1783ss04[rev3-15-07]

13

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Flexible Polyurethane Foam Production

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III) (Renewal)

1(b) Short Characterization/Abstract

The Maximum Achievable Control Technology (MACT) standards for Flexible Polyurethane Foam Production, published at 40 CFR part 63, subpart III, were proposed on December 27, 1996 and promulgated on October 7, 1998. These standards apply to owners or operators of new and existing facilities that engage in the manufacture of flexible polyurethane foam products which emit hazardous air pollutants (HAPs). This includes facilities making slabstock flexible polyurethane foam (slabstock foam), rebond flexible polyurethane foam (rebond foam), and/or molded flexible polyurethane foam (molded foam).

In general, all MACT standards require initial notifications, performance tests, and periodic reports. Owners or operators of flexible polyurethane foam production facilities to which this rule is applicable must choose one of the compliance options described in the standard or reduce HAP emissions to below the compliance level. Specifically, the rule requirements for slabstock foam producers include an initial notification, notification of compliance status, semiannual reports and annual compliance certifications. In addition, respondents are required to submit a pre-compliance report that describes the HAP compliance procedures, and recordkeeping procedures. Those electing to comply with the slabstock foam emission limitation using recovery devices must measure and record emissions as specified in 40 CFR 63.1297 of the rule. The rule requirements for molded and rebond foam producers include a notification of compliance status report and an annual compliance certification. These notifications, reports, and records are essential in determining compliance, and are required of all sources subject to MACT.

Any owner or 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 United States Environmental Protection Agency (EPA) regional office.

There are approximately 132 respondents, i.e., flexible polyurethane foam production facilities, currently subject to the regulation, and it is estimated that no new respondents per year will become subject to the regulation in the next three years. Since there are no changes in the regulatory requirements and we have determined that there is no significant industry growth, the labor hours and cost figures in the previous Information Collection Request (ICR) are used in this ICR renewal. Therefore, there is no change in burden to industry, the “Affected Public”. Details regarding the calculation of the industry burden can be found in Table 1. Annual Respondent Burden and Cost: NESHAP for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III), attached. In addition, the burden to the “Federal Government”, which is attributed entirely to work performed by federal employees or government contractor, will remain steady due to the same reasons explained above. Details regarding the calculation of the Federal Government burden can be found in Table 2: Annual Burden and Cost for the Federal Government: NESHAP for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III), attached.

There are no capital/startup or Operation and Maintenance (O&M) costs associated with this regulation. The continuous parameter monitoring equipment used by facilities affected by this regulation are used to maintain a high level of operational efficiency and would have been installed and maintained with or without regulation. Details on this estimate can be found in Section 6(b)(iii) of this report.

The Office of Management and Budget (OMB) approved the currently active ICR without any ATerms of Clearance.@

The 132 facilities in the United States, which are respondents to this ICR, are publicly owned and operated by flexible polyurethane foam production facilities. None of the facilities are owned by either state, local and tribal agencies or the Federal Government.

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 or 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, hazardous air pollutants (HAP) emissions from flexible polyurethane foam production facilities cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the MACT standards were promulgated for this source category at 40 CFR part 63, subpart III.

2(b) Practical Utility/Users of the Data

The control of emissions from HAP emissions from flexible polyurethane foam production facilities requires not only the installation of properly designed equipment, but also the operation and maintenance of that equipment. Emissions of HAP from flexible polyurethane foam production facilities are the result of operation of each slabstock production line, each storage vessel, equipment cleaning, or from leaking equipment (e.g., transfer pumps, connectors, valves, etc.). The subject standards are achieved by the capture of HAP emissions using vapor recovery systems or carbon adsorption systems and leak detection and repair procedures. The notifications required in the applicable regulations 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, leaks are being detected and repaired, and the regulations are being met. The semiannual reports are used for problem identification, as a check on source operation and maintenance, 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 MACT standards continue to operate the control equipment in compliance with the regulation. Adequate monitoring, recordkeeping, and reporting are necessary to ensure compliance with the applicable regulations, as required by the Clean Air Act. The information collected from recordkeeping and reporting requirements is also used for targeting inspections, and is of sufficient quality to be used as evidence in court.

3. Nonduplication, Consultations, and Other Collection Criteria

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

3(a) Nonduplication

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 their own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists.

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

An announcement of a public comment period for the renewal of this ICR was published in the Federal Register on October 6, 2006 at 71 FR 58853. No comments were received on the burden published on the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted and the Agency’s internal data sources and projections of industry growth over the next three years also considered. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the AFS (AIRS Facility Subsystem) which is operated and maintained by EPA's Office of Compliance. AFS is EPA’s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 132 respondents will be subject to the standard over the three-year period covered by this ICR.

Industry trade associations, such as the Polyurethane Foam Association, and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. The standard has been previously reviewed to determine the minimum information needed for compliance purposes.

It is our policy to carefully review any comments received since the last ICR renewal including those submitted in response to the first Federal Register notice and respond appropriately. In this case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the likelihood of detecting poor operation and maintenance of control equipment and noncompliance would decrease.

3(e) General Guidelines

None of these reporting or recordkeeping requirements violate any of the regulations established by OMB at 5 CFR part 1320, section 1320.5. These standards require affected facilities 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. Also, the retention of records for five years would allow EPA to establish the compliance history of a source and any pattern of compliance for purposes of determining the appropriate level of enforcement action. Historically, EPA has found that the most flagrant violators frequently have violations extending beyond the five years. EPA would be prevented from pursuing the worst violators due to the destruction or nonexistence of records if records were retained for less than five years.

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

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC and NAICS Codes

The respondents to the recordkeeping and reporting requirements are owners or operators of flexible polyurethane foam production facilities. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards is code 3086 which corresponds to the North American Industry Classification System (NAICS) code 326150 for Urethane and Other Foam Product (except Polystyrene) Manufacturing.

4(b) Information Requested

(i) Data Items

All data in this ICR that is recorded and/or reported is required by National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III).

A source must make the following reports:

Notification Reports	Citation
Initial notification	63.1306(a)
Application for approval of construction or reconstruction	63.1306(b)
Pre-compliance report	63.1306(c)
Notification of compliance status	63.1306(d)
Notification of special compliance requirements	63.9(d)
Change in selected emission limitation/compliance method	63.1306(f)(1)&(2)
Request for extension of compliance, adjustments to time periods, and changes in information	63.9(c), 63.9(i), 63.9(j)

Reports	Citation
Semiannual compliance reports	63.1306(e)
Annual compliance certification	63.1306(g)

A source must keep the following records:

Recordkeeping	Citation
Startups, shutdowns, malfunctions, periods where the continuous monitoring system is inoperative	63.10(b)(2)
All reports and notifications	63.10(b)
Record of applicability	63.10(a)
Slabstock sources shall maintain storage vessel records, equipment leaks record, HAP auxiliary blowing unit (ABA) records for emission point specific limitations or source-wide limitations, records of product data sheet for HAP cleaners, and if using a recovery device, the records of the recovered HAP ABA recordkeeping program, the monitoring device=s Quality Assurance (QA) data, parameter monitoring, and the HAP ABA recovered.	63.1307(a-f)
Molded/rebond foam sources shall maintain records of product data sheets for each compound other than diisocyanates used to flush the mixhead and associated piping during periods of startup or maintenance, and the product data sheets for each mold release agent used that has HAPs.	63.1307(g-h)
Records are required to be retained for five years; however, only the data of the most recent two years must be kept on-site	63.10(b)(1)

Electronic Reporting

Currently, sources are using monitoring equipment that provides parameter data in an automated way, e.g., flow rate monitoring and pump revolution per minute monitoring. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. In addition, some regulatory agencies are setting up electronic reporting systems to allow sources to report electronically which is reducing the reporting burden. However, electronic reporting systems are still not widely used by the regulatory agencies. It is estimated that approximately 10 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Slabstock foam sources shall install, calibrate, maintain, and operate Continuous Monitoring System (CMS) for flow rate or pump revolutions to continuously monitor the amount of polyol added and for HAP ABA.

Performance tests are not required by MACT, subpart III. However, sources are required to use Reference Method 18 of part 60 for HAP concentration; Method 25A of part 60 for organic compounds measurements; Method 21 of part 60 for equipment leaks; and American Society for Testing and Materials (ASTM) method D3574-91, Standard Test methods for Flexible Cellular Materials-Slab, Bonded, and Molded.

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.

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.

Transmit, or otherwise disclose the information.

Currently, sources are using monitoring equipment that provides parameter data in an automated way, e.g., flow rate monitors; however, personnel at the facility still need to evaluate the data. 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. In addition, some regulatory agencies are setting up electronic reporting systems to allow sources to report electronically which is reducing the reporting burden. However, electronic reporting systems are still not widely used by the regulatory Agencies. It is estimated that approximately 10 percent of the respondents use electronic reporting.

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

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the AIRS Facility Subsystem (AFS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properly installed and operated. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports and annual compliance certifications are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into the AFS which is operated and maintained by EPA's Office of Compliance. AFS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses the AFS 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 or operator for five years.

5(c) Small Entity Flexibility

There is a distribution of business sizes. However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these requirements the minimum needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown in Table 1: Annual Respondent Burden and Cost: NESHAP for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III).

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 under the NESHAP subpart III standards, 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 9,047 hours, which is shown in Table 1, attached. 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: $93.09 per hour for Executive, Administrative, and Managerial labor; $64.13 per hour for Technical labor, and $39.65 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2003, Table 10. Private Industry, 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.

Managerial $93.04 ($44.33 + 110%)

Technical $64.13 ($30.54 + 110%)

Clerical $39.65 ($18.88 + 110%)

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

The only costs to the regulated industry resulting from information collection activities required by the subject standards are labor costs. The capital/startup costs are one-time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitors 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)
Leak detectors	$29,786	0	$0	$5,250	0	$0

There are no total capital/startup costs for this ICR since we have assumed that no new sources will become subject to these standards and that the existing sources conducting modifications will not be purchasing new monitoring equipment. This is the total of column D in the table above.

There are no operation and maintenance costs for this ICR since sources electing to comply with the source-wide emission limit and are not using bag leak detectors and the monitoring parameter monitors were already being used in their operations prior to promulgation of this rule. This is the total of column G in the table above.

The total respondent costs have been calculated as the addition of the capital/startup costs, and the annual operation and maintenance costs. Therefore, there is no average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR.

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 emissions, and the publication and distribution of collected information.

The average annual cost to the Federal Government during the three years of the ICR is estimated to be $18,689. This cost is based on the average hourly labor rates below:

Managerial $53.22 (GS-13, Step 5, $33.26 x 1.6)

Technical $39.49 (GS-12, Step 1, $24.68 x 1.6)

Clerical $21.38 (GS-6, Step 3, $13.36 x 1.6)

These rates are from the Office of Personnel Management (OPM) 2003 General Schedule which excludes locality rates of pay. Details upon which this estimate is based appear in Table 2: Annual Burden and Cost for the Federal Government: NESHAP for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III), attached.

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

Based on our research for this ICR, approximately 132 existing respondents (i.e., 59 slabstock foam producers and 73 molded/rebond foam producers) are currently subject to the standard. It is estimated that no respondents per year will become subject to the regulation in the next three years. However, it is estimated that six existing sources will be modifying/reconstructing its operations and will have new affected facilities.

The number of respondents is calculated using the following table which addresses the three years covered by this ICR.

Number of Respondents*
Year	(A) Number of New Respondents That Submit Reports	(B) Number of Existing Respondents That Submit Reports	(C) Number of Respondents That Keep Records but Do Not Submit Reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	6	132	0	6	132
2	6	132	0	6	132
3	6	132	0	6	132
Average	6	132	0	6	132

* New respondents are defined for this calculation as sources that recently became subject to the rule and existing sources that have modified/reconstructed their facilities.

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 132.

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

Total Annual Responses
(A) Number of New Respondents *	(B) Number of Reports for New Sources	(C) Number of Existing Respondents**	(D) Number of Reports for Existing Sources	(F) Number of Respondents That Keep Records but Do Not Submit Reports	(E) Total Annual Responses E=(AxB)+(CxD)+F
6	3	59	2	0	209
		73	1

* New respondents are defined for this calculation as sources that recently became subject to the rule and existing sources that have modified/reconstructed their facilities.

** There are 59 existing slabstock foam producers and 73 existing molded/rebond foam producers which total 132 respondents.

The number of Total Annual Responses is 209. The total annual labor costs are $572,300. Details regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost: NESHAP for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III), attached.

Note that there are no total annual capital/start up and operation and maintenance (O&M) costs to the regulated entity that can be attributed to this rule. These costs are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance Costs.

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

The bottom line burden hours and cost tables for both the Agency and the respondents appear below or are attached. The annual public reporting and recordkeeping burden for this collection of information is estimated to average 43 hours per response.

6(f) Reasons for Change in Burden

There is no change in the labor hours or cost in this ICR compared to the previous ICR. This is due to two considerations. First, the regulations have not changed over the past three years and are not anticipated to change over the next three years. Secondly, the growth rate for the industry is very low, negative or non-existent, so there is no significant change in the overall burden.

Since there are no changes in the regulatory requirements and there is no significant industry growth, the labor hours and cost figures in the previous ICR are used in this ICR to estimate the industry burden, as well as the Federal Government burden estimate with one exception. The burden associated with regulators attending performance tests was deleted since it would be considered an activity which is part of the implementation of the enforcement program and therefore, cannot be attributed to this rule.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 43 hours per response. Burden means the total time, effort, or financial resources expended 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’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-2006-0751. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1927. 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-2006-0751 and OMB Control Number 2060-0357 in any correspondence.

Part B of the Supporting Statement

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

Table 1. Annual Respondent Burden and Cost:

NESHAP for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III)

Burden item	(A) Person-hours per occurrence	(B) Number of occurrences per respondent per year	(C) Person-hours per respondent per year (C=AxB)	(D) Respondent per year a	(E) Technical person-hours per year (E=CxD)	(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost,$ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Acquisition, Installation, and Utilization of Technology and Systems	N/A
4. Reporting Requirements
A. Read instructions	1	1	1	6	6	0.3	0.6	$436.50
B. Required activities:
Monitoring of emissions operations c&d
i. Slabstock sources - Metering pump calibrations	4	2	8	59	472	23.6	47.2	$34,337.76
- Storage tank measurements	1	12	12	59	708	35.4	70.8	$51,506.65
ii. Molded/rebond sources	Included in 5E
C. Create Information	Included in 4B and 5E
D. Gather Existing Information	Included in 4B and 5E
E. Write report
Initial Notification e	2	1	2	0	0	0.0	0.0	$0.00
Notification of modification/reconstructiona	2	1	2	6	12	0.6	1.2	$872.99
Precompliance Report	4	1	4	6	24	1.2	2.4	$1,745.99
Notification of compliance status: a
i. Molded/rebond foam producers	4	1	4	3	12	0.6	1.2	$872.99
ii. Slabstock foam producers	16	1	16	3	48	2.4	4.8	$3,491.98
Semiannual reports f	4	2	8	59	472	23.6	47.2	$34,337.76
Annual compliance certifications g	2	1	2	73	146	7.3	14.6	$10,621.43
Notification of special compliance requirements h	2	1	2	0	0	0.0	0.0	$0.00
Request for extension of compliance, adjustments to the time periods, and changes in information i	2	1	2	1	2	0.1	0.2	$145.50
Change in selected compliance method or emission limit j	1	1	1	1	1	0.05	0.1	$72.75
Progress report for extensions	4	2	8	1	8	0.4	0.8	$582.00
5. Recordkeeping
A. Read instructions	Included in 4A
B. Plan activities	Included in 4B
C. Implement activities	Included in 4B
D. Develop record system	40	1	40	0	0	0.0	0.0	$0.00
E. Time to enter and transmit information: records of monitoring and operations: k
i. Molded/rebond foam producers	4	1	4	73	292	14.6	29.2	$21,242.85
ii. Slabstock foam producers	8	12	96	59	5,664	283.2	566.4	$412,053.17
F. Time to train personnel	40	1	40	0	0	0.0	0.0	$0.00
G. Time for audits	N/A
Subtotal					7,867.0	393.4	786.7	$572,320.32
TOTAL LABOR BURDEN AND COST (Rounded)					9,047			$572,320

Assumptions:

^a We have assumed that are approximately 59 existing slabstock foam producers and 73 existing rebond/molded foam producers for a total of 132 existing foam producers (i.e., respondents) that are major sources and subject to the NESHAP subpart III. We have further assumed that there will be no new foam producers commencing operations over the period of this ICR. However, we have assumed that 6 existing respondents (3 slabstock foam producers and 3 molded/rebound foam producers) a year will be conducting some type of modification but they will continue to meet compliance requirements while the reconstruction/modification application is under review. Therefore, the average number of respondents per year for this ICR is estimated to be 132.

^b This ICR uses the following labor rates: $93.09 per hour for Executive, Administrative, and Managerial labor; $64.13 per hour for Technical labor, and $39.65 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2003, ATable 10. Private Industry, by occupational and industry group@. The rates are from column 1, ATotal compensation.@ These rates have been increased by 110% to account for the benefit packages available to those employed by private industry.

^c We have assumed that all slabstock foam producers are meeting the source-wide emission limit and control diisocyanate emissions monitoring, recordkeeping and reporting requirements. Molded/rebond foam producers are required to eliminate the use of HAP or HAP-based materials, cleaners or agents and only have recordkeeping and reporting requirements.

^d Sources are required to use Method 21 of Appendix A of part 63 for equipment leaks; Standard Methods for Flexible Cellular Materials for determining foam properties, ASTM D3574-91; Method 18 of part 60 for HAP concentration; and Method 25A of 40 CFR part 60 for organic compounds.

^e We have assumed that all existing sources are in compliance with the initial rule requirements.

^f Slabstock foam producers (i.e., 59 respondents) are required to submit semiannual reports.

^g All sources are required to submit compliance certifications annually. However, we have assumed that all of the existing molded foam producers sources that are major sources are collocated at slabstock foam production sites, and therefore, there won=t be an additional reporting burden due to meeting this requirement concurrently with the semiannual compliance status reports.

^h We have determined that there will be no sources submitting a special compliance report for this ICR since the compliance date for this rule has passed. Owners or operators of an affected source for which reconstruction occurs after the proposal date of the subject rule under 40 CFR part 63 and before the promulgation of such rule or before the proposal date of a relevant standard established pursuant to section of 112(f) of the Clean Air Act, is required to submit this report, as described in section 63.6(b)(3) and (4) of the General Provisions of part 63.

ⁱ This notification is required when an owner or operator request approval of an extension of a time period or postmark deadline, according to section 63.9(i) of the General Provisions under part 63.

^j We have assumed that one existing source will be changing its compliance period from monthly rolling to annual rolling or vice-versa.

^k The types of records include: storage vessel records; equipment leaks records; HAP ABA records for point-specific and source-wide limitations for both rolling annual compliance and monthly compliance alternative records; recovery devices records, and maintain proper product data sheets.

N/A = Not applicable.

Table 2. Annual Burden and Cost for the Federal Government:

NESHAP for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III)

Activity	(A) EPA person-hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person-hours per plant per year (C=AxB)		(D) Plants per year a	(E) Technical person-hours per year (E=CxD)		(F) Management person-hours per year (Ex0.05)	(G) Clerical person-hours per year (Ex0.1)	(H) Cost, $ b
Initial Notification c	2	1	2		0	0		0.0	0.0	$0.00
Notification of reconstruction/ modification	2	1	2		6	12		0.6	1.2	$531.43
Pre-compliance report	2	1	2		6	12		0.6	1.2	$531.43
Notification of special compliance requirements d	2	1	2		0	0		0.0	0.0	$0.00
Notification of compliance status	2	1	2		6	12		0.6	1.2	$531.43
Semiannual reports e	2	2	4		59	236		11.8	23.6	$10,451.50
Annual compliance certifications f	2	1	2		73	146		7.3	14.6	$6,465.76
Change in selected compliance method or emission limit g	2	1	2		1	2		0.1	0.2	$88.57
Progress report for extensions, adjustments to time periods, and changes in Information g	2	1	2		1	2		0.1	0.2	$88.57
Subtotal						422		21.1	42.0	$18,688.69
TOTAL ANNUAL COST (rounded)							485			$18,689

Table 2. Annual Burden and Cost for the Federal Government:

NESHAP for Flexible Polyurethane Foam Production (40 CFR part 63, subpart III) (continued)

Assumptions:

^a We have assumed that there are approximately 59 existing slabstock foam producers and 73 existing rebond/molded foam producers for a total of 132 respondents. We have further assumed that about 6 existing respondents a year will be conducting some type of modification at its facility and that there will be no new sources over the period of this ICR. Therefore, the average number of respondents per year is estimated to be 132. These rates are from the Office of Planning and Management (OPM) A2003 General Schedule@ which excludes locality rates of pay.

^b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $53.22 (GS-13, Step 5, $33.26 x 1.6), Technical rate of $39.49 (GS-12, Step 1, $24.68 x 1.6), and Clerical rate of $21.38 (GS-6, Step 3, $13.36 x 1.6)

^c We have assumed that all existing sources are in compliance with the initial rule requirements. In addition, we have assumed that facilities seeking to reconstruct will continue to meet compliance requirements while application is under review.

^d We have determined that there will be no sources submitting a special compliance report for this ICR since the compliance date for this rule has passed.

^e Slabstock foam producers (i.e., 59 sources) are required to submit semiannual reports.

^f All respondents (i.e., 132 foam producers) are required to submit annual compliance certifications. However, we have assumed that slabstock sources will be complying with this requirement concurrently when submitting semiannual reports. Molded foam producers would still need to meet this requirement separately.

^g We have assumed that one existing source will be changing its compliance period from monthly rolling to ann