| Table 1a: Annual Respondent Burden and Cost for Private Facilities – NESHAP for Flexible Polyurethane Foam Product (40 CFR Part 63, Subpart III) (Renewal) |
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| Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
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Note to OAQPS: Previous ICRs indicated that at least one facility is owned by the federal government. This was confirmed by reviewing the 2014 RTR facility list. The burden has been separated into into two tables to account for private labor rates for 11 facilities (mix of slabstock and molded/rebond sources), and federal labor rates for the 1 facility, which appears to be a molded/rebond source. |
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| Person Hours Per Occurrence |
Number of Occurrences Per Respondent Per Year |
Person Hours Per Respondent Per Year (C=AxB) |
Respondents Per Year a |
Technical Person-Hours Per Year (E=CxD) |
Management Person- Hours Per Year
(E x 0.05) |
Clerical Person Hours Per Year
(E x 0.10) |
Cost ($) b |
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|
|
| 1. Applications |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Labor Rates |
| 2. Survey and studies |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Management |
$172.41 |
| 3. Acquisition, Installation, and Utilization of Tech. & Systems |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Technical |
$141.75 |
| 4. Reporting Requirements |
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|
|
|
|
|
|
|
|
Clerical |
$71.36 |
| A. Familiarization with instructions |
1 |
1 |
1 |
11 |
11 |
0.55 |
1.1 |
$1,732.57 |
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| B. Required Activities |
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| Monitoring of Emissions Operations, Slabstock Facilities - Storage Tank Measurements c |
1 |
12 |
12 |
6 |
72 |
3.6 |
7.2 |
$11,340.47 |
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| C. Create Information |
Included in 4B and 5E |
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| D. Gather Existing Information |
Included in 4B and 5E |
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| E. Write Report |
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| Initial notification d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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|
|
| Notification of modification/reconstruction d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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|
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| Notification of Special Compliance Requirements e |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
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|
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| Pre-compliance Report d |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
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|
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| Notification of Compliance Status d |
16 |
1 |
16 |
0 |
0 |
0 |
0 |
$0 |
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|
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| Semiannual Reports f |
4 |
2 |
8 |
6 |
48 |
2.4 |
4.8 |
$7,560.31 |
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| Annual Compliance Certifications g |
2 |
1 |
2 |
11 |
22 |
1.1 |
2.2 |
$3,465.14 |
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| Subtotal for Reporting Requirements |
34 |
21 |
49 |
|
176 |
$24,098 |
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| 5. Recordkeeping Requirements |
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| A. Familiarization with instructions |
Included in 4A |
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| B. Plan activities |
Included in 4B |
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| C. Implement activities |
Included in 4B |
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| D. Develop record system |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| E. Time to enter information: records of monitoring and operations a |
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| Slabstock producers |
8 |
12 |
96 |
6 |
576 |
28.8 |
57.6 |
$90,723.74 |
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| Molded/rebond facilities |
4 |
1 |
4 |
5 |
20 |
1 |
2 |
$3,150.13 |
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| F. Train personnel |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| G. Audits |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
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| Subtotal for Recordkeeping Requirements |
92 |
15 |
180 |
|
685 |
$93,874 |
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| TOTAL LABOR BURDEN AND COSTS (rounded) h |
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|
861 |
$118,000 |
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| TOTAL CAPITAL AND O&M COST (rounded) h |
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|
|
$0 |
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| GRAND TOTAL (rounded) h |
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|
|
$118,000 |
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| Assumptions: |
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| a We have assumed that there are approximately 6 existing slabstock foam producers and 6 existing molded/rebond foam producers for a total of 12 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. Therefore, the average number of respondents per year for this ICR is estimated to be 12 and 11 of these facilities are private sector facilities. |
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| b This ICR uses the following labor rates: Managerial $172.41 ($82.10+ 110%); Technical $141.75 ($67.50 + 110%); and Clerical $71.36 ($33.98 + 110%). These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2023, “Table 2. Civilian workers by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates are increased by 110 percent to account for varying industry wage rates and the additional overhead business costs of employing workers beyond their wages and benefits, including business expenses associated with hiring, training, and equipping their employees. |
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| c Molded/rebond foam producers only have recordkeeping and reporting requirements. |
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| d We have assumed that all existing sources are in compliance with the initial rule requirements and no reconstructions will occur during this ICR renewal period. |
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| e 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. |
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| f Only slabstock foam producers are required to submit semiannual reports. |
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| g All respondents are required to submit annual compliance certifications. |
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| h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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| Table 1b: Annual Respondent Burden and Cost for Federal Facilities – NESHAP for Flexible Polyurethane Foam Product (40 CFR Part 63, Subpart III) (Renewal) |
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|
|
|
|
|
|
|
|
|
Note to OAQPS: Previous ICRs indicated that at least one facility is owned by the federal government. This was confirmed by reviewing the 2014 RTR facility list. The burden has been separated into into two tables to account for private labor rates for 11 facilities (mix of slabstock and molded/rebond sources), and federal labor rates for the 1 facility, which appears to be a molded/rebond source. |
|
| Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
|
Labor Rates |
| Person Hours Per Occurrence |
Number of Occurrences Per Respondent Per Year |
Person Hours Per Respondent Per Year (C=AxB) |
Respondents Per Year a |
Technical Person-Hours Per Year (E=CxD) |
Management Person Hours Per Year
(E x 0.05) |
Clerical Person Hours Per Year
(E x 0.10) |
Cost ($) b |
|
Management |
$76.91 |
| 1. Applications |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Technical |
$57.07 |
| 2. Survey and studies |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Clerical |
$30.88 |
| 3. Acquisition, Installation, and Utilization of Tech. & Systems |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
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| 4. Reporting Requirements |
|
|
|
|
|
|
|
|
|
|
|
| A. Familiarization with instructions |
1 |
1 |
1 |
1 |
1 |
0.05 |
0.1 |
$64.00 |
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|
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| B. Required Activities |
|
|
|
|
|
|
|
|
|
|
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| Monitoring of Emissions Operations, Slabstock Facilities - Storage Tank Measurements c |
1 |
12 |
12 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| C. Create Information |
Included in 4B and 5E |
|
|
|
|
|
|
|
|
|
| D. Gather Existing Information |
Included in 4B and 5E |
|
|
|
|
|
|
|
|
|
| E. Write Report |
|
|
|
|
|
|
|
|
|
|
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| Initial notification d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Notification of modification/reconstruction d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Notification of Special Compliance Requirements e |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Pre-compliance Report d |
4 |
1 |
4 |
0 |
0 |
0 |
0 |
$0 |
|
|
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| Notification of Compliance Status d |
16 |
1 |
16 |
0 |
0 |
0 |
0 |
$0 |
|
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| Semiannual Reports f |
4 |
2 |
8 |
0 |
0 |
0 |
0 |
$0 |
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| Annual Compliance Certifications g |
2 |
1 |
2 |
1 |
2 |
0.1 |
0.2 |
$128.01 |
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| Subtotal for Reporting Requirements |
34 |
21 |
49 |
|
3 |
$192 |
|
|
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| 5. Recordkeeping Requirements |
|
|
|
|
|
|
|
|
|
|
|
| A. Familiarization with instructions |
Included in 4A |
|
|
|
|
|
|
|
|
|
| B. Plan activities |
Included in 4B |
|
|
|
|
|
|
|
|
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| C. Implement activities |
Included in 4B |
|
|
|
|
|
|
|
|
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| D. Develop record system |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
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| E. Time to enter information: records of monitoring and operations a |
|
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|
|
|
|
|
|
|
|
|
| Slabstock producers |
8 |
12 |
96 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Molded/rebond facilities |
4 |
1 |
4 |
1 |
4 |
0.2 |
0.4 |
$256.01 |
|
|
|
| F. Train personnel |
40 |
1 |
40 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| G. Audits |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
|
|
| Subtotal for Recordkeeping Requirements |
92 |
15 |
180 |
|
5 |
$256 |
|
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| TOTAL LABOR BURDEN and COSTS (rounded) h |
|
|
|
|
8 |
$448 |
|
|
|
| TOTAL CAPITAL AND O&M COST (rounded) h |
|
|
|
|
|
$0 |
|
|
|
| GRAND TOTAL (rounded) h |
|
|
|
|
|
$448 |
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|
|
|
|
|
|
|
|
|
|
|
|
|
| Assumptions: |
|
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|
|
|
|
|
|
|
|
|
| a We have assumed that there are approximately 6 existing slabstock foam producers and 6 existing molded/rebond foam producers for a total of 12 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. Therefore, the average number of respondents per year for this ICR is estimated to be 12 and 1 of these facilities is a federal government facility. This federal facility is assumed to be a molded/rebond source. |
|
|
|
| b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 General Schedule, which excludes locality, rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. |
|
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| c Molded/rebond foam producers only have recordkeeping and reporting requirements. |
|
|
|
| d We have assumed that all existing sources are in compliance with the initial rule requirements. |
|
|
|
| e We have determined that there will be no sources submitting a special compliance report for this ICR since the compliance date for this rule has passed. |
|
|
|
| f Only slabstock foam producers are required to submit semiannual reports. |
|
|
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| g All respondents are required to submit annual compliance certifications. |
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| h Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
|
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| Table 2: Average Annual EPA Burden and Cost – NESHAP for Flexible Polyurethane Foam Product (40 CFR Part 63, Subpart III) (Renewal) |
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| |
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| Burden Item |
A |
B |
C |
D |
E |
F |
G |
H |
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|
| EPA Hours per Occurrence |
Number of Occurrences Per Year |
EPA Person Hours Per Year
(A x B) |
Plants Per Year a |
Technical Hours Per Year
(C x D) |
Management Hours Per Year
(E x 0.05) |
Clerical Hours Per Year
(E x 0.10) |
Cost ($) b |
|
|
|
| Initial Notification c |
2 |
0 |
0 |
0 |
0 |
0 |
0 |
$0 |
|
Labor Rates |
| Notification of Reconstruction/Modification c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
Management |
$76.91 |
| Pre-compliance Report c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
Technical |
$57.07 |
| Notification of Special Compliance Requirements d |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
Clerical |
$30.88 |
| Notification of Compliance Status c |
2 |
1 |
2 |
0 |
0 |
0 |
0 |
$0 |
|
|
|
| Semiannual Reports e |
2 |
2 |
4 |
6 |
24 |
1.2 |
2.4 |
$1,536.08 |
|
|
|
| Annual Compliance Certifications f |
2 |
1 |
2 |
12 |
24 |
1.2 |
2.4 |
$1,536.08 |
|
|
|
| TOTAL (rounded) g |
|
|
|
|
55 |
$3,070 |
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|
|
|
|
|
|
|
|
|
| Assumptions: |
|
|
|
|
|
|
|
|
|
|
|
| a We have assumed that there are approximately 6 existing slabstock foam producers and 6 existing molded/rebond foam producers for a total of 12 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. Therefore, the average number of respondents per year for this ICR is estimated to be 12. |
|
|
|
| b This cost is based on the average hourly labor rate as follows: Managerial $76.91 (GS-13, Step 5, $48.07 + 60%); Technical $57.07 (GS-12, Step 1, $35.67 + 60%); and Clerical $30.88 (GS-6, Step 3, $19.30+ 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. These rates are from the Office of Personnel Management (OPM), 2024 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 We have assumed that all existing sources are in compliance with the initial rule requirements. |
|
|
|
| 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 Only slabstock foam producers are required to submit semiannual reports. |
|
|
|
| f All respondents are required to submit annual compliance certifications. |
|
|
|
| g Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. |
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|