from a malfunction, and only a subset of ex cess

emissions caused by malfunctions would result in the source choosing to assert the affirmative

defense. Thus we believe the number of instances in which source operators might be expected to

avail themselves of the affirmative defense will be extremel y small.

6(g) Burden Statement

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

estimated to average 32 hours per response. Burden means the total time, effort, or financial

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

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

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

information, processing and maintaining information, and disclosing and providing information;

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

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

complete and review the collection of information; and to 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 inform ation unless it displays a valid OMB Control Number. The OMB Control

### 17

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

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

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

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

ID Number EPA

- HQ

- OECA

- 2009

- 0388. An electronic version of the public docket is avai lable 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 content of the docket,

and to access t hose documents in the public docket that are available electronically. When in the

system, select “search” than key in the docket ID number identified in this document. The

documents are also available for public viewing at the Enforcement and Compliance Docket and

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301

Constitution Avenue, N.W., 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 ho lidays. The

telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the

Enforcement and Compliance Docket and Information Center Docket is (202) 566

- 1752

. Also,

you can send comments to the Office of Information and Regulato ry Affairs, Office of

Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer

for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2009

- 0388 and OMB

Control Number 2060

- 0417 in any correspondence.

Part B of the Supporting Statement

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

information.

### 18

Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements for the Proposed NESHAP for

the Manufacture of Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO ) (Revised)

(A) (B) (C) (D) (E) (F) (G) (H)

Person

- No. of Person

- hours Respondents Technical Management Clerical Cost,$ (c)

Burden Item hours per occurrences per source per year person

- hours person

- hours person

- hours

occurrence per source per year per year per year per year (a) per year (b) (C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements N/A

A. Read instructions N/A

B. Plan activities N/A

C. Training N/A

D. Create information N/A

E. Gather existing information N/A

F. Write report N/A

Precompliance report N/A

Notification of compliance status (PRDs) 4 1 4 18 72 3.6 7.2 $4,628

Notification of compliance status (Storage vessels) 4 1 4 18 72 3.6 7.2 $4,628

Notification of compliance status (Continuous process vents) 4 1 4 2 8 0.4 0.8 $514

Semiannual summary report (PRDs) 5.5 2 11 18 198 9.9 19.8 $12,726

Semiannual summary report (Storage vessels) 5.5 2 11 18 198 9.9 19.8 $12,726

Semiannual summary report (Continuous process vents) 5.5 2 11 2 22 1.1 2.2 $1,414

Reports of malfunctions

Other reports

Affirmative defense (e) 30 1 30 1 18 12 0 $2,375

REPORTING SUBTOTAL (Rounded) 686 $39,012

4. Recordkeeping Requirements

A. Read instructions N/A

B. Plan activities N/A

C. Implementation activities

### 19

(A) (B) (C) (D) (E) (F) (G) (H)

Person

- No. of Person

- hours Respondents Technical Management Clerical Cost,$ (c)

Burden Item hours per occurrences per source per year person

- hours person

- hours person

- hours

occurrence per source per year per year per year per year (a) per year (b) (C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

Malfunction records N/A

Storage vessel records 4 2 8 18 144 7.2 14.4 $9,256

Continuous process vent records 4 2 8 2 16 0.8 1.6 $1,028

Pressure Relief Devices 2 1 2 18 36 1.8 3.6 $2,314

D. Develop record system

Record/disclose information

Store, file, and maintain information

Pressure relief devices 2 1 2 18 36 1.8 3.6 $2,314

E. Time to enter information

Malfunction records

Storage vessel records 4 2 8 18 144 7.2 14.4 $9,256

Continuous process vent records 4 2 8 2 16 0.8 1.6 $1,028

Pressure relief devices 2 1 2 18 36 1.8 3.6 $2,314

F. Time to train personnel N/A

G. Time for audit N/A

RECORDKEEPING SUBTOTAL (Rounded) 492 $27,510

TOTAL LABOR BURDEN AND COST (Rounded) 1,178 $66,522

N/A = Not Applicable.
(a) Estimate of burden for each activity, technical hours only.
(b) Estimate based on average facilities.
(c) Costs are rounded and based on the following hourly rates: Technical at $54.66, Management at $115.96, and Clerical at $ 38.14 from May 2012 National Occupational
Employment and Wage Estimates United States

- Production Occupations. Mean Hourly Rate (http://www.bls.gov/oes/current/oes_nat.htm#51

- 0000).
(d) Assumes 1 affirmative defense report for entire industry during each year of the 3

- year ICR period. For affirmative defense, hours required assumes 18 hours technical, 12 hours
management, and 0 hours clerical for each instance of affirmative defense. Formulas not followed for person hours per year

### 20

Table 2: Average Annual EPA Burden for the Proposed NESHAP for

the Manufacture of Amino/Phenolic Resins (40 CFR Part 63, Subpart OOO ) (Revised)

(A) (B) (C) (D) (E) (F) (G) (H)

EPA person

- No. of EPA person

- Plants Technical Management Clerical Cost,$ (a)

Burden Item hours per occurrences hours per per person

- hours person

- hours person

occurrence per plant plant per year per year per year hours per

per year year (E=CxD) (Ex0.05) year

(C=AxB) (Ex0.1)

Initial performance test N/A

Repeat performance test 20 1 20 0.9 18 0.9 1.8 $933

REPORT REVIEW
Notification of construction/reconstruction N/A

Notification of anticipated startup N/A

Notification of actual startup N/A

Notification of modification N/A

Notification of compliance status N/A

Notification of performance test 4 1 4 2 8 0.4 0.8 $415

Notification of process change N/A

Notification of inspection of storage vessel N/A

Notification of change in primary product N/A

Pre

- compliance report N/A

Storage vessel initial compliance demonstration N/A

Semiannual summary report 4 2 8 18 144 7.2 14.4 $7,462

Reports of malfunctions 2 2 4 18 72 3.6 7.2 $3,731

Other reports 2 2 4 18 72 3.6 7.2 $3,731

Affirmative defense 2 1 2 1 2 0.1 0.2 $104

TOTAL ANNUAL EPA BURDEN AND COST (Rounded) 343 $15,443

(a) Agency labor rates are from the Office of Personnel Management (OPM) 2013 General Schedule which excludes locality rates of pay. Salary Table 2013

- GS. Labor
rates are inflated to reflect average locality pay increase from base rates. Ava ilable at http://www.opm.gov/policy

- data

- oversight/pay

- leave/salaries

- wages/2013/general

- schedule/2013

- gs

- hourlyovertime

- rates

- by

- grade

- and

- step/