INFORMATION
COLLECTION
REQUEST
FOR
PROPOSED
AMENDMENTS
TO
THE
PART
63
GENERAL
PROVISIONS:

POLLUTION
PREVENTION
ALTERNATIVES
SUPPORTING
STATEMENT
March
14,
2003
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Emission
Standards
Division
Research
Triangle
Park,
NC
27709
i
CONTENTS
1.
Identification
of
the
Information
Collection
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1
1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Short
Characterization/
Abstract
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1
2.
Need
for
and
Use
of
the
Collection
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2
2(
a)
Need/
Authority
for
the
Collection
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2
2(
b)
Use/
Users
of
the
Data
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2
3.
Non­
duplication,
Consultations,
and
other
Collection
Criteria
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2
3(
a)
Non­
duplication
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2
3(
b)
Public
Notice
required
prior
to
ICR
submission
to
OMB
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2
3(
c)
Consultations
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3
3(
d)
Effects
of
Less
Frequent
Collection
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3
3(
e)
General
Guidelines
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3
3(
f)
Confidentiality
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3
3(
g)
Sensitive
Questions
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3
4.
The
Respondents
and
the
Information
Requested
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3
4(
a)
Industry
Respondents/
SIC
Codes
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3
4(
b)
Information
Requested
from
Industry
Respondents
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6
(
i)
Data
items,
including
record
keeping
requirements
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6
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ii)
Industry
Respondent
Activities
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7
4(
c)
State/
Local
Agencies
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7
ii
CONTENTS
4(
d)
Information
Requested
from
State/
Local
Agencies
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7
(
i)
Data
items,
including
record
keeping
requirements
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7
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ii)
State/
Local
Agency
Activities
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7
5.
The
Information
Collected
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Agency
Activities,
Collection
Methodology,
and
Information
Management
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7
5(
a)
Agency
Activities
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7
5(
b)
Collection
Methodology
and
Management
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7
5(
c)
Small
Entity
Flexibility
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7
5(
d)
Collection
Schedule
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8
6.
Estimating
the
Burden
and
Cost
of
the
Collection
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8
6(
a)
Estimating
Respondent
Burden
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8
6(
b)
Estimating
Respondent
Costs
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8
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i)
Estimating
Labor
Costs
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8
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
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8
6(
c)
Estimating
State/
Local
Agency
Burden
and
Cost
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9
6(
d)
Estimating
Agency
Burden
and
Cost
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9
6(
e)
Estimating
the
Respondent
Universe
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10
6(
f)
Bottom
Line
Burden
Hours
and
Cost
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10
(
i)
Respondent
Tally
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10
(
ii)
EPA/
State/
Local
Tally
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10
(
iii)
Variations
in
the
Annual
Bottom
Line
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10
6(
g)
Reasons
for
Change
in
Burden
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11
6(
h)
Burden
Statement
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11
iii
TABLES
Table
1.1
Potential
Industry
Respondents
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4
Table
6.1
Annual
Respondent
Burden
and
Cost
(
Industry)
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12
Table
6.2
Annual
Respondent
Burden
and
Cost
(
EPA/
State/
Local
Agencies)
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13
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
­
Implementation
of
Pollution
Prevention
Alternatives
in
the
40
CFR
63
General
Provisions.
The
is
a
new
ICR
and
the
ICR
number
is
2099.01.

1(
b)
Short
Characterization/
Abstract
­
Respondents
are
owners
or
operators
of
facilities
subject
to
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
promulgated
under
section
112(
d)
of
the
Clean
Air
Act
that
voluntarily
choose
to
comply
with
pollution
prevention
alternatives
proposed
for
the
Part
63
General
Provisions.
Consistent
with
EPA's
policy
of
promoting
pollution
prevention,
the
proposed
amendments
would
revise
the
Part
63
General
Provisions
to
provide
regulatory
relief,
where
appropriate,
to
facilities
that
use
pollution
prevention
to
achieve
and
maintain
reductions
of
hazardous
air
pollutants
(
HAP)
equivalent
to
or
better
than
the
level
of
control
required
under
an
applicable
NESHAP.

Facilities
subject
to
a
NESHAP
that
implement
pollution
prevention
to
reduce
air
toxics
emissions
at
least
to
the
level
of
MACT
may
apply
for
alternative
compliance
requirements.
Such
facilities
have
two
options
under
the
proposed
amendments:

Option
1:
Facilities
that
implement
pollution
prevention
to
eliminate
all
air
toxics
emissions
subject
to
the
regulation
could
apply
to
no
longer
be
subject
to
that
regulation.

Option
2:
Facilities
that
implement
pollution
prevention
to
reduce
air
toxics
emissions
to
at
least
the
level
required
by
the
regulation
could
apply
for
pollution
prevention
alternative
requirements.
Alternative
compliance
requirements
could
include
monitoring,
recordkeeping,
reporting,
and/
or
other
requirements
consistent
with
the
pollution
prevention
measures
implemented
by
the
facility.
They
could
not
include
alternative
emission
limits.

Under
either
option,
if
the
facility
failed
to
maintain
the
approved
pollution
prevention
measures,
the
NESHAP
would
apply
immediately.

To
qualify
for
Option1,
an
owner
or
operator
must
first
submit
a
written
request
that
includes
all
information
necessary
to
show
that
the
applicable
rule
should
no
longer
apply,
including
at
a
minimum
a
statement
identifying
the
rule
and
the
operations
subject
to
it,
a
description
and
demonstration
of
the
pollution
prevention
measures
and
that
all
HAP
emissions
have
been
eliminated,
a
certification
that
the
source
will
not
resume
emitting
HAP
unless
a
30­
day
prior
notification
is
given,
and
a
certification
that
the
NESHAP
will
again
apply
on
the
date
that
HAP
emissions
resume.
The
owner
or
operator
may
submit
additional
information
if
the
original
request
is
not
approved
or
is
deemed
to
be
insufficient.
2
To
apply
for
Option
2,
an
owner
or
operator
must
submit
a
written
request
documenting
compliance
status
and
demonstrating
that
the
pollution
prevention
alternative
is
justified.
The
minimum
information
requirements
include
identifying
sources
of
emissions
subject
to
the
applicable
rule,
sources
of
emissions
for
which
pollution
prevention
has
been
applied,
a
description
of
the
pollution
prevention
techniques,
a
demonstration
that
the
techniques
reduce
emission
to
the
level
(
or
below)
required
by
the
rule,
procedures
for
monitoring
and
demonstrating
continuous
compliance,
citations
in
the
rule
of
the
requirements
to
be
replaced,
and
certifications
that
ensure
the
source
will
remain
in
compliance.
The
owner
or
operator
may
submit
additional
information
if
the
original
request
is
not
approved
or
is
deemed
to
be
insufficient.

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
NESHAP
for
new
or
existing
major
sources
or
area
sources
that
reflect:

...
the
maximum
degree
of
reduction
in
emissions
of
[
HAPs]
that
is
achievable
taking
into
consideration
the
cost
of
achieving
the
emission
reduction,
any
nonair
quality
health
and
environmental
reduction,
and
energy
requirements.
[
section
112(
d)(
2)]

This
level
of
control
is
commonly
referred
to
as
the
maximum
achievable
control
technology
(
MACT).
Certain
records
and
reports
are
necessary
for
the
Administrator
to:
(
1)
confirm
the
compliance
status
of
major
sources,
identify
any
non­
major
sources
not
subject
to
the
standards,
and
identify
new
or
reconstructed
sources
subject
to
the
standards;
and
(
2)
ensure
that
the
MACT
standards
are
being
achieved.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
section
114
of
the
Act
(
42
U.
S.
C.
7414)
and
set
out
in
the
NESHAP
General
Provisions.

2(
b)
Use/
Users
of
the
Data
­
The
facility's
notifications
and
reports
to
the
Agency
will
be
used
by
EPA
and
participating
regulatory
entities
to
monitor
a
facility's
compliance
with
the
pollution
prevention
alternative(
s)
and
to
determine
whether
the
facility
continues
to
be
eligible
for
alternative(
s).

3.
Non­
duplication,
Consultations,
and
other
Collection
Criteria
3(
a)
Non­
duplication
­
The
information
to
be
obtained
under
this
ICR
has
not
been
collected
by
EPA
or
any
other
state
or
local
agency.

3(
b)
Public
Notice
required
prior
to
ICR
submission
to
OMB
­
The
proposed
rule
will
be
published
in
the
Federal
Register
prior
to
submitting
the
ICR
to
OMB
for
review.
The
proposal
preamble
addresses
Paperwork
Reduction
Act
requirements.
3
3(
c)
Consultations
­
State
and
local
agencies
have
urged
EPA
to
do
more
to
encourage
pollution
prevention
in
the
MACT
standards
program.
As
a
result,
EPA
has
partnered
with
states
and
local
agency
air
pollution
control
representatives
to
develop
alternatives
within
the
program
that
would
be
incentives
for
using
pollution
prevention
techniques.
A
series
of
meetings
was
conducted
to
discuss
these
proposed
amendments
and
to
develop
acceptable
details
for
implementation.
These
proposed
pollution
prevention
alternatives
are
a
result
of
consultations
with
state
and
local
agencies
as
well
as
industry
stakeholders.

3(
d)
Effects
of
Less
Frequent
Collection
­
The
proposed
rule
provides
voluntary
options
that
reduce
the
reporting
burden
for
affected
respondents
that
qualify
for
the
pollution
prevention
alternatives.
Consequently,
the
net
effect
of
this
proposal
will
be
less
frequent
collection
than
is
currently
required.
The
information
requested
by
the
proposed
rule
is
important
to
determine
whether
participants
continue
to
be
eligible
for
the
incentive.
If
the
information
were
collected
less
frequently,
EPA
would
not
be
reasonably
assured
that
the
plant
is
in
compliance.

3(
e)
General
Guidelines
­
This
information
collection
adheres
to
the
general
guidelines
set
forth
by
the
Office
of
Management
and
Budget.

3(
f)
Confidentiality
­
All
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
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
28,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
­
The
reporting
requirements
addressed
in
this
information
request
do
not
include
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Industry
Respondents/
SIC
Codes
­
Potential
respondents
include
all
entities
regulated
by
EPA
pursuant
to
its
authority
under
section
112(
d)
of
the
Clean
Air
Act.
The
respondents
represent
numerous
SIC
codes
and
source
categories.
Table
1.1
lists
the
various
source
categories
that
may
qualify
for
pollution
prevention
alternatives
and
the
number
of
affected
sources
in
each
category.
These
facilities
are
subject
to
NESHAP
promulgated
as
of
October
1,
2002.
Only
a
fraction
of
the
affected
facilities
are
expected
to
qualify.
The
categories
are
grouped
according
to
their
estimated
potential
to
implement
the
pollution
prevention
options.

Group
1
includes
source
categories
such
as
surface
coatings
that
have
the
best
opportunities
to
eliminate
HAP
emissions
by
HAP
substitution.
Group
2
represents
source
categories
that
have
moderate
opportunities
for
HAP
substitution
or
new
process
technology
to
eliminate
HAP
emissions.
Group
3
is
for
source
categories
that
have
no
chance
of
completely
eliminating
HAP
emissions
because
the
HAP
is
an
integral
or
unavoidable
part
of
the
processing;
however,
they
Table
1.1
Potential
Industry
Respondents
4
Group
1
Sources:
Most
Potential
for
Pollution
Prevention
Alternatives
Source
Category
Subpart
Compliance
Date
Number
of
Affected
Sources
Aerospace
Industry
GG
9/
1/
1998
2,800
Large
Appliance
Surface
Coating
NNNN
7/
23/
2005
70
Magnetic
Tape
EE
12/
15/
1996
14
Metal
Coil
Surface
Coating
SSSS
6/
10/
2005
90
Printing/
Publishing
KK
5/
30/
1999
200
Shipbuilding
and
Ship
Repair
II
12/
16/
1996
35
Wood
Furniture
JJ
11/
21/
1997
750
Total
3,959
Group
2
Sources:
Moderate
Potential
for
Pollution
Prevention
Alternatives
Source
Category
Subpart
Compliance
Date
Number
of
Affected
Sources
Boat
Manufacturing
VVVV
8/
22/
2004
119
Commercial
Sterilizers
O
12/
6/
1998
114
Flexible
Polyurethane
Foam
Production
III
10/
8/
2001
176
Leather
Finishing
TTTT
2/
27/
2005
16
Pesticide
Active
Ingredient
Production
MMM
6/
30/
2002
28
Pharmaceuticals
Production
GGG
9/
21/
2001
100
Tire
Manufacturing
XXXX
7/
11/
2005
31
Solvent
Extraction
for
Vegetable
Oil
Production
GGGG
4/
12/
2004
106
Total
690
Group
3
Sources:
Low
Potential
for
Pollution
Prevention
Alternatives
Source
Category
Subpart
Compliance
Date
Number
of
Affected
Sources
Cellulose
Production
Manufacturing
UUUU
6/
11/
2005
13
Coke
Ovens:
Doors,
Lids,
Offtakes,
and
Charging
L
11/
15/
1993
19
Combustion
Sources
at
Kraft,
Soda,
and
Sulfite
Pulp
and
Paper
Mills
(
MACT
II)
MM
1/
12/
2004
136
Ferroalloys
Production
XXX
5/
20/
2001
1
Gasoline
Distribution
(
Stage
1)
R
12/
15/
1997
100
Generic
MACT
YY
6/
29/
2002
84
Hazardous
Organic
NESHAP
F,
G,
H,
I
5/
14/
2001
370
Hazardous
Waste
Combustion
EEE
9/
30/
2002
172
Industrial
Cooling
Towers
Q
3/
8/
1995
400
Manufacturing
Nutritional
Yeast
CCCC
5/
21/
2004
10
Marine
Vessel
Loading
Operations
Y
9/
19/
1999
30
Mineral
Wool
Production
DDD
6/
1/
2002
14
Natural
Gas
Transmission
and
Storage
HHH
6/
17/
2002
5
Off­
Site
Waste
Recovery
Operations
DD
2/
1/
2000
250
Oil
and
Natural
Gas
Production
HH
6/
17/
2002
440
Petroleum
Refineries
(
MACT
1)
CC
8/
18/
1998
192
Petroleum
Refineries:
Catalytic
Cracking,
Catalytic
Reforming,
and
Sulfur
Plant
Units
UUU
4/
11/
2005
129
Table
1.1
Potential
Industry
Respondents
Group
3
Sources:
Low
Potential
for
Pollution
Prevention
Alternatives
Source
Category
Subpart
Compliance
Date
Number
of
Affected
Sources
5
Phosphate
Fertilizers
BB
6/
10/
2002
29
Phosphoric
Acid
AA
6/
10/
2002
31
Polyether
Polyols
Production
PPP
6/
1/
2002
80
Polymers
and
Resins
I
U
7/
31/
1997
36
Polymers
and
Resins
II
W
3/
3/
1998
20
Polymers
and
Resins
III
OOO
1/
20/
2003
40
Polymers
and
Resins
IV
JJJ
7/
31/
1997
66
Polyvinyl
Chloride
and
Copolymers
Production
J
7/
10/
2005
28
Portland
Cement
Manufacturing
LLL
6/
10/
2002
180
Primary
Aluminum
Production
LL
10/
7/
1999
23
Primary
Copper
QQQ
6/
12/
2005
4
Primary
Lead
Smelting
TTT
5/
4/
2001
3
Publicly
Owned
Treatment
Works
(
POTW)
VVV
10/
26/
2002
new
only
Pulp
and
Paper
(
non­
chemical)
MACT
III
S
4/
16/
2001
155
Pulp
and
Paper
(
non­
combustion)
MACT
I
S
4/
15/
2001
155
Secondary
Lead
Smelters
X
6/
23/
1997
23
Steel
Pickling­
HCl
Process
CCC
6/
22/
2001
64
Tetrahydrobenzaldehyde
Manufacture
F
5/
12/
2001
2
Wet
Formed
Fiberglass
Mat
Production
HHHH
4/
11/
2005
14
Wool
Fiberglass
Manufacturing
NNN
6/
14/
2002
21
Total
3,339
Group
4
Sources:
Very
Low
Potential
for
Burden
Reduction
Source
Category
Subpart
Compliance
Date
Number
of
Affected
Sources
Chromium
Electroplating
N
1/
25/
1996
5,020
Degreasing
Organic
Cleaners
(
Halogenated
Solvent
Cleaning)
T
12/
2/
1997
24,500
Dry
Cleaning
M
9/
23/
1996
3,600
Secondary
Aluminum
RRR
3/
24/
2003
2,050
Total
35,170
Group
5
Sources:
Proposed
Rules
with
Future
Potential
for
Pollution
Prevention
Alternatives
Source
Category
Subpart
Proposal
Date
Number
of
Affected
Facilities
Asphalt
Roofing
and
Processing
LLLLL
11/
21/
2001
9
Brick
and
Structural
Clay
Products
Manufacturing
JJJJJ
7/
22/
2002
169
Clay
Ceramics
Manufacturing
KKKKK
7/
22/
2002
8
Coke
Ovens:
Pushing,
Quenching,
and
Battery
Stacks
CCCCC
7/
3/
2001
19
Table
1.1
Potential
Industry
Respondents
Group
5
Sources:
Proposed
Rules
with
Future
Potential
for
Pollution
Prevention
Alternatives
Source
Category
Subpart
Proposal
Date
Number
of
Affected
Facilities
6
Engine
Test
Cells/
Stands
PPPPP
5/
14/
2002
new
only
Fabric
Printing,
Coating
and
Dyeing
OOOO
7/
11/
2002
135
Flexible
Polyurethane
Foam
MMMMM
8/
8/
2001
48
Friction
Products
Manufacturing
QQQQQ
10/
4/
2001
4
Hydrochloric
Acid
Production
NNNNN
9/
18/
2001
32
Integrated
Iron
and
Steel
FFFFF
7/
13/
2001
18
Mercury
Cell
Chlor­
Alkali
Plants
IIIII
7/
3/
2002
11
Metal
Furniture
(
Surface
Coating)
RRRR
4/
24/
2002
655
Miscellaneous
Metal
Parts
and
Products
(
Surface
Coating)
MMMM
8/
13/
2002
1,500
Miscellaneous
Organic
Chemical
Production
and
Processes
FFFF
4/
4/
2002
251
Municipal
Solid
Waste
Landfills
AAAA
11/
7/
2000
1,309
Organic
Liquids
Distribution
(
non­
gasoline)
EEEE
4/
2/
2002
650
Paper
and
Other
Web
(
Surface
Coating)
JJJJ
9/
13/
2000
200
Refractory
Products
Manufacturing
SSSSS
6/
20/
2002
8
Reinforced
Plastic
Composites
Production
WWWW
8/
2/
2001
433
Semiconductor
Manufacturing
BBBBB
5/
8/
2002
1
Site
Remediation
GGGGG
7/
30/
2002
250
Wood
Building
Products
QQQQ
6/
21/
2002
205
Total
5,915
have
some
opportunities
for
pollution
prevention
alternatives
under
Option
2.
Group
4
source
categories
have
few
opportunities
for
burden
reduction
and
thus
are
not
likely
to
benefit
much
by
pollution
prevention
alternatives.
These
are
mostly
area
sources
and/
or
small
businesses
that
are
subject
to
the
least
burdensome
of
the
MACT
monitoring,
reporting,
and
recordkeeping
requirements.
For
example,
the
average
annual
burden
for
dry
cleaning
is
only
49
hrs/
yr
per
respondent
(
3,600
sources)
and
42
hr/
yr
for
degreasing
operations
using
halogenated
solvents
(
24,500
sources).
Group
5
is
for
proposed
MACT
rules
that
may
have
opportunities
for
pollution
prevention
opportunities
in
the
future.
However,
they
would
not
have
the
opportunities
within
the
3­
year
period
of
this
ICR.

4(
b)
Information
Requested
from
Industry
Respondents
(
i)
Data
items,
including
record
keeping
requirements
­
Respondents
that
are
eligible
for
the
pollution
prevention
alternatives
will
need
to
comply
with
the
requirements
in
the
proposed
rule.
For
the
pollution
prevention
alternative,
respondents
must
maintain
records
7
documenting
conformance
with
the
approved
alternative
requirements
for
monitoring
and
demonstrating
continuous
compliance.

(
ii)
Industry
Respondent
Activities
­
To
qualify
for
a
pollution
prevention
alternative,
the
owner
or
operator
must
submit
a
written
request
and
provide
enough
information
to
document
that
the
source
qualifies
for
the
pollution
prevention
exemption
or
for
the
pollution
prevention
alternative.
The
owner
or
operator
may
submit
additional
information
if
the
original
request
is
not
approved
or
is
found
to
be
insufficient.
Other
reports
that
will
be
made
must
be
proposed
by
the
owner
or
operator
and
approved
by
EPA
on
a
case­
by­
case
basis.
Similarly,
alternatives
for
monitoring
and
demonstrating
continuous
compliance
will
be
made
on
a
case­
bycase
basis
and
must
be
appropriate
for
the
pollution
prevention
techniques
that
are
used.
The
respondent
activities
and
associated
burden
are
identified
in
Table
2
and
introduced
in
section
6(
a).

4(
c)
State/
Local
Agencies
include
all
State
and
local
agencies
with
delegated
authority
to
administer
and
enforce
MACT
standards.

4(
d)
Information
Requested
from
State/
Local
Agencies
(
i)
Data
items,
including
record
keeping
requirements
­
To
implement
the
alternatives
contained
in
this
proposed
rulemaking,
certain
State
and
local
agencies
will
need
to
maintain
records
of
alternative
compliance
results.
However,
this
is
expected
to
be
a
reduction
in
the
recordkeeping
burden
because
the
alternatives
will
replace
more
frequent
compliance
reporting
that
is
currently
required.

(
ii)
State/
Local
Agency
Activities
­
Delegated
State
and
local
agencies
will
need
to
review
written
requests
for
the
pollution
prevention
alternatives
and
issue
a
notice
of
approval
or
disapproval.

5.
The
Information
Collected
­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
­
EPA
will
need
to
continue
to
provide
oversight
of
its
delegated
programs.
The
Agency
does
not
anticipate
any
significant
increase
in
its
administrative
duties
to
implement
these
pollution
prevention
alternatives.

5(
b)
Collection
Methodology
and
Management
­
Required
documents
and
reports
submitted
to
implement
the
pollution
prevention
alternatives
will
be
sent
to
the
delegated
agency.
To
the
extent
practicable,
the
delegated
agency
will
utilize
electronic
submissions
of
reporting
requirements.

5(
c)
Small
Entity
Flexibility
­
This
program
is
voluntary
and
all
participants
are
expected
to
have
reduced
burdens
associated
with
monitoring,
reporting,
and
recordkeeping.
8
This
opportunity
for
burden
reduction
is
available
for
all
small
businesses
subject
to
a
NESHAP
promulgated
under
section
112(
d)
of
the
Clean
Air
Act.

5(
d)
Collection
Schedule
­
The
proposed
rule
allows
the
owner
or
operator
to
propose
a
collection
schedule,
which
must
be
approved
by
the
delegated
authority.
In
almost
all
cases,
the
collection
schedule
is
expected
to
be
equal
to
or
less
frequent
than
what
would
otherwise
have
been
required
by
the
applicable
NESHAP.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
This
section
presents
EPA's
estimates
of
the
respondent's
burden
hours
and
cost
to
complete
the
activities
associated
with
this
information
collection.
In
using
this
analysis,
it
should
be
noted
again
that
all
responses
to
this
information
collection
are
voluntary.
There
are
expected
benefits
to
those
who
choose
to
participate
in
the
pollution
prevention
alternative
requirements.
EPA
does
not
expect
a
response
from
a
facility
where
the
burdens
associated
with
preparing
the
response
outweigh
the
expected
benefits
to
the
facility.

In
addition
to
industry
respondents,
this
section
presents
EPA's
estimates
of
the
State/
local
agency
and
EPA
burden
hours
and
costs
to
implement
the
alternatives
associated
with
this
proposed
rulemaking.
Some
State
and
local
regulatory
authorities
may
need
to
spend
time
reviewing
requests
and
issuing
approvals
or
disapprovals.
Finally,
these
rulemaking
changes
will
result
in
a
small
increased
administrative
cost
for
EPA.

6(
a)
Estimating
Industry
Respondent
Burden
­
This
ICR
requires
the
calculation
of
the
amount
of
burden
hours
associated
with
each
activity
for
each
respondent.
For
those
facilities
that
qualify
for
the
pollution
prevention
alternatives,
there
will
be
a
reduction
in
the
burden
associated
with
monitoring,
reporting,
and
recordkeeping.

6(
b)
Estimating
Industry
Respondent
Costs
(
i)
Estimating
Labor
Costs
­
In
this
ICR,
EPA
has
used
a
graded
approach
in
calculating
cost
as
recommended
in
the
ICR
handbook.
Wage
rates
for
industry
respondents
were
retrieved
from
the
Bureau
of
Labor
Statistics.
(
http://
www.
bls.
gov/
news.
release/
ecec.
t12.
htm;
updated
June
2002.)
The
hourly
rates
are
listed
as
follows:
$
49.66
for
management
labor,
$
38.96
for
technical
labor,
and
$
21.14
for
clerical
labor.
These
labor
rates
were
multiplied
by
1.5
to
account
for
overhead
costs.
Therefore,
we
estimated
the
hourly
cost
of
labor
for
industry
respondents
to
be
$
74.49
for
management
labor,
$
58.44
for
technical
labor,
and
$
31.71
for
clerical
labor.
Table
6.1
provides
a
breakdown
of
labor
hours
and
associated
costs
per
activity.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
­
The
facilities
that
may
apply
for
pollution
prevention
alternatives
maintain
environmental
compliance
data
as
a
customary
business
practice.
EPA
does
not
expect
any
start­
up
or
capital
costs
to
affect
participants
beyond
those
labor
costs
outlined
in
the
tables
in
this
section.
9
6(
c)
Estimating
State/
Local
Agency
Burden
and
Cost
Similar
to
sections
6(
a)
and
6(
b),
the
activities
for
State/
local
agencies
are
divided
into
the
activities
that
would
take
place
to
implement
the
relevant
pollution
prevention
alternatives
in
this
proposed
rulemaking.
Wage
rates
(
including
benefits)
for
State/
local
employees
were
retrieved
from
the
Bureau
of
Labor
Statistics
(
http://
www.
bls.
gov/
news.
release/
ecec.
t04.
htm;
updated
June
2002)
and
are
as
follows:
$
39.17
per
hour
for
management
labor,
$
40.42
per
hour
for
professional
technical
labor,
and
$
20.34
per
hour
for
clerical
labor.
We
chose
20
percent
of
the
labor
rate
(
including
benefits)
as
the
percentage
that
constitutes
overhead.
Therefore,
we
estimated
the
hourly
cost
of
labor
for
State/
local
employees
to
be
$
47.00
for
management
labor,
$
48.50
for
technical
labor,
and
$
24.41
for
clerical
labor.

Table
6.2
provides
a
breakdown
of
labor
hours
and
associated
costs
for
State/
local
agencies.

6(
d)
Estimating
Agency
Burden
and
Cost
EPA
would
provide
a
contact
for
Performance
Track
facilities
to
expedite
their
requests
for
pollution
prevention
alternatives.
As
recommended
in
the
ICR
Handbook,
wage
rates
for
EPA
employees
are
based
upon
the
Federal
government
pay
scale.
We
calculated
the
hourly
rates
for
EPA
employees
using
information
on
annual
salaries
from
the
Internet
site
for
the
Office
of
Personnel
Management.
(
http://
www.
opm.
gov/
oca/
02tables/
02rus.
pdf;
accessed
January
2002)
.
We
used
the
appropriate
pay
grade
levels
for
management,
technical,
and
clerical
personnel.
We
divided
the
annual
pay
rate
by
2080,
the
amount
of
working
hours
during
a
calendar
year,
to
get
the
hourly
wage
rate.
We
then
multiplied
this
rate
by
1.6
to
produce
a
pay
rate
that
reflects
the
true
cost
to
the
Federal
government
to
employ
a
worker.
The
value
of
1.6
incorporates
the
addition
of
benefits
at
40
percent
of
salary
and
the
addition
of
overhead
at
20
percent
of
salary
to
the
hourly
rate.
Following
is
a
summary
of
the
computed
wages
for
EPA
personnel.

Hourly
Labor
Rates
for
EPA
Labor
Type
Pay
Grade
Annual
Salary
Hourly
Rate
Benefits
(
40
%
Salary)
Overhead
(
20
%
Salary)
Adjusted
Hourly
Rate
Management
GS­
15
$
89,715
$
43.13
$
17.25
$
8.63
$
69.01
Technical
GS­
12
$
54,275
$
26.09
$
10.44
$
5.22
$
41.75
Clerical
GS­
6
$
27,534
$
13.24
$
5.30
$
2.65
$
21.19
A
separate
line
item
is
included
in
Table
6.2
for
the
hours
and
cost
associated
with
EPA
personnel.
10
6(
e)
Estimating
the
Respondent
Universe
The
respondents
for
this
ICR
are
facilities
subject
to
promulgated
MACT
standards
as
listed
in
Table
1.1.
All
of
these
facilities
will
not
be
able
to
qualify
for
the
pollution
prevention
alternatives
in
the
proposed
amendments.
The
Group
1
sources
in
Table
1.1
(
primarily
those
with
HAP
in
surface
coatings)
are
expected
to
have
the
best
opportunities
for
eliminating
all
HAP
and
qualifying
for
an
exemption
to
the
MACT
standard
Option
1).
Those
in
Group
2
will
have
fewer
opportunities,
and
facilities
in
Group
3
will
likely
not
be
able
to
eliminate
all
HAP.
As
a
conservative
estimate,
we
believe
that
at
least
3%
of
the
Group
1
facilities
(
3,959
x
0.03
=
119)
and
1.5%
of
the
Group
2
facilities
(
690
x
0.015
=
10)
will
qualify
for
the
pollution
prevention
exemption
(
a
total
of
129
facilities).
None
of
the
Group
3
facilities
are
expected
to
be
able
to
completely
eliminate
all
HAP
emissions
and
qualify
for
the
exemption.

More
facilities
are
expected
to
qualify
for
the
pollution
prevention
alternative
that
can
be
applied
to
individual
emission
points
(
Option
2).
We
expect
some
facilities
to
apply
for
reduced
compliance
reporting
(
e.
g.,
from
semiannual
to
annual)
and
other
facilities
to
use
pollution
prevention
techniques
that
will
make
it
unnecessary
to
conduct
performance
testing
for
HAP
emissions.
Conservatively,
we
estimate
that
3%
of
the
Groups
1,
2,
and
3
facilities
(
7,988
x
0.03
=
240)
will
qualify
for
the
pollution
prevention
alternative
of
reduced
compliance
reporting
and
reduced
performance
testing.
We
are
estimating
no
burden
reduction
or
other
effect
for
the
Group
4
facilities
(
a
total
of
35,170)
because
they
currently
have
low
burden
requirements
and
are
not
expected
to
apply
for
the
pollution
prevention
alternatives.

We
reviewed
a
representative
sampling
of
ICRs
for
existing
MACT
rules
to
estimate
potential
burden
reductions
for
Options
1
and
2.
The
results
are
summarized
in
Attachment
1.
We
used
a
median
burden
reduction
of
501
hours
per
year
for
facilities
that
obtain
an
exemption
from
the
applicable
MACT
standard
(
Option
1).
For
Option
2,
we
used
an
annual
reduction
of
16
hours
per
year
for
facilities
that
reduce
compliance
reporting
from
semi­
annual
to
annual.
For
facilities
that
qualify
for
eliminating
a
performance
test,
we
used
a
median
value
of
204
hours
per
year
based
on
a
review
of
several
ICRs.

6(
f)
Bottom
Line
Burden
Hours
and
Cost
(
i)
Industry
Respondent
Tally
­
Table
6.1
presents
a
summary
of
the
annual
burden
and
costs,
or
cost
savings,
associated
with
each
of
the
pollution
prevention
alternatives
proposed
in
this
rulemaking.

(
ii)
EPA/
State/
Local
Tally
­
Table
6.2
presents
a
summary
of
the
annual
burden
hours
and
labor
costs
associated
with
this
proposed
rulemaking
for
EPA
and
State/
local
agencies,
and
the
total
anticipated
burden
and
costs.
11
(
iii)
Variations
in
the
Annual
Bottom
Line
­
EPA
does
not
anticipate
significant
variation
in
the
annual
respondent
reporting
burden
over
the
course
of
the
requested
ICR
period.

6(
g)
Reasons
for
Change
in
Burden
­
This
is
an
new
ICR.
There
are
no
changes
in
burden.

6(
h)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
a
reduction
of
137
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
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
No.
OAR­
2002­
0044,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center,
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
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
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2002­
0044)
in
any
correspondence.
12
Table
6.1
Annual
Respondent
Burden
and
Cost
(
Industry)

Burden
item
(
A)

Hours
per
occurrence
(
B)
Occurrences
per
year
per
facility
(
C)
Number
of
facilities
(
D)
Technical
personhours
per
year
(
D=
AxBxC)
(
E)
Management
person­
hours
per
year
(
Dx0.05)
(
F)
Clerical
personhours
per
year
(
Dx0.1)
(
G)
Cost,$
a
1.
Submit
request
for
pollution
prevention
exemption
(
Option
1)
40
0.33b
129c
1,703
85
170
$
111,246
2.
Submit
additional
information
for
Option
1
8
0.33
b
12.9d
34
2
3
$
2,231
3.
Burden
reduction
for
Option
1
(
501)
g
0.67e
129c
(
43,301)
(
2,165)
(
4,330)
($
2,829,086)

4.
Submit
request
for
pollution
prevention
alternative
(
Option
2)
for
annual
compliance
reporting
(
instead
of
semiannual)
16
0.33b
240f
1,267
63
127
$
82,764
5.
Submit
additional
information
for
Option
2
8
0.33
b
24d
63
3
6
$
4,095
6.
Burden
reduction
for
Option
2
for
annual
compliance
reporting
(
instead
of
semiannual)
(
16)
0.67e
240f
(
2,573)
(
129)
(
257)
($
168,125)

7.
Submit
request
for
pollution
prevention
alternative
for
performance
test
(
Option
2)
40
0.33b
240f
3,168
158
317
$
206,959
8.
Submit
additional
information
for
Option
2
8
0.33
b
24d
63
3
6
$
4,095
9.
Burden
reduction
for
Option
2
for
no
performance
test
(
204)
h
0.67e
240f
(
32,803)
(
1,640)
(
3,280)
($
2,143,180)

Total
(
72,379)
(
3,620)
(
7,238)
($
4,729,000)

a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
58.44,
management
at
$
74.49,
and
clerical
at
$
31.71.

b
This
is
a
one
time
event
for
each
facility
over
the
3­
year
term
of
the
ICR
(
1/
3
=
0.33
occurrences
per
year).

c
Based
on
3%
of
the
Group
1
(
surface
coating)
facilities
qualifying
for
the
exemption
(
3,959
x
0.03
=
119)
plus
1.5%
of
the
Group
2
facilities
(
690
x
0.015
=
10)
for
a
total
of
129.

d
Assumes
10%
of
the
facilities
must
submit
additional
information.

e
Assumes
facilities
apply
for
alternatives
during
the
first
year
and
get
burden
reductions
during
the
second
and
third
year
of
the
3­
year
term
of
this
ICR
(
2/
3=
0.67
occurrences
per
year).

f
Assumes
3%
of
the
facilities
in
Groups
1,
2,
and
3
apply
for
annual
reporting
instead
of
semiannual
reporting
and
the
same
number
use
pollution
prevention
to
eliminate
an
annual
performance
test
(
7,988
x
0.03
=
240).
13
g
Based
on
the
median
value
for
the
recurring
annual
burden
for
a
representative
mix
of
source
categories
(
see
Attachment
1).

h
Based
on
the
median
annual
burden
for
performance
tests
for
several
source
categories
(
see
Attachment
1).

Table
6.2
Annual
Respondent
Burden
and
Cost
(
EPA/
State/
Local
Agencies)

Burden
item
(
A)

Hours
per
occurrence
(
B)
Occurrences
per
year
per
facility
(
C)
Number
of
facilities
(
D)
Technical
personhours
per
year
(
D=
AxBxC)
(
E)
Management
person­
hours
per
year
(
Dx0.05)
(
F)
Clerical
personhours
per
year
(
Dx0.1)
(
G)
Cost,$
a
1.
Review
requests
for
pollution
prevention
exemption
(
Option
1)
8
0.33
b
129c
341
17.0
34.0
18,167
2.
Review
additional
information
for
Option
1
4
0.33b
12.9d
17
1.0
2.0
920
3.
Review
requests
for
pollution
prevention
alternative­
annual
compliance
report
(
Option
2)
8
0.33
b
240e
634
32.0
63.0
33,791
4.
Review
additional
information
for
Option
2
(
annual
compliance)
4
0.33
b
24d
32
2.0
3.0
1,719
5.
Review
requests
for
pollution
prevention
alternative­
no
performance
test
(
Option
2)
8
0.33
b
240e
634
32.0
63.0
33,791
6.
Review
additional
information
for
Option
2
(
no
performance
test)
4
0.33
b
24d
32
2.0
3.0
1,719
7.
Burden
reduction
from
fewer
compliance
reports
to
review
and
file
(
2)
0.67f
609g
(
816)
(
41.0)
(
82.0)
(
43,505)

8.
EPA
facilitation
for
Performance
Track
facilities
16
0.33b
12h
63
3.0
6.0
2,964i
Total
937
48
92
49,567
a
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
48.50,
management
at
$
47.00,
and
clerical
at
$
24.41.

b
This
is
a
one
time
event
for
each
facility
over
the
3­
year
term
of
the
ICR
(
1/
3
=
0.33
occurrences
per
year).

c
Based
on
3%
of
the
Group
1
(
surface
coating)
facilities
qualifying
for
the
exemption
(
3,959
x
0.03
=
119)
plus
1.5%
of
the
Group
2
facilities
(
690
x
0.015
=
10)
for
a
total
of
129.

d
Assumes
10%
of
the
facilities
must
submit
additional
information.

e
Assumes
3%
of
the
facilities
in
Groups
1,
2,
and
3
apply
for
annual
reporting
instead
of
semiannual
reporting
and
the
same
number
use
pollution
prevention
to
eliminate
an
annual
performance
test
(
7,988
x
0.03
=
240).
14
f
Assumes
facilities
apply
for
alternatives
during
the
first
year
and
get
burden
reductions
during
the
second
and
third
year
of
the
3­
year
term
of
this
ICR
(
2/
3=
0.67
occurrences
per
year).

g
For
all
qualifying
facilities
(
129
+
240
+
240
=
609).

h
A
total
of
12
Performance
Track
facilities
are
estimated
to
be
eligible
based
on
reporting
emissions
of
hazardous
air
pollutants.

i
EPA
costs
are
based
on
the
following
hourly
rates:
technical
at
$
41.75,
management
at
$
69.01,
and
clerical
at
$
21.19.
15
ATTACHMENT
1.
ESTIMATE
OF
BURDEN
REDUCTION
1.
Estimate
the
burden
reduction
for
an
exemption
from
the
NESHAP
(
Option
1)
from
the
median
value
from
ICRs
for
several
source
categories.
Use
annual
recurring
items
only:

Source
Burden
(
technical
hrs/
yr)

Aerospace
­
coatings
532
Aerospace
­
depainting
253
Leather
finishing
114
Magnetic
tape
manufacturing
782
Metal
coil
(
surface
coating)
470
Pesticide
active
ingredient
778
Phosphoric
acid
and
phosphate
fertilizer
345
Printing
and
publishing
1,136
Vegetable
oil
720
Wood
furniture
198
Median
501
2.
Estimate
the
burden
reduction
from
eliminating
performance
tests
from
the
average
of
several
ICRs:

Source
category
Performance
tests
(
hr/
yr)

Metal
coil
192
Pesticides
188
Phosphate
fertilizer
168
Aerospace
280
Magnetic
Tape
215
Printing/
Publishing
240
Median
204
