1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection
"
Reporting
and
Recordkeeping
Requirements
for
the
National
Emissions
Standards
for
Hazardous
Air
Pollutants
for
Amino/
Phenolic
Resins
Production."
This
is
a
new
information
collection
request
(
ICR),
and
the
U.
S.
Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
ICR
is
1869.02.
(
b)
Short
Characterization
(
i)
Applicability:
Respondents
are
owners
and
operators
of
new
and
existing
facilities
that
engage
in
the
manufacture
of
amino/
phenolic
resins
and
emit
hazardous
air
pollutants
(
HAP's).
Forty
facilities
are
expected
to
meet
the
applicability
criteria
defined
in
the
final
rule.
No
new
facilities
are
expected
to
be
constructed
in
the
next
5
years.
For
this
reason,
burden
estimates
have
not
been
made
for
new
facilities.
(
ii)
Amino/
Phenolic
Resins
Production
Facilities:
Owners
or
operators
of
amino/
phenolic
resins
production
facilities
to
which
this
regulation
is
applicable
must
choose
one
of
the
compliance
options
described
in
the
proposed
rule,
which
may
include
installing
and
monitoring
a
specific
control
system
that
reduces
HAP
emissions
to
the
compliance
level.
The
respondents
would
be
subject
to
follow
sections
of
subpart
A
of
40
CFR
part
63
relating
to
NESHAP.
These
requirements
include
those
associated
with
the
notification
of
compliance
status
for
the
first
5
months,
and
semiannually
thereafter.
Respondents
electing
to
comply
with
the
emission
limit
or
emission
reduction
requirements
as
described
in
the
final
rule
for
batch
process
vents
or
storage
vessels
must
record
the
following:
daily
or
monthly
average
values
of
equipment
operating
parameters
and/
or
process
information
specified
to
be
monitored.
The
recorded
parameters
shall
be
calculated
as
described
in
§
63.1415
of
the
final
rule.
(
iii)
Record
Retention:
Owners
or
operators
of
amino/
phenolic
resins
manufacturing
facilities
must
maintain
a
copy
of
all
specified
records
onsite
for
a
minimum
of
5
years.
All
records
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
facilities
subject
to
the
NESHAP
are
achieving
the
standards.
(
iv)
Reports:
The
general
recordkeeping
and
reporting
requirements
of
this
subpart
are
very
similar
to
those
found
in
the
HON.
The
final
rule
also
relies
on
the
provisions
of
subpart
A
of
40
CFR
part
63.
A
table
included
in
the
final
rule
designates
which
sections
of
subpart
A
apply
to
the
final
rule.
Specific
recordkeeping
and
reporting
requirements
for
each
type
of
emission
point
are
also
included
in
the
final
rule.
The
final
rule
references
the
recordkeeping
and
reporting
requirements
from
the
Hazardous
Organic
NESHAP
(
HON)
for
continuous
process
vents,
storage
vessels,
and
equipment
leaks.
2
The
following
reports
must
be
submitted
to
the
Administrator
as
appropriate:
(
1)
Precompliance
Report,
(
2)
Notification
of
Compliance
Status,
(
3)
Periodic
Reports,
and
(
4)
Other
Reports.
The
requirements
for
each
of
the
four
reports
are
summarized
in
the
final
rule.
In
addition,
sources
complying
with
the
equipment
leak
requirements,
which
reference
40
CFR
part
63,
subpart
H,
must
follow
the
recordkeeping
and
reporting
requirements
of
40
CFR
part
63,
subpart
H.
2.
Need
For
and
Use
of
the
Collection
The
EPA
is
required
under
section
112(
d)
of
the
Clean
Air
Act
(
the
Act)
to
regulate
emissions
of
HAP's
listed
in
section
112(
b).
The
predominant
HAP's
emitted
from
amino/
phenolic
resins
production
include
formaldehyde,
methanol,
and
phenol.
In
the
Administrator's
judgement,
the
pollutants
emitted
from
amino/
phenolic
resins
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.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
identify
facilities
subject
to
the
standard
and
to
ensure
that
the
standard,
which
is
based
on
maximum
achievable
control
technology
(
MACT)
specific
to
amino/
phenolic
resins
facilities,
is
being
achieved.
All
respondents
must
submit
a
semiannual
report
of
compliance
for
batch
process
vents,
storage
vessels,
and
equipment
leaks
to
the
EPA
that
contains
all
the
information
requested
in
§
63.1417
of
the
final
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]).
(
a)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
Agency
enforcement
personnel
to
(
1)
identify
new,
modified,
reconstructed,
and
existing
facilities
subject
to
the
standards;
and
(
2)
ensure
that
MACT
is
being
properly
applied
and
that
compliance
is
being
maintained
and
documented.
In
addition,
records
and
reports
are
necessary
to
enable
the
Agency
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
facilities.
The
records
that
facilities
maintain
would
indicate
to
EPA
whether
the
owners
or
operators
are
in
compliance
with
the
standards.
Much
of
the
information
the
EPA
would
need
to
determine
compliance
would
be
recorded
and
compiled
monthly.
Such
information
would
be
reviewed
by
enforcement
personnel
during
an
inspection.
3.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
Code
Respondents
are
owners
or
operators
of
amino/
phenolic
resins
production
facilities
that
are
classified
as
major
sources
under
section
112
of
CAA.
The
primary
SIC
code
for
the
respondents
affected
by
the
rule
is
2821
(
plastic
materials
and
resins).
3
(
b)
Information
Requested
(
i)
Data
items:
Attachment
1,
Source
Data
and
Information
Requirements,
summarizes
the
recordkeeping
and
reporting
requirements.
(
ii)
Respondent
activities:
The
respondent
activities
required
by
the
standards
in
the
first
3
years
following
the
effective
date
are
listed
in
the
first
columns
of
Tables
1a
and
1b,
which
are
presented
in
section
6(
a).
Individual
tables
for
each
of
the
first
2
years
after
the
effective
date
were
developed
because
the
annual
burden
varied
between
the
first
and
second
year.
The
third
year
burden
is
expected
to
be
identical
to
the
second
year
burden.
4.
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
Agency
activities
for
the
first
3
years
following
the
effective
date
of
the
standards
are
provided
in
Tables
2a
and
2b,
and
are
discussed
in
section
6c.
Individual
tables
for
the
first
2
years
after
the
effective
date
were
developed
because
the
annual
burden
varied
between
the
first
and
second
year.
The
third
year
burden
is
expected
to
be
identical
to
the
second
year
burden.
(
b)
Collection
Methodology
and
Management
Information
contained
in
the
initial,
one­
time
only
reports
will
be
entered
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
operated
and
maintained
by
the
Agency's
Office
of
Air
Quality
Planning
and
Standards.
Data
obtained
during
periodic
visits
by
Agency
personnel,
from
records
maintained
by
the
respondents,
and
from
information
provided
in
semiannual
reports
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.
The
regulation
does
not
require
the
use
of
automated,
electronic,
mechanical,
or
other
technological
collection
techniques
or
other
forms
of
information
technology.
Although
many
of
the
large
companies
have
elaborate
collection
methods,
automated
systems
are
not
expected
to
reduce
the
burden.
(
c)
Small
Entity
Flexibility
Eleven
of
the
40
affected
facilities
in
this
source
category
are
owned
by
small
businesses
as
defined
by
the
Small
Business
Administration
(
SBA).
The
Agency
does
not
expect
that
any
amino/
phenolic
resins
production
facilities,
including
the
small
businesses,
would
experience
more
than
minimal
adverse
impacts
related
to
the
cost
of
the
required
reporting
and
recordkeeping.
(
d)
Collection
Schedule
For
all
existing
facilities,
the
initial
Notification
of
Compliance
Status
must
be
submitted
within
5
months
of
the
effective
date
of
this
standard.
Records
necessary
to
determine
compliance
would
be
compiled
on
a
monthly
basis
and
notifications
of
compliance
status
would
be
submitted
to
the
Administrator
on
a
semiannual
basis.
5.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
4
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.
(
b)
Consultations
The
EPA
advised
interested
parties
on
July
16,
1992
(
57
FR
31576)
of
the
categories
considered
as
sources
of
HAP's,
and
"
Amino
and
Phenolic
Resins
Production"
was
listed
as
a
category
of
major
sources.
No
specific
information
was
provided
with
respect
to
burden
estimates
at
that
time.
Representatives
from
other
interested
EPA
offices
and
programs,
including
State
and
Regional
environmental
agency
personnel,
participated
in
the
regulatory
development
and
were
given
opportunities
to
review
and
comment
on
the
rule
before
proposal.
Therefore,
the
EPA
believes
that
the
implication
to
other
EPA
offices
and
programs
was
adequately
considered
during
the
development
of
the
proposed
rule.
In
addition,
the
EPA
has
met
with
some
members
of
industry
concerning
the
proposed
rule.
Finally,
industry,
regulatory
authorities,
and
environmental
groups
had
the
opportunity
to
comment
on
the
rule
and
provide
additional
information
during
the
public
comment
period
following
proposal.
No
public
comments
were
received
regarding
any
aspect
of
the
information
collection.
(
c)
Effects
of
Less
Frequent
Collection
If
the
relevant
information
were
collected
less
frequently
by
the
owner
or
operator,
the
EPA
would
not
be
reasonably
assured
that
a
facility
is
in
compliance
with
the
standards.
Less
frequent
collection
could
result
in
longterm
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
lower
burden.
(
d)
General
Guidelines
This
ICR
requires
that
amino/
phenolic
resins
production
facilities
retain
records
of
control
device
monitoring
or
HAP
emissions
calculations
records
at
facilities
for
a
period
of
5
years,
which
exceeds
the
3­
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.5;
however,
the
5­
year
period
is
consistent
with
the
General
Provisions
to
40
CFR
part
63
and
the
permit
requirements
under
40
CFR
part
70.
All
facilities
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
4
CFR
1320.6
are
being
exceeded.
(
e)
Confidentiality
All
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B­­
Confidentiality
of
Business
Information
(
see
40
CFR
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).
5
6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
The
annual
burden
estimates
for
reporting
and
recordkeeping
activities
are
presented
in
Tables
1a
and
1b.
Individual
tables
for
the
first
2
years
after
the
effective
date
were
developed
because
the
annual
burden
varied
between
the
first
and
second
year.
The
third
year
burden
is
expected
to
be
identical
to
the
second
year
burden.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
the
Agency's
experience
with
other
standards.
These
costs
represent
the
average
burden
that
will
be
incurred
by
facilities
and
the
entire
industry
in
the
first
3
years
after
the
standards
go
into
effect.
(
b)
Estimating
Respondent
Costs
Labor
costs
for
the
information
collection
activities
at
amino/
phenolic
resins
production
facilities
are
also
presented
in
Tables
1a
and
1b.
Labor
rates
and
associated
costs
are
based
on
estimated
hourly
rates
of
technical
at
$
45,
management
at
$
67,
and
clerical
at
$
21.
TABLE
1a.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
­­
FIRST
YEAR
6
Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Person­
hrs.
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.

per
year
(
E=
C*
D)
(
F)
Management
person­
hrs.
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hrs.

per
year
(
G=
E*
0.1)
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
60
1
60
40
2400
120
240
121.1
2.0
Plan
Activities
80
1
80
40
3200
160
320
161.4
3.0
Training
32
1
32
40
1280
64
128
64.6
4.0
Create,
Test,
and
Research
and
Development
320
1
320
40
12800
640
1280
645.8
5.0
Gather
Information,

Monitor,
and
Inspect
208
1
208
40
8320
416
832
419.7
6.0
Process/
Compile
and
Review
48
2
96
40
3840
192
384
193.7
7.0
Complete
Reports
40
2
80
40
3200
160
320
161.4
8.0
Record/
Disclose
16
2
32
40
1280
64
128
64.6
9.0
Store/
File
4
2
8
40
320
16
32
16.1
10.0
LDAR
Reporting
and
Recordkeeping
a
200
b
340
1
1
200
340
25
2
5680
284
568
286.6
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
80.0
TOTAL
BURDEN
(
HRS)
AND
COSTS
42320
2116
4232
2215.0
a
Less
than
500
components
b
Greater
than
500
components
TABLE
1b.
ESTIMATED
ANNUAL
BURDEN
AND
LABOR
COST
TO
INDUSTRY
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
­­
SECOND
AND
THIRD
YEAR
7
Burden
Item
(
A)

Person­
hours
per
occurrence
(
B)
Number
of
occurrences
per
year
(
C)
Person­
hrs.
per
respondent
per
year
(
C=
A*
B)
(
D)
Respondents
per
year
(
E)
Technical
person
­
hrs.

per
year
(
E=
C*
D)
(
F)
Management
person­
hrs.
per
year
(
F=
E*
0.05)
(
G)
Clerical
person­
hrs.

per
year
(
G=
E*
0.1)
(
H)
Annual
costs
($
1000/
yr)

1.0
Read
Rule
and
Instructions
16
1
16
40
640
32
64
32.3
2.0
Plan
Activities
8
1
8
40
320
16
32
16.1
3.0
Training
16
1
16
40
640
32
64
32.3
4.0
Create,
Test,
and
Research
and
Development
320
1
320
2
640
32
64
32.3
5.0
Gather
Information,

Monitor,
and
Inspect
208
1
208
40
8320
416
832
419.7
6.0
Process/
Compile
and
Review
48
2
96
40
3840
192
384
193.7
7.0
Complete
Reports
40
2
80
40
3200
160
320
161.4
8.0
Record/
Disclose
16
2
32
40
1280
64
128
64.6
9.0
Store/
File
4
2
8
40
320
16
32
16.1
10.0
LDAR
Reporting
and
Recordkeeping
a
60
b
104
1
1
60
104
25
2
1708
85
171
86.1
11.0
Capital
Costs
of
Monitoring
and
Recordkeeping
Equipment
TOTAL
BURDEN
(
HRS)

AND
COSTS
20908
1045
2091
1054.8
a
Less
than
500
components
b
Greater
than
500
components
8
It
was
assumed
that
a
pH
monitor
and
a
liquid
flow
monitor
would
be
included
as
components
of
the
scrubber
because
they
are
necessary
for
the
proper
operation
and
maintenance
of
a
scrubber.
Capital
costs
for
these
devices
are
included
in
the
control
costs
and
not
as
a
component
of
the
information
collection
costs.
Therefore,
capital
costs
for
information
collection
at
amino/
phenolic
resins
production
facilities
are
only
associated
with
the
purchase
of
a
desktop
computer
to
be
used
for
compiling
monitoring
data.
The
capital
costs,
assumed
to
be
a
one­
time
cost
for
the
life
of
the
equipment,
were
estimated
to
be
$
2,000
per
source.
Total
costs
for
the
first
year
for
40
facilities
are
$
80,000.

(
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.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
Act,
no
operational
costs
will
be
incurred
by
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
AIRS,

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
Agency'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
semiannually
by
the
9
sources,
(
unless
the
semiannual
reports
indicate
a
violation,
thereby
triggering
an
enforcement
action)
as
presented
in
Tables
2a
and
2b.
TABLE
2a.
ESTIMATE
OF
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL
GOVERNMENT
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
­­
FIRST
YEAR
10
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
and
test
20
40
800
40
80
40.4
2.0
Repeat
performance
test
N/
A
3.0
Litigation
N/
A
4.0
Report
review
a)
notification
of
const./
reconst.
N/
A
b)
notif.
of
anticipated
startup
N/
A
c)
notif.
of
actual
startup
N/
A
d)
notif.
of
modification
N/
A
e)
notif.
of
compliance
status
8
40
320
16
32
16.1
f)
notif.
of
performance
test
4
40
160
8
16
8.1
g)
notif.
of
process
change
N/
A
h)
notif.
of
inspection
of
storage
vessel
N/
A
I)
notif.
of
change
in
primary
product
N/
A
j)
precompliance
report
8
40
320
16
32
16.1
k)
storage
vessel
initial
compliance
demonstration
N/
A
l)
periodic
reports
of
compliance
status
4
80
320
16
32
16.1
TABLE
2a.
ESTIMATE
OF
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL
GOVERNMENT
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
­­
FIRST
YEAR
11
TOTAL
BURDEN
(
HRS)
AND
COSTS
1920
96
192
96.9
TABLE
2b.
ESTIMATE
OF
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL
GOVERNMENT
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
­­
SECOND
AND
THIRD
YEARS
12
Burden
Item
(
A)
Person­
hours
per
activity
(
B)
Number
of
activities
per
year
(
C)
Technical
person­
hours
per
year
(
C=
A*
B)
(
D)
Management
person­
hours
per
year
(
D=
C*
0.05)
(
E)
Clerical
person­
hours
per
year
(
E=
C*
0.1)
(
F)
Annual
costs
($
1000/
yr)

1.0
Initial
performance
test
N/
A
2.0
Repeat
performance
test
20
2
40
2
4
2.0
3.0
Litigation
N/
A
4.0
Report
review
a)
notification
of
const./

reconstr.
N/
A
b)
notif.
of
anticipated
startup
N/
A
c)
notif.
of
actual
startup
N/
A
d)
notif.
of
modification
N/
A
e)
notif.
of
compliance
status
N/
A
f)
notif.
of
performance
test
4
2
8
0
1
0.4
g)
notif.
of
process
change
N/
A
h)
notif.
of
inspection
of
storage
vessel
N/
A
I)
notif.
of
change
in
primary
product
N/
A
j)
precompliance
report
N/
A
k)
storage
vessel
initial
compliance
demonstration
N/
A
l)
periodic
reports
of
compliance
status
4
80
320
16
32
16.1
TABLE
2b.
ESTIMATE
OF
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL
GOVERNMENT
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
­­
SECOND
AND
THIRD
YEARS
13
TOTAL
BURDEN
(
HRS)

AND
COSTS
368
18
37
18.5
14
Individual
tables
for
the
first
2
years
after
the
effective
date
were
developed
because
the
annual
burden
varied
between
the
first
and
second
year.

The
third
year
burden
is
expected
to
be
identical
to
the
second
year
burden.

Labor
rates
and
associated
costs
are
based
on
estimated
hourly
rates
of
technical
at
$
45,
management
at
$
67,
and
clerical
at
$
21.

(
d)
Bottom
Line
Burden
Hours
and
Costs/
Master
Tables
(
i)
The
simple
collection:
The
annual
bottom
line
respondent
burden
hours
and
costs
are
calculated
by
adding
the
total
person­
hours
and
labor
costs
from
Table
1a
to
the
total
person­
hours
and
labor
costs
from
Table
1b
multiplied
by
2,
and
then
dividing
by
the
3­
year
review
period.
The
total
annual
burden
hours
and
labor
costs
are:

Total
burden,

hours
Total
costs,

$

Table
1a
(
first
year)
48,668
2,215,044
Table
1b
x
2
(
second
and
third
years)
48,088
2,109,572
Total
96,756
4,324,616
Bottom
line
annual
burden
32,252
1,441,539
(
ii)
The
Agency
tally:
The
annual
bottom
line
Agency
burden
hours
and
costs
are
calculated
by
adding
the
total
person­
hours
and
labor
costs
from
Table
2a
to
the
total
person­
hours
and
labor
costs
from
Table
2b
multiplied
by
2,
and
then
dividing
by
the
3­
year
review
period.
The
annual
number
of
hours
averaged
over
the
first
3
years
is
1,018
at
a
cost
of
$
44,650
per
year.
15
Total
burden,
hours
Total
costs,
$

Table
2a
(
first
year)
2,208
96,864
Table
2b
x
2
(
second
and
third
years)
846
37,086
Total
3,054
133,950
Bottom
line
annual
burden
1,018
44,650
(
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
vary
over
the
course
of
the
3­
year
review
period
because
of
the
burden
associated
with
initial
reports
and
other
one­
time
activities
(
e.
g.,

developing
the
recordkeeping
system).
Also,
more
hours
are
allotted
for
training
personnel
in
the
first
year
over
the
second
and
third
years.
The
respondent
annual
burden
hours
and
costs
for
the
first
year
are
shown
in
Table
1a.
In
the
second
and
third
years,
the
burden
hours
and
costs
are
lower
because
all
existing
facilities
will
have
completed
the
first
year
activities.

Table
1b
presents
the
total
respondent
burden
hours
for
the
second
and
third
years
following
the
effective
date
of
the
rule.
These
costs
are
representative
of
the
on­
going
recordkeeping
and
reporting
burden
resulting
from
the
rule.

The
Agency
burden
hours
and
costs
will
also
vary
over
the
3­
year
review
period
because
review
of
the
notification
of
compliance
status
plan
will
occur
only
in
the
first
year.
Tables
2a
and
2b
present
the
Agency
burden
hours
and
costs
of
each
of
the
3
years
following
the
effective
date
of
the
rule.
The
overall
Agency
burden
after
the
first
year
of
implementation
will
decrease
to
423
hours.
16
(
e)
Reasons
for
Change
in
Burden
This
section
does
not
apply
because
this
is
a
new
collection.

(
f)
Burden
Statement
(
i)
The
EPA
is
required
under
section
112(
d)
of
the
Clean
Air
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.

(
iii)
The
total
annual
reporting
and
recordkeeping
burden
for
this
collection
averaged
over
the
first
3
years
is
estimated
to
be
$
1,441,539
per
year
for
the
entire
source
category.
The
average
burden,
per
respondent,
is
806
hours
per
year,
and
a
one­
time
capital
cost
of
$
2,000.
The
rule
requires
an
initial
one­
time
notification
from
each
respondent
and
subsequent
notification
every
6
months
to
indicate
their
compliance
status.
A
respondent
would
also
be
required
to
keep
necessary
records
of
data
to
determine
compliance
with
the
standards
in
the
regulation.
The
data
would
be
recorded
monthly.
There
would
be
an
estimated
40
respondents
initially
applicable
to
the
proposed
collection
requirements.
This
burden
estimate
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,

processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
17
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
to
the
Director,

OPPE
Regulatory
Information
Division;
U.
S.
Environmental
Protection
Agency
(
2136),
401
M
St.
S.
W.,
Washington,
DC
20460,
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
St.
N.
W.,
Washington,
DC
20503,
marked
"
Attention:
Desk
Officer
for
EPA."

Include
the
ICR
number
in
any
correspondence.

(
iv)
The
respondents
would
be
subject
to
applicable
recordkeeping,

reporting,
and
other
requirements
in
40
CFR
63.9
and
63.10,
as
specified
in
the
final
rule.

(
v)
All
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B­­
Confidentiality
of
Information
(
see
40
CFR
part
2;
41
FR
36902,
September
1,
1076;
amended
by
43
FR
39999,
September
8,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,

March
23,
1979).

(
vi)
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
a
table
in
40
CFR
part
9.
The
EPA
will
amend
part
9
when
the
ICR
is
approved.
18
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
REQUIREMENT
CITATION
NOTIFICATIONS
Notification
of
construction
or
reconstruction
63.5;
63.1417
Notification
of
anticipated
date
of
initial
startup
63.5;
63.1417
Notification
of
actual
date
of
initial
startup
63.5;
63.1417
Notification
of
modification
63.5;
63.1417
Notification
of
intent
to
conduct
a
performance
test
63.1417
RECORDKEEPING
Start­
up,
shutdown,
and
malfunction
plan/
records
63.6;
63.1416
Documentation
of
control
device
performance
63.1416
design
evaluation
63.1416
performance
test
63.1416
Values
measured
by
continuous
monitoring
systems
63.1416
Monitoring
system
calibrations,
maintenance
63.1416
Periods
of
monitoring
system
failure/
shutdown
63.1416
REPORTING
Precompliance
report
63.1417
Notification
of
Compliance
Status
63.1417
Periodic
reports
(
semiannual)
63.1417
statement
of
compliance
(
if
no
exceedances
occurred)
63.1417
daily,
batch
cycle,
&
block
average
monitoring
data
for
any
periods
where
exceedances
or
excursions
occur
63.1417
periods
of
monitoring
system
downtime
63.1417
results
of
any
performance
tests
63.1417
start­
up,
shutdown,
malfunction
reports
63.1417
Other
reports
63.1417
notification
of
change
in
primary
product
63.1417
notification
of
process
change
that
impacts
group
status
63.1417
notification
of
change
in
designation
of
control
device
from
small
to
large
63.1417
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
points
at
a
facility.

(
2)
Plan
Activities
represents
such
burdens
as
design,
redesign,

scheduling,
and
selecting
methods
of
compliance.

(
3)
Training
represents
the
portion
of
activities
from
(
1)
Read
Rule
and
Instruction
for
which
an
average
facility
would
elect
to
provide
classroom
instruction.
The
standard
does
not
require
specific
training
itself.

(
4)
Create,
Test,
and
Research
and
Development
are
the
activities
involving
testing,
retesting,
establishing
parameter
monitoring
levels
and
determining
emission
point
applicability.

(
5)
Gather
Information,
Monitor,
and
Inspect
are
the
activities
involving
physical
inspections
of
equipment,
collection
of
monitored
data
and
other
related
activities.
Calibration
and
maintenance
activities
associated
with
monitoring
devices
are
also
included
under
this
heading.
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)
Process/
Compile
and
Review
are
the
activities
that
involve
analysis
of
the
information
collected
for
accuracy
and
compliance,
and
include
generation
of
appropriate
reports
and
records
required
as
a
result.
(
7)
Complete
Reports
represents
the
activities
normally
associated
with
filling
out
forms.
Because
the
standard
requires
no
standardized
forms,
these
activities
relate
to
the
preparing
of
formal
reports
and
cover
letters
as
appropriate.

(
8)
Record/
Disclose
are
activities
that
are
solely
recordkeeping
that
occur
once
the
appropriate
report
information
has
been
extracted.
These
activities
involve
software
translation,
duplication,
or
archival
processes
normally
associated
with
data
management
and
storage
common
to
this
industry.

(
9)
Store/
File
are
again
activities
that
are
solely
recordkeeping
that
occur
once
the
appropriate
report
information
has
been
extracted.
The
activities
involve
the
management
life
cycle
of
records,
from
the
time
they
are
filed
and
stored,
to
the
time
they
are
disposed.
ATTACHMENT
3
Assumptions
Used
in
Cost
Estimates
Assumptions
Used
in
Burden
Estimates
(
a)
There
are
40
major
(
or
"
affected")
sources
and
all
are
assumed
to
come
into
compliance
during
the
first
year.

(
b)
There
are
expected
to
be
no
new,
modified,
or
reconstructed
sources
during
the
first
three
years.

(
c)
The
typical
affected
source
has
4
reactor
batch
process
vents,
3
non­
reactor
batch
process
vents,
and
no
affected
storage
vessels
or
heat
exchange
systems.

(
d)
There
are
27
affected
sources
that
will
be
required
to
comply
with
the
equipment
leaks
LDAR
program;
25
have
less
than
500
components
and
2
have
more
than
500
components.

(
e)
Each
affected
source
will
purchase
a
desktop
computer
to
be
used
for
compiling
monitored
data
and
for
preparing
reports.
This
purchase
will
occur
during
the
first
year
and
is
the
only
capital
cost
attributed
to
the
recordkeeping
and
reporting
requirements.

(
f)
Management
hours
are
assumed
to
equal
5
percent
of
the
total
technical
hours
required
and
clerical
hours
are
10
percent
of
the
technical
hours.

(
g)
Initial
performance
testing
was
assumed
to
take
280
technical
hours
(
1
test
leader
for
two
weeks
and
5
test
crew
for
one
week).
An
additional
40
hours
were
assumed
for
the
establishment
of
parameter
monitoring
levels.
Five
percent
of
the
initial
tests
will
be
repeated
during
the
second
year
and
five
percent
during
the
third
year.

(
h)
Four
hours
per
week
were
estimated
for
gathering
monitoring
information
and
maintaining
monitoring
equipment.
