1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
(
a)
Title
and
Number
of
the
Information
Collection
ICR:
Control
Technology
for
Equivalent
Emissions
Limitations
by
Permit
under
section
112(
j)
OMB
Control
Number:
2060­
0266,
EPA
ICR
#
1648.04.

(
b)
Short
Characterization
Section
112(
j)
of
the
Clean
Air
Act
as
amended
in
1990
(
CAAA)
requires
that
if
EPA
fails
to
promulgate
a
standard
for
a
category
or
subcategory
of
major
sources
within
18
months
after
its
scheduled
date
of
promulgation,
then
sources
must
submit
a
title
V
permit
application
by
that
date.
For
the
so­
called
10­
year
maximum
achievable
control
technology
(
MACT)
standards,
scheduled
for
promulgation
by
November
15,
2000,
sources
must
submit
permit
applications
by
May
15,
2002,
if
standards
are
not
promulgated
by
that
date.
States
(
with
approved
Title
V
operating
permit
programs)
will
issue
permits
containing
MACT
emission
limitations
that
the
State
will
determine
on
a
case­
by­
case
basis
equivalent
to
what
would
have
been
promulgated
by
EPA.

After
promulgation
of
the
section
112(
j)
rule
on
May
20,
1994,
several
petitioners
filed
for
review
of
the
section
112(
j)
rule.
EPA
has
proposed
to
amend
the
original
rule
based
upon
those
petitions.
As
a
result
of
internal
discussions,
EPA
will
also
clarify
and
streamline
the
section
112(
j)
rule.

This
ICR
supports
the
amended
regulations
under
development
to
implement
Section
112(
j)
(
40
CFR
part
63,
subpart
B,
§
§
63.50­
56).
It
addresses
the
information
collection
burden
(
hours
and
costs)
to
industry
respondents
subject
to
these
amended
provisions;
State
and
Local
agencies
that
review
applications
made
under
these
amended
provisions;
and
the
EPA
oversight
review
of
a
percentage
of
State/
Local
decisions.

This
ICR
includes
about
84,000
affected
sources,
estimated
to
be
subject
to
the
revised
section
112(
j)
rule,
that
we
anticipate
will
perform
the
reporting
that
the
rule
requires.
We
anticipate
that
about
84,000
affected
sources
will
have
to
prepare
and
submit
a
Part
1
title
V
permit
application.
Because
all
MACT
standards
will
be
issued
before
the
Part
2
application
is
required,
no
Part
2
applications
will
be
necessary
(
and
thus
no
associated
burden).
It
should
be
noted
that
the
number
of
affected
sources
is
greater
than
the
number
of
facilities
or
plant
sites
affected,
since
a
plant
site
can
contain
numerous
affected
sources
and
be
affected
by
multiple
MACT
standards.
We
have
determined
estimated
costs
based
on
the
number
of
affected
sources;
however,
we
believe
that
the
actual
cost
will
be
somewhat
less
for
facilities
that
contain
several
2
affected
sources.
The
average
administrative
cost
per
affected
source
to
perform
the
reporting
was
estimated
to
be
$
260.
Total
estimated
administrative
costs
for
existing
sources
are
about
$
21,840,000
for
all
affected
sources
in
all
affected
source
categories
during
the
first
three
years
after
promulgation
of
the
revised
section
112(
j)
rule.
3
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
(
a)
Need/
Authority
for
the
Collection
Section
112(
j)
of
the
Clean
Air
Act
as
amended
in
1990
contains
the
need
and
authority
for
this
information
collection.
[
42
U.
S.
C.
7401
(
et.
seq.)
as
amended
by
Public
Law
101­
549]

(
b)
Practical
Utility/
Users
of
the
Data
The
information
collected
in
the
application
documents
will
be
used
for
the
purposes
of
permit
approval,
compliance
determination,
and
the
selection
of
particular
control
technology
on
a
case­
by­
case
basis.
The
Federal
or
State
administrator
of
the
operating
permits
program
will
use
the
information
for
the
case­
by­
case
emission
limit
determinations.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
information
collection
activities
required
under
the
section
112(
j)
amended
regulations
are
not
routinely
collected
elsewhere
by
EPA.
The
permitting
authority
may
have
collected
a
few
of
the
information
items
previously
in
support
of
other
applications.
In
some
cases,
the
source
will
not
have
been
subject
to
previous
Federal
air
standards,
and
the
source's
entry
into
the
section
112(
j)
program
will
be
its
first
encounter
with
information
collection
activities
under
the
Clean
Air
Act.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
A
public
review
and
comment
period
will
occur
after
proposal
of
the
section
112(
j)
amended
regulations
in
the
Federal
Register.

3(
c)
Consultations
Because
the
section
112(
j)
revised
regulations
have
resulted
from
legal
actions
filed
by
the
petitioners,
it
is
not
appropriate
or
legal
to
conduct
consultations
beyond
any
discussion
with
the
petitioners.
Thus,
to
keep
the
section
112(
j)
revised
regulations
privileged
and
confidential,
EPA
did
not
consult
with
anyone
not
involved
with
the
revision
of
these
regulations.

3(
d)
Effects
of
Less
Frequent
Collection
4
Each
applicant
would
submit
the
required
information
on
a
one­
time­
only
basis.

3(
e)
General
Guidelines
The
recordkeeping
and
reporting
requirements
contained
in
the
section
112(
j)
amended
regulations
do
not
violate
any
of
the
Paperwork
Reduction
Act
guidelines
contained
in
5
CFR
1320.6.

3(
f)
Confidentiality
Any
information
submitted
to
a
permitting
authority
with
a
claim
of
confidentiality
will
be
safeguarded
according
to
that
agency's
policies
set
forth
prior
to
approval
of
the
agency's
operating
permit
program
by
EPA.
Any
confidential
information
submitted
to
EPA
will
be
safeguarded
according
to
policies
in
40
CFR,
Chapter
1,
Party
2,
Subpart
B
­­
Confidentiality
of
Business
Information.
All
members
of
the
public
will
have
opportunity
to
comment
on
the
proposed
regulation.

3(
g)
Sensitive
Questions
This
section
is
not
applicable.
This
ICR
does
not
contain
any
sensitive
questions
relating
to
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
SIC
Codes
Respondents
include
owners/
operators
of
major
sources
of
hazardous
air
pollutants
(
HAPs).
A
major
source
is
one
that
emits
more
than
10
tons
per
year
of
any
HAP,
25
tons
per
year
for
the
total
of
all
HAP,
or
amounts
exceeding
any
lesser
quantity
cutoff
established
pursuant
to
§
112(
a)(
1)
of
the
CAA.
This
definition
of
major
source
cuts
across
a
wide
variety
of
industries,
including
both
manufacturing
and
nonmanufacturing
sources.
Thus,
the
proposed
amendments
to
the
section
112(
j)
regulations
would
regulate
owners
and
manufacturers
of
major
sources.
For
purposes
of
this
information
collection
request
period,
only
those
sources
in
the
2000
source
category
"
bin"
(
the
so­
called
10­
year
bin)
would
potentially
be
subject
to
the
section
112(
j)
program
due
to
a
failure
by
the
EPA
to
promulgate
MACT
standards
for
these
categories
by
the
section
112(
j)
hammer
date
of
May
15,
2002.
Table
1
lists
the
source
categories
in
the
10­
year
bin
for
the
respondents.
As
discussed
in
section
(
6)(
b),
EPA
estimates
that
59
of
these
source
categories
would
potentially
become
subject
to
the
section
112(
j)
program.

4(
b)
Information
Requested
5
(
i)
Data
items,
including
recordkeeping
requirements
Implementation
of
the
section
112(
j)
program
involves
information
submitted
with
the
application
for
a
section
112(
j)
determination.
Section
112(
j)
does
not
contain
recordkeeping
requirements,
although
the
source
would
already
keep
some
of
the
information
necessary
to
document
certain
control
options.

The
section
112(
j)
revised
regulations
would
simplify
and
streamline
the
section
112(
j)
process.
Instead
of
requiring
all
information
for
a
section
112(
j)
MACT
determination
at
once,
the
section
112(
j)
revised
regulations
divide
the
section
112(
j)
application
process
for
the
case­
bycase
MACT
determination
into
two
parts.
The
first
part
of
the
section
112(
j)
MACT
application
consists
of
submitting
summary
administrative
information
while
the
second
part
of
the
section
112(
j)
MACT
application,
due
24
months
later,
requires
the
technical
information
necessary
for
a
MACT
floor
determination.
Furthermore,
the
source
is
no
longer
required
to
present
a
recommended
MACT
floor
or
MACT
limits
in
their
application.

For
a
section
112(
j)
MACT
determination
under
the
revised
rules,
new
or
existing
sources
must
submit
the
following
information
in
a
two
part­
application:

Part
1
(
§
63.53(
a))
of
the
application
shall
contain:


The
name
and
address
(
physical
location)
of
the
major
source;


A
brief
description
of
the
major
source,
and
an
identification
of
the
relevant
source
category;


An
identification
of
the
types
of
major
sources
belonging
to
the
relevant
source
category;
and

An
identification
of
any
affected
major
sources
for
which
a
section
112(
g)
MACT
determination
has
been
made.

Part
2
(
§
63.53(
b)(
1))
of
the
application
shall
contain:


For
new
affected
sources,
the
anticipated
date
of
startup
of
operation;


The
HAPs
emitted
by
each
affected
source
in
the
relevant
source
category;


An
estimated
total
uncontrolled
and
controlled
emission
rate
for
HAPs
from
the
affected
source;


Any
existing
Federal,
State,
or
Local
limitations
or
requirements
applicable
to
the
affected
major
source;


An
identification
of
control
technology
in
place
for
each
piece
of
equipment
or
activity
or
major
source;


Information
relevant
to
establishing
the
MACT
floor,
and
at
the
option
of
the
owner
or
operator,
a
recommended
MACT
floor;
and
6

Any
other
information
reasonably
needed
by
the
permitting
authority,
including
information
required
pursuant
to
subpart
A
of
this
part.

Part
2
(
§
63.53(
b)(
2))
of
the
application
may
include
the
following:


Recommended
emission
limitations
for
the
affected
major
source
and
any
necessary
supporting
information;


A
description
of
the
control
technologies
that
the
respondent
will
apply
to
meet
the
emission
limitation;
and

Relevant
parameters
to
be
monitored
and
the
frequency
of
monitoring
to
demonstrate
continuous
compliance
with
the
MACT
emission
limitation
over
the
applicable
reporting
period.

Because
all
MACT
standards
will
be
promulgated
before
the
Part
2
application
is
required,
no
source
will
have
to
submit
a
Part
2
application.

(
ii)
Respondent
Activities
Activities
(
Tables
2a
and
2b)
that
the
owner
or
operator
must
perform
are:

Part
1
application:


Read
applicable
regulations
to
determine
source
applicability
and
compliance
requirements

Collect
basic
information
required
to
fulfill
§
63.53(
a)


Prepare
and
submit
Part
1
application

Store,
file,
and
maintain
application
information
Part
2
application:


Collect
basic
information
required
to
fulfill
§
63.53(
b)(
1)


Draft
and
review
Part
2
application

Complete
and
submit
Part
2
application

Store,
file,
and
maintain
application
information
7
5.
THE
INFORMATION
COLLECTED
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
This
section
addresses
the
activities
of
State
and
Local
agencies,
as
the
permitting
authority,
and
EPA,
in
an
oversight
capacity.
The
permitting
authority,
typically
the
State
or
Local
air
agency,
will
perform
the
following
activities
(
Tables
3a
and
3b):

Part
1
application:


Develop
application
form
(
1­
time
event)


Identify
affected
sources
(
1­
time
event)


Answer
respondent
questions
about
submitting
the
application

Receive,
review,
and
file
application
Part
2
application:


Review
applications
for
technical
completeness

Analyze
requests
for
confidentiality
and
provide
protection

Approve
or
disapprove
application
and
notify
respondents
of
decision

Set
emission
limits
on
a
case­
by­
case
basis

Prepare
draft
permit

Allow
for
public
review
of
draft
permit

Issue
permit
containing
case­
by­
case
MACT

File
and
maintain
permit
Acting
in
an
oversight
capacity,
EPA
will
perform
the
following
activities
(
Table
4):


Audit
and
review
applications

Review
the
decisions
of
permitting
authorities
5(
b)
Collection
Methodology
and
Management
The
owners
or
operators
of
the
sources
affected
by
these
amended
regulations
will
have
the
responsibility
of
submitting
a
Part
1
application
to
the
permitting
authority.
It
is
the
responsibility
of
the
permitting
authority
to
provide
information
necessary
for
EPA
oversight
review.

Qualified
staff
that
work
for
the
permitting
authority
will
perform
the
permit
reviews
and
check
the
quality
of
data
submitted
by
the
applicant
on
a
case­
by­
case
basis.
The
permitting
8
authority's
employees
will
handle
confidential
information
submitted
by
the
applicant
according
to
the
permitting
authority's
confidential
information
handling
procedures.

The
amended
section
112(
j)
regulations
will
not
require
the
request
of
information
through
any
type
of
survey.

5(
c)
Small
Entity
Flexibility
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
on
EPA's
part.
EPA
has
reduced
the
information
required
by
requiring
only
basic
information
needed
by
the
permitting
authority
to
make
a
case­
by­
case
MACT
determination.

The
section
112(
j)
revised
regulations
do
not
require
recordkeeping.
Furthermore,
the
section
112(
j)
revised
regulations
streamline
the
application
process
and
require
only
2
one­
time
submittals
of
information
to
State/
Local
agencies.
(
Note
that
the
Part
2
application
will
be
unnecessary.)

5(
d)
Collection
Schedule
The
section
112(
j)
amended
regulations
were
proposed
on
March
23,
2001,
and
are
scheduled
for
promulgation
by
the
end
of
February
2002.
This
ICR
does
not
require
surveys.
Each
source
affected
by
the
section
112(
j)
amended
regulations
will
be
required
to
submit
an
application.
Preparation
of
an
application
in
compliance
with
the
section
112(
j)
amended
rules
is
a
one­
time
only
activity
(
there
are
2
submittals
for
each
application).
The
section
112(
j)
amended
regulations
will
not
require
periodic
reporting
or
surveys.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
This
ICR
requires
the
calculation
of
the
amount
of
burden
hours
associated
with
each
activity
for
each
respondent.
In
the
section
112(
j)
permitting
process
for
major
sources,
each
respondent
must
submit
the
permit
application
in
two
parts
as
specified
in
section
4(
b)(
i)
of
this
Supporting
Statement.
All
activities
are
conducted
on
a
one­
time
only
basis
and
are
divided
into
two
parts
in
accordance
to
the
tasks
for
each
part.
Tables
2a
and
2b
provide
a
breakdown
of
the
burden
hours
per
occurrence
for
the
respondents.

For
the
section
112(
j)
revised
regulations,
burden
for
the
respondents
is
a
combination
of
administrative
costs
(
preparing
the
permit
applications)
and
compliance
costs.
The
permitting
process
and
thus
the
administrative
costs
are
divided
into
two
parts.
The
first
part
of
the
permit
9
contains
summary
administrative
information.
For
existing
sources,
the
first
part
of
the
permit
contains
administrative
information
and
is
submitted
to
the
permitting
authority
no
later
than
that
18
months
after
the
statutory
deadline
of
November
15,
2000,
which
is
May
15,
2002.
The
second
part
of
the
permit
contains
more
technical
information
and
is
submitted
24
months
after
the
first
part
(
May
15,
2004).
After
receiving
the
title
V
permit
containing
section
112(
j)
provisions,
the
source
would
then
install
and
operate
control
equipment
to
comply
with
the
emission
limit
established
by
the
section
112(
j)
case­
by­
case
MACT
determination.
The
sources
also
would
comply
with
any
monitoring,
recordkeeping,
and
reporting
requirements
set
by
the
permitting
authority
and
the
EPA.
However,
we
expect
all
the
remaining
MACT
standards
will
be
issued
well
before
the
Part
2
application
is
required,
negating
the
need
submit
a
Part
2
application,
and
eliminating
the
need
for
permitting
authorities
to
determine
case­
by­
case
MACT.

Under
the
provisions
in
the
section
112(
j)
rule,
a
new
source
is
a
source
that
is
constructed
after
the
issuance
of
the
existing
source
permit.
Since
the
earliest
possible
date
for
issuance
of
a
permit
for
an
existing
source
is
well
after
May
2004
(
the
date
Part
2
applications
are
due)
and
we
expect
all
MACT
standards
to
be
promulgated
by
then,
there
will
be
no
permitting
costs
or
compliance
costs
for
new
sources
during
the
period
that
this
ICR
covers.

6(
b)
Estimating
Respondent
Costs
(
i)
Labor
costs
In
this
ICR,
EPA
has
used
a
graded
approach
in
calculating
cost
as
recommended
in
the
ICR
handbook.
Due
to
the
lack
of
an
economic
analysis
on
the
cost
of
the
section
112(
j)
revised
regulations,
wage
rates
for
industry
respondents
were
retrieved
from
the
Bureau
of
Labor
Statistics.
(
http://
www.
bls.
gov/
news.
release/
ecec.
t12.
htm;
accessed
January
2002.)
The
hourly
rates
are
listed
as
follows:
$
47.00
for
management
labor,
$
37.36
for
technical
labor,
and
$
20.36
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
sources
submitting
permit
applications
to
be
$
70.50
for
management
labor,
$
56.04
for
technical
labor,
and
$
30.54
for
clerical
labor.
Tables
2a
and
2b
provide
a
breakdown
of
labor
hours
and
associated
costs
per
occurrence
for
each
activity
in
each
part
of
the
application
process.

(
ii)
Capital
and
Operation
and
Maintenance
Costs
As
explained
in
6(
a),
compliance
with
the
112(
j)
rule,
including
resultant
capital
and
operation
and
maintenance
costs,
will
occur
well
after
May
2004.
There
will
also
be
no
emission
reductions
attributable
to
the
section
112(
j)
program
during
the
period
covered
by
this
ICR,
since
sources
will
generally
have
up
to
3
years
after
permit
issuance
to
comply.

6(
c)
Estimating
State/
Local
Agency
Burden
and
Cost
10
Similar
to
sections
6(
a)
and
6(
b),
the
activities
for
State/
Local
agencies
are
divided
into
the
activities
that
would
take
place
for
both
parts
of
the
application
process
as
described
in
section
4(
b)(
i)
of
this
Supporting
Statement.
Wage
rates
for
State/
Local
employees
were
retrieved
from
the
Bureau
of
Labor
Statistics
(
http://
www.
bls.
gov/
news.
release/
ecec.
t04.
htm;
accessed
January
2002)
and
are
as
follows:
$
26.31
per
hour
for
management
labor,
$
29.35
per
hour
for
technical
labor,
and
$
12.88
per
hour
for
clerical
labor
instead
of
the
flat
rate
($
34/
hr)
as
mentioned
in
the
previous
ICR.
We
added
in
the
value
of
total
benefits
in
BLS
Table
4.
We
chose
20
percent
of
the
base
rate
as
the
percentage
of
salary
that
constitutes
overhead.
The
addition
of
benefits
and
overhead
to
the
hourly
rate
produces
a
pay
rate
that
reflects
the
true
cost
to
employ
a
State
,
Local,
or
Tribal
agency
worker.
Following
is
a
summary
of
the
computed
hourly
wages
for
State,
Local,
and
Tribal
agency
employees.

Hourly
Labor
Rates
for
State,
Local
and
Tribal
Respondents
Labor
Type
Hourly
Rate
Benefits
Overhead
(
20
%
Salary)
Adjusted
Hourly
Rate
Management
$
26.31
$
11.12
$
5.26
$
42.69
Technical
$
29.35
$
9.92
$
5.87
$
45.14
Clerical
$
12.88
$
6.39
$
2.58
$
21.85
Tables
3a
and
3b
provide
a
breakdown
of
labor
hours
and
associated
costs
for
State/
Local/
Tribal
agencies.

6(
d)
Estimating
Agency
Burden
and
Cost
Under
the
section
112(
j)
revised
regulations,
EPA
would
serve
in
an
oversight
capacity
and
audit
approximately
10
percent
of
all
applications
processed
by
State/
Local
agencies.
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
govenrment
to
employ
a
worker.
The
value
of
1.6
incorporates
the
addition
of
benefits
at
40
%
of
salary
and
the
addition
of
overhead
at
20%
of
salary
to
the
hourly
rate.
Following
is
a
summary
of
the
computed
wages
for
EPA
personnel.

Hourly
Labor
Rates
for
EPA
11
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
Table
4
provides
a
breakdown
in
the
amount
of
hours
associated
with
each
activity
and
the
total
burden
hours
and
cost
per
occurrence.

6(
e)
The
Respondent
Universe
In
order
to
estimate
the
number
of
sources
subject
to
the
section
112(
j)
amended
regulations,
EPA
reviewed
information
in
its
existing
source
category
tracking
system
to
determine
the
estimated
number
of
sources
affected
by
the
2000
MACT
standards
that
it
anticipates
will
not
be
promulgated
by
May
15,
2002;
we
anticipate
those
sources
affected
will
be
covered
by
31
standards
covering
59
source
categories
(
approximately
84,000
affected
sources).

6(
f)
Bottom
Line
Burden
Hours
and
Cost
Over
the
three­
year
period
of
this
ICR,
the
average
annual
burden
and
cost
associated
with
the
section
112(
j)
revised
regulations
are
172,200
hours
and
$
9,043,440
respectively.
Table
5
contains
the
total
burden
and
cost
breakdown
associated
with
the
section
112(
j)
amended
regulations.
Table
6
provides
a
summary
of
the
bottom
line
burden
hours
and
costs
associated
with
the
section
112(
j)
revised
regulations.

It
should
be
noted
that
much
of
this
burden
associated
with
section
112(
j)
is
eliminated
when
the
MACT
rules
are
promulgated.
In
fact,
we
anticipate
that
all
the
MACT
rules
will
be
promulgated
before
any
section
112(
j)
Part
2
applications
are
required.

6(
g)
Reasons
for
Change
in
Burden
The
ICR
1648­
02
spanned
the
period
in
which
the
section
112(
j)
rule
would
have
applied
to
any
of
the
source
categories
covered
by
the
1997
MACT
standards.
This
ICR
spans
the
period
in
which
the
section
112(
j)
rule
would
apply
to
any
of
the
source
categories
covered
by
the
2000
MACT
standards,
which
is
a
completely
different
set
of
source
categories.
Therefore,
the
number
of
respondents
is
completely
different
and
unrelated
for
this
ICR.
The
total
burden
is
based
primarily
on
the
number
of
respondents.
The
burden
per
occurrence
has
also
been
adjusted
downward,
reflecting
the
less
burdensome
requirements
of
only
the
Part
1
application.
12
Because
no
case­
by­
case
permits
will
actually
be
developed
or
issued,
there
are
no
compliance
costs
for
this
ICR.
Finally,
EPA
has
updated
the
labor
rates
for
respondents,
State,
Local,
and
Tribal
agencies,
and
the
EPA
as
discussed
in
sections
6(
b),
(
c),
and
(
d)
of
this
ICR.
These
adjustments
were
made
to
more
accurately
reflect
the
true
cost
of
an
hour
of
labor
for
the
respondents,
State,
Local,
and
Tribal
agencies,
and
the
EPA
The
unloaded
hourly
rates
are
different
because
they
are
based
on
the
latest
available
rates
from
the
BLS
and
the
OPM.
Table
7
provides
a
summary
of
the
differences
between
burden
hours
and
costs
associated
with
each
occurrence
for
the
previous
and
current
ICR.

The
difference
in
the
burden
estimate
is
due
to
the
adjustments
discussed
above,
including
number
of
respondents
and
labor
rates.

6(
h)
Burden
Statement
This
estimate
includes
all
activities
associated
with
the
respondents
or
government
agencies.
Overall,
the
section
112(
j)
program
will
have
the
following
average
annual
burden:
131,600
hours
and
$
7,280,000
for
respondents;
39,200
hours
and
$
1,697,360
for
State/
Local/
Tribal
agencies;
and
1,400
hours
and
$
66,080
for
the
EPA.
Table
5
presents
the
annual
burden
for
respondents,
State/
Local
agencies,
and
the
EPA
over
the
3­
year
period
studied
for
existing
sources.

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
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.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Avenue,
NW,
Washington,
DC
20460;
and
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.
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.
13
14
Part
B
of
the
Supporting
Statement
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
the
section
112(
j)
amended
regulations.
15
TABLES
16
Table
1.
Year
2000
Source
Categories
for
Respondents
Fuel
Combustion:
Combustion
Turbines
Engine
Test
Facilities
Industrial
Boilers
Institutional/
Commercial
Boilers
Process
Heaters
Reciprocating
Internal
Combustion
Engines
Rocket
Testing
Facilities
Non­
Ferrous
Metals
Processing:
Primary
Copper
Smelting
Primary
Magnesium
Refining
Ferrous
Metals
Processing:
Coke
By­
Product
Plants
Coke
Ovens:
Pushing,
Quenching,
Battery
Stacks
Integrated
Iron
and
Steel
Manufacturing
Iron
Foundries
Electric
Arc
Furnace
(
EAF)
Operation
Steel
Foundries
Mineral
Products
Processing:
Alumina
Processing
Asphalt
Concrete
Manufacturing
Asphalt
Processing
Asphalt
Roofing
Manufacturing
Asphalt/
Coal
Tar
Application­­
Metal
Pipes
Clay
Products
Manufacturing
Lime
Manufacturing
Refractories
Manufacturing
Taconite
Iron
Ore
Processing
Petroleum
and
Natural
Gas
Production
and
Refining:
Natural
Gas
Transmission
and
Storage
Petroleum
Refineries­­
Catalytic
Cracking
(
Fluid
and
other)
Units,
Catalytic
Reforming
Units,
and
Sulfur
Plant
Units
Liquids
Distribution:
Organic
Liquids
Distribution
(
Non­
Gasoline)

Surface
Coating
Processes:
Auto
and
Light
Duty
Truck
Large
Appliance
Manufacture
of
Paints,
Coatings,
and
Adhesives
Metal
Can
Metal
Coil
Metal
Furniture
Miscellaneous
Metal
Parts
and
Products
Paper
and
Other
Webs
Plastic
Parts
and
Products
Printing,
Coating,
and
Dyeing
of
Fabrics
Wood
Building
Products
17
Waste
Treatment
and
Disposal:
Hazardous
Waste
Incineration
Municipal
Landfills
Sewage
Sludge
Incineration
Site
Remediation
Solid
Waste
Treatment,
Storage
and
Disposal
Facilities
(
TSDF)

Fibers
Production
Processes:
Rayon
Production
Spandex
Production
Food
and
Agriculture
Processes:
Manufacturing
of
Nutritional
Yeast
Cellulose
Food
casing
Manufacturing
Vegetable
Oil
Production
Polymers
and
Resins
Production:
Alkyd
Resins
Production
Boat
Manufacturing
Carboxymethylcellulose
Production
Cellophane
Production
Cellulose
Ethers
Production
Maleic
Anhydride
Copolymers
Production
Methylcellulose
Production
Nitrile
Resins
Production
Polyester
Resins
Production
Polymerized
Vinylidene
Chloride
Production
Polymethyl
Methacrylate
Resins
Production
Polyvinyl
Acetate
Emulsions
Production
Polyvinyl
Alcohol
Production
Polyvinyl
Butyral
Production
Polyvinyl
Chloride
and
Copolymers
Production
Reinforced
Plastic
Composites
Production.

Production
of
Inorganic
Chemicals:
Ammonium
Sulfate
Production­­
Caprolactam
By­
Product
Plants
Carbon
Black
Production
Chlorine
Production
Cyanide
Chemicals
Manufacturing
Fumed
Silica
Production
Hydrochloric
Acid
Production
Uranium
Hexafluoride
Production
Production
of
Organic
Chemicals:
Ethylene
Processes
Quaternary
Ammonium
Compounds
Production
Miscellaneous
Processes:
Benzyltrimethylammonium
Chloride
Production.
Butadiene
Dimers
Production
Carbonyl
Sulfide
Production
Cellulosic
Sponge
Manufacturing
Chelating
Agents
Production
Chlorinated
Paraffins
18
Dry
Cleaning
(
Petroleum
Solvent)
Ethylidene
Norbornene
Production
Explosives
Production
Flexible
Polyurethane
Foam
Fabrication
Operations.
Friction
Products
Manufacturing
Hydrazine
Production
Leather
Tanning
and
Finishing
Operations
OBPA/
1,3­
Diisocyanate
Production
Paint
Stripping
Operations
Photographic
Chemicals
Production
Phthalate
Plasticizers
Production
Plywood
and
Composite
Wood
Products
Pulp
and
Paper
Production
Rubber
Chemicals
Manufacturing
Rubber
Tire
Manufacturing
Semiconductor
Manufacturing
Symmetrical
Tetrachloropyridine
Production
19
Table
2a.
Summary
of
Activities,
Labor
Hours,
and
Administrative
Costs
for
Respondents
for
Part
1
of
Application
Labor
Hours
per
Occurrence
(
hr/
occ)

Activity
Revised
112(
j)

Management
Technical
Clerical
Total
Wage
Rate
($/
hr)
70.5
56.04
30.54
A.
Read
applicable
regulations
to
determine
source
applicability
0.5
1
0
1.5
Cost
of
A
per
occurrence
35.25
56.04
0.00
91.29
B.
Collect
basic
information
to
fulfill
63.53(
a)
0
1
0
1
Cost
of
B
per
occurrence
0.00
56.04
0.00
56.04
C.
Prepare
and
submit
application
0.5
1
0.5
2
Cost
of
C
per
occurrence
35.25
56.04
15.27
106.56
D.
File
and
maintain
application
0
0
0.2
0.2
Cost
of
D
per
occurrence
0.00
0.00
6.11
6.11
Total
Hours
per
Occurrence
(
hr/
occ)
1.0
3.0
0.7
4.7
Total
Cost
per
Occurrence
($/
occ)
$
70.50
$
168.12
$
21.38
$
260.00
Table
2b.
Summary
of
Activities,
Labor
Hours,
and
Administrative
Costs
for
Respondents
for
Part
2
of
Application
Labor
Hours
per
Occurrence
(
hr/
occ)

Activity
Revised
112(
j)

Management
Technical
Clerical
Total
A.
Collect
information
required
by
63.53.(
b)(
1)
0
4
0
4
Cost
of
A
per
occurrence
0.00
224.16
0.00
224.16
B.
Fulfill
any
state
or
local
requirements
as
set
forth
by
63.53(
b)(
1)(
vi)
1
4
0
5
Cost
of
B
per
occurrence
70.50
224.16
0.00
294.66
C.
Process,
compile,
and
review
application
for
accuracy,
and
appropriateness
1
8
2
11
Cost
of
C
per
occurrence
70.50
448.32
61.08
579.90
D.
Complete
and
submit
written
application
1
4
2
7
Cost
of
D
per
occurrence
70.50
224.16
61.08
355.74
E.
Store,
file,
and
maintain
application
information
0.5
1
1
2.5
Cost
of
E
per
occurrence
35.25
56.04
30.54
121.83
Total
Hours
per
Occurrence
(
hr/
occ)
3.5
21
5
29.5
Total
Cost
per
Occurrence
($/
occ)
$
246.75
$
1,176.84
$
152.70
$
1,576.29
20
Table
3a.
Summary
of
Activities,
Labor
Hours,
and
Administrative
Costs
for
S/
L/
T
Agencies
for
Part
1
of
Application
Labor
Hours
per
Occurrence
(
hr/
occ)

Revised
112(
j)

Activity
Management
Technical
Clerical
Total
Wage
Rate
($/
hr)
42.69
45.14
21.85
A.
Develop
application
form
(
1­
time
event)
1
2
1
4
Cost
of
A
per
occurrence
42.69
90.28
21.85
154.82
B.
Identify
affected
sources
(
1­
time
event)
0
8
2
10
Cost
of
B
per
Occurrence
0.00
361.12
43.70
404.82
C.
Answer
respondent
questions
about
submitting
applications.
0
0.2
0
0.2
Cost
of
C
per
occurrence
0.00
9.03
0.00
9.03
D.
Review
and
file
applciations
0.1
1
0.1
1.2
Cost
of
D
per
occurrence
4.27
45.14
2.19
51.59
Total
Hours
per
Occurrence
(
hr/
occ)
0.1
1.2
0.1
1.4
Total
Cost
per
Occurrence
($/
occ)
$
4.27
$
54.17
$
2.19
$
60.62
Table
3b.
Summary
of
Activities,
Labor
Hours,
and
Administrative
Costs
for
S/
L/
T
Agencies
for
Part
2
of
Application
Labor
Hours
per
Occurrence
(
hr/
occ)

Revised
112(
j)

Activity
Management
Technical
Clerical
Total
A.
Review
applications
for
technical
completeness
0
4
0
4
Cost
of
A
per
occurrence
0.00
180.56
0.00
180.56
B.
Analyze
requests
for
confidentiality
and
provide
protection
0
1
0
1
Cost
of
B
per
occurrence
0.00
45.14
0.00
45.14
C.
Approve
or
disapprove
application
and
notify
respondents
of
decision
0.5
2
1
3.5
Cost
of
C
per
occurrence
21.35
90.28
21.85
133.48
D.
Set
emission
limitations
on
a
case­
by­
case
basis
0.1
5
2
7.1
Cost
of
D
per
occurrence
4.27
225.70
43.70
273.67
E.
Prepare
draft
permit
0.5
4
1
5.5
Cost
of
E
per
occurrence
21.35
180.56
21.85
223.76
F.
Public
hearing
1
2
1
4
Cost
of
F
per
occurrence
42.69
90.28
21.85
154.82
G.
Issue
permit
0.5
2
1
3.5
Cost
of
G
per
occurrence
21.35
90.28
21.85
133.48
H.
File
and
maintain
permit
0
1
1
2
Cost
of
H
per
occurrence
0.00
45.14
21.85
66.99
Total
Hours
per
Occurrence
(
hr/
occ)
2.6
21
7
30.6
Total
Cost
per
Occurrence
($/
occ)
$
110.99
$
947.94
$
152.95
$
1,211.88
21
Table
4.
Summary
of
Activities,
Labor
Hours,
and
Administrative
Costs
for
the
EPA
Labor
Hours
per
Occurrence
(
hr/
occ)

Revised
112(
j)

Activity
Management
Technical
Clerical
Total
Wage
Rate
($/
hr)
69.01
41.75
21.19
A.
Audit
and
review
application
0.1
0.2
0
0.3
Cost
of
A
per
occurrence
6.90
8.35
0.00
15.25
B.
Review
decisions
of
permitting
authority
0
0.2
0
0.2
Cost
of
B
per
Occurrence
0.00
8.35
0.00
8.35
Total
Hours
per
Occurrence
(
hr/
occ)
0.1
0.4
0.0
0.5
Total
Cost
per
Occurrence
($/
occ)
$
6.90
$
16.70
$
0.00
$
23.60
22
Table
5.
Administrative
Burden
and
Cost
Estimates
for
Respondents,
State
and
Local
Agencies,
and
the
EPA
for
Existing
Sources
Yeara
Number
of
Occurences
Total
Respondent
Burden
Hours
(
hr)
Total
Respondent
Costs
Total
State/
Local
Burden
Hours
(
hr)
Total
State/
Local
Costs
Total
EPA
Burden
Hours
(
hr)
c
Total
EPA
Costsc
Total
Burden
Hours
(
hr)
Total
Cost
Year
1
84,000
394,800
$
21,840,000
117,600
$
5,092,080
4,200
$
198,240
516,600
$
27,130,320
Year
2b
0
0
0
0
0
0
0
0
0
Year
3b
0
0
0
0
0
0
0
0
0
Total
84,000
394,800
$
21,840,000
117,600
$
5,092,080
4,200
$
198,240
516,600
$
27,130,320
Ann.
Avg.
28,000
131,600
$
7,280,000
39,200
$
1,697,360
1,400
$
66,080
172,200
$
9,043,440
a
Year
1
=
Mar
2002
­
Mar
2003;
Year
2
=
Mar
2003
­
Mar
2004;
Year
3
=
Mar
2004
­
Mar
2005.

b
All
MACT
rules
will
be
issued
before
Part
2
applications
are
due.

c
EPA
reviews
10%
of
permit
applications.

Table
6.
Summary
of
Total
Burden
and
Cost
Estimate
for
the
Section
112(
j)
Program
Year
Number
of
Respondents
Total
Annual
Hours
Requested
(
hr)
Total
Annualized
Costs
Year
1
84,000
516,600
$
27,130,320
Year
2
0
0
0
Year
3
0
0
0
Total
84,000
516,600
$
27,130,320
Ann.
Avg.
28,000
172,200
$
9,043,440
23
Table
7.
Comparison
of
Burden
and
Costs
for
1999
ICR
and
Current
ICR
Parameter
Unit
1999
ICR
Current
ICR
Percent
Difference
Respondent
Burden
Hours
per
Occurrence
(
hr/
occ)
175
4.7
­
97%

State/
Local
Burden
Hours
per
Occurrence
(
hr/
occ)
90
1.4
­
98%

EPA
Burden
Hours
per
Occurrence
(
hr/
occ)
50
0.5
­
99%

Total
Hourly
Wage
Rate
per
Occurrence
(
Respondents)
($/
hr)
45
55
22%

Total
Hourly
Wage
Rate
per
Occurrence
(
State/
Local
Agencies)
($/
hr)
30
43
41%

Total
Hourly
Wage
Rate
per
Occurrence
(
EPA)
($/
hr)
32
47
47%

Respondent
Cost
per
Occurrence
($/
occ)
8,980
260
­
97%

State/
Local
Cost
per
Occurrence
($/
occ)
2,744
61
­
98%

EPA
Cost
per
Occurrence
($/
occ)
1,595
24
­
98%
