OMB files this comment in accordance with 5 CFR 1320.11( c ). This OMB action is not
an approval to conduct or sponsor an information collection under the Paperwork Reduction Act of 1995. This action has no effect on any current approvals. If OMB has assigned this ICR a new OMB Control Number, the OMB Control Number will not appear in the active inventory. For future submissions of this information collection, reference the OMB Control Number provided. OMB is withholding approval at this time. Prior to publication of the final rule, the agency should provide a summary of any comments related to the information collection and their response, including any changes made to the ICR as a result of comments. In addition, the agency must enter the correct burden estimates. This action has no effect on any current approvals.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
10/31/2016
36 Months From Approved
01/31/2017
76
0
76
22,370
0
22,370
14,800
0
14,800
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 proposed 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 collected to assure compliance with 40 CFR part 63, subpart OOO. Organic HAP emissions are the pollutants regulated under this subpart.
The proposed rulemaking would amend 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 device 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 related to these new provisions is required to be submitted in the semi-annual 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 caused 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 for 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 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 will 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. The average annual burden from the recordkeeping and reporting requirements is 18,991 person hours, with an annual average cost of $1,062,090 and an annualized capital and operations and maintenance cost of $424,612.
The proposed rulemaking would amend 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 device 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 related to these new provisions is required to be submitted in the semi-annual 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 caused 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 for 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.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
P&RIII Supporting Statement 121213.docx
NESHAP for the Manufacture of Amino/Phenolic Resins