
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP
Subpart
MMM­­
Pesticide
Active
Ingredient
(
PAI)
Production
(
1807.2)

1(
b)
Short
Characterization/
Abstract
Respondents
are
owners
and
operators
of
new
and
existing
facilities
that
engage
in
the
production
of
pesticide
active
ingredients
and
emit
hazardous
air
pollutants
(
HAP's).
The
source
category
comprises
approximately
300
plants;
of
these,
78
facilities
were
determined
to
meet
the
applicability
criteria
at
the
time
the
rule
was
issued.
A
2
percent
annual
increase
in
the
number
of
facilities
was
expected,
which
has
been
rounded
up
to
approximately
2
facilities
per
year
from
the
date
of
the
issuance
of
the
regulation
through
the
period
covered
by
this
ICR.

Owners
or
operators
of
PAI
production
facilities
to
which
this
regulation
applies
must
choose
one
of
the
compliance
options
described
in
the
rule
or
install
and
monitor
a
specific
control
system
that
reduces
HAP
emissions
to
the
compliance
level.
The
respondents
are
subject
to
sections
of
subpart
A
of
40
CFR
part
63
relating
to
NESHAP.
These
requirements
include
those
associated
with
the
applicability
determination;
the
notification
that
the
facility
is
subject
to
the
rule;
and
the
notification
of
testing
(
control
device
performance
test
and
CMS
performance
evaluation);
the
results
of
performance
testing
and
CMS
performance
evaluations;
startup,
shutdown,
and
malfunction
reports;
and
semiannual
or
quarterly
summary
reports
and/
or
excess
emissions
and
CMS
performance
reports.
In
addition
to
the
requirements
of
subpart
A,
many
respondents
are
required
to
submit
a
precompliance
plan
and
LDAR
reports,
and
plants
that
wish
to
implement
emissions
averaging
provisions
must
submit
an
emissions
averaging
plan.

Respondents
electing
to
comply
with
the
emission
limit
or
emission
reduction
requirements
for
process
vents,
storage
tanks,
or
wastewater
must
record
the
values
of
equipment
operating
parameters
as
specified
in
§
63.1367
of
the
rule.
Owners
or
operators
are
required
to
install,
operate,
and
maintain
a
continuous
monitoring
system
(
CMS).

If
the
owner
or
operator
identifies
any
deviation
resulting
from
a
known
cause
for
which
no
Federally­
approved
or
promulgated
exemption
from
an
emission
limitation
or
standard
applies,
the
compliance
report
shall
also
include
all
records
that
the
source
is
required
to
maintain
that
pertain
to
the
periods
during
which
such
deviation
occurred,
as
well
as
the
following:
the
magnitude
of
each
deviation;
the
reason
for
each
deviation;
a
description
of
the
corrective
action
taken
for
each
deviation,
including
action
taken
to
minimize
each
deviation
and
action
taken
to
prevent
recurrence;
and
a
copy
of
all
quality
assurance
activities
performed
on
any
element
of
the
monitoring
protocol.
2
Owners
or
operators
of
PAI
production
facilities
subject
to
the
rule
must
maintain
a
copy
of
all
monitored
equipment
operating
parameter
values
that
demonstrate
compliance
with
the
standards.
Those
records
must
be
maintained
for
a
minimum
of
5
years.
At
a
minimum,
the
most
recent
2
years
of
data
shall
be
retained
onsite.
The
remaining
3
years
of
data
may
be
retained
offsite.
All
reports
are
to
be
submitted
upon
request
to
EPA
or
the
respondent's
State
or
local
agency,
whichever
has
been
delegated
enforcement
authority
by
EPA.
The
information
is
used
to
determine
whether
or
not
all
sources
subject
to
the
NESHAP
are
achieving
the
standards.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
required
under
section
112(
d)
of
the
1990
Clean
Air
Act
(
the
Act)
to
regulate
emissions
of
HAP's
listed
in
section
112(
b).
The
predominant
HAP's
used
in
PAI
production
operations
include
toluene,
methanol,
and
HCl.
In
the
Administrator's
judgement,
the
pollutants
emitted
from
PAI
production
facilities
cause
or
contribute
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health.
Therefore,
this
source
category
was
listed
for
regulation
under
section
112.
(
Note:
The
original
source
category
list
included
10
source
categories
in
the
Agricultural
Chemicals
Production
industry
group.
The
rule
groups
these
10
source
categories
into
one
category,
adds
production
of
additional
chemicals,
and
changes
the
name
of
the
source
category
to
Pesticide
Active
Ingredient
Production.)

Records
and
reports
are
necessary
to
enable
the
Administrator
to
identify
sources
subject
to
the
standard.
The
precompliance
plan
and
emissions
averaging
plan
are
necessary
to
ensure
that
the
standard,
which
is
based
on
maximum
achievable
control
technology
(
MACT)
for
PAI
production
facilities,
will
be
achieved.
After
the
compliance
date,
all
respondents
must
submit
semiannual
(
every
6
months)
summary
reports
that
contain
the
information
requested
in
§
63.1368
of
the
rule.
In
addition,
respondents
that
elect
to
comply
with
the
alternative
standard
for
process
vents
and
storage
vessels
and
experience
excess
emissions
above
threshold
time
periods
must
submit
quarterly
summary
reports
and
excess
emissions
reports
containing
information
requested
in
§
63.1368.
Respondents
that
elect
to
use
the
emissions
averaging
provisions
must
submit
an
annual
report
as
specified
in
§
63.1368
of
the
rule.
These
records
and
reports
are
required
under
the
General
Provisions
of
40
CFR
part
63,
subpart
A
[
as
authorized
under
sections
101,
112,
114,
116,
and
301
of
the
Act
as
amended
by
Pub.
L
101­
549
(
42
U.
S.
C.
7401,
7412,
7414,
7416,
7601)].

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
EPA
enforcement
personnel
to:
(
1)
identify
new,
modified,
reconstructed,
and
existing
sources
subject
to
the
standards;
(
2)
ensure
that
MACT
is
being
properly
applied;
and
(
3)
ensure
that
the
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis
In
addition,
records
and
reports
are
necessary
to
enable
the
EPA
to
identify
facilities
that
are
not
in
compliance
with
the
standards.
Based
on
reported
information,
the
EPA
can
decide
which
facilities
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
these
3
facilities.
The
records
that
facilities
maintain
would
indicate
to
the
EPA
whether
the
owners
or
operators
are
in
compliance
with
the
standards.

Much
of
the
information
EPA
would
need
to
determine
compliance
would
be
recorded
on
a
continuous,
daily,
or
monthly
basis.
Such
information
would
be
reviewed
by
enforcement
personnel
during
an
inspection
and
would
need
to
be
reported
on
a
semiannual
or
quarterly
basis.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
rule.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
rule.

3(
b)
Consultations
The
EPA
published
a
list
of
categories
of
major
and
area
sources
of
HAP
on
July
16,
1992
(
57
FR
21592),
under
authority
of
section
112(
c);
this
notice
listed
PAI
production
as
a
category
of
major
sources
of
HAP.
(
As
noted
above,
this
rule
changes
the
name
of
the
source
category
from
Agricultural
Chemicals
Production
to
Pesticide
Active
Ingredient
Production.)
Representatives
of
the
PAI
production
industry,
including
the
American
Crop
Protection
Association
(
ACPA),
were
consulted
during
the
development
of
the
standards,
and
several
meetings
have
been
held
with
ACPA
during
this
time.
The
EPA
has
distributed
a
number
of
preliminary
standards
development
packages
to
both
State
and
Federal
government
agencies
and
ACPA,
and
all
were
given
opportunity
to
comment
on
the
presented
regulatory
development
activities
for
these
standards.
In
meetings
with
ACPA
and
government
agencies,
representatives
were
given
an
opportunity
to
comment
on
the
regulatory
approach.
The
major
topics
of
these
discussions
included
the
applicability,
MACT
floor
approach,
regulatory
strategies,
and
the
national
impacts
of
the
regulation.
No
specific
information
was
provided
with
respect
to
burden
estimates.

On
April
18,
2000,
EPA
published
a
notification
(
65
FR
20813)
regarding
the
proposed
renewal
of
this
ICR.
In
that
notice
EPA
requested
comments
regarding
the
utility
of
this
collection,
accuracy
of
burden
estimates,
and
suggestions
to
enhance
the
clarity,
utility,
and
quality
of
the
collection
and
to
minimize
the
burden.
No
comments
were
submitted
to
the
Agency
in
response
to
this
request.

3(
c)
Effects
of
Less
Frequent
Collection
In
the
three
years
following
the
effective
date
of
the
standard,
existing
sources
will
submit
only
one­
time
reports
to
the
Agency.
In
this
instance,
less
frequent
reporting
would
not
be
practical
because
the
EPA
needs
the
information
provided
in
these
one­
time
reports.
In
addition
to
these
one­
time
reports,
new
and
reconstructed
sources
will
also
submit
semiannual
or
quarterly
4
reports
in
the
three
years
following
the
effective
date
of
the
standard.
If
the
relevant
information
were
collected
less
frequently
than
semiannually
or
quarterly,
EPA
would
not
be
reasonable
assured
that
a
PAI
production
facility
is
in
compliance
with
the
standards.
Less
frequent
collection
could
result
in
long­
term
exceedances
of
the
applicable
emission
limits.
This
reporting
frequency
is
consistent
with
the
requirements
of
title
V
permit
programs.
Consequently,
less
frequent
reports
would
not
result
in
a
reduced
burden.

3(
d)
General
Guidelines
This
ICR
requires
that
PAI
production
facilities
retain
records
for
a
period
of
5
years,
which
exceeds
the
3­
year
limit
specified
in
5
CFR
1320.6.
However,
maintaining
records
for
5
years
is
consistent
with
the
General
Provisions
in
subpart
A
of
40
CFR
part
63
and
the
permitting
requirements
under
40
CFR
part
70.
All
sources
subject
to
this
rule
will
be
required
to
obtain
operating
permits
either
through
the
State­
approved
permitting
program
or,
if
one
does
not
exist,
in
accordance
with
the
provisions
of
40
CFR
part
71,
when
promulgated.
None
of
the
other
guidelines
in
5
CFR
1320.6
are
being
exceeded.

3(
e)
Confidentiality
(
i)
Confidentiality
All
information
submitted
to
the
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
EPA
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B­­
Confidentiality
of
Business
Information
(
see
40
CFR
part
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).

(
ii)
Sensitive
Questions.

This
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
NAICS
and
SIC
Codes
Respondents
are
owners
or
operators
of
PAI
production
facilities
that
are
classified
as
major
sources
under
section
112
of
the
Act.
The
primary
North
American
Industry
Codes
(
NAICS)
are
325199
and
32532.
The
primary
SIC
codes
for
the
respondents
affected
by
the
rule
are
2869
(
industrial
organic
chemicals,
NEC)
and
2879
(
pesticides
and
agricultural
chemicals).
Not
all
processes
classified
in
the
NAICS
or
SIC
codes
above
would
be
regulated
by
the
standards.

4(
b)
Information
Requested
5
(
i)
Data
items
Attachment
1,
Source
Data
and
Information
Requirements,
summarizes
recordkeeping
and
reporting
requirements.

(
ii)
Respondent
activities
The
respondent
activities
required
by
the
standards
in
the
three­
year
period
covered
by
this
ICR
are
listed
in
the
first
columns
of
Tables
1a
through
1d
on
pages
12­
15.
Table
1a
presents
the
one­
time
activities
for
the
first
year;
Table
1b
presents
the
recurrent
activities
required
in
the
first
year;
Table
1c
presents
the
one­
time
activities
required
in
the
second
and
third
year;
and
Table
1d
presents
the
recurrent
activities
required
by
the
standards
in
the
second
and
third
years.

5.
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
Agency
activities
for
the
first
3
years
following
the
effective
date
of
the
standards
are
provided
in
Tables
2a,
2b,
and
2c
and
are
discussed
in
section
6(
c).

5(
b)
Collection
Methodology
and
Management
Information
contained
in
the
initial,
one­
time
only
reports
will
be
collected
by
the
Agency
and
entered
into
a
data
system
for
information
collection.
Data
obtained
during
periodic
visits
by
EPA
personnel,
from
records
maintained
by
the
respondents,
and
from
information
provided
in
reports
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.
The
NESHAP
does
not
require
the
use
of
automated,
electronic,
mechanical,
or
other
technological
data
collection
techniques
or
other
forms
of
information
technology.
Although
many
of
the
larger
companies
have
elaborate
data
collection
methods,
automated
systems
are
not
expected
to
reduce
the
reporting
burden.

5(
c)
Small
Entity
Flexibility
Few
of
the
facilities
in
this
source
category
are
expected
to
meet
the
applicability
criteria
for
small
businesses.
The
EPA
does
not
expect
that
any
PAI
production
facilities,
including
the
small
businesses,
will
experience
adverse
impacts
related
to
the
cost
of
the
required
reporting
and
recordkeeping.

5(
d)
Collection
Schedule
For
all
existing
sources,
the
initial
notification
report
stating
that
the
source
is
subject
to
the
regulation
must
be
submitted
within
4
months
(
120
days)
after
the
effective
date
of
this
standard.
New
sources
for
which
construction
or
reconstruction
commenced
after
the
effective
date
of
this
standard
must
submit
the
initial
notification
as
soon
as
practicable
before
the
6
construction
or
reconstruction
commences
(
but
no
sooner
than
the
effective
date
of
the
standard).
New
sources
for
which
the
construction
or
reconstruction
has
commenced
but
initial
startup
has
not
occurred
before
the
effective
date
of
this
standard
must
submit
the
initial
report
as
soon
as
practicable
before
startup
but
no
later
than
60
days
after
the
effective
date
of
the
standard.
New
or
reconstructed
PAI
production
facilities
must
comply
immediately
upon
the
effective
date
of
the
promulgated
rule
if
their
startup
date
is
before
the
effective
date
or
upon
startup
if
the
startup
date
is
on
or
after
the
effective
date.

Within
150
calendar
days
after
the
compliance
date,
owners
or
operators
of
new
and
existing
PAI
production
facilities
must
submit
an
initial
notification
of
compliance
status
(
and
implementation
plan
if
averaging
emissions)
to
the
Administrator.
Records
necessary
to
determine
on­
going
compliance
must
be
compiled
on
a
daily
or
monthly
basis
and
notifications
of
compliance
status
must
be
submitted
to
the
Administrator
on
a
semiannual
or
quarterly
basis,
as
discussed
in
section
1(
b).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
The
annual
burden
estimates
for
reporting
and
recordkeeping
activities
are
presented
in
Tables
1(
a)­
1(
d).
Tables
1(
a)
and
1(
b)
present
the
estimated
one­
time
total
and
recurrent
hourly
burden
to
the
industry
for
reporting
and
recordkeeping
activities
during
the
last
year
prior
to
the
compliance
date,
i.
e.,
the
first
year
of
this
ICR.
Tables
1(
c)
and
1(
d)
present
the
estimated
onetime
total
and
recurrent
hourly
burden
to
the
industry
for
reporting
and
recordkeeping
activities
during
the
first
and
second
years
after
the
compliance
date,
i.
e.,
the
second
and
third
years
of
this
ICR.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
the
EPA's
experience
with
other
standards,
and
were
used
in
the
initial
ICR
submitted
at
rule
promulgation.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
technical
labor
rate
of
$
54.94
per
hour.
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rate
is
from
column
1:
Total
compensation.
The
wage
rate
has
been
loaded
by
adding
110%
overhead.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
average
annual
capital
costs
are
being
adjusted
upward
from
the
annual
capital
costs
estimated
in
the
first
ICR.
The
adjustment
reflects
the
total
capital
costs
for
this
information
collection
incurred
in
the
period
of
the
ICR,
and
does
not
ammortize
it
over
an
extended
period.
This
is
a
more
accurate
way
to
account
for
the
capital
costs
at
the
time
that
they
are
actually
incurred
by
the
respondents.
7
Capital
costs
include
performance
testing,
and
file
storage
and
CMS
equipment
acquisition
and
maintenance.
Performance
testing
is
considered
to
be
a
capital
cost
as
it
is
customarily
performed
by
contractor
support.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
annual
operations
and
maintenance
costs
are
the
ongoing
costs
all
persons
must
meet.
Total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.

Performance
tests
are
estimated
to
cost
$
26,100
(
times
two
for
each
facility)
for
process
vents
CMS
and
$
10,690
each
for
wastewater
CMS.
Monitoring
systems
including
data
acquisition
are
estimated
to
cost
$
15,920
each.
File
cabinets
are
estimated
to
cost
$
250
each.
These
costs
are
based
on
the
previous
ICR,
corrected
for
a
three­
year
aggregate
inflation
rate
of
6.9%
from
June
1997
through
June,
2000.
This
inflation
rate
was
determined
from
the
monthly
producer
price
index
(
PPI)
values
for
this
industry
(
i.
e.,
chemical
production)
determined
by
the
Department
of
Labor
Bureau
of
Labor
Statistics.

In
1997
the
affected
industry
was
estimated
to
comprise
78
facilities,
with
2
new
facilities
added
per
year
and
one
reconstructed
each
year.
Prior
to
the
year
of
the
compliance
date
(
year
2
of
this
ICR)
only
the
new
and
reconstructed
facilities
are
subject
to
compliance
costs.
At
the
year
of
the
compliance
date,
the
facilities
subject
to
capital
costs
comprise
the
original
78
facilities,
less
the
three
that
have
undergone
reconstruction
from
1999
through
2001,
plus
the
estimated
2
new
facilities
that
year,
for
a
total
of
77.
Subsequent
years'
capital
costs
are
based
on
the
assumption
that
2
new
facilities
will
be
added
per
year,
and
that
operational
changes
will
affect
10%
of
existing
facilities.

Each
facility
is
estimated
to
need
process
vent
monitoring
systems
and
performance
testing.
Of
those,
40%
are
estimated
to
also
need
wastewater
monitoring
systems
and
performance
testing.
Each
facility
will
need
to
acquire
data
acquisition
systems
and
file
storage
equipment.

Capital
costs
for
the
three
year
period
of
this
ICR
are
estimated
to
total
$
4.81
million
for
performance
tests,
$
0.02
million
for
file
storage,
and
$
1.80
million
for
data
acquisition
systems.
This
is
a
total
of
$
6.63
million,
and
an
average
annual
capital
cost
of
$
2.21
million.

As
the
monitoring
equipment
is
considered
reliable,
the
operation
and
maintenance
costs
are
estimated
to
be
25%
of
the
average
annualized
capital
costs
of
that
equipment
operating
at
all
facilities
under
compliance.
As
the
average
annualized
costs
of
such
equipment
is
approximately
$
102,000
($
92,000
for
equipment
installed
per
this
ICR;
$
10,000
for
equipment
installed
during
the
previous
ICR),
the
annual
O&
M
costs
are
estimated
to
be
approximately
$
25,500.

(
iii)
Capital
Start­
up
vs.
Operating
and
Maintenance
Costs
The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
6.63
million.
This
corresponds
to
an
annualized
cost
of
$
2,210,000,
shown
on
the
OMB
83­
I
form
in
block
14
letter
a:
Total
annualized
capital/
startup
costs.
8
The
total
annual
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
are
$
25,500.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
b:
Total
annual
costs
(
O&
M).

The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
The
average
annual
cost
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
2,235,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
c:
Total
annualized
cost
requested.

6(
c)
Estimating
Agency
Burden
and
Costs
Because
the
information
collection
requirements
were
estimated
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
In
addition,
no
operational
costs
will
be
incurred
by
the
Federal
Government
because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
Act.
Publication
and
distribution
of
the
information
are
part
of
EPA's
Compliance
Data
System,
with
the
result
that
no
Federal
costs
can
be
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
the
EPA's
overall
compliance
and
enforcement
program
and,
therefore,
is
not
attributable
to
the
ICR.

The
only
costs
that
the
Federal
Government
will
incur
are
user
costs
associated
with
the
analysis
of
the
information
reported
by
the
sources
in
one­
time
reports
and
semiannual
or
quarterly
reports
(
unless
the
compliance
report
indicates
a
violation,
thereby
triggering
an
enforcement
action).
Tables
2a,
2b,
and
2c
represent
the
estimated
annual
burden
to
the
Federal
Government
during
the
first,
second,
and
third
years
after
the
effective
date
of
the
standards.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
Costs
The
number
of
existing
sources
subject
to
NESHAP
Subpart
MMM
is
78.
The
number
of
new
sources
subject
to
NESHAP
Subpart
MMM
is
6.
An
estimated
2
new
sources
per
year
will
be
added
to
the
respondent
universe.
Total
annual
labor
costs
are
$
2,953,153
and
total
annualized
capital
and
O&
M
costs
are
$
2,235,000.

6(
e)
Bottom
Line
Burden
Hours
and
Costs/
Master
Tables
(
i)
The
simple
collection
See
Tables
1a
through
1d
on
pages
12­
15
for
determinations
of
respondent
implementation
and
recurrent
costs.
The
burden
totals
and
calculated
costs
from
these
tables
are
summarized
in
table
1e,
below.
9
Table
1e.
Summary
of
Annual
Burden
to
Respondents.

Total
burden,
hours
Total
costs,
$

Table
1a
(
one­
time
activities
in
first
year)
3,052
$
167,677
Table
1b
(
recurrent
activities
in
first
year)
7,306
$
401,392
Table
1c
(
one­
time
activities
in
second
year)
29,493
$
1,620,345
Table
1c
(
one­
time
activities
in
third
year)
978
$
53,731
Table
1d
(
recurrent
activities
in
second
year)
59,532
$
3,270,688
Table
1d
(
recurrent
activities
in
third
year)
60,896
$
3,345,626
Total
161,257
$
8,859,459
Bottom
line
annual
burden
53,752
$
2,953,153
(
ii)
The
Agency
tally
See
Tables
2a,
2b,
and
2c
on
pages
16­
18
for
determination
of
Agency
costs.
Table
2d
below
summarizes
the
costs
in
this
table.

Table
2d.
Summary
of
Agency
Burden
Total
burden,
hours
Total
costs,
$

Table
2a
(
first
year)
2,756
$
109,201
Table
2b
(
second
year)
5,944
$
240,861
Table
2c
(
third
year)
2,734
$
108,337
Total
11,434
$
458,399
Bottom
line
annual
burden
3,811
$
152,800
(
iii)
The
complex
collection
This
section
does
not
apply
because
this
is
a
simple
collection.

(
iv)
Variations
in
the
annual
bottom
line
The
annual
burden
hours
and
costs
associated
with
one­
time
activities
vary
over
the
course
of
the
3­
year
review
period
because
existing
sources
are
subject
to
different
requirements
in
each
year
as
follows:
(
1)
notification
of
performance
tests,
CMS
performance
evaluation,
and
10
submission
of
precompliance
reports
in
the
first
year;
(
2)
developing
and
submitting
an
emissions
averaging
plan
(
if
appropriate),
notification
of
compliance
status
in
the
second
year;
and
(
3)
recordkeeping
and
reporting
in
the
second
and
third
(
and
subsequent)
years
for
all
facilities.
The
burden
associated
with
recurrent
activities
increases
each
year
(
by
a
constant
amount)
because
additional
new
and
reconstructed
facilities
are
subject
to
the
standard.
The
respondent
annual
burden
hours
and
costs
for
the
three
years
of
this
ICR
are
shown
in
Tables
1a­
1d.
The
EPA
burden
hours
and
costs
will
also
vary
over
the
3­
year
review
period
because
they
will
be
reviewing
the
initial
notifications,
the
emissions
averaging
plan
(
if
appropriate),
the
precompliance
plan,
and
the
notifications
of
performance
tests
and
CMS
performance
evaluations.
The
EPA
will
also
review
notifications
and
compliance
reports
for
new
sources
over
the
three
years
as
they
are
constructed/
reconstructed
and
as
startup
begins.
Tables
2a,
2b,
and
2c
present
the
EPA
burden
hours
and
costs
of
each
of
the
3
years
of
this
ICR.

6(
f)
Reasons
for
Change
in
Burden
The
reason
for
the
change
in
burden
is
a
program
change.
This
ICR
encompasses
the
compliance
date
whereafter
the
existing
78
sources
must
perform
the
reporting
and
recordkeeping
activities
addressed
by
this
ICR.
The
previous
ICR
addressed
pre­
compliance
activities
for
these
facilities,
and
full
compliance
activities
only
for
the
estimated
two
new
sources
per
year
that
were
required
to
comply
immediately
upon
the
effective
date
of
the
rule.
Therefore,
this
ICR
represents
a
significant
change
in
burden
from
the
previous
ICR.

6(
g)
Burden
Statement
(
i)
The
EPA
is
required
under
section
112(
d)
of
the
Act
to
regulate
emissions
of
HAP's
listed
in
section
112(
b).

(
ii)
The
information
is
needed
as
part
of
the
overall
compliance
and
enforcement
program.
The
information
in
the
one­
time
notification
of
compliance
status
will
be
stored
in
EPA's
Compliance
Data
System
and
will
be
available
to
stakeholders.

(
iii)
The
total
annual
reporting
and
recordkeeping
burden
for
this
collection
is
estimated
to
be
53,752
hours,
or
$
2,953,153
per
year
for
the
entire
source
category.
The
average
burden
per
respondent
(
the
average
number
of
respondents
over
the
three
year
period
of
the
ICR
is
86)
is
625
hours
per
year.
During
these
three
years,
the
rule
requires
several
initial
one­
time
notifications
and
reports
from
all
facilities.
In
addition,
new
and
reconstructed
sources
are
required
to
submit
an
initial
one­
time
notification
of
compliance
status
and
subsequent
notification
semiannually
or
quarterly
to
indicate
their
ongoing
compliance
status.
Each
respondent
also
must
keep
necessary
records
of
data
to
determine
compliance
with
the
NESHAP.
In
the
first
year,
the
collection
requirements
would
be
applicable
to
an
estimated
84
respondents,
and
an
estimated
2
additional
facilities
will
be
subject
to
the
standard
in
each
subsequent
year.
This
estimate
of
the
average
burden
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;
11
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
and
search
data
sources.
Send
comments
on
the
EPA'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,
OEI
Collection
Strategies
Division;
U.
S.
Environmental
Protection
Agency
(
2137),
401
M
Street
S.
W.,
Washington,
DC
20460,
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street
N.
W.,
Washington,
DC
20503,
marked
"
Attention:
Desk
Officer
for
EPA."
Include
the
ICR
number
1807.02
and
OMB
Control
Number
2060­
0370
in
any
correspondence.

(
iv)
Capital
costs
for
the
three
year
period
of
this
ICR
are
estimated
to
total
$
4.81
million
for
performance
tests,
$
0.02
million
for
file
storage,
and
$
1.80
million
for
data
acquisition
systems.
This
is
a
total
of
$
6.63
million,
and
an
average
annual
capital
cost
of
$
2.21
million.
The
total
annualized
cost
is
approximately
$
2,235,000.
The
total
annual
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR
are
$
25,500.

(
v)
The
respondents
would
be
subject
to
applicable
recordkeeping,
reporting,
and
other
requirements
in
40
CFR
63.9
and
63.10,
the
General
Provisions
for
the
part
63
rules.

(
vi)
All
information
submitted
to
the
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
EPA
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B­­
Confidentiality
of
Information
(
see
40
CFR
part
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
39999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).

(
vii)
The
EPA
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
the
EPA's
regulations
are
listed
in
a
table
in
40
CFR
part
9.
The
EPA
will
amend
part
9
when
the
ICR
is
approved.
12
TABLE
1a.
ESTIMATED
LABOR
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
LAST
YEAR
PRIOR
TO
COMPLIANCE
DATE
(
2001)

Burden
Item
(
a)
A
Person­
hours
per
occurrence
B
Number
of
occurrences
per
year
C
Person­
hour
per
respondent
per
year
(
C=
A*
B)
D
Respondents
Per
Year
E
Total
Burden
Hours
1st
Year
(
E=
C*
D)

1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
(
c,
d)
2
1
2
2
4
B.
Required
Activities
Performance
evaluation
test
(
certification
of
CMS)
(
d,
e)
13
6
77
3
230
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
Notification
of
construction/
reconstruction
(
d)
2
1
2
3
6
Notification
of
anticipated
startup
(
d)
2
1
2
3
6
Notification
of
actual
start­
up
(
d)
2
1
2
3
6
Notification
of
applicability
of
the
standard
­
Existing
source
(
d)
2
1
2
0
0
­
New
source
(
d)
2
1
2
2
4
Emissions
averaging
plan
(
f)
40
1
40
0
0
Precompliance
plan
(
g)
40
1
40
40
1,600
Notification
of
initial
performance
test(
s)
(
d,
h)
2
1
2
70
140
Notification
of
initial
CMS
performance
evaluation
(
d)
2
1
2
78
156
Notification
of
compliance
status
­
With
performance
test
(
h,
i)
80
1
80
3
240
­
Without
performance
test
(
j)
120
1
120
0
0
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
record
system
(
k)
40
1
40
3
120
E.
Develop
startup,
shutdown,
and
malfunction
plan
(
l)
100
1
100
3
300
F.
Develop
QA/
QC
plan
for
CMS
(
m)
40
1
40
3
120
G.
Time
to
train
personnel
(
n)
40
1
40
3
120
H.
Time
for
audits
N/
A
Total
3052
(
a)
See
attachment
2
for
further
explanation
of
respondent
activities.
(
b)
Costs
are
based
on
the
technical
hourly
rate
of
$
54.94,
which
includes
an
overhead
adjustment
of
110%
of
the
hourly
rate.
(
c)
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.
(
d)
There
were
an
estimated
78
existing
major
source
facilities
subject
to
the
NESHAP
at
the
time
of
rulemaking.
Assuming
2
percent
growth
per
year,
2
new
facilities
will
be
built
each
year.
Also
assumes
1
existing
facilitywill
be
reconstructed
each
year.
(
e)
Person­
hours
per
occurrence
were
computed
in
1997
based
on
the
performance
specification
costs
to
certify
CMS
($
500)
divided
by
the
composite
hourly
labor
rate
at
that
time.
Facilities
will
each
conduct
6
initial
CMS
performance
evaluations
(
assume
3
for
process
vents
and
3
for
wastewater
per
facility).
(
f)
Assumes
10
percent
of
facilities
will
comply
with
emissions
averaging
requirements;
new
facilities
are
not
allowed
to
use
emissions
averaging.
(
g)
Assumes
50
percent
of
facilities
will
submit
a
precompliance
plan.
(
h)
Assumes
90
percent
of
facilities
will
conduct
a
performance
test.
(
i)
The
notification
of
compliance
status
includes
the
report
of
the
performance
test
and
report
of
the
CMS
performance
evaluation.
(
j)
Assumes
10
percent
of
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
The
notification
of
compliance
status
includes
those
calculations
and
the
report
of
CMS
performance
evaluations.
(
k)
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.
(
l)
Assumes
1
person
would
require
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
then
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.
(
m)
Assumes
40
hours
to
develop
and
review
the
QA/
QC
plan
for
the
CMS.
(
n)
Assumes
40
hours
to
train
personnel.
13
TABLE
1b.
ESTIMATED
RECURRENT
LABOR
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
LAST
YEAR
PRIOR
TO
COMPLIANCE
DATE
(
2001)

Burden
Item
(
a)
A
Person­
hours
per
occurrence
B
Number
of
occurrences
per
year
C
Person­
hour
per
respondent
per
year
(
C=
A*
B)
D
Respondents
Per
Year
E
Total
Burden
Hours
1st
Year
(
E=
C*
D)

1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
N/
A
B.
Required
Activities
N/
A
C.
Create
Information
N/
A
D.
Gather
Existing
Information
N/
A
E.
Write
Periodic
Report
(
c)
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
(
d,
e)
24
4
96
2
192
Semiannual
reporting
of
no
exceedances
(
e,
f)
8
2
16
7
112
LDAR
Reporting
(
g)
94
2
188
9
1,692
Annual
emissions
averaging
plan
report
(
h)
20
1
20
0
0
4.
Recordkeeping
Requirements
A.
Read
Instructions
N/
A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
Records
of
startup,
shutdown,
and
malfunction
1.5
52
78
9
702
Records
of
CMS
data
Record
continuously
monitored
parameters
(
e)
1
320
320
9
2,880
Compile
data
(
e)
24
4
96
9
864
Enter/
verify
information
for
semiannual
reports
(
e)
16
2
32
9
288
LDAR
Recordkeeping
Included
in
3E
F.
Calibration
of
CMS
(
i)
48
1
48
9
432
G.
Time
to
train
personnel
N/
A
H.
Time
for
refresher
training
for
personnel
(
j)
16
1
16
9
144
I.
Time
for
audits
N/
A
Total
7,306
(
a)
See
attachment
2
for
further
explanation
of
respondent
activities.
(
b)
Costs
are
based
on
the
technical
hourly
rate
of
$
54.94,
which
includes
an
overhead
adjustment
of
110%
of
the
hourly
rate.
(
c)
There
were
an
estimated
78
existing
major
source
facilities
subject
to
the
NESHAP
at
the
time
of
rulemaking.
Assuming
2
percent
growth
per
year,
2
new
facilities
will
be
built
each
year.
Also
assumes
1
existing
facilitywill
be
reconstructed
each
year.
The
number
of
respondents
per
year
is
based
on
the
average
number
of
respondents
(
6)
over
the
three
years
following
the
effective
date.
(
d)
Assumes
10
percent
of
facilities
will
have
exceedances
and
periods
of
noncompliance.
(
e)
This
entry
includes
process
vent,
storage
tank,
and
wastewater
monitoring
and
inspections.
(
f)
Assumes
90
percent
of
facilities
will
have
no
exceedances.
(
g)
According
to
EPA
guidance,
annual
recordkeeping
and
reporting
costs
for
the
Reg
Neg
LDAR
program
are
estimated
to
be
40
percent
of
initial
and
annual
monitoring
and
repair
labor.
In
1997
this
was
computed
at
$
9,246
per
facility
(
40%
x
$
9,246
=
$
3,698
per
facility).
Person­
hours
per
occurrence
were
based
on
this
cost
divided
by
the
composite
hourly
labor
rate
at
that
time.
Both
recordkeeping
costs
and
reporting
costs
are
included
in
this
entry.
(
h)
Assumes
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements;
new
facilities
are
not
allowed
to
use
emissions
averaging.
(
i)
Assumes
calibration
of
the
CMS
will
require
8
hours
per
year
for
each
monitor.
Assuming
a
total
of
6
monitoring
parameters
for
each
facility,
a
total
of
48
hours
per
year
per
facility
is
required.
(
j)
Assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.
14
TABLE
1c.
ESTIMATED
ONE­
TIME
LABOR
FOR
INDUSTRY
TO
IMPLEMENT
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
FIRST
YEAR
AND
SUBSEQUENT
YEARS
FOLLOWING
THE
COMPLIANCE
DATE
(
2002
AND
2003)

Burden
Item
(
a)
A
Person­
hours
per
occurrence
B
Number
of
occurrences
per
year
C
Person­
hour
per
respondent
per
year
(
C=
A*
B)
D
Respondents
First
year
after
the
compliance
date
E
Respondents
Subsequent
years
Burden
hours­
1st
yr
after
c.
d.
Burden
hourssub
yrs
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
(
b)
2
1
2
2
2
4
4
B.
Required
Activities
Performance
evaluation
test
(
certification
of
CMS)
(
c)
13
6
77
77
2
5929
154
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
Notification
of
construction/
reconstruction
(
d)
2
1
2
3
3
6
6
Notification
of
process
changes
(
e)
8
1
8
8
8
64
64
Notification
of
anticipated
startup
(
d)
2
1
2
3
3
6
6
Notification
of
actual
start­
up
(
d)
2
1
2
3
3
6
6
­
Existing
source
(
b)
2
1
2
0
0
0
0
­
New
source
(
b)
2
1
2
3
3
6
6
Precompliance
report
(
f)
40
1
40
1
1
40
40
Notification
of
initial
performance
test(
s)
(
b,
g)
2
1
2
3
3
6
6
Notification
of
CMS
performance
evaluation
(
b)
2
1
2
3
3
6
6
Notification
of
compliance
status
­
With
performance
test
(
g,
h)
80
1
80
69
3
5520
240
­
Without
performance
test
(
i)
120
1
120
8
0
960
0
Emissions
averaging
plan
(
j)
40
1
40
0
0
0
0
4.
Recordkeeping
Requirements
(
k)
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
record
system
(
l)
40
1
40
77
2
3080
80
E.
Develop
startup,
shutdown,
and
malfuction
plan
(
m)
100
1
100
77
2
7700
200
F.
Develop
QA/
QC
plan
for
CMS
(
n)
40
1
40
77
2
3080
80
G.
Time
to
train
personnel
(
o)
40
1
40
77
2
3080
80
H.
Time
for
audits
N/
A
Total
29493
978
(
a)
See
attachment
2
for
further
explanation
of
respondent
activities.
(
b)
There
were
an
estimated
78
existing
major
source
facilities
subject
to
the
NESHAP
at
the
time
of
rulemaking.
Assuming
2
percent
growth
per
year,
2
new
facilities
will
be
built
each
year.
In
addition,
one
existing
facility
was
estimated
to
be
reconstructed
in
each
year,
including
each
of
3
years
prior
to
the
compliance
date.
(
c)
Person­
hours
per
occurrence
were
computed
in
1997
based
on
the
performance
specification
costs
to
certify
CMS
($
500)
divided
by
the
composite
hourly
labor
rate
at
that
time.
Facilities
will
each
conduct
6
initial
CMS
performance
evaluations
(
assume
3
for
process
vents
and
3
for
wastewater
per
facility).
(
d)
Assumes
there
will
be
growth
of
2
percent
per
year
(
2
facilities)
and
that
1
existing
facility
will
be
reconstructed
each
year.
(
e)
Assumes
10
percent
of
existing
facilities
will
implement
process
changes.
(
f)
Assumes
50
percent
of
new
or
reconstructed
facilities
will
submit
a
precompliance
report
with
their
notificationof
construction/
reconstruction.
(
g)
Assumes
90
percent
of
facilities
will
conduct
a
performance
test.
(
h)
The
notification
of
compliance
status
includes
the
report
of
the
performance
test
and
report
of
the
CMS
performance
evaluation.
(
i)
Assumes
10
percent
of
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
The
notification
of
compliance
status
includes
those
calculations
and
the
report
of
CMS
performance
evaluation.
(
j)
Assumes
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements;
new
facilities
are
not
allowed
to
use
emissions
averaging.
(
k)
Number
of
respondents
in
subsequent
years
assumes
reconstructed
sources
do
not
need
to
develop
a
new
record
system;
startup,
shutdown,
and
malfunction
plan;
or
QA/
QC
plan,
or
retrain
personnel.
(
l)
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.
(
m)
Assumes
1
person
would
require
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
then
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.
(
n)
Assumes
40
hours
to
develop
and
review
the
QA/
QC
plan
for
the
CMS.
(
o)
Assumes
40
hours
to
train
personnel.
15
TABLE
1d.
ESTIMATED
RECURRENT
LABOR
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
RECORDKEEPING
AND
REPORTING
REQUIREMENTS
FIRST
YEAR
AND
SUBSEQUENT
YEAR
FOLLOWING
THE
COMPLIANCE
DATE
(
2002
AND
2003)

Burden
Item
(
a)
A
Person­
hours
per
occurrence
B
Number
of
occurrences
per
year
C
Person­
hour
per
respondent
per
year
(
C=
A*
B)
D
Respondents­
First
year
after
the
compliance
date
E
Respondents­
Second
year
after
compliance
date
Burden
hours,
first
yr
after
c.
d.
Burden
hours,
second
yr
after
c.
d.

1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructions
N/
A
B.
Required
Activities
N/
A
C.
Create
Information
N/
A
D.
Gather
Existing
Information
N/
A
E.
Write
Periodic
Report
(
b)
Quarterly
report
of
monitoring
exceedances
and
periods
of
noncompliance
(
c,
d)
24
4
96
9
9
864
864
Semiannual
reporting
of
no
exceedances
(
d,
e)
8
2
16
77
79
1232
1264
LDAR
Reporting
(
f)
94
2
188
86
88
16168
16544
Emissions
averaging
plan
(
g)
20
1
20
8
8
160
160
4.
Recordkeeping
Requirements
A.
Read
Instructions
N/
A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
Records
of
startup,
shutdown,
and
malfunction
1.5
52
78
86
88
6708
6864
Records
of
CMS
data
Record
continuously
monitored
parameters
(
d)
1
320
320
86
88
27520
28160
Enter/
verify
information
for
semiannual
reports
(
d)
16
2
32
86
88
2752
2816
LDAR
Recordkeeping
Included
in
3E
F.
Calibration
of
CMS
(
h)
48
1
48
86
88
4128
4224
G.
Time
to
train
personnel
N/
A
H.
Time
for
audits
N/
A
Total
59532
60896
(
a)
See
attachment
2
for
further
explanation
of
respondent
activities.
(
b)
There
were
an
estimated
78
existing
major
source
facilities
subject
to
the
NESHAP
at
the
time
of
rulemaking.
Assuming
2
percent
growth
per
year,
2
new
facilities
will
be
built
each
year.
(
c)
Assumes
10
percent
of
facilities
will
have
exceedances
and
periods
of
noncompliance.
(
d)
This
entry
includes
process
vent,
storage
tank,
and
wastewater
monitoring
and
inspections.
(
e)
Assumes
90
percent
of
facilities
will
have
no
exceedances.
(
f)
According
to
EPA
guidance,
annual
recordkeeping
and
reporting
costs
for
the
Reg
Neg
LDAR
program
are
estimated
to
be
40
percent
of
initial
and
annual
monitoring
and
repair
labor.
In
1997
this
was
computed
at
$
9,246
per
facility
(
40%
x
$
9,246
=
$
3,698
per
facility).
Person­
hours
per
occurrence
were
based
on
this
cost
divided
by
the
composite
hourly
labor
rate
at
that
time.
Both
recordkeeping
costs
and
reporting
costs
are
included
in
this
entry.
(
g)
Assumes
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements;
new
sources
are
not
allowed
to
use
emissions
averaging.
(
h)
Assumes
calibration
of
the
CMS
will
require
8
hours
per
year
for
each
monitor.
Assuming
a
total
of
6
monitoring
parameters
for
each
facility,
a
total
of
48
hours
per
year
per
facility
is
required.
16
TABLE
2a.
ESTIMATE
OF
ANNUAL
LABOR
AND
COST
TO
FEDERAL
GOVERNMENT
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIRST
YEAR
A
B
C
Activity
EPA­
Hours
per
operation
Operations
per
year
Technical
person­
hours
per
year
(
C=
A*
B)
(
a)

1.
Attend
performance
test
(
b,
c,
d)
40
1
40
2.
Attend
repeat
performance
test
(
e)
40
0
0
3.
Attend
performance
evaluation
test
2
4
8
(
certification
of
CMS)
(
b,
d)
4.
Litigation
(
f)
2,080
1
2080
5.
Report
review
A.
Review
of
notification
of
construction/
reconstruction
(
g,
h)
2
3
6
B.
Review
of
notification
of
process
changes
(
g,
h)
8
0
0
C.
Review
of
notification
of
anticipated
startup
(
g,
h)
2
3
6
D.
Review
of
actual
startup
notification
(
g,
h)
2
3
6
E.
Review
of
notification
of
applicability
of
standard
(
b)
2
2
4
F.
Review
of
precompliance
report
(
i)
4
40
160
G.
Review
of
notification
of
performance
test
(
b,
c)
2
70
140
H.
Review
of
notification
of
CMS
performance
evaluation
(
b)
2
78
156
I.
Review
of
notification
of
compliance
status
­
With
performance
test
(
j)
40
3
120
­
Without
performance
test
(
j)
40
0
0
K.
Review
of
emissions
averaging
plan
(
l)
20
0
0
L.
Review
of
semi­
annual
reporting
of
no
exceedances
(
m)
2
7
14
M.
Review
of
quarterly
report
of
monitoring
8
2
16
exceedances
and
periods
of
noncompliance
(
n)
TOTAL
BURDEN
2756
COST
(
SALARY)
@$
39.26/
hr
(
a)
$
108,201
TRAVEL
EXPENSES
FOR
TEST
ATTENDED
(
o)
=
(
1
person
*
2
facilities/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
1
round
trips/
yr)
=
$
1000
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES
$
109,201
(
a)
Assume
technical
rate
of
GS­
10/
1
plus
110%
OVH
(
b)
In
1997
there
were
an
estimated
78
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
per
year,
2
new
facilities
will
be
built
each
year.
(
c)
Assume
90
percent
of
facilities
will
conduct
a
performance
test.
(
d)
Assumes
EPA
personnel
will
attend
10
percent
of
these
tests
(
because
this
is
a
fraction
of
a
facility,
assume
1
facility).
(
e)
Assumes
that
5
percent
of
facilities
will
repeat
the
performance
test
and
that
EPA
personnel
will
attend
10
percent
of
the
repeat
tests.
(
f)
Assumes
1
percent
of
facilities
will
be
involved
in
litigation
(
because
this
is
a
fraction
of
a
facility,
assume
1
facility).
(
g)
One­
time
only
cost.
This
cost
will
occur
prior
to
the
first
year,
but
it
is
included
in
first
year
cost.
(
h)
Assumes
10
percent
of
existing
facilities
will
require
process
changes
and
assume
there
will
be
a
growth
of
2
percent
per
year.
(
i)
Assumes
50
percent
of
facilities
will
submit
a
precompliance
report.
(
j)
Assumes
90
percent
of
facilities
will
conduct
a
performance
test.
The
notification
of
compliance
status
includes
the
performance
test
report
and
the
report
of
CMS
performance
evaluation.
(
k)
Assumes
10
percent
of
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
The
notification
of
compliance
status
includes
these
calculations
and
the
report
of
CMS
performance
evaluation.
(
l)
Assumes
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements;
new
sources
are
not
allowed
to
use
emissions
averaging.
(
m)
Assumes
90
percent
of
facilities
will
have
no
exceedances.
3
facilities
reporting
twice
per
year
is
6
operations.
(
n)
Assumes
10
percent
of
facilities
will
have
excess
emissions
and
periods
of
noncompliance.
No
facilities
reporting
4
times
per
year
is
0
operations.
(
o)
Tests
attended
include
1
initial
performance
test,
no
repeat
performance
tests,
for
a
total
of
1
tests
attended
(
assumes
CMS
performance
evaluations
occur
at
the
same
time
as
the
performance
tests).
17
TABLE
2b.
ESTIMATE
OF
ANNUAL
LABOR
AND
COST
TO
FEDERAL
GOVERNMENT
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIRST
YEAR
A
B
C
Activity
EPA­
Hours
per
operation
Operations
per
year
Technical
person­
hours
per
year
(
C=
A*
B)
(
a)

1.
Attend
performance
test
(
b,
c,
d)
40
7
280
2.
Attend
repeat
performance
test
(
e)
40
0
0
3.
Attend
performance
evaluation
test
2
8
16
(
certification
of
CMS)
(
b,
d)
4.
Litigation
(
f)
2,080
1
2080
5.
Report
review
A.
Review
of
notification
of
construction/
reconstruction
(
g,
h)
2
3
6
B.
Review
of
notification
of
process
changes
(
g,
h)
8
8
64
C.
Review
of
notification
of
anticipated
startup
(
g,
h)
2
3
6
D.
Review
of
actual
startup
notification
(
g,
h)
2
3
6
E.
Review
of
notification
of
applicability
of
standard
(
b)
2
2
4
F.
Review
of
precompliance
report
(
i)
4
1
4
G.
Review
of
notification
of
performance
test
(
b,
c)
2
3
6
H.
Review
of
notification
of
CMS
performance
evaluation
(
b)
2
3
6
I.
Review
of
notification
of
compliance
status
­
With
performance
test
(
j)
40
69
2760
­
Without
performance
test
(
j)
40
8
320
K.
Review
of
emissions
averaging
plan
(
l)
20
8
160
L.
Review
of
semi­
annual
reporting
of
no
exceedances
(
m)
2
77
154
M.
Review
of
quarterly
report
of
monitoring
8
9
72
exceedances
and
periods
of
noncompliance
(
n)
TOTAL
BURDEN
5944
COST
(
SALARY)
@$
39.26/
hr
(
a)
$
233,361
TRAVEL
EXPENSES
FOR
TEST
ATTENDED
(
o)
=
(
1
person
*
15
facilities/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
1
round
trips/
yr)
=
$
7500
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES
$
240,861
(
a)
Assume
technical
rate
of
GS­
10/
1
plus
110%
OVH
(
b)
In
1997
there
were
an
estimated
78
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
per
year,
2
new
facilities
will
be
built
each
year.
(
c)
Assume
90
percent
of
facilities
will
conduct
a
performance
test.
(
d)
Assumes
EPA
personnel
will
attend
10
percent
of
these
tests
(
because
this
is
a
fraction
of
a
facility,
assume
1
facility).
(
e)
Assumes
that
5
percent
of
facilities
will
repeat
the
performance
test
and
that
EPA
personnel
will
attend
10
percent
of
the
repeat
tests.
(
f)
Assumes
1
percent
of
facilities
will
be
involved
in
litigation
(
because
this
is
a
fraction
of
a
facility,
assume
1
facility).
(
g)
One­
time
only
cost.
This
cost
will
occur
prior
to
the
first
year,
but
it
is
included
in
first
year
cost.
(
h)
Assumes
10
percent
of
existing
facilities
will
require
process
changes
and
assume
there
will
be
a
growth
of
2
percent
per
year.
(
i)
Assumes
50
percent
of
facilities
will
submit
a
precompliance
report.
(
j)
Assumes
90
percent
of
facilities
will
conduct
a
performance
test.
The
notification
of
compliance
status
includes
the
performance
test
report
and
the
report
of
CMS
performance
evaluation.
(
k)
Assumes
10
percent
of
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
The
notification
of
compliance
status
includes
these
calculations
and
the
report
of
CMS
performance
evaluation.
(
l)
Assumes
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements;
new
sources
are
not
allowed
to
use
emissions
averaging.
(
m)
Assumes
90
percent
of
facilities
will
have
no
exceedances.
3
facilities
reporting
twice
per
year
is
6
operations.
(
n)
Assumes
10
percent
of
facilities
will
have
excess
emissions
and
periods
of
noncompliance.
No
facilities
reporting
4
times
per
year
is
0
operations.
(
o)
Tests
attended
include
1
initial
performance
test,
no
repeat
performance
tests,
for
a
total
of
1
tests
attended
(
assumes
CMS
performance
evaluations
occur
at
the
same
time
as
the
performance
tests).
18
TABLE
2c.
ESTIMATE
OF
ANNUAL
LABOR
AND
COST
TO
FEDERAL
GOVERNMENT
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIRST
YEAR
A
B
C
Activity
EPA­
Hours
per
operation
Operations
per
year
Technical
person­
hours
per
year
(
C=
A*
B)
(
a)

1.
Attend
performance
test
(
b,
c,
d)
40
1
40
2.
Attend
repeat
performance
test
(
e)
40
0
0
3.
Attend
performance
evaluation
test
2
1
2
(
certification
of
CMS)
(
b,
d)
4.
Litigation
(
f)
2,080
1
2080
5.
Report
review
A.
Review
of
notification
of
construction/
reconstruction
(
g,
h)
2
3
6
B.
Review
of
notification
of
process
changes
(
g,
h)
8
8
64
C.
Review
of
notification
of
anticipated
startup
(
g,
h)
2
3
6
D.
Review
of
actual
startup
notification
(
g,
h)
2
3
6
E.
Review
of
notification
of
applicability
of
standard
(
b)
2
2
4
F.
Review
of
precompliance
report
(
i)
4
1
4
G.
Review
of
notification
of
performance
test
(
b,
c)
2
3
6
H.
Review
of
notification
of
CMS
performance
evaluation
(
b)
2
3
6
I.
Review
of
notification
of
compliance
status
­
With
performance
test
(
j)
40
3
120
­
Without
performance
test
(
j)
40
0
0
K.
Review
of
emissions
averaging
plan
(
l)
20
8
160
L.
Review
of
semi­
annual
reporting
of
no
exceedances
(
m)
2
79
158
M.
Review
of
quarterly
report
of
monitoring
8
9
72
exceedances
and
periods
of
noncompliance
(
n)
TOTAL
BURDEN
2734
COST
(
SALARY)
@$
39.26/
hr
(
a)
$
107,337
TRAVEL
EXPENSES
FOR
TEST
ATTENDED
(
o)
=
(
1
person
*
2
facilities/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip*
1
round
trips/
yr)
=
$
7500
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES
$
108,337
(
a)
Assume
technical
rate
of
GS­
10/
1
plus
110%
OVH
(
b)
In
1997
there
were
an
estimated
78
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
per
year,
2
new
facilities
will
be
built
each
year.
(
c)
Assume
90
percent
of
facilities
will
conduct
a
performance
test.
(
d)
Assumes
EPA
personnel
will
attend
10
percent
of
these
tests
(
because
this
is
a
fraction
of
a
facility,
assume
1
facility).
(
e)
Assumes
that
5
percent
of
facilities
will
repeat
the
performance
test
and
that
EPA
personnel
will
attend
10
percent
of
the
repeat
tests.
(
f)
Assumes
1
percent
of
facilities
will
be
involved
in
litigation
(
because
this
is
a
fraction
of
a
facility,
assume
1
facility).
(
g)
One­
time
only
cost.
This
cost
will
occur
prior
to
the
first
year,
but
it
is
included
in
first
year
cost.
(
h)
Assumes
10
percent
of
existing
facilities
will
require
process
changes
and
assume
there
will
be
a
growth
of
2
percent
per
year.
(
i)
Assumes
50
percent
of
facilities
will
submit
a
precompliance
report.
(
j)
Assumes
90
percent
of
facilities
will
conduct
a
performance
test.
The
notification
of
compliance
status
includes
the
performance
test
report
and
the
report
of
CMS
performance
evaluation.
(
k)
Assumes
10
percent
of
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
The
notification
of
compliance
status
includes
these
calculations
and
the
report
of
CMS
performance
evaluation.
(
l)
Assumes
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements;
new
sources
are
not
allowed
to
use
emissions
averaging.
(
m)
Assumes
90
percent
of
facilities
will
have
no
exceedances.
3
facilities
reporting
twice
per
year
is
6
operations.
(
n)
Assumes
10
percent
of
facilities
will
have
excess
emissions
and
periods
of
noncompliance.
No
facilities
reporting
4
times
per
year
is
0
operations.
(
o)
Tests
attended
include
1
initial
performance
test,
no
repeat
performance
tests,
for
a
total
of
1
tests
attended
(
assumes
CMS
performance
evaluations
occur
at
the
same
time
as
the
performance
tests).
19
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
this
regulation.
ATTACHMENT
1
Source
Data
and
Information
Requirements
SUMMARY
OF
RECORDKEEPING
REQUIREMENTS
Requirements
Regulation
Reference
Control
device
operating
parameters
to
monitor
and
record
63.1366(
b)(
1)
and
63.1367(
b)(
1)
and
(
b)(
5)

Monitoring
and
records
for
alternative
standard
63.10(
c),
63.1366(
b)(
5),
63.1367(
a)(
4),
and
63.1367(
b)(
3)

Monitoring
and
records
for
process
vent
annual
emission
limits
standard
63.1366(
c)
and
63.1367(
b)(
4)

Monitoring
and
records
for
equipment
leaks
63.1366(
d)
and
63.1367(
c)

Monitoring
and
records
for
heat
exchanger
systems
63.1362(
f),
63.1366(
e),
and
63.1367(
e)

Monitoring
and
records
for
pollution
prevention
63.1366(
f)
and
63.1367(
b)(
2)

Monitoring
and
records
for
emissions
averaging
63.1366(
g)
and
63.1367(
d)

Records
of
process
operating
parameters
63.1367(
b)(
6)
and
(
b)(
7)

Applicability
determinations
63.10(
b)(
3)
and
63.1367(
a)(
2)

Startup,
shutdown,
and
malfunction
plan
63.6(
e)(
3)
and
63.1367(
a)(
3)

Application
for
approval
of
construction
or
reconstruction
63.5(
d)
and
63.1367(
a)(
5)

Records
for
vapor
collection
systems
and
closed­
vent
systems
63.1367(
f)

SUMMARY
OF
REPORTING
REQUIREMENTS
Requirements
Regulation
Reference
Initial
notification
63.9
and
63.1368(
b)

Application
for
approval
of
construction
or
reconstruction
63.5(
d)
and
63.1368
(
c)

Notification
of
CMS
performance
evaluation
63.8(
e)(
2)
and
63.1368(
d)

Notification
of
performance
test
and
test
plan
63.7(
c)
and
63.1368(
m)

Request
for
extension
of
compliance
63.1364(
a)(
2)
and
63.1368(
n)

Precompliance
report
63.1368(
e)

Request
for
approval
to
use
alternative
monitoring
parameters
63.8(
f),
63.1366(
b)(
4),
and
63.1368(
e)(
l)

Notification
of
compliance
status
report
63.9(
h)
and
63.1368(
f)

Periodic
reports
of
excess
emissions
and
noncompliance
63.10(
e)(
3)
and
63.1368(
g)

Notification
of
process
change
63.1368(
h)

Startup,
shutdown,
and
malfunction
reports
63.10(
d)(
5)
and
63.1368(
i)

Equipment
leaks
reports
63.1363(
h)
and
63.1368(
j)

Emissions
averaging
reports
63.1368(
k)

Heat
exchanger
system
reports
63.1368(
l)
ATTACHMENT
2
Description
of
Respondent
Activities
Description
of
Respondent
Activities
(
1)
Read
Rule
and
Instructions
are
the
activities,
less
training,
which
involve
comprehending
the
provisions
in
the
standard
and
understanding
how
they
apply
to
the
respective
emission
points
at
a
facility.

(
2)
Plan
Activities
represents
such
burdens
as
design,
redesign,
scheduling,
and
selecting
methods
of
compliance.
The
costs
for
planning
and
selection
are
included
in
the
capital
costs
for
the
performance
test,
as
explained
in
(
4)
below.

(
3)
Training
represents
activities
involved
in
communicating
specific
definitions,
compliance
limits,
and
other
requirements
such
as
recordkeeping,
monitoring,
and
reporting.
An
average
facility
may
elect
to
provide
classroom
instructions
for
all
workers
directly
impacted
by
the
requirements.
The
standard
does
not
require
specific
training
itself.

(
4)
Create
Information
are
the
activities
involving
testing,
retesting,
establishing
operating
range
parameters
and
analyzing
point
by
point
applicability.
Because
respondents
are
expected
to
hire
outside
contractors
to
conduct
the
performance
tests,
these
costs
are
not
included
as
labor
and
cost
burden
in
this
table;
the
costs
associated
with
the
performance
test
are
capital
costs
and
are
discussed
in
the
text.

(
5)
Gather
Information,
Monitor,
and
Inspect
are
the
activities
involving
physical
inspections
of
equipment,
collection
of
monitored
data
and
other
related
activities.
This
estimate
does
not
include
the
monitoring
of
equipment
leak
components.
The
cost
for
monitoring
equipment
leak
components
is
included
as
part
of
the
cost
of
the
leak
detection
and
repair
program.

(
6)
Reporting
represents
the
activities
normally
associated
with
filling
out
forms.
Since
the
standard
requires
no
standard
forms,
these
activities
relate
to
the
preparing
of
formal
reports
and
cover
letters
as
appropriate.

(
7)
Recordkeeping
are
the
activities
that
involve
analysis
of
the
information
collected
for
accuracy,
compliance,
and
appropriate
records
required
as
a
result;
software
translation,
duplication,
or
archival
processes
normally
associated
with
data
management
and
storage
common;
and
the
management
life
cycle
of
records,
from
the
time
they
are
filed
and
boxed
up
to
the
time
they
are
disposed
of.

TOTAL
BURDEN
AND
COST
is
the
sum
of
technical
hours
and
the
costs
associated
with
these
hours.
