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
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
from
Miscellaneous
Coating
Manufacturing."
This
is
a
new
information
collection
request
(
ICR),
and
a
U.
S.
Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
ICR
is
2115.01.

(
b)
Short
Characterization
(
i)
Applicability.
Respondents
are
owners
or
operators
of
new
and
existing
facilities
that
manufacture
a
miscellaneous
coating
and
are
located
at,
or
are
part
of,
major
sources
of
hazardous
air
pollutant
(
HAP)
emissions.
"
Major
source"
means
that
the
process
equipment
used
to
manufacture
the
miscellaneous
coatings
and
any
other
operations
or
equipment
at
the
facility
emit,
or
have
the
potential
to
emit,
10
tons
per
year
or
more
of
a
single
HAP
or
25
tons
per
year
or
more
of
any
combination
of
HAP.
A
process
is
subject
to
the
miscellaneous
coating
manufacturing
NESHAP
under
the
following
criteria:

1.
It
is
used
to
manufacture
coatings,
including
inks,

paints,
or
adhesives
described
by
Standard
Industrial
Classification
(
SIC)
codes
285
or
289
or
North
American
Industrial
Classification
System
(
NAICS)
codes
3255
or
3259;

2.
It
processes,
uses,
or
produces
HAP.

3.
It
is
not
part
of
an
affected
source
under
another
subpart
of
40
CFR
part
63.

Approximately
127
of
the
miscellaneous
coating
manufacturing
facilities
nationwide
are
expected
to
meet
the
applicability
criteria
defined
in
the
rule.
Three
facilities
are
expected
to
2
be
constructed
in
the
next
3
years,
based
on
a
2
percent
growth
rate
over
the
3
years.
(
A
2
percent
increase
over
the
next
3
years
is
approximately
0.85
facilities
per
year;
rather
than
assume
0.85
facilities,
we
assumed
1
facility
per
year
for
the
first
3
years
in
calculating
the
burden
estimates.)

(
ii)
Miscellaneous
coating
manufacturing
facilities.
Owners
or
operators
of
miscellaneous
coating
manufacturing
facilities
subject
to
this
rule
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.

Owners
or
operators
are
required
to
install,
operate,
and
maintain
a
continuous
monitoring
system
(
CMS)
to
demonstrate
compliance
with
the
emission
limitations
in
Tables
1
through
3
and
5
through
6
of
the
rule
and
the
operating
limits
in
Table
7
of
the
rule;
they
must
also
record
the
values
of
equipment
operating
parameters
as
specified
in
Table
7
of
the
rule.

Owners
or
operators
are
required
to
conduct
equipment
inspections
and
equipment
leak
monitoring
to
demonstrate
compliance
with
the
work
practice
standards
in
Tables
1
through
5
of
the
rule.

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
determinations;

notifications
that
the
facilities
are
subject
to
the
rule;

notifications
of
performance
tests;
notifications
of
compliance
status,
including
the
results
of
performance
tests
and
design
evaluations;
and
semi­
annual
compliance
reports.
In
addition
to
the
requirements
of
subpart
A,
many
respondents
are
required
to
submit
a
precompliance
report
and
leak
detection
and
repair
(
LDAR)
reports,
and
existing
facilities
that
wish
to
implement
emissions
averaging
provisions
must
submit
an
emissions
averaging
plan.

All
reports
are
to
be
submitted
to
the
respondent's
State
or
local
agency
or
to
the
EPA
Regional
Office,
whichever
has
been
3
delegated
enforcement
authority
by
EPA.
The
information
is
used
to
determine
whether
or
not
all
sources
subject
to
the
rule
are
achieving
the
emission
limitations
and
work
practice
standards
in
the
rule.

(
iii)
Deviations
from
the
standard.
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
work
practice
standard
applies,
the
compliance
report
must
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.

(
iv)
Record
retention.
Owners
or
operators
of
a
miscellaneous
coating
manufacturing
facility
must
maintain
a
copy
of
all
monitored
equipment
operating
parameter
values
that
demonstrate
compliance
with
the
operating
limits
in
the
rule,
as
well
as
records
of
inspections
and
results
of
equipment
leak
monitoring
that
demonstrate
compliance
with
the
work
practice
standards
in
the
rule.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,

shutdown,
or
malfunction
in
the
operation
of
a
source,
or
any
period
during
which
the
monitoring
system
is
inoperative.
Those
records
must
be
maintained
for
a
minimum
of
5
years.
At
a
minimum,
the
most
recent
2
years
of
data
must
be
retained
onsite.

The
remaining
3
years
of
data
may
be
retained
offsite.
4
2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
section
112(
d)
of
the
Clean
Air
Act
(
CAA),
as
amended,
to
establish
emission
standards
for
each
category
or
subcategory
of
major
and
area
sources
of
HAP
listed
for
regulation
in
section
112(
b).
These
standards
are
applicable
to
new
or
existing
sources
of
HAP
and
shall
require
the
maximum
degree
of
emission
reduction.

The
predominant
HAP
emitted
from
miscellaneous
coating
manufacturing
facilities
include
toluene
and
xylene.
In
the
Administrator's
judgment,
the
pollutants
emitted
from
miscellaneous
coating
manufacturing
facilities
cause
or
contribute
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health.
Therefore,
this
category
is
listed
for
regulation
under
section
112.
(
Note:
The
original
source
category
list
included
several
source
categories
as
surface
coating
processes.
The
miscellaneous
coating
manufacturing
NESHAP
groups
these
source
categories
into
one
category
and
changes
the
name
of
the
source
category
to
Miscellaneous
Coating
Manufacturing.)

Section
114(
a)
of
the
CAA
states
that
the
Administrator
may
require
any
owner
or
operator
subject
to
any
requirement
of
the
Act
to:

...(
A)
establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
as
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables,
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.
5
The
required
notifications
are
used
to
inform
the
EPA
or
delegated
authority
when
a
source
becomes
subject
to
the
miscellaneous
coating
manufacturing
NESHAP.
The
reviewing
authority
may
then
inspect
the
source
to
determine
if
the
pollution
control
devices
are
properly
installed
and
operated,

leaks
are
being
detected
and
repaired,
and
the
emission
limitations
and
work
practice
standards
in
the
rule
are
being
met.
Performance
test
reports
are
needed
because
they
are
EPA's
record
of
a
source's
initial
capability
to
comply
with
the
emission
limitations
and
work
practice
standards,
and
they
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
precompliance
reports
and
emissions
averaging
plans
are
necessary
to
ensure
that
the
emission
limitations,

which
are
based
on
maximum
achievable
control
technology
(
MACT)

for
miscellaneous
coating
manufacturing
facilities,
will
be
achieved.

After
their
compliance
date,
all
respondents
must
submit
semi­
annual
(
every
6
months)
compliance
reports
that
contain
the
information
requested
in
§
63.8050
of
the
rule.
In
addition,

respondents
that
elect
to
use
the
emissions
averaging
provisions
in
the
rule
must
submit
an
emissions
averaging
report
(
as
specified
in
§
63.8060)
as
part
of
the
semi­
annual
report.
The
semi­
annual
compliance
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,

and
for
compliance
determinations.
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
CAA
as
amended
by
Pub.
L
101­
549
[
42
U.
S.
C.
7401,
7412,
7414,

7416,
7601]).
6
(
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
rule;
(
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
EPA
to
identify
miscellaneous
coating
manufacturing
facilities
that
are
not
in
compliance
with
the
emission
limitations
and
work
practice
standards
in
the
rule.
Based
on
reported
information,

EPA
can
decide
which
miscellaneous
coating
manufacturing
facilities
should
be
inspected
and
what
records
or
processes
should
be
inspected
at
these
facilities.
The
records
that
facilities
maintain
will
indicate
to
EPA
whether
the
owners
or
operators
are
in
compliance
with
the
emission
limitations
and
work
practice
standards.

Much
of
the
information
EPA
needs
to
determine
compliance
will
be
recorded
on
a
continuous
or
daily
basis.
Other
information
will
be
recorded
on
a
monthly,
quarterly,
annual,
or
other
basis.
Such
information
will
be
reviewed
by
enforcement
personnel
during
an
inspection
and
will
need
to
be
reported
on
a
semi­
annual
basis.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
rule
(
such
as,
reports
of
performance
tests).
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.
7
A
search
of
existing
rules
revealed
some
duplication
of
information­
gathering
efforts
in
those
cases
where
facilities
are
subject
to
other
rules
in
addition
to
the
miscellaneous
coating
manufacturing
NESHAP.
In
each
case
that
has
been
identified,
an
effort
has
been
made
to
eliminate
this
duplication.
Two
examples
of
these
efforts
are
provided
below.

The
miscellaneous
coating
manufacturing
NESHAP
allows
facilities
that
are
also
subject
to
the
provisions
of
40
CFR
parts
264
and/
or
265
to
comply
with
those
provisions
(
which
constitutes
compliance
with
the
requirements
of
this
rule)
or
with
the
provisions
of
this
rule.
If
facilities
comply
with
the
provisions
of
40
CFR
parts
264
and/
or
265,
then
they
must
report
the
information
described
in
§
63.8070
of
this
rule
and
identify
in
the
notification
of
compliance
status
required
by
§
63.8070
the
recordkeeping
and
reporting
authority
under
which
they
will
comply.

Also
noted
in
the
miscellaneous
coating
manufacturing
NESHAP,
facilities
with
an
affected
wastewater
stream
that
is
also
subject
to
the
provisions
of
40
CFR
parts
260
through
272
may
determine
whether
this
rule
or
40
CFR
parts
260
through
272
contain
the
more
stringent
requirements.
Compliance
with
provisions
of
40
CFR
parts
260
through
272
that
are
determined
to
be
more
stringent
than
the
requirements
of
this
rule
constitutes
compliance
with
this
rule.
In
the
notification
of
compliance
status
required
by
§
63.8045,
the
facilities
must
identify
the
more
stringent
provisions
of
40
CFR
parts
260
through
272
with
which
they
will
comply,
as
well
as
provide
the
information
and
procedures
that
they
used
to
make
any
stringency
determinations.
8
(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
A
public
review
and
comment
period
will
occur
after
proposal
of
the
miscellaneous
coating
manufacturing
NESHAP
in
the
Federal
Register.

(
c)
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
most
of
the
various
source
categories
comprising
the
Miscellaneous
Coating
Manufacturing
source
category
as
categories
of
major
sources
of
HAP.
(
As
noted
above,
this
rule
groups
several
surface
coating
process
source
categories
into
one
category
and
changes
the
name
of
the
source
category
to
Miscellaneous
Coating
Manufacturing.)

Representatives
of
the
affected
companies
and
industry
trade
associations,
including
the
Chemical
Manufacturers
Association
and
Synthetic
Organic
Chemical
Manufacturers
Association,
were
consulted
during
the
development
of
the
rule,
and
several
meetings
have
been
held
with
them
during
this
time.
During
these
meetings,
the
representatives
were
given
the
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
rule.
No
specific
information
was
provided
to
the
representatives
with
respect
to
burden
estimates.
9
(
d)
Effects
of
Less
Frequent
Data
Collection.

In
the
3
years
following
the
effective
date
of
the
rule,

existing
sources
will
submit
only
one­
time
notifications
to
EPA.

In
this
instance,
less
frequent
reporting
would
not
be
practical
because
EPA
needs
the
information
provided
in
these
one­
time
notifications.
In
addition
to
these
one­
time
notifications,
new
and
reconstructed
sources
will
also
submit
semi­
annual
compliance
reports
in
the
3
years
following
the
effective
date
of
the
rule.

If
the
relevant
information
was
collected
less
frequently,
EPA
would
not
be
reasonably
assured
that
the
facilities
are
applying
good
operation
and
maintenance
practices
and
meeting
the
emission
limitations
and
work
practice
standards
in
the
rule.
Less
frequent
collection
could
decrease
the
likelihood
of
detection
poor
operation
and
maintenance
of
control
equipment
and
long­
term
deviations
from
the
applicable
emission
limitations
and
work
practice
standards.

In
addition,
EPA's
authority
to
take
administrative
action
would
be
significantly
reduced.
Section
113(
d)
of
the
CAA
limits
the
assessment
of
administrative
penalties
to
deviations
which
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.
Since
administrative
proceedings
are
less
costly
and
require
fewer
resources
than
judicial
proceedings,
both
EPA
and
the
regulated
community
benefit
from
preservation
of
EPA's
administrative
powers.

Also,
the
reporting
frequency
in
the
rule
is
consistent
with
the
requirements
of
Title
V
permit
programs.
Consequently,
less
frequent
reports
would
not
result
in
a
reduced
burden.

(
e)
General
Guidelines
The
miscellaneous
coating
manufacturing
NESHAP
requires
that
facilities
retain
records
for
a
period
of
5
years,
which
exceeds
the
3­
year
retention
period
specified
in
the
general
information
10
collection
guidelines
in
5
CFR
1320.6(
f)
of
the
Office
of
Management
and
Budget
(
OMB)
regulations
implementing
the
Paperwork
Reduction
Act.
However,
the
5­
year
retention
period
is
consistent
with
the
retention
requirement
in
the
General
Provisions
in
subpart
A
of
40
CFR
part
63
and
the
retention
requirement
in
the
operating
permit
program
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.
Thus,
the
5­
year
record
retention
requirement
of
the
rule
adds
no
additional
burden.
At
a
minimum,

respondents
will
be
required
to
retain
onsite
the
most
recent
2
years
of
data.
The
remaining
3
years
of
data
could
be
retained
at
a
readily
accessible
onsite
or
offsite
storage
facility.
None
of
the
other
guidelines
in
5
CFR
1320.6
are
being
exceeded.

(
f)
Confidentiality
All
information
submitted
to
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
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;
and
44
FR
17674,
March
23,
1979.)

(
g)
Sensitive
Questions.

The
information
to
be
reported
consists
of
emissions
data
and
other
information
that
are
not
of
a
sensitive
nature.

Therefore,
this
section
is
not
applicable
because
this
ICR
does
not
involve
matters
of
a
sensitive
nature.
11
4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
and
NAICS
Codes
Respondents
are
owners
or
operators
of
any
facilities
that
engage
in
the
manufacture
of
miscellaneous
coatings
and
are
classified
as
major
sources
under
section
112
of
the
CAA.
The
primary
SIC
codes
for
the
respondents
affected
by
the
miscellaneous
coating
manufacturing
NESHAP
are
285
(
Paints,

Varnishes,
Lacquers,
Enamels,
and
Allied
Products)
and
289
(
Miscellaneous
Chemical
Products).
The
primary
NAICS
codes
are
3255
(
Paint,
Coating,
and
Adhesive
Manufacturing)
and
3259
(
Other
Chemical
Product
and
Preparation
Manufacturing).
Not
all
processes
classified
in
the
SIC
and
NAICS
codes
above
will
be
regulated
by
the
miscellaneous
coating
manufacturing
NESHAP
(
i.
e.,
they
will
not
be
regulated
if
they
are
already
subject
to
another
NESHAP).

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

(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
rule
in
the
first
3
years
following
the
effective
date
of
the
rule
are
listed
in
the
first
columns
of
Tables
1a
through
1d
and
are
presented
in
section
6(
a).
The
respondent
activities
are
described
in
more
detail
in
Attachment
2,

Description
of
Respondent
Activities.

Tables
1a,
1b,
and
1c
present
the
one­
time
activities
for
the
first,
second,
and
third
years,
respectively,
after
the
effective
date
of
the
rule.
Table
1d
presents
the
recurrent
activities
required
by
the
rule
in
the
first
3
years
after
the
12
effective
date
of
the
rule;
this
table
presents
the
average
number
of
respondents
over
the
3
years.
13
TABLE
1a.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructionsd
1
1
1
128
128
6
13
147
$
6,552
B.
Required
Activities
°
Initial
CMS
performance
evaluatione
10
1
10
0
0
0
0
0
$
0
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
°
Notification
of
construction/
reconstruction
2
1
2
1
2
0.1
0.2
2
$
102
°
Notification
of
anticipated
startup
2
1
2
1
2
0.1
0.2
2
$
102
°
Notification
of
actual
startup
2
1
2
1
2
0.1
0.2
2
$
102
14
TABLE
1a.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
°
Notification
of
applicability
of
standard
Existing
sources
2
1
2
127
254
13
25
292
$
13,002
New
sources
2
1
2
1
2
0.1
0.2
2
$
102
°
Emissions
averaging
planf
40
1
40
0
0
0
0
0
$
0
°
Precompliance
reportg
40
1
40
1
40
2
4
46
$
2,048
°
Notification
of
initial
performance
testh
2
1
2
0
0
0
0
0
$
0
°
Notification
of
initial
CMS
performance
evaluatione
2
1
2
0
0
0
0
0
$
0
°
Notification
of
compliance
status
With
performance
testh
80
1
80
0
0
0
0
0
$
0
Without
performance
testi
120
1
120
1
120
6
12
138
$
6,143
15
TABLE
1a.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*
0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
Systemj
40
1
40
1
40
2
4
46
$
2,048
E.
Develop
Startup,

Shutdown,
Malfunction
Plank
100
1
100
1
100
5
10
115
$
5,119
F.
Develop
QA/
QC
Plan
for
CMSl
40
1
40
0
0
0
0
0
$
0
G.
Time
to
Train
Personnelm
40
1
40
1
40
2
4
46
$
2,048
H.
Time
for
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
n
730
37
73
840
$
37,369
Average
first
year
cost
per
facilityo
128
$
292
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
127
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
over
3
years,
1
new
facility
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.

d
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.
16
TABLE
1a.
(
continued)

e
Person­
hours
per
occurrence
are
based
on
the
performance
specification
costs
to
certify
CMS
($
500)
divided
by
the
composite
hourly
labor
rate.
No
performance
evaluations
are
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,

which
requires
CEMS
and
performance
evaluations.

f
Assumes
10
percent
of
existing
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
report.

h
Assumes
one
existing
facility
and
no
new
facilities
will
be
required
to
conduct
a
performance
test(
s).
The
notification
of
compliance
status
includes
the
report
of
the
performance
test(
s).

i
Assumes
all
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
with
no
performance
tests.
The
notification
of
compliance
status
includes
those
calculations.

j
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

k
Assumes
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

l
Assumes
40
hours
to
develop
and
review
the
QA/
QC
plan
for
the
CMS.
No
QA/
QC
plan
is
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,
which
requires
CEMS
and
QA/
QC
plans.

m
Assumes
40
hours
to
train
personnel.

n
The
one­
time
burden
and
cost
are
equal
to
the
person­
hours
added
down
each
column
for
technical,
management,
clerical,
and
total
respondent
labor
and
the
sum
of
the
cost
column.

o
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
128)
subject
to
the
rule.
17
TABLE
1b.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*

0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructionsd
1
1
1
1
1
0.05
0.1
1
$
51
B.
Required
Activities
Initial
CMS
performance
evaluatione
10
1
10
0
0
0
0
0
$
0
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
°
Notification
of
construction/
reconstruction
2
1
2
1
2
0.1
0.2
2
$
102
°
Notification
of
anticipated
startup
2
1
2
1
2
0.1
0.2
2
$
102
°
Notification
of
actual
startup
2
1
2
1
2
0.1
0.2
2
$
102
°
Notification
of
applicability
of
standard
Existing
sources
2
1
2
0
0
0
0
0
$
0
New
sources
2
1
2
1
2
0.1
0.2
2
$
102
18
TABLE
1b.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*

0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
°
Emissions
averaging
planf
40
1
40
13
520
26
52
598
$
26,619
°
Precompliance
reportg
40
1
40
64
2,560
128
256
2,944
$
131,048
°
Notification
of
initial
performance
testh
2
1
2
1
2
0.1
0.2
2
$
102
°
Notification
of
initial
CMS
performance
evaluatione
2
1
2
0
0
0
0
0
$
0
°
Notification
of
compliance
status
With
performance
testh
80
1
80
0
0
0
0
0
$
0
Without
performance
testi
120
1
120
1
120
6
12
138
$
6,143
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
System
j
40
1
40
1
40
2
4
46
$
2,048
19
TABLE
1b.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*

0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
E.
Develop
Startup,

Shutdown,
Malfunction
Plank
100
1
100
1
100
5
10
115
$
5,119
F.
Develop
QA/
QC
Plan
for
CMSl
40
1
40
0
0
0
0
0
$
0
G.
Time
to
Train
Personnel
m
40
1
40
1
40
2
4
46
$
2,048
H.
Time
for
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
n
3,391
170
339
3,900
$
173,587
Average
second
year
cost
per
facilityo
129
$
1,346
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
127
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
over
3
years,
1
new
facility
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.

d
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.

e
Person­
hours
per
occurrence
are
based
on
the
performance
specification
costs
to
certify
CMS
($
500)
divided
by
the
composite
hourly
labor
rate.
No
performance
evaluations
are
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,

which
requires
CEMS
and
performance
evaluations.

f
Assumes
10
percent
of
existing
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
report.

h
Assumes
one
existing
facility
and
no
new
facilities
will
be
required
to
conduct
a
performance
test(
s).
The
notification
of
compliance
status
includes
the
report
of
the
performance
test(
s).

i
Assumes
all
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
with
no
performance
tests.
The
notification
of
compliance
status
includes
those
calculations.

j
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

k
Assumes
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.
20
TABLE
1b.
(
continued)

l
Assumes
40
hours
to
develop
and
review
the
QA/
QC
plan
for
the
CMS.
No
QA/
QC
plan
is
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,
which
requires
CEMS
and
QA/
QC
plans.

m
Assumes
40
hours
to
train
personnel.

n
The
one­
time
burden
and
cost
are
equal
to
the
person­
hours
added
down
each
column
for
technical,
management,
clerical,
and
total
respondent
labor
and
the
sum
of
the
cost
column.

o
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
129)
subject
to
the
rule.
21
TABLE
1c.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*

0.05)
G
Clerical
personhours
per
year
(
G
=
E
*

0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructionsd
1
1
1
1
1
0.05
0.1
1
$
51
B.
Required
Activities
°
Initial
CMS
performance
evaluatione
10
1
10
0
0
0
0
0
$
0
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
°
Notification
of
construction/
reconstruction
2
1
2
1
2
0.1
0.2
2
$
102
°
Notification
of
anticipated
startup
2
1
2
1
2
0.1
0.2
2
$
102
°
Notification
of
actual
startup
2
1
2
1
2
0.1
0.2
2
$
102
°
Notification
of
applicability
of
standard
Existing
sources
2
1
2
0
0
0
0
0
$
0
New
sources
2
1
2
1
2
0.1
0.2
2
$
102
°
Emissions
averaging
planf
40
1
40
0
0
0
0
0
$
0
°
Precompliance
reportg
40
1
40
1
40
2
4
46
$
2,048
°
Notification
of
initial
performance
testh
2
1
2
0
0
0
0
0
$
0
22
TABLE
1c.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*

0.05)
G
Clerical
personhours
per
year
(
G
=
E
*

0.1)
H
Respondent
person­
hours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
°
Notification
of
initial
CMS
performance
evaluatione
2
1
2
0
0
0
0
0
$
0
°
Notification
of
compliance
status
With
performance
testh
80
1
80
1
80
4
8
92
$
4,095
Without
performance
testi
120
1
120
128
15,360
768
1,536
17,664
$
786,286
4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
Systemj
40
1
40
1
40
2
4
46
$
2,048
E.
Develop
Startup,
Shutdown,

Malfunction
Plank
100
1
100
1
100
5
10
115
$
5,119
F.
Develop
QA/
QC
Plan
for
CMSl
40
1
40
0
0
0
0
0
$
0
G.
Time
to
Train
Personnelm
40
1
40
1
40
2
4
46
$
2,048
H.
Time
for
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
n
15,669
783
1,567
18,019
$
802,104
Average
third
year
cost
per
facilityo
130
$
6,170
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
127
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
over
3
years,
1
new
facility
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.

d
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.
23
TABLE
1c.
(
continued)

e
Person­
hours
per
occurrence
are
based
on
the
performance
specification
costs
to
certify
CMS
($
500)
divided
by
the
composite
hourly
labor
rate.
No
performance
evaluations
are
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,

which
requires
CEMS
and
performance
evaluations.

f
Assumes
10
percent
of
existing
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
report.

h
Assumes
one
existing
facility
and
no
new
facilities
will
be
required
to
conduct
a
performance
test(
s).
The
notification
of
compliance
status
includes
the
report
of
the
performance
test(
s).

i
Assumes
all
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
with
no
performance
tests.
The
notification
of
compliance
status
includes
those
calculations.

j
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

k
Assumes
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

l
Assumes
40
hours
to
develop
and
review
the
QA/
QC
plan
for
the
CMS.
No
QA/
QC
plan
is
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,
which
requires
CEMS
and
QA/
QC
plans.

m
Assumes
40
hours
to
train
personnel.

n
The
one­
time
burden
and
cost
are
equal
to
the
person­
hours
added
down
each
column
for
technical,
management,
clerical,
and
total
respondent
labor
and
the
sum
of
the
cost
column.

o
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
130)
subject
to
the
rule.
24
TABLE
1d.
RECURRENT
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
AVERAGE
OF
FIRST,
SECOND,
AND
THIRD
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*

0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
personhours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
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
Report
°
Notification
of
process
changed
8
1
8
0
0
0
0
0
$
0
°
Semi­
annual
compliance
report
No
deviationse
8
2
16
2
32
2
3
37
$
1,638
Deviationse
24
2
48
0
0
0
0
0
$
0
Startup,
shutdown,
and
malfunction
reportf
8
2
16
2
32
2
3
37
$
1,638
LDAR
reportg
404
2
808
2
342
17
34
393
$
17,499
Emissions
averaging
reporth
20
2
40
0
0
0
0
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
25
TABLE
1d.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
D
Respondents
per
yearb
E
Technical
person­
hours
per
year
(
E
=
C
*
D)
F
Management
person­
hours
per
year
(
F
=
E
*

0.05)
G
Clerical
person­
hours
per
year
(
G
=
E
*
0.1)
H
Respondent
personhours
per
year
(
H
=
E
+
F
+
G)
I
Labor
cost,

$
c
E.
Time
to
Enter
Information
°
Records
of
startup,

shutdown,
and
malfunction
1.5
52
78
2
156
8
16
179
$
7,986
°
Records
of
CMS
data
Record
continuously
monitored
parametersi
1
365
365
2
730
37
73
840
$
37,369
Compile
datai
24
2
48
2
96
5
10
110
$
4,914
Enter/
verify
information
for
semi­
annual
reportsi
16
2
32
2
64
3
6
74
$
3,276
LDAR
recordkeeping
Included
in
3E
F.
Calibration
of
CMSj
376
1
376
2
752
38
75
865
$
38,495
G.
Time
to
Train
Personnel
N/
A
H.
Time
for
Refresher
Training
for
Personnelk
16
1
16
2
16
1
2
18
$
819
I.
Time
for
Audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
l
2,220
111
222
2,553
$
113,635
Average
cost
per
facilitym
2
$
56,817
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
127
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
over
3
years,
1
new
facility
will
be
built
each
year.

c
Labor
cost
assumes
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.

d
Assumes
10
percent
of
facilities
will
implement
process
changes.

e
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.
26
TABLE
1d.
(
continued)

f
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
startup,
shutdown,
and
malfunction
plan.

g
According
to
EPA
guidance,
annual
recordkeeping
and
reporting
coasts
for
the
LDAR
program
are
estimated
to
be
40
percent
of
monitoring
and
repair
labor,
which
averages
$
10,937
per
facility
(
40%
*
$
10,937
=
$
4,375
per
facility).
Person­
hours
per
occurrence
are
based
on
this
cost
divided
by
the
composite
hourly
labor
rate.

h
Assumes
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements;
new
facilities
are
not
allowed
to
use
emissions
averaging.

i
Includes
process
vessel,
storage
tank,
transfer
operation,
and
wastewater
monitoring
and
inspections.

j
Assumes
calibration
of
the
CMS
will
require
8
hours
per
year
for
each
monitor.
Assuming
1
CMS
for
each
process
vessel
and
47
process
vessels
per
facility,
a
total
of
376
hours
per
year
per
facility
is
required.

k
Assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

l
The
recurrent
burden
and
cost
are
equal
to
the
person­
hours
added
down
each
column
for
technical,
management,
clerical,
and
total
respondent
labor
and
the
sum
of
the
cost
column.

m
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
(
2)
complying
with
the
rule.
27
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
The
Agency
activities
in
the
first
3
years
following
the
effective
date
of
the
rule
are
listed
in
the
first
columns
of
Tables
2a
through
2c
and
are
presented
in
section
6(
c).

Tables
2a,
2b,
and
2c
present
the
Agency
activities
for
the
first,
second,
and
third
years,
respectively,
after
the
effective
date
of
the
rule.

(
b)
Collection
Methodology
and
Management
Information
contained
in
the
initial,
one­
time
only
notifications
will
be
entered
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
AIRS
is
EPA's
database
for
the
collection,
maintenance,

and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
The
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
State
and
local
agencies
and
EPA
Regional
Offices
and
Headquarters.
The
EPA
and
its
delegated
authorities
can
edit,
store,
retrieve,
and
analyze
the
data.
The
AIRS
database
can
be
publicly
accessed
via
the
Internet
at
http://
www.
epa.
gov/
enviro/
index_
java.
html
or
through
a
Freedom
of
Information
Act
request
to
EPA.
Data
obtained
during
periodic
visits
by
EPA
personnel,
from
records
maintained
by
the
respondents,
and
from
information
provided
in
semi­
annual
reports
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.

The
rule
does
not
require
the
use
of
automated,
electronic,

mechanical,
or
other
technology
data
collection
techniques
or
28
TABLE
2a.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FIRST
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
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
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
1.
Attend
Initial
Performance
Testc
40
0
0
0
0
0
$
0
2.
Attend
Repeat
Performance
Testd
40
0
0
0
0
0
$
0
3.
Attend
Initial
CMS
Performance
Evaluatione
2
0
0
0
0
0
$
0
4.
Litigation
N/
A
5.
Report
Review
A.
Review
Notification
of
Construction/
Reconstruction
2
1
2
0.1
0.2
2
$
102
B.
Review
Notification
of
Anticipated
Startup
2
1
2
0.1
0.2
2
$
102
C.
Review
Notification
of
Actual
Startup
2
1
2
0.1
0.2
2
$
102
D.
Review
Notification
of
Applicability
of
Standard
2
128
256
13
26
294
$
13,105
E.
Review
Emissions
Averaging
Planf
20
0
0
0
0
0
$
0
F.
Review
Precompliance
Reportg
4
1
4
0.2
0.4
5
$
205
G.
Review
Notification
of
Initial
Performance
Test
2
0
0
0
0
0
$
0
H.
Review
Notification
of
Initial
CMS
Performance
Evaluatione
2
0
0
0
0
0
$
0
I.
Review
Notification
of
Compliance
Status
°
With
performance
testh
40
0
0
0
0
0
$
0
°
Without
performance
testi
40
1
40
2
4
46
$
2,048
J.
Review
Notification
of
Process
Changej
8
0
0
0
0
0
$
0
29
TABLE
2a.
(
continued)

Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
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
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
K.
Review
Semi­
Annual
Compliance
Report
°
No
deviationsk
2
2
4
0.2
0.4
5
$
205
°
Deviationsk
8
0
0
0
0
0
$
0
°
Startup,
shutdown,
and
malfunction
reportl
2
2
4
0.2
0.4
5
$
205
°
LDAR
reportm
8
2
16
0.8
2
18
$
819
°
Emissions
averaging
reportf
8
0
0
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY):
n
330
17
33
380
$
16,893
TRAVEL
EXPENSES
FOR
TEST
ATTENDEDo
=
(
1
person
*
0
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
0
round
trip/
yr):
$
0
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES:
$
16,893
a
Operations
per
year
are
equal
to
the
number
of
operations
(
e.
g.,
performance
tests,
notifications,
reports)
per
facility
times
the
number
of
facilities.
There
are
an
estimated
127
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
over
3
years,
1
new
facility
will
be
built
each
year.

b
Labor
cost
assumes
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.

c
Assumes
one
existing
facility
and
no
new
facilities
will
conduct
initial
performance
tests,
and
EPA
personnel
will
attend
10
percent
of
the
initial
tests
(
approximately
0
tests).

d
Assumes
no
repeat
performance
tests.

e
Assumes
no
performance
evaluations
are
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,
which
requires
CEMS
and
performance
evaluations.

f
Assumes
10
percent
of
existing
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
report.

h
Assumes
one
existing
facility
and
no
new
facilities
will
conduct
initial
performance
tests.
The
notification
of
compliance
status
includes
the
report
of
the
performance
tests.

i
Assumes
all
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
with
no
performance
tests.
The
notification
of
compliance
status
includes
those
calculations.
30
TABLE
2a.
(
continued)

j
Assumes
10
percent
of
facilities
will
implement
process
changes.

k
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.
90
percent
of
1
facility
with
no
deviations
reporting
twice
per
year
is
2
operations.
10
percent
of
1
facility
with
deviations
reporting
twice
per
year
is
0
operations.

l
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
startup,
shutdown,
and
malfunction
plan.

m
Assumes
all
facilities
will
report
the
specified
information
for
processes
subject
to
the
equipment
leak
standards.

n
The
burden
and
cost
are
equal
to
the
person­
hours
added
down
each
column
for
technical,
management,
clerical,
and
total
respondent
labor
and
the
sum
of
the
cost
column.

o
Tests
attended
include
no
initial
performance
tests,
no
repeat
performance
tests,
for
a
total
of
0
tests
attended.
31
TABLE
2b.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
SECOND
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
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
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
1.
Attend
Initial
Performance
Testc
40
0
0
0
0
0
$
0
2.
Attend
Repeat
Performance
Testd
40
0
0
0
0
0
$
0
3.
Attend
Initial
CMS
Performance
Evaluatione
2
0
0
0
0
0
$
0
4.
Litigation
N/
A
5.
Report
Review
A.
Review
Notification
of
Construction/
Reconstruction
2
1
2
0.1
0.2
2
$
102
B.
Review
Notification
of
Anticipated
Startup
2
1
2
0.1
0.2
2
$
102
C.
Review
Notification
of
Actual
Startup
2
1
2
0.1
0.2
2
$
102
D.
Review
Notification
of
Applicability
of
Standard
2
1
2
0.1
0.2
2
$
102
E.
Review
Emissions
Averaging
Planf
20
13
260
13
26
299
$
13,310
F.
Review
Precompliance
Reportg
4
64
256
13
26
294
$
13,105
G.
Review
Notification
of
Initial
Performance
Test
2
1
2
0.1
0.2
2
$
102
H.
Review
Notification
of
Initial
CMS
Performance
Evaluatione
2
0
0
0
0
0
$
0
I.
Review
Notification
of
Compliance
Status
°
With
performance
testh
40
0
0
0
0
0
$
0
°
Without
performance
testi
40
1
40
2
4
46
$
2,048
J.
Review
Notification
of
Process
Changej
8
0
0
0
0
0
$
0
32
TABLE
2b.
(
continued)

Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
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
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
K.
Review
Semi­
Annual
Compliance
Report
°
No
deviationsk
2
4
8
0.4
0.8
9
$
410
°
Deviationsk
8
0
0
0
0
0
$
0
°
Startup,
shutdown,
and
malfunction
reportl
2
4
8
0.4
0.8
9
$
410
°
LDAR
reportm
8
4
32
2
3
37
$
1,638
°
Emissions
averaging
reportf
8
0
0
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY):
n
614
31
61
706
$
31,431
TRAVEL
EXPENSES
FOR
TEST
ATTENDEDo
=
(
1
person
*
0
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
0
round
trip/
yr):
$
0
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES:
$
31,431
a
Operations
per
year
are
equal
to
the
number
of
operations
(
e.
g.,
performance
tests,
notifications,
reports)
per
facility
times
the
number
of
facilities.
There
are
an
estimated
127
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
over
3
years,
1
new
facility
will
be
built
each
year.

b
Labor
cost
assumes
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.

c
Assumes
one
existing
facility
and
no
new
facilities
will
conduct
initial
performance
tests,
and
EPA
personnel
will
attend
10
percent
of
the
initial
tests
(
approximately
0
tests).

d
Assumes
no
repeat
performance
tests.

e
Assumes
no
performance
evaluations
are
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,
which
requires
CEMS
and
performance
evaluations.

f
Assumes
10
percent
of
existing
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
report.

h
Assumes
one
existing
facility
and
no
new
facilities
will
conduct
initial
performance
tests.
The
notification
of
compliance
status
includes
the
report
of
the
performance
tests.
33
TABLE
2b.
(
continued)

i
Assumes
all
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
with
no
performance
tests.
The
notification
of
compliance
status
includes
those
calculations.

j
Assumes
10
percent
of
facilities
will
implement
process
changes.

k
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.
90
percent
of
1
facility
with
no
deviations
reporting
twice
per
year
is
2
operations.
10
percent
of
1
facility
with
deviations
reporting
twice
per
year
is
0
operations.

l
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
startup,
shutdown,
and
malfunction
plan.

m
Assumes
all
facilities
will
report
the
specified
information
for
processes
subject
to
the
equipment
leak
standards.

n
The
burden
and
cost
are
equal
to
the
person­
hours
added
down
each
column
for
technical,
management,
clerical,
and
total
respondent
labor
and
the
sum
of
the
cost
column.

o
Tests
attended
include
no
initial
performance
tests,
no
repeat
performance
tests,
for
a
total
of
0
tests
attended.
34
TABLE
2c.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
THIRD
YEAR
FOLLOWING
THE
EFFECTIVE
DATE
Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
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
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
1.
Attend
Initial
Performance
Testc
40
0
0
0
0
0
$
0
2.
Attend
Repeat
Performance
Testd
40
0
0
0
0
0
$
0
3.
Attend
Initial
CMS
Performance
Evaluatione
2
0
0
0
0
0
$
0
4.
Litigation
N/
A
5.
Report
Review
A.
Review
Notification
of
Construction/
Reconstruction
2
1
2
0.1
0.2
2
$
102
B.
Review
Notification
of
Anticipated
Startup
2
1
2
0.1
0.2
2
$
102
C.
Review
Notification
of
Actual
Startup
2
1
2
0.1
0.2
2
$
102
D.
Review
Notification
of
Applicability
of
Standard
2
1
2
0.1
0.2
2
$
102
E.
Review
Emissions
Averaging
Planf
20
0
0
0
0
0
$
0
F.
Review
Precompliance
Reportg
4
1
4
0.2
0.4
5
$
205
G.
Review
Notification
of
Initial
Performance
Test
2
0
0
0
0
0
$
0
H.
Review
Notification
of
Initial
CMS
Performance
Evaluatione
2
0
0
0
0
0
$
0
I.
Review
Notification
of
Compliance
Status
°
With
performance
testh
40
1
40
2
4
46
$
2,048
°
Without
performance
testi
40
128
5,120
256
512
5,888
$
262,095
J.
Review
Notification
of
Process
Changej
8
0
0
0
0
0
$
0
K.
Review
Semi­
Annual
Compliance
Report
°
No
deviationsk
2
5
10
0.5
1
12
$
512
°
Deviationsk
8
1
8
0.4
0.8
9
$
410
35
TABLE
2c.
(
continued)

Activity
A
EPA
hours
per
operation
B
Operations
per
yeara
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
Total
person­
hours
per
year
(
F
=
C
+
D
+
E)
G
Labor
cost,

$
b
°
Startup,
shutdown,
and
malfunction
reportl
2
6
12
0.6
1
14
$
614
°
LDAR
reportm
8
6
48
2
5
55
$
2,457
°
Emissions
averaging
reportf
8
0
0
0
0
0
$
0
TOTAL
BURDEN
AND
COST
(
SALARY):
n
5,250
263
525
6,038
$
268,750
TRAVEL
EXPENSES
FOR
TEST
ATTENDEDo
=
(
1
person
*
0
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*
0
round
trips/
yr):
$
0
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES:
$
268,750
a
Operations
per
year
are
equal
to
the
number
of
operations
(
e.
g.,
performance
tests,
notifications,
reports)
per
facility
times
the
number
of
facilities.
There
are
an
estimated
127
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
over
3
years,
1
new
facility
will
be
built
each
year.

b
Labor
cost
assumes
a
rate
of
$
45.04/
hour
for
technical
labor,
$
66.73/
hour
for
management
labor,
and
$
28.14/
hour
for
clerical
labor.

c
Assumes
one
existing
facility
and
no
new
facilities
will
conduct
initial
performance
tests,
and
EPA
personnel
will
attend
10
percent
of
the
initial
tests
(
approximately
0
tests).

d
Assumes
no
repeat
performance
tests.

e
Assumes
no
performance
evaluations
are
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,
which
requires
CEMS
and
performance
evaluations.

f
Assumes
10
percent
of
existing
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
report.

h
Assumes
one
existing
facility
and
no
new
facilities
will
conduct
initial
performance
tests.
The
notification
of
compliance
status
includes
the
report
of
the
performance
tests.

i
Assumes
all
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
with
no
performance
tests.
The
notification
of
compliance
status
includes
those
calculations.

j
Assumes
10
percent
of
facilities
will
implement
process
changes.

k
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.
90
percent
of
1
facility
with
no
deviations
reporting
twice
per
year
is
2
operations.
10
percent
of
1
facility
with
deviations
reporting
twice
per
year
is
0
operations.
36
TABLE
2c.
(
continued)

l
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
startup,
shutdown,
and
malfunction
plan.

m
Assumes
all
facilities
will
report
the
specified
information
for
processes
subject
to
the
equipment
leak
standards.

n
The
burden
and
cost
are
equal
to
the
person­
hours
added
down
each
column
for
technical,
management,
clerical,
and
total
respondent
labor
and
the
sum
of
the
cost
column.

o
Tests
attended
include
no
initial
performance
tests,
no
repeat
performance
tests,
for
a
total
of
0
tests
attended.
37
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
Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
by
EPA.
The
EPA
has
reduced
the
reporting
and
recordkeeping
burden
for
respondents
to
include
only
the
information
that
EPA
needs
to
determine
compliance
with
the
rule.
Few
of
the
127
existing
facilities
subject
to
the
miscellaneous
coating
manufacturing
NESHAP
are
expected
to
meet
the
applicability
criteria
for
small
businesses.

The
EPA
does
not
expect
that
small
coating
manufacturing
businesses
will
experience
adverse
impacts
related
to
the
cost
of
the
required
reporting
and
recordkeeping.

(
d)
Collection
Schedule
Collection
of
data
will
begin
after
the
effective
date
of
the
miscellaneous
coating
manufacturing
NESHAP.
The
schedule
for
notifications
and
reports
required
by
the
rule
is
summarized
below.

For
all
existing
miscellaneous
coating
manufacturing
facilities,
the
initial
notification
report
stating
that
the
facility
is
subject
to
the
rule
must
be
submitted
no
later
than
4
months
(
120
days)
after
the
effective
date
of
the
rule.
New
or
reconstructed
miscellaneous
coating
manufacturing
facilities
for
which
startup
occurs
on
or
after
the
effective
date
must
submit
the
initial
notification
no
later
than
120
days
after
the
source
becomes
subject
to
the
rule.
New
or
reconstructed
facilities
must
comply
immediately
upon
the
effective
date
of
the
final
rule
if
their
date
is
before
the
effective
date
or
upon
startup
if
the
startup
date
is
on
or
after
the
effective
date.
38
Facilities
required
to
conduct
a
performance
test
must
submit
a
notification
of
intent
to
conduct
a
performance
test
at
least
60
days
before
the
performance
test
is
scheduled
to
begin.

For
each
initial
compliance
demonstration
that
does
not
include
a
performance
test,
facilities
must
submit
an
initial
notification
of
compliance
status
no
later
than
30
days
following
the
completion
of
the
initial
compliance
demonstration.
For
each
initial
compliance
demonstration
that
includes
a
performance
test,
facilities
must
submit
an
initial
notification
of
compliance
status
no
later
than
60
days
following
the
completion
of
the
performance
test.
If
averaging
emissions,
existing
facilities
must
also
submit
an
emissions
averaging
plan
at
least
18
months
before
their
compliance
date.

Records
necessary
to
determine
compliance
will
be
compiled
on
a
daily
basis,
and
compliance
reports
must
be
submitted
to
the
Administrator
on
a
semi­
annual
basis,
as
discussed
in
section
1(
b).

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
through
1d.
Tables
1a,
1b,

and
1c
present
the
estimated
one­
time
burden
to
the
industry
for
reporting
and
recordkeeping
activities
during
the
first,
second,

and
third
years,
respectively,
after
the
effective
date
of
the
rule.
Table
1d
presents
the
average
recurrent
burden
to
the
industry
during
each
of
the
3
years
following
the
effective
date
of
the
rule.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
EPA's
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts.
39
(
b)
Estimating
Respondent
Costs
(
i)
Estimating
labor
costs.
The
annual
labor
costs
for
reporting
and
recordkeeping
activities
are
also
presented
in
Tables
1a
through
1d.
The
costs
of
these
activities
were
estimated
based
on
data
from
the
U.
S.
Bureau
of
Labor
Statistics.

Labor
costs
are
divided
into
the
following
three
categories:

(
1)
technical,
(
2)
management,
and
(
3)
clerical.
The
cost
of
technical
labor
was
estimated
at
$
45.04
per
hour
($
45.04/
hr),
the
cost
of
management
labor
at
$
66.73/
hr,
and
the
cost
of
clerical
labor
at
$
28.14/
hr.
These
estimates
include
fringe
benefits,

overhead,
and
profit
rate.

(
ii)
Estimating
capital
and
O&
M
costs.
There
are
two
types
of
non­
labor
related
costs
associated
with
information
collection
activities:
capital
costs
and
operation
and
maintenance
(
O&
M)

costs.
The
methods
used
to
estimate
the
capital
and
O&
M
costs
for
this
Supporting
Statement
are
presented
in
Attachment
3,

Methods
Used
in
Cost
Estimates.

One­
time
capital
costs
usually
include
any
produced
physical
good,
such
as
computers,
machinery,
or
equipment,
that
must
be
purchased
for
the
specific
purpose
of
satisfying
EPA's
reporting
or
recordkeeping
requirements.
Capital
costs
are
usually
incurred
only
once,
at
the
beginning
of
an
information
collection
period.
A
one­
time
capital
cost
can
be
estimated
over
multiple
years
by
annualizing
the
cost
using
an
OMB­
approved
interest
rate.
For
this
Supporting
Statement,
capital
costs
were
annualized
over
10
years
for
transfer
operations
and
15
years
for
process
vessels
and
wastewater
operations,
assuming
an
interest
rate
of
7
percent.
In
most
cases,
administrative
charges,

insurance,
and
property
taxes
were
also
included
with
the
annualized
capital
costs,
at
4
percent
of
the
capital
cost.

The
capital
costs
associated
with
monitoring
equipment
include
the
monitoring
equipment,
installation,
ancillary
costs
40
(
planning
and
selection),
and
a
data
acquisition
system
(
DAS)

(
data
logger,
computer,
logging
and
reporting
software,
and
printer).
The
capital
costs
for
the
monitoring
equipment
were
estimated
based
on
the
following
assumptions:
(
1)
the
monitoring
equipment
cost
per
facility
is
$
29,986
for
process
vessels,
which
includes
the
cost
for
thermocouple,
wire,
and
DAS;
(
2)
one
new
facility
will
purchase
this
equipment
for
process
vessels
in
each
of
the
first
3
years
after
the
effective
date
of
the
rule;
(
3)
no
new
facilities
will
purchase
monitoring
equipment
for
transfer
operations
or
wastewater
systems;
and
(
4)
no
monitoring
equipment
are
required
for
storage
tanks.

The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility
(
assume
$
235
per
file
cabinet).
An
estimated
one
new
facility
will
purchase
this
equipment
in
each
of
the
first
3
years
after
the
effective
date
of
the
rule.

Costs
for
performance
testing
are
also
considered
capital
costs
because
it
is
expected
that
facilities
will
hire
a
contractor
to
conduct
the
test.
The
capital
costs
associated
with
performance
testing
include
the
costs
for
performance
tests
for
transfer
operations
at
existing
facilities.
Performance
test
costs
were
estimated
based
on
the
following
assumptions:

(
1)
capital
costs
per
test
are
$
24,420;
(
2)
one
existing
facility
with
transfer
operations
will
conduct
a
performance
test
in
the
third
year
after
the
effective
date;
(
3)
no
new
facilities
will
conduct
a
performance
test;
(
4)
no
performance
tests
are
required
for
process
vessels,
storage
tanks,
or
wastewater
systems;
and
(
5)
no
facilities
will
repeat
the
performance
test.
Because
no
equipment
is
purchased,
no
administrative
charges,
insurance,
or
property
taxes
were
estimated
for
performance
testing.

Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
41
monitoring
equipment.
Those
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment.
The
monitoring
labor
costs
for
process
vessels
were
estimated
based
on
8,760
operating
hours
per
year,

0.5
hour
of
labor
per
8­
hr
shift,
and
a
wage
rate
of
$
17.21/
hr.

Maintenance
materials
and
supplies
were
estimated
at
$
500.

Overhead
was
estimated
at
60
percent
of
labor
costs
plus
maintenance
materials
and
supplies
costs.
The
O&
M
cost
per
facility
associated
with
the
monitoring
equipment
is
$
15,875
for
process
vessels.
Because
no
new
facilities
are
expected
to
purchase
monitoring
equipment
for
transfer
operations
or
wastewater
systems
and
no
monitoring
equipment
are
required
for
storage
tanks,
there
are
no
O&
M
costs
associated
with
the
monitoring
equipment
for
these
emission
points
for
the
first
3
years
after
the
effective
date
of
the
rule.

Operation
and
maintenance
costs
also
include
the
costs
associated
with
the
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
For
example,
the
O&
M
costs
for
rules
that
require
respondents
to
submit
reports
to
EPA
and
maintain
records
should
be
estimated
as
costs
for
photocopying
and
postage.
Photocopying
costs
per
response
were
estimated
at
0.5
hour
of
clerical
labor
at
a
wage
rate
of
$
28.14/
hr.
First
class
postage
was
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
Photocopying
and
postage
costs
will
be
applied
to
the
135
responses
submitted
during
the
first
year,
the
87
responses
submitted
during
the
second
year,
and
the
140
responses
submitted
during
the
third
year.
(
The
number
of
responses
was
determined
by
adding
the
number
of
reports
submitted
to
EPA
by
respondents,
as
shown
in
Tables
1a
through
1d.)
42
(
c)
Estimating
Agency
Burden
and
Costs
Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
the
standards
development,
no
costs
can
be
attributed
to
the
development
of
these
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
CAA.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
Facility
Subsystem,
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
facilities.
Periodic
inspections
are
part
of
EPA's
overall
compliance
and
enforcement
program.
Therefore,
this
examination
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
facilities
in
one­
time
notifications
and
semiannual
compliance
reports
(
unless
the
compliance
report
indicates
a
deviation,
thereby
triggering
an
enforcement
action).
Tables
2a,
2b,
and
2c
present
the
estimated
annual
burden
to
the
Federal
Government
during
the
first,
second,
and
third
years,

respectively,
after
the
effective
date
of
the
rule.
Labor
costs
were
estimated
based
on
estimated
wage
rates
of
$
45.04/
hr
for
technical
labor,
$
66.73/
hr
for
management
labor,
and
$
28.14/
hr
for
clerical
labor.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Once
the
burden
and
costs
per
activity
have
been
established
on
a
per
respondent
basis,
the
total
burden
and
cost
must
be
calculated
for
all
respondents
and
for
EPA.
To
calculate
the
43
total
burden
and
costs,
the
number
of
respondents
needed
to
complete
each
information
collection
activity
must
be
estimated.

The
total
number
of
respondents
is
also
referred
to
as
the
"
respondent
universe."
The
respondent
universe
varies
among
the
activities
listed
because
not
all
respondents
must
complete
each
activity.

The
respondent
universe
for
this
ICR
is
based
on
data
collected
from
nearly
130
sources
in
SIC
Codes
285
and
289.
The
burden
and
costs
were
estimated
for
an
existing
respondent
universe
of
127
miscellaneous
coating
manufacturing
facilities
and
a
projected
new
respondent
universe
of
3
miscellaneous
coating
manufacturing
facilities
over
the
first
3
years
after
the
effective
date.

To
determine
the
burden
for
each
activity
for
technical
staff,
the
number
of
hours
per
respondent
was
multiplied
by
the
number
of
respondents.
Management
and
clerical
labor
hours
were
calculated
at
5
percent
and
10
percent
of
technical
labor
hours,

respectively.
The
total
burden
was
determined
by
summing
the
technical,
management,
and
clerical
burden
estimates.
To
determine
the
total
labor
cost,
the
burden
estimates
for
technical,
management,
and
clerical
labor
were
multiplied
by
their
respective
wage
rates
and
then
summed.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
tally.
The
bottom
line
annual
respondent
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Tables
1a,
1b,
and
1c,
dividing
the
sums
by
the
3­
year
review
period,
and
then
adding
the
average
recurrent
burden
and
costs
from
Table
1d.
The
total
annual
respondent
burden
hours
and
costs
are
summarized
as
follows:
44
Total
burden,
hours
Total
costs,
$

Table
1a
(
one­
time
activities
in
first
year)
840
$
37,369
Table
1b
(
one­
time
activities
in
second
year)
3,900
$
173,587
Table
1c
(
one­
time
activities
in
third
year)
18,019
$
802,104
Table
1d
*
3
(
recurrent
activities
in
all
3
years)
7,658
$
340,905
Total
30,417
$
1,353,965
Bottom
line
annual
burden
10,139
$
451,322
The
bottom
line
annual
burden,
averaged
over
the
first
3
years
after
the
effective
date,
is
10,139
labor
hours,
at
a
cost
of
$
451,322.
The
average
annual
burden
per
respondent,

based
on
an
average
129
respondents
over
the
3­
year
review
period,
is
79
labor
hours,
at
a
cost
of
$
3,499.

There
are
an
estimated
121
total
annual
responses
for
the
first
3
years
after
the
effective
date.
The
total
annual
responses
are
based
on
an
estimated
135
one­
time
and
recurrent
notifications
and
reports
submitted
during
the
first
year,
87
during
the
second
year,
and
140
during
the
third
year.
Of
these
121
total
annual
responses,
approximately
20
percent
are
assumed
to
be
collected
electronically.

The
total
nationwide
capital
cost
associated
with
monitoring
equipment
was
estimated
to
be
$
29,986
in
each
of
the
first
3
years
after
the
effective
date
of
the
rule.
The
average
annualized
capital
cost
for
the
monitoring
equipment
is
$
8,984
for
the
3
years
following
the
effective
date.

The
total
nationwide
capital
cost
associated
with
file
cabinets
for
storing
collected
data
and
reports
was
estimated
to
be
$
235
in
each
of
the
first
3
years
after
the
effective
date
of
45
the
rule.
The
average
annualized
capital
cost
for
file
cabinets
is
$
70
for
the
3
years
following
the
effective
date.

The
total
nationwide
capital
cost
for
performance
tests
was
estimated
to
be
$
0
for
the
first
2
years
after
the
effective
date
of
the
rule
and
$
24,420
for
the
third
year
after
the
effective
date.
The
average
annualized
capital
cost
for
the
performance
tests
is
$
1,159
for
the
3
years
following
the
effective
date.

Annual
O&
M
costs,
which
include
monitoring
labor,

maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment,
as
well
as
photocopying
and
postage
for
the
reports,
average
$
34,369
for
the
3
years
following
the
effective
date
of
the
rule.

Combining
the
annualized
capital
costs
for
the
monitoring
equipment,
file
cabinets,
and
performance
tests
results
in
a
total
annualized
capital
cost
of
$
10,213
for
the
3
years
following
the
effective
date.
Summing
this
total
annualized
capital
cost
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
44,582
for
the
3
years
following
the
effective
date.
A
discussion
of
the
respondent
burden
and
costs
in
later
years
is
provided
in
Attachment
4,
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date.

(
ii)
Agency
tally.
The
bottom
line
annual
Agency
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Tables
2a,
2b,
and
2c
and
then
dividing
by
the
3­
year
review
period.
The
total
annual
Agency
burden
hours
and
costs
are
summarized
as
follows:
46
Total
burden,
hours
Total
costs,
$

Table
2a
(
first
year)
380
$
16,893
Table
2b
(
second
year)
706
$
31,431
Table
2c
(
third
year)
6,038
$
268,750
Total
7,123
$
317,074
Bottom
line
annual
burden
2,374
$
105,691
The
bottom
line
annual
burden,
averaged
over
the
first
3
years
after
the
effective
date,
is
2,374
labor
hours,
at
a
cost
of
$
105,691.
A
discussion
of
the
Agency
burden
and
costs
in
later
years
is
provided
in
Attachment
4,
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
for
the
Fourth,
Fifth,

and
Sixth
Years
Following
the
Effective
Date.

(
iii)
The
complex
collection.
This
section
does
not
apply
because
this
collection
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)
determining
applicability
and
notifying
EPA
that
the
facility
is
subject
to
the
rule
in
the
first
year;
(
2)
developing
and
submitting
an
emissions
averaging
plan
(
if
appropriate)
and
a
precompliance
report
and
notifying
EPA
of
upcoming
performance
tests
in
the
second
year;
and
(
3)
conducting
performance
tests
and
submitting
the
initial
notification
of
compliance
status
in
the
third
year.
Increasing
numbers
of
sources
installed
after
the
effective
date
will
also
be
subject
to
ongoing
requirements,

such
as
submitting
semi­
annual
compliance
reports,
over
the
3­
year
review
period.

The
Agency
burden
hours
and
costs
will
also
vary
over
the
3­
year
review
period
because
they
will
be
reviewing
the
following
47
notifications
and
reports
from
existing
sources:
(
1)
the
notifications
of
applicability
of
the
standard
in
the
first
year,

(
2)
the
emissions
averaging
plans
(
if
appropriate),
precompliance
reports,
and
notifications
of
performance
tests
in
the
second
year,
and
(
3)
the
notifications
of
compliance
status
in
the
third
year.
The
EPA
will
also
review
notifications
and
semi­
annual
compliance
reports
for
new
sources
over
the
3
years
as
they
are
constructed
and
as
startup
begins.

(
f)
Reasons
for
Change
In
Burden
This
section
does
not
apply
because
this
collection
is
a
new
collection.

(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
79
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,

retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;

develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,

and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
48
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

The
total
annual
reporting
and
recordkeeping
burden
and
cost
for
this
collection
averaged
over
the
first
3
years
after
the
effective
date
of
the
rule
were
estimated
to
be
10,139
labor
hours,
at
a
cost
of
$
451,322.
The
average
burden
and
cost,
per
respondent,
are
79
labor
hours
and
$
3,499.

During
these
3
years,
the
rule
requires
several
initial
onetime
notifications
and
reports
from
all
facilities.
In
addition,

new
facilities
are
required
to
submit
an
initial
one­
time
notification
of
compliance
status
and
subsequent
compliance
reports
semi­
annually
to
indicate
their
ongoing
compliance
status.
Each
respondent
also
must
keep
necessary
records
of
data
to
determine
compliance
with
the
rule.

In
the
first
year,
the
collection
requirements
will
be
applicable
to
an
estimated
128
respondents
(
127
existing
facilities
and
1
new
facility),
and
an
estimated
1
additional
facility
will
be
subject
to
the
rule
in
each
subsequent
year.

The
total
capital
cost
in
each
of
the
first
2
years
after
the
effective
date
of
the
rule
is
$
30,221;
this
cost
includes
$
29,986
for
monitoring
equipment
and
$
235
for
file
cabinets.
The
total
capital
cost
in
the
third
year
after
the
effective
date
is
$
54,641,
which
includes
$
29,986
for
monitoring
equipment,
$
235
for
file
cabinets,
and
$
24,420
for
performance
tests.
The
annualized
capital
cost
for
the
monitoring
equipment,
file
cabinets,
and
performance
tests
is
$
10,213
for
the
3
years
after
the
effective
date.
The
average
annual
O&
M
cost,
which
includes
monitoring
labor,
maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment,
as
well
as
photocopying
and
postage
for
the
reports,
is
$
34,369
for
the
3
years
after
the
effective
date.
Combining
the
annualized
capital
costs
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
44,582
for
the
3
years
after
the
effective
date.
49
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2003­
0178,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,

Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
Docket
is
(
202)
566­
1742).
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:

Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­

2003­
0178).
50
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
this
rule.

4
attachments
ATTACHMENT
1
Source
Data
and
Information
Requirements
Attachment
1
SUMMARY
OF
RECORDKEEPING
REQUIREMENTS
Requirements
Regulation
Reference
Record
retention
63.10(
b)(
1)
and
63.8085
Documentation
supporting
initial
notifications
and
notifications
of
compliance
status
63.10(
b)(
2)(
xiv)
and
63.8080(
a)(
1)

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

Records
related
to
startup,
shutdown,
and
malfunction
63.6(
e)(
3)(
iii)­(
iv)
and
63.8080(
a)(
2)

Records
of
performance
tests
and
CMS
performance
evaluations
63.10(
b)(
2)(
viii)
and
63.8080(
a)(
3)

Records
for
equipment
leaks
63.1038(
b)­(
c)
and
63.8080(
a)(
4)

Daily
schedule
or
log
of
each
operating
scenario
63.8080(
a)(
5)

Records
for
process
vessels
complying
with
percent
reduction
emission
limitation
63.8080(
a)(
6)

Planned
routine
maintenance
records
for
storage
tank
control
devices
63.8080(
a)(
7)

Maintenance
wastewater
plan
63.8080(
a)(
8)

Records
for
safety
device
openings
63.8080(
a)(
9)

Results
of
each
CMS
calibration,
validation
check,
and
inspection
63.8035(
c)(
6)­(
8),
(
d)(
4)­(
5),
(
e)(
4)­(
7),
(
f)(
3)­(
4),
63.8080(
a)(
10)

Records
for
emissions
averaging
63.1250­
63.1260,
63.8060
Records
for
each
CMS
63.8(
d)(
3),
63.8(
f)(
6)(
i),
63.10(
b)(
2)(
vi)­
(
xi),
and
63.8080(
b)

SUMMARY
OF
REPORTING
REQUIREMENTS
Requirements
Regulation
Reference
Initial
notifications
(
including
construction/
reconstruction)
63.5,
63.9(
b),
and
63.8070(
a)­(
c)

Notification
of
performance
test,
test
plan,
and
emission
profile
63.7(
b)­(
c),
63.9(
e),
and
63.8070(
a),(
d)

Notification
of
CMS
performance
evaluation
63.8(
e)(
2)
and
63.9(
g)

Notification
of
compliance
status
(
including
performance
test
results)
63.9(
h),
63.10(
d)(
2),
and
63.8070(
e)

Notification
of
process
change
63.8070(
f)

Emissions
averaging
plan
63.1250­
63.1260,
63.8060
Precompliance
report
63.8075(
c)
SUMMARY
OF
REPORTING
REQUIREMENTS
(
continued)
Attachment
1
Requirements
Regulation
Reference
Semi­
annual
compliance
report
°
Startup,
shutdown,
and
malfunction
reports
°
Deviations/
no
deviations/
out­
of­
control
CMS
°
No
out­
of­
control
CMS
°
Heat
exchange
system
reports
(
delay
of
repair)
°
Maintenance
and
inspection
reports
for
storage
tank
control
devices
°
Operating
scenario
reports
°
Equipment
leak
reports
°
Emissions
averaging
reports
63.10(
e)(
3)
and
63.8075(
b),(
d)
63.10(
d)(
5)
and
63.8075(
d)(
4)
63.8075(
d)(
5)
63.8(
c)(
7),
63.8075(
d)(
6)
63.104(
e),
(
f)(
2)(
i)­(
iv),
63.8075(
d)(
7)
63.1063(
c)(
2)(
iv)(
B)
or
(
e)(
2),
63.8075(
d)(
8)
63.8075(
d)(
9)
63.1039(
b)(
1)­(
8)
and
63.8075(
d)(
10)
63.1250­
63.1260,
63.8060
ATTACHMENT
2
Description
of
Respondent
Activities
Attachment
2
DESCRIPTION
OF
RESPONDENT
ACTIVITIES
(
1)
Read
Instructions
represents
the
activities,
less
training,
which
involve
comprehending
the
provisions
in
the
rule
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
item
(
4)
below.

(
3)
Train
Personnel
represents
activities
involved
in
communicating
specific
definitions,
compliance
options,
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.
However,
the
rule
does
not
require
specific
training
itself.

(
4)
Create
Information
represents
the
activities
involving
testing,
retesting,
establishing
operating
parameter
limits,
and
analyzing
point­
by­
point
applicability.
Because
respondents
are
expected
to
hire
outside
contractors
to
conduct
the
performance
tests,
these
costs
are
not
included
in
the
burden
tables.
Instead,
the
costs
associated
with
the
performance
test
are
included
as
capital
costs
and
are
discussed
in
the
text.

(
5)
Gather
Existing
Information
represents
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)
Write
Reports
represents
the
activities
normally
associated
with
filling
out
forms.
Since
the
rule
requires
no
standard
forms,
these
activities
relate
to
the
preparation
of
formal
reports
and
cover
letters,
as
appropriate.

(
7)
Enter
Information
represent
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;
and
the
management
life
cycle
of
records,
from
the
time
they
are
filed
and
boxed
up
to
the
time
at
which
they
are
disposed.
ATTACHMENT
3
Methods
Used
in
Cost
Estimates
Attachment
3
METHODS
USED
IN
COST
ESTIMATES
(
a)
Costs
for
Monitoring
Equipment
The
capital
cost
for
the
monitoring
equipment
was
estimated
based
on
the
following
assumptions:

1.
The
monitoring
equipment
cost
per
facility
for
process
vessels
is
$
29,986,
which
includes
the
cost
for
thermocouple,
wire,
and
data
acquisition
system.

2.
The
monitoring
equipment
cost
per
facility
for
wastewater
systems
is
$
20,120,
which
includes
the
cost
for
steam
flow
meter,
liquid
flow
meter,
thermocouple,
wire,
and
data
acquisition
system.

3.
The
monitoring
equipment
cost
per
facility
for
transfer
operations
is
$
3,000,
which
includes
the
cost
for
a
data
logger.

To
determine
the
total
capital
cost
for
monitoring
equipment
for
existing
and
new
facilities,
the
unit
costs
were
applied
to
process
vessels,
wastewater
systems,
and
transfer
operations
at
the
127
existing
facilities
as
follows:

Emission
point
Number
of
facilities
Unit
capital
cost
Capital
cost
Annualized
capital
cost
Process
vessels
Existing
127
$
29,986
$
3,808,209
$
570,470
New
(
each
year)
1
$
29,986
$
29,986
$
4,492
Existing
wastewater
systems
2
$
20,120
$
40,240
$
6,028
Existing
transfer
operations
1
$
3,000
$
3,000
$
547
The
annualized
capital
cost
for
monitoring
equipment
was
calculated
as
a
sum
of
the
capital
recovery
cost,
administrative
charges,
insurance,
and
property
taxes.
The
capital
recovery
cost
was
determined
as
a
product
of
a
capital
recovery
factor
and
the
total
capital
cost.
The
capital
recovery
factor
for
monitoring
equipment
for
process
vessels
and
wastewater
systems
was
estimated
to
be
0.1098,
based
on
a
15­
year
equipment
life
and
7
percent
interest
rate.
The
capital
recovery
factor
for
Attachment
3
monitoring
equipment
for
transfer
operations
was
estimated
to
be
0.1424,
based
on
a
10­
year
equipment
life
and
7
percent
interest
rate.
The
administrative
charges,
insurance,
and
property
taxes
were
calculated
as
4
percent
of
the
capital
cost.
Using
these
estimated
costs,
the
capital
and
annualized
capital
costs
for
monitoring
equipment
for
the
first
6
years
after
the
effective
date
were
estimated
as
follows:

New
process
vessels
Existing
process
vessels
Existing
wastewater
systems
Existing
transfer
operations
Total
CAPITAL
COSTS
Year
1
$
29,986
$
0
$
0
$
0
$
29,986
Year
2
$
29,986
$
0
$
0
$
0
$
29,986
Year
3
$
29,986
$
0
$
0
$
0
$
29,986
AVERAGE
(
Years
1­
3)
$
29,986
$
0
$
0
$
0
$
29,986
Year
4
$
29,986
$
3,808,209
$
40,240
$
3,000
$
3,881,435
Year
5
$
29,986
$
0
$
0
$
0
$
29,986
Year
6
$
29,986
$
0
$
0
$
0
$
29,986
AVERAGE
(
Years
4­
6)
$
29,986
$
1,269,403
$
13,413
$
1,000
$
1,313,802
ANNUALIZED
CAPITAL
COSTSa
Year
1
$
4,492
$
0
$
0
$
0
$
4,492
Year
2
$
8,984
$
0
$
0
$
0
$
8,984
Year
3
$
13,476
$
0
$
0
$
0
$
13,476
AVERAGE
(
Years
1­
3)
$
8,984
$
0
$
0
$
0
$
8,984
Year
4
$
17,968
$
570,470
$
6,028
$
547
$
595,012
Year
5
$
22,459
$
570,470
$
6,028
$
547
$
599,504
Year
6
$
26,951
$
570,470
$
6,028
$
547
$
603,996
AVERAGE
(
Years
4­
6)
$
22,459
$
570,470
$
6,028
$
547
$
599,504
aWith
one
new
facility
being
added
each
year,
the
increase
in
annualized
capital
costs
each
year
is
equal
to
the
amount
of
annualized
capital
cost
for
one
facility.
For
example,
the
annualized
capital
cost
for
Year
1
would
be
$
4,492,
while
the
annualized
capital
cost
for
Year
2
would
be
2
times
$
4,492,
or
$
8,984.
Attachment
3
(
b)
Costs
for
File
Cabinets
The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility.
We
assumed
$
235
per
file
cabinet.
Using
a
capital
recovery
factor
of
0.1098
and
estimating
administrative
charges,
insurance,
and
property
taxes
at
4
percent
of
total
capital
cost,
the
average
annualized
capital
cost
per
facility
for
file
cabinets
was
estimated
to
be
$
35.
Using
these
estimated
costs,
the
capital
and
annualized
capital
costs
for
file
cabinets
for
the
first
6
years
after
the
effective
date
were
estimated
as
follows:

Capital
cost/
respondent
Annualized
capital
cost/
respondent
Capital
cost
respondents/
yr
Annual
cost
respondents/
yr
Capital
cost
Annualized
capital
cost
Year
1
$
235
$
35
1
1
$
235
$
35
Year
2
$
235
$
35
1
2
$
235
$
70
Year
3
$
235
$
35
1
3
$
235
$
105
AVERAGE
(
Years
1­
3)
$
470
$
70
Year
4
$
235
$
35
128
131
$
30,080
$
4,585
Year
5
$
235
$
35
1
132
$
235
$
4,620
Year
6
$
235
$
35
1
133
$
235
$
4,655
AVERAGE
(
Years
4­
6)
$
10,183
$,
4620
(
c)
Costs
for
Performance
Tests
The
capital
costs
associated
with
performance
testing
include
the
costs
for
performance
tests
for
transfer
operations
at
existing
facilities.
Performance
test
costs
were
estimated
based
on
the
following
assumptions:

1.
Capital
costs
per
facility
are
$
24,420;

2.
One
existing
facility
with
transfer
operations
will
conduct
a
performance
test
in
the
third
year
after
the
effective
date;

3.
No
new
facilities
will
conduct
a
performance
test;
Attachment
3
4.
No
performance
tests
are
required
for
process
vessels,

storage
tanks,
or
wastewater
systems;
and
5.
No
facilities
will
repeat
the
performance
test.

The
annualized
capital
cost
for
performance
tests
was
estimated
as
a
capital
recovery
cost,
which
was
calculated
as
a
product
of
a
capital
recovery
factor
and
the
total
capital
cost.

The
capital
recovery
factor
was
estimated
to
be
0.1424,
based
on
a
10­
year
annualization
and
7
percent
interest
rate.
Because
no
equipment
is
purchased,
no
administrative
charges,
insurance,
or
property
taxes
were
estimated
for
performance
tests.
The
annualized
capital
cost
was
estimated
to
be
$
3,477.
Using
these
test
costs,
the
capital
and
annualized
capital
costs
for
performance
testing
for
the
first
6
years
after
the
effective
date
were
estimated
as
follows:

Capital
cost
Annualized
capital
cost
Year
1
$
0
$
0
Year
2
$
0
$
0
Year
3
$
24,420
$
3,477
AVERAGE
(
Years
1­
3)
$
8,140
$
1,159
Year
4
$
0
$
3,477
Year
5
$
0
$
3,477
Year
6
$
0
$
3,477
AVERAGE
(
Years
4­
6)
$
0
$
3,477
(
d)
Costs
for
Operation
and
Maintenance
Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
monitoring
equipment.
These
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment.
The
monitoring
labor
costs
for
process
vessels
were
estimated
based
on
8,760
operating
hours
per
year,

0.5
hour
of
labor
per
8­
hr
shift,
and
a
wage
rate
of
$
17.21/
hr.
Attachment
3
The
monitoring
labor
costs
for
wastewater
systems
were
estimated
based
on
834
operating
hours
per
year,
0.5
hour
of
labor
per
8­
hr
shift,
and
a
wage
rate
of
$
22.50/
hr.
The
monitoring
labor
costs
for
transfer
operations
were
estimated
based
on
300
operating
days
per
year,
0.5
hour
of
labor
per
24­
hour
day,
and
a
wage
rate
of
$
17.21/
hr.
Maintenance
materials
and
supplies
were
estimated
at
$
500
for
process
vessels
and
transfer
operations
and
$
50
for
wastewater
operations.
Overhead
for
process
vessels
was
estimated
at
60
percent
of
labor
costs
plus
maintenance
materials
and
supplies
costs;
no
overhead
costs
were
estimated
for
wastewater
systems
or
transfer
operations.
Based
on
these
estimates,
the
O&
M
cost
associated
with
the
monitoring
equipment
is
$
15,875
for
process
vessels,
$
1,957
for
wastewater
systems,

and
$
3,082
for
storage
tanks.
To
determine
the
total
O&
M
cost
for
existing
and
new
facilities,
the
unit
costs
were
applied
to
process
vessels,
wastewater
systems,
and
transfer
operations
at
the
127
existing
facilities
as
follows:

Emission
point
Number
of
facilities
Unit
O&
M
cost
O&
M
cost
Process
vessels
Existing
127
$
15,875
$
2,016,150
New
(
each
year)
1
$
15,875
$
15,875
Wastewater
systems
2
$
1,957
$
3,914
Transfer
operations
1
$
3,082
$
3,082
Using
these
estimated
O&
M
costs,
the
O&
M
costs
for
the
first
6
years
after
the
effective
date
were
estimated
as
follows:

New
process
vessels
Existing
process
vessels
Existing
wastewater
systems
Existing
transfer
operations
Totala
Year
1
$
15,875
$
0
$
0
$
0
$
15,875
Year
2
$
31,750
$
0
$
0
$
0
$
31,750
Year
3
$
47,625
$
0
$
0
$
0
$
47,625
AVERAGE
(
Years
1­
3)
$
31,750
$
0
$
0
$
0
$
31,750
Attachment
3
New
process
vessels
Existing
process
vessels
Existing
wastewater
systems
Existing
transfer
operations
Totala
Year
4
$
63,500
$
2,016,150
$
3,914
$
3,082
$
2,086,647
Year
5
$
79,375
$
2,016,150
$
3,914
$
3,082
$
2,102,522
Year
6
$
95,250
$
2,016,150
$
3,914
$
3,082
$
2,118,397
AVERAGE
(
Years
4­
6)
$
79,375
$
2,016,150
$
3,914
$
3,082
$
2,102,522
aWith
one
new
facility
being
added
each
year,
the
increase
in
O&
M
costs
each
year
is
equal
to
the
amount
of
O&
M
cost
for
one
facility.
For
example,
the
O&
M
cost
for
Year
1
would
be
$
15,875,
while
the
O&
M
cost
for
Year
2
would
be
2
times
$
15,875,
or
$
31,750.

Operation
and
maintenance
costs
also
include
the
costs
associated
with
the
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
For
example,
the
O&
M
costs
for
rules
that
require
respondents
to
submit
reports
to
EPA
and
maintain
records
should
be
estimated
as
costs
for
photocopying
and
postage.
Photocopying
costs
per
response
were
estimated
at
0.5
hour
of
clerical
labor
at
a
wage
rate
of
$
28.14/
hr.
First
class
postage
was
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
Using
the
estimated
costs
per
response,
the
O&
M
costs
for
photocopying
and
postage
for
the
first
6
years
after
the
effective
date
were
estimated
as
follows:

Cost
item
Photocopy
cost/
report
Postage
cost/
report
Reports/

respondent
Respondents
yr
Reports/
yr
Photocopy
cost
Postage
cost
Notification
of
construction/
reconstruction
(
Years
1­
6)
$
14.07
$
7.63
1
1
1
$
14
$
7
Notification
of
anticipated
startup
(
Years
1­
6)
$
14.07
$
7.63
1
1
1
$
14
$
7
Notification
of
actual
start­
up
(
Years
1­
6)
$
14.07
$
7.63
1
1
1
$
14
$
7
Notification
of
initial
CMS
performance
evaluation
$
14.07
$
7.63
1
0
0
$
0
$
0
Attachment
3
Cost
item
Photocopy
cost/
report
Postage
cost/
report
Reports/

respondent
Respondents
yr
Reports/
yr
Photocopy
cost
Postage
cost
Notification
of
applicability
of
standard
Year
1
$
14.07
$
7.63
1
128
128
$
1,801
$
977
Years
2­
6
$
14.07
$
7.63
1
1
1
$
14
$
8
Emissions
averaging
plan
Years
1,
3­
6
$
14.07
$
7.63
1
0
0
0
0
Year
2
$
14.07
$
7.63
1
13
13
$
183
$
99
Precompliance
report
Years
1,
3­
6
$
14.07
$
7.63
1
1
1
$
14
$
8
Year
2
$
14.07
$
7.63
1
64
64
$
900
$
488
Notification
of
initial
performance
test
Years
1,
3­
6
$
14.07
$
7.63
1
0
0
$
0
$
0
Year
2
$
14.07
$
7.63
1
1
1
$
14
$
8
Notification
of
compliance
status
Years
1­
2,
4­
6
$
14.07
$
7.63
1
1
1
$
14
$
7
Year
3
$
14.07
$
7.63
1
129
129
$
1,815
$
984
Notification
of
process
change
Years
1­
3
$
14.07
$
7.63
1
0
0
$
0
$
0
Years
4­
6
$
14.07
$
7.63
1
13
13
$
183
$
99
Semi­
annual
compliance
report
Year
1
$
14.07
$
7.63
2
1
2
$
28
$
15
Year
2
$
14.07
$
7.63
2
2
4
$
56
$
31
Year
3
$
14.07
$
7.63
2
3
6
$
84
$
46
Year
4
$
14.07
$
7.63
2
131
262
$
3,686
$
1,999
Attachment
3
Cost
item
Photocopy
cost/
report
Postage
cost/
report
Reports/

respondent
Respondents
yr
Reports/
yr
Photocopy
cost
Postage
cost
Year
5
$
14.07
$
7.63
2
132
264
$
3,714
$
2,014
Year
6
$
14.07
$
7.63
2
133
266
$
3,743
$
2,030
TOTAL
(
Year
1)
$
1,899
$
1,030
TOTAL
(
Year
2)
$
1,224
$
664
TOTAL
(
Year
3)
$
1,970
$
1,068
AVERAGE
(
Years
1­
3)
$
1,704
$
2,762
TOTAL
(
Year
4)
$
3,954
$
2,144
TOTAL
(
Year
5)
$
3,982
$
2,159
TOTAL
(
Year
6)
$
4,010
$
2,175
AVERAGE
(
Years
4­
6)
$
3,982
$
2,159
ATTACHMENT
4
Burden
and
Cost
of
Reporting
and
Recordkeeping
Requirements
For
the
Fourth,
Fifth,
and
Sixth
Years
Following
the
Effective
Date
Attachment
4
1
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
FOR
THE
FOURTH,
FIFTH,
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
1.
The
Information
Collected
 
­
Respondent
Activities
and
Agency
Activities
(
a)
Respondent
Activities
As
shown
in
the
Supporting
Statement,
there
are
several
onetime
notifications
and
reports
that
both
existing
and
new
sources
must
complete
in
the
3
years
between
the
effective
date
of
the
miscellaneous
coating
manufacturing
NESHAP
and
the
compliance
date
for
existing
sources.
These
reports
include:

(
1)
determining
applicability
and
notifying
EPA
that
the
facility
is
subject
to
the
rule,
(
2)
developing
and
submitting
an
emissions
averaging
plan
(
if
appropriate),
(
3)
developing
and
submitting
a
precompliance
report,
(
4)
notifying
EPA
of
upcoming
performance
tests,
and
(
5)
conducting
performance
tests
and
submitting
the
initial
notification
of
compliance
status.
New
sources
are
also
required
to
submit
notifications
of
construction/
reconstruction,
notifications
of
anticipated
and
actual
startup,
and
semi­
annual
compliance
reports
during
the
3
years
between
the
effective
date
of
the
NESHAP
and
the
compliance
date
for
existing
sources.

In
the
3
years
following
the
compliance
date
for
existing
sources,
existing
sources
must
submit
other
reports,
and
ongoing
recordkeeping
and
reporting
begins.
In
the
first
year
following
the
compliance
date
for
existing
sources
(
or
the
fourth
year
following
the
effective
date
of
the
rule),
existing
facilities
develop
their
startup,
shutdown,
and
malfunction
plans
and
begin
ongoing
monitoring
and
recordkeeping
for
various
operating
parameters,
equipment
leaks,
emissions
averaging
(
if
appropriate),
etc.
The
existing
facilities
also
begin
to
submit
Attachment
4
2
semi­
annual
reports
that
include
information
on
deviations,

periods
of
startup,
shutdown,
or
malfunction,
equipment
leaks,

emissions
averaging
(
if
appropriate),
etc.

The
respondent
activities
required
in
the
fourth,
fifth,
and
sixth
years
following
the
effective
date
of
the
rule
are
listed
in
the
first
columns
of
Tables
1a
and
1b
of
this
attachment.

Table
1a
presents
the
one­
time
respondent
activities,
and
Table
1b
presents
the
recurrent
respondent
activities.

(
b)
Agency
Activities
As
shown
in
the
Supporting
Statement,
in
the
3
years
between
the
effective
date
of
the
NESHAP
and
the
compliance
date
for
existing
sources,
EPA
will
review
the
notifications
of
applicability,
emissions
averaging
plans
(
if
appropriate),

precompliance
reports,
notifications
of
performance
tests,
and
notifications
of
compliance
status
submitted
by
existing
and
new
sources.
The
EPA
will
also
review
the
notifications
of
construction/
reconstruction,
notifications
of
actual
and
anticipated
startup,
and
semi­
annual
compliance
reports
submitted
by
new
sources
over
the
3
years
between
the
effective
date
of
the
NESHAP
and
the
compliance
date
for
existing
sources.

In
the
3
years
following
the
compliance
date
for
existing
sources,
EPA
will
continue
to
review
the
notifications
and
semiannual
compliance
reports
submitted
by
new
sources.
In
the
first
year
following
the
compliance
date
for
existing
sources
(
or
the
fourth
year
following
the
effective
date
of
the
rule),
EPA
will
also
begin
reviewing
the
semi­
annual
compliance
reports
submitted
by
existing
sources.
The
Agency
activities
for
the
fourth,

fifth,
and
sixth
years
following
the
effective
date
of
the
rule
are
listed
in
the
first
columns
of
Table
2
of
this
attachment.
3
Attachment
4
TABLE
1a.
ONE­
TIME
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FOURTH,
FIFTH,
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*

B)
Fourth
year
after
effective
date
Fifth
year
after
effective
date
Sixth
year
after
effective
date
D
Respondentsb
E
Respondent
personhours
F
Labor
cost,

$
G
Respondentsb
H
Respondent
personhours
I
Labor
cost,

$
J
Respondentsb
K
Respondent
personhours
L
Labor
cost,

$

1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
Instructionsc
1
1
1
1
1
51
1
1
51
1
1
51
B.
Required
Activities
°
Initial
CMS
performance
evaluationd
10
1
10
0
0
0
0
0
0
0
0
0
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
°
Notification
of
construction/
reconstruction
2
1
2
1
2
102
1
2
102
1
2
102
°
Notification
of
anticipated
startup
2
1
2
1
2
102
1
2
102
1
2
102
°
Notification
of
actual
startup
2
1
2
1
2
102
1
2
102
1
2
102
4
Attachment
4
TABLE
1a.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*

B)
Fourth
year
after
effective
date
Fifth
year
after
effective
date
Sixth
year
after
effective
date
D
Respondentsb
E
Respondent
personhours
F
Labor
cost,

$
G
Respondentsb
H
Respondent
personhours
I
Labor
cost,

$
J
Respondentsb
K
Respondent
personhours
L
Labor
cost,

$

°
Notification
of
applicability
of
standard
Existing
sources
2
1
2
0
0
0
0
0
0
0
0
0
New
sources
2
1
2
1
2
102
1
2
102
1
2
102
°
Emissions
averaging
plane
40
1
40
0
0
0
0
0
0
0
0
0
°
Precompliance
reportf
40
1
40
1
46
2,048
1
46
2,048
1
46
2,048
°
Notification
of
initial
performance
testg
2
1
2
0
0
0
0
0
0
0
0
0
°
Notification
of
initial
CMS
performance
evaluation
2
1
2
0
0
0
0
0
0
0
0
0
°
Notification
of
compliance
status
With
performance
testg
80
1
80
0
0
0
0
0
0
0
0
0
Without
performance
testh
120
1
120
1
138
6,143
1
138
6,143
1
138
6,143
5
Attachment
4
TABLE
1a.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*

B)
Fourth
year
after
effective
date
Fifth
year
after
effective
date
Sixth
year
after
effective
date
D
Respondentsb
E
Respondent
personhours
F
Labor
cost,

$
G
Respondentsb
H
Respondent
personhours
I
Labor
cost,

$
J
Respondentsb
K
Respondent
personhours
L
Labor
cost,

$

4.
Recordkeeping
Requirements
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
D.
Develop
Record
Systemi
40
1
40
128
5,888
262,095
1
46
2,048
1
46
2,048
E.
Develop
Startup,

Shutdown,
Malfunction
Planj
100
1
100
128
14,720
655,238
1
115
5,119
1
115
5,119
F.
Develop
QA/
QC
Plan
for
CMSk
40
1
40
0
0
0
0
0
0
0
0
0
G.
Time
to
Train
Personnell
40
1
40
128
5,888
262,095
1
46
2,048
1
46
2,048
H.
Time
for
Audits
N/
A
ONE­
TIME
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
m
26,690
1,188,080
401
17,865
401
17,865
Average
cost
per
facilityn
131
9,069
132
135
133
134
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
127
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
over
3
years,
1
new
facility
will
be
built
each
year.

c
This
will
occur
only
in
the
first
year
after
a
facility
becomes
subject
to
the
rule.
6
Attachment
4
TABLE
1a.
(
continued)

d
Person­
hours
per
occurrence
are
based
on
the
performance
specification
costs
to
certify
CMS
($
500)
divided
by
the
composite
hourly
labor
rate.
No
performance
evaluations
are
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,

which
requires
CEMS
and
performance
evaluations.

e
Assumes
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements;
new
facilities
are
not
allowed
to
use
emissions
averaging.

f
Assumes
50
percent
of
facilities
will
submit
a
precompliance
report.

g
Assumes
one
existing
facility
and
no
new
facilities
will
be
required
to
conduct
a
performance
test(
s).
The
notification
of
compliance
status
includes
the
report
of
the
performance
test(
s).

h
Assumes
all
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
with
no
performance
tests.
The
notification
of
compliance
status
includes
those
calculations.

i
Assumes
40
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

j
Assumes
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
20
hours
of
review/
revisions,
for
a
total
of
100
hours.

k
Assumes
40
hours
to
develop
and
review
the
QA/
QC
plan
for
the
CMS.
No
QA/
QC
plan
is
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,
which
requires
CEMS
and
QA/
QC
plans.

l
Assumes
40
hours
to
train
personnel.

m
The
one­
time
burden
and
cost
are
equal
to
the
person­
hours
added
down
each
column
for
technical,
management,
clerical,
and
total
respondent
labor
and
the
sum
of
the
cost
column.

n
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
subject
to
the
rule.
7
Attachment
4
TABLE
1b.
RECURRENT
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FOURTH,
FIFTH,
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
Fourth
year
after
effective
date
Fifth
year
after
effective
date
Sixth
year
after
effective
date
D
Respondentsb
E
Respondent
personhours
F
Labor
cost,

$
G
Respondentsb
H
Respondent
personhours
I
Labor
cost,

$
J
Respondentsb
K
Respondent
personhours
L
Labor
cost,

$

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
Report
°
Notification
of
process
changec
8
1
8
13
120
5,324
13
120
5,324
13
120
5,324
°
Semi­
annual
compliance
report
No
deviationsd
8
2
16
118
2,171
96,648
119
2,190
97,467
120
2,208
98,286
Deviationsd
24
2
48
13
718
31,943
13
718
31,943
13
718
31,943
Startup,
shutdown,
and
malfunction
reporte
8
2
16
131
2,410
107,295
132
2,429
108,114
133
2,447
108,933
LDAR
reportf
404
2
808
131
25,749
1,146,198
132
25,946
1,154,947
133
26,143
1,163,697
Emissions
averaging
reportg
20
2
40
13
598
26,619
13
598
26,619
13
598
26,619
4.
Recordkeeping
Requirements
A.
Read
Instructions
N/
A
B.
Plan
Activities
N/
A
C.
Implement
Activities
N/
A
8
Attachment
4
TABLE
1b.
(
continued)

Burden
itema
A
Personhours
per
occurrence
B
Number
of
occurrences
per
year
C
Technical
personhours
per
respondent
per
year
(
C
=
A
*
B)
Fourth
year
after
effective
date
Fifth
year
after
effective
date
Sixth
year
after
effective
date
D
Respondentsb
E
Respondent
personhours
F
Labor
cost,

$
G
Respondentsb
H
Respondent
personhours
I
Labor
cost,

$
J
Respondentsb
K
Respondent
personhours
L
Labor
cost,

$

D.
Develop
Record
System
N/
A
E.
Time
to
Enter
Information
°
Records
of
startup,

shutdown,
and
malfunction
1.5
52
78
131
11,751
523,065
132
11,840
527,057
133
11,930
531,050
°
Records
of
CMS
data
Record
continuously
monitored
parametersh
1
365
365
131
54,987
2,447,674
132
55,407
2,466,358
133
55,827
2,485,043
Compile
datah
24
2
48
131
7,231
321,886
132
7,286
324,343
133
7,342
326,800
Enter/
verify
information
for
semi­
annual
reportsh
16
2
32
131
4,821
214,591
132
4,858
216,229
133
4,894
217,867
LDAR
recordkeeping
Included
in
3E
F.
Calibration
of
CMSi
376
1
376
131
56,644
2,521,439
132
57,077
2,540,687
133
57,509
2,559,935
G.
Time
to
Train
Personnel
N/
A
H.
Time
for
Refresher
Training
for
Personnelj
16
1
16
3
55
2,457
131
2,410
107,295
132
2,429
108,114
I.
Time
for
Audits
N/
A
RECURRENT
BURDEN
AND
COST
(
SALARY)
NATIONWIDE:
k
167,256
7,445,137
170,878
7,606,384
172,164
7,663,611
Average
cost
per
facilityl
131
56,833
132
57,624
133
57,621
a
See
Attachment
2
for
further
explanation
of
respondent
activities.

b
There
are
an
estimated
127
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
over
3
years,
1
new
facility
will
be
built
each
year.
9
Attachment
4
TABLE
1b.
(
continued)

c
Assumes
10
percent
of
facilities
will
implement
process
changes.

d
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.

e
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
startup,
shutdown,
and
malfunction
plan.

f
According
to
EPA
guidance,
annual
recordkeeping
and
reporting
coasts
for
the
LDAR
program
are
estimated
to
be
40
percent
of
monitoring
and
repair
labor,
which
averages
$
10,937
per
facility
(
40%
*
$
10,937
=
$
4,375
per
facility).
Person­
hours
per
occurrence
are
based
on
this
cost
divided
by
the
composite
hourly
labor
rate.

g
Assumes
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements;
new
facilities
are
not
allowed
to
use
emissions
averaging.

h
Includes
process
vessel,
storage
tank,
transfer
operation,
and
wastewater
monitoring
and
inspections.

i
Assumes
calibration
of
the
CMS
will
require
8
hours
per
year
for
each
monitor.
Assuming
1
CMS
for
each
process
vessel
and
47
process
vessels
per
facility,
a
total
of
376
hours
per
year
per
facility
is
required.

j
Assumes
2
days
(
16
hours)
to
provide
refresher
training
for
personnel.

k
The
recurrent
burden
and
cost
are
equal
to
the
person­
hours
added
down
each
column
for
technical,
management,
clerical,
and
total
respondent
labor
and
the
sum
of
the
cost
column.

l
The
average
facility
cost
is
calculated
by
dividing
the
total
facility
burden
by
the
number
of
facilities
complying
with
the
rule.
10
Attachment
4
TABLE
2.
AGENCY
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS­­
FOURTH,

FIFTH,
AND
SIXTH
YEARS
FOLLOWING
THE
EFFECTIVE
DATE
Activity
A
EPA
hours
per
operation
Fourth
year
after
effective
date
Fifth
year
after
effective
date
Sixth
year
after
effective
date
B
Operationsa
C
Personhours
D
Labor
cost,
$
E
Operationsa
F
Personhours
G
Labor
cost,
$
H
Operationsa
I
Personhours
J
Labor
cost,
$

1.
Attend
Initial
Performance
Testb
40
0
0
0
0
0
0
0
0
0
2.
Attend
Repeat
Performance
Testc
40
0
0
0
0
0
0
0
0
0
3.
Attend
Initial
CMS
Performance
Evaluationd
2
0
0
0
0
0
0
0
0
0
4.
Litigation
N/
A
5.
Report
Review
A.
Review
Notification
of
Construction/
Reconstruction
2
1
2
102
1
2
102
1
2
102
B.
Review
Notification
of
Anticipated
Startup
2
1
2
102
1
2
102
1
2
102
C.
Review
Notification
of
Actual
Startup
2
1
2
102
1
2
102
1
2
102
D.
Review
Notification
of
Applicability
of
Standard
2
1
2
102
1
2
102
1
2
102
E.
Review
Emissions
Averaging
Plane
20
0
0
0
0
0
0
0
0
0
F.
Review
Precompliance
Reportf
4
1
5
205
1
5
205
1
5
205
G.
Review
Notification
of
Initial
Performance
Test
2
0
0
0
0
0
0
0
0
0
H.
Review
Notification
of
Initial
CMS
Performance
Evaluation
2
0
0
0
0
0
0
0
0
0
I.
Review
Notification
of
Compliance
Status
°
With
performance
testg
40
0
0
0
0
0
0
0
0
0
11
Attachment
4
TABLE
2.
(
continued)

Activity
A
EPA
hours
per
operation
Fourth
year
after
effective
date
Fifth
year
after
effective
date
Sixth
year
after
effective
date
B
Operationsa
C
Personhours
D
Labor
cost,
$
E
Operationsa
F
Personhours
G
Labor
cost,
$
H
Operationsa
I
Personhours
J
Labor
cost,
$

°
Without
performance
testh
40
1
46
2,048
1
46
2,048
1
46
2,048
J.
Review
Notification
of
Process
Changei
8
13
120
5,324
13
120
5,324
13
120
5,324
K.
Review
Semi­
Annual
Compliance
Report
°
No
deviationsj
2
236
543
24,162
238
547
24,367
239
550
24,469
°
Deviationsj
8
26
239
10,648
26
239
10,648
27
248
11,057
°
Startup,
shutdown,
and
malfunction
reportk
2
262
603
26,824
264
607
27,029
266
612
27,233
°
LDAR
reportl
8
262
2,410
107,295
264
2,429
108,114
266
2,447
108,933
°
Emissions
averaging
reporte
8
25
230
10,238
25
230
10,238
25
230
10,238
TOTAL
BURDEN
AND
COST
(
SALARY):
m
961
42,795
966
43,000
978
43,512
TRAVEL
EXPENSES
FOR
TEST
ATTENDEDn
=
(
1
person
*

0
facility/
yr
*
2
days/
facility
*
$
50
per
diem)
+
($
400/
round
trip
*

0
round
trip/
yr):
0
0
0
TOTAL
COST
=
TOTAL
COST
(
SALARY)
+
TRAVEL
EXPENSES:
42,795
43,000
43,512
a
Operations
per
year
are
equal
to
the
number
of
operations
(
e.
g.,
performance
tests,
notifications,
reports)
per
facility
times
the
number
of
facilities.
There
are
an
estimated
127
existing
major
source
facilities
subject
to
the
NESHAP.
Assuming
2
percent
growth
over
3
years,
1
new
facility
will
be
built
each
year.

b
Assumes
one
existing
facility
and
no
new
facilities
will
conduct
initial
performance
tests,
and
EPA
personnel
will
attend
10
percent
of
the
initial
tests
(
approximately
0
tests).

c
Assumes
no
repeat
performance
tests.

d
Assumes
no
performance
evaluations
are
required
for
the
parameter
monitoring
systems
included
in
the
rule.
Assumes
no
facilities
will
use
the
alternative
standard,
which
requires
CEMS
and
performance
evaluations.

e
Assumes
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements;
new
facilities
are
not
allowed
to
use
emissions
averaging.
12
Attachment
4
TABLE
2.
(
continued)

f
Assumes
50
percent
of
facilities
will
submit
a
precompliance
report.

g
Assumes
one
existing
facility
and
no
new
facilities
will
conduct
initial
performance
tests,
and
the
notification
of
compliance
status
includes
the
report
of
the
performance
tests.

h
Assumes
all
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations,
etc.
with
no
performance
tests.
The
notification
of
compliance
status
includes
those
calculations.

i
Assumes
10
percent
of
facilities
will
implement
process
changes.

j
Assumes
90
percent
of
facilities
will
have
no
deviations,
and
10
percent
will
have
deviations.
The
number
of
operations
for
reviewing
a
semi­
annual
report
with
no
deviations
is
equal
to
90
percent
of
the
facilities
times
two
reports
per
year.
The
number
of
operations
for
reviewing
a
semi­
annual
report
with
deviations
is
equal
to
10
percent
of
the
facilities
times
two
reports
per
year.

k
Assumes
all
facilities
will
report
actions
taken
during
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
startup,
shutdown,
and
malfunction
plan.

l
Assumes
all
facilities
will
report
the
specified
information
for
processes
subject
to
the
equipment
leak
standards.

m
The
burden
and
cost
are
equal
to
the
person­
hours
added
down
each
column
for
technical,
management,
clerical,
and
total
respondent
labor
and
the
sum
of
the
cost
column.

n
Tests
attended
include
no
initial
performance
tests,
no
repeat
performance
tests,
for
a
total
of
0
tests
attended.
Attachment
4
13
2.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
and
Costs
(
i)
Estimating
respondent
burden
and
labor
costs.
Tables
1a
and
1b
of
this
attachment
present
the
annual
respondent
burden
estimates
and
labor
costs
for
reporting
and
recordkeeping
activities
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date
of
the
rule.
Table
1a
presents
the
one­
time
burden
and
costs,
and
Table
1b
presents
the
recurrent
burden
and
costs.
The
burden
estimates
in
each
table
were
derived
from
estimates
based
on
EPA's
experience
with
similar
information
collection
requirements
in
other
standards
development
efforts.

The
costs
of
the
reporting
and
recordkeeping
activities
in
each
table
were
estimated
based
on
data
from
the
U.
S.
Bureau
of
Labor
Statistics.
Labor
costs
are
divided
into
the
following
three
categories:
(
1)
technical,
(
2)
management,
and
(
3)
clerical.
The
cost
of
technical
labor
was
estimated
at
$
45.04/
hr,
the
cost
of
management
labor
at
$
66.73/
hr,
and
the
cost
of
clerical
labor
at
$
28.14/
hr.
These
estimates
include
fringe
benefits,
overhead,
and
profit
rate.

(
ii)
Estimating
capital
and
O&
M
costs.
There
are
two
types
of
non­
labor
related
costs
associated
with
information
collection
activities
 
capital
costs
and
O&
M
costs.
The
methods
used
to
estimate
the
capital
and
O&
M
costs
for
this
attachment
to
the
Supporting
Statement
are
presented
in
Attachment
3,
Methods
Used
in
Cost
Estimates.

One­
time
capital
costs
usually
include
any
produced
physical
good,
such
as
computers,
machinery,
or
equipment,
that
must
be
purchased
for
the
specific
purpose
of
satisfying
EPA's
reporting
or
recordkeeping
requirements.
Capital
costs
are
usually
incurred
only
once,
at
the
beginning
of
an
information
collection
period.
A
one­
time
capital
cost
can
be
estimated
over
multiple
years
by
annualizing
the
cost
using
an
OMB­
approved
interest
Attachment
4
14
rate.
For
this
attachment
to
the
Supporting
Statement,
capital
costs
were
annualized
over
10
years
for
transfer
operations
and
15
years
for
process
vessels
and
wastewater
systems,
assuming
an
interest
rate
of
7
percent.
Administrative
charges,
insurance,

and
property
taxes
were
also
included
with
the
annualized
capital
costs,
at
4
percent
of
the
capital
cost.

The
capital
costs
associated
with
monitoring
equipment
include
the
monitoring
equipment,
installation,
ancillary
costs
(
planning
and
selection),
and
a
DAS
(
data
logger,
computer,

logging
and
reporting
software,
and
printer).
The
capital
costs
for
the
monitoring
equipment
were
estimated
based
on
the
following
assumptions:
(
1)
the
monitoring
equipment
cost
per
facility
for
process
vessels
is
$
29,286,
which
includes
the
cost
for
thermocouple,
wire,
and
DAS;
(
2)
the
monitoring
equipment
cost
per
facility
for
wastewater
systems
is
$
20,120,
which
includes
the
cost
for
steam
flow
meter,
liquid
flow
meter,

thermocouple,
wire,
and
DAS;
(
3)
the
monitoring
equipment
cost
per
facility
for
transfer
operations
is
$
3,000,
which
includes
the
cost
for
a
data
logger;
(
4)
there
is
no
monitoring
equipment
cost
for
storage
tanks
because
no
monitoring
equipment
are
required
(
all
tanks
use
floating
roofs);
(
5)
in
the
fourth
year
after
the
effective
date,
127
existing
facilities
will
purchase
monitoring
equipment
for
process
vessels,
2
existing
facilities
will
purchase
monitoring
equipment
for
wastewater
systems,
and
one
existing
facility
will
purchase
monitoring
equipment
for
transfer
operations;
and
(
6)
in
each
of
the
fourth,
fifth,
and
sixth
years
after
the
effective
date,
one
new
facility
will
purchase
monitoring
equipment
for
process
vessels;
no
new
facilities
will
purchase
monitoring
equipment
for
wastewater
systems
or
transfer
operations.

The
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
include
the
purchase
of
one
standard
four­
drawer
file
cabinet
for
each
facility
(
assume
$
235
per
file
Attachment
4
15
cabinet).

Costs
for
performance
testing
are
also
considered
capital
costs
because
it
is
expected
that
facilities
will
hire
a
contractor
to
conduct
the
test.
The
capital
costs
associated
with
performance
testing
include
the
costs
for
performance
tests
for
transfer
operations
at
existing
facilities.
One
existing
facility
with
transfer
operations
is
expected
to
conduct
a
performance
test,
but
the
test
will
be
conducted
in
the
third
year
following
the
effective
date
of
the
rule.
No
other
facilities
are
expected
to
conduct
a
performance
test.

Therefore,
there
are
no
performance
test
costs
for
the
fourth,

fifth,
and
sixth
years
following
the
effective
date
of
the
rule.

Operation
and
maintenance
costs
include
those
costs
associated
with
the
general
upkeep
of
capital
equipment,
such
as
monitoring
equipment.
These
costs
would
include
monitoring
labor,
maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment.
The
monitoring
labor
costs
for
process
vessels
were
estimated
based
on
8,760
operating
hours
per
year,

0.5
hour
of
labor
per
8­
hr
shift,
and
a
wage
rate
of
$
17.21/
hr.

The
monitoring
labor
costs
for
wastewater
systems
were
estimated
based
on
834
operating
hours
per
year,
0.5
hour
of
labor
per
8­
hr
shift,
and
a
wage
rate
of
$
22.50/
hr.
The
monitoring
labor
costs
for
transfer
operations
were
estimated
based
on
300
operating
days
per
year,
0.5
hour
of
labor
per
day,
and
a
wage
rate
of
$
17.21/
hr.
Maintenance
materials
and
supplies
were
estimated
at
$
500
for
process
vessels
and
transfer
operations
and
$
50
for
wastewater
systems.
Overhead
was
estimated
at
60
percent
of
labor
costs
plus
maintenance
materials
and
supplies
costs
for
process
vessels;
no
overhead
costs
were
estimated
for
wastewater
systems
or
transfer
operations.
The
O&
M
cost
associated
with
the
monitoring
equipment
is
$
15,875
for
process
vessels,
$
1,957
for
wastewater
systems,
and
$
3,082
for
transfer
operations.
The
O&
M
costs
will
be
applied
to
all
existing
and
new
facilities
for
Attachment
4
16
process
vessels,
two
existing
facilities
for
wastewater
systems,

and
one
existing
facility
for
transfer
operations
for
the
fourth,

fifth,
and
sixth
years
following
the
effective
date
of
the
rule.

Operation
and
maintenance
costs
also
include
the
costs
associated
with
the
paperwork
requirement
incurred
continuously
over
the
life
of
the
ICR.
For
example,
the
O&
M
costs
for
rules
that
require
respondents
to
submit
reports
to
EPA
and
maintain
records
should
be
estimated
as
costs
for
photocopying
and
postage.
Photocopying
costs
per
response
were
estimated
at
0.5
hour
of
clerical
labor
at
a
wage
rate
of
$
28.14/
hr.
First
class
postage
was
estimated
at
$
7.63
per
response
for
mailing
to
regulatory
agencies.
Photocopying
and
postage
costs
will
be
applied
to
the
281
responses
submitted
during
the
fourth
year,

the
283
responses
submitted
during
the
fifth
year,
and
the
285
responses
submitted
during
the
sixth
year.
(
The
number
of
responses
was
determined
by
adding
the
number
of
reports
submitted
to
EPA
by
respondents,
as
shown
in
Tables
1a
and
1b
of
this
attachment.)

(
b)
Estimating
Agency
Burden
and
Costs
Table
2
of
this
attachment
presents
the
estimated
annual
Agency
burden
estimates
and
costs
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date
of
the
rule.
The
only
burden
and
costs
that
the
Federal
Government
will
incur
as
a
result
of
the
information
collection
requirements
are
associated
with
the
analysis
of
the
information
reported
by
facilities
in
one­
time
notifications
and
semi­
annual
compliance
reports
(
unless
the
compliance
report
indicates
a
deviation,
thereby
triggering
an
enforcement
action).
Labor
costs
were
estimated
based
on
estimated
wage
rates
of
$
45.04/
hr
for
technical
labor,
$
66.73/
hr
for
management
labor,
and
$
28.14/
hr
for
clerical
labor.
Attachment
4
17
(
c)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
tally.
The
bottom
line
annual
respondent
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
and
costs
from
Tables
1a
and
1b
and
dividing
the
sums
by
the
3­
year
period
(
i.
e.,
fourth,
fifth,
and
sixth
years
after
the
effective
date).
The
total
annual
respondent
burden
hours
and
costs
are
summarized
as
follows:

Total
burden,
hours
Total
costs,
$

Table
1a
(
one­
time
activities
in
first
year)
26,690
$
1,188,080
Table
1a
(
one­
time
activities
in
second
year)
401
$
17,865
Table
1a
(
one­
time
activities
in
third
year)
401
$
17,865
Table
1b
(
recurrent
activities
in
first
year)
167,256
$
7,445,137
Table
1b
(
recurrent
activities
in
second
year)
170,878
$
7,606,384
Table
1b
(
recurrent
activities
in
third
year)
172,164
$
7,663,611
Total
537,791
$
23,938,943
Bottom
line
annual
burden
179,264
$
7,979,648
The
bottom
line
annual
burden,
averaged
over
the
3­
year
period,
is
179,264
labor
hours,
at
a
cost
of
$
7,979,648.
The
average
annual
burden
per
respondent,
based
on
an
average
132
respondents
over
the
3­
year
period,
is
1,358
labor
hours,
at
a
cost
of
$
60,452.

There
are
an
estimated
283
total
annual
responses
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
The
total
annual
responses
are
based
on
an
estimated
281
one­
time
and
recurrent
notifications
and
reports
submitted
during
the
fourth
year,
283
during
the
fifth
year,
and
285
during
the
sixth
year.
Attachment
4
18
Of
these
283
total
annual
responses,
approximately
20
percent
are
assumed
to
be
collected
electronically.

The
total
nationwide
capital
costs
associated
with
monitoring
equipment
were
estimated
to
be
$
3,911,515
the
fourth
year
after
the
effective
date
of
the
rule,
and
$
30,221
in
each
of
the
fifth
and
sixth
years.
The
average
annualized
capital
cost
for
the
monitoring
equipment
is
$
599,504
for
the
fourth,
fifth,

and
sixth
years
following
the
effective
date.

The
total
nationwide
capital
costs
associated
with
file
cabinets
for
storing
collected
data
and
reports
were
estimated
to
be
$
30,080
in
the
fourth
year
after
the
effective
date
of
the
rule,
and
$
235
in
each
of
the
fifth
and
sixth
years.
The
average
annualized
capital
cost
for
file
cabinets
is
$
4,620
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date.

The
total
nationwide
capital
costs
for
performance
tests
were
estimated
to
be
$
0
for
each
of
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule.
The
average
annualized
capital
cost
for
the
performance
tests
is
$
3,477
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date.

Annual
O&
M
costs,
which
include
monitoring
labor,

maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment,
as
well
as
photocopying
and
postage
for
the
reports,
average
$
2,108,663
for
the
fourth,
fifth,
and
sixth
years
following
the
effective
date
of
the
rule.

Combining
the
annualized
capital
costs
for
the
monitoring
equipment,
file
cabinets,
and
performance
tests
results
in
a
total
annualized
capital
cost
of
$
607,602
for
the
fourth,
fifth,

and
sixth
years
following
the
effective
date
of
the
rule.

Summing
this
total
annualized
capital
cost
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
2,716,265
for
the
fourth,

fifth,
and
sixth
years
following
the
effective
date.

(
ii)
Agency
tally.
The
bottom
line
annual
Agency
burden
hours
and
costs
were
calculated
by
adding
the
total
person­
hours
Attachment
4
19
and
costs
from
Table
2
and
then
dividing
by
the
3­
year
period
(
i.
e.,
fourth,
fifth,
and
sixth
years
after
the
effective
date).

The
total
annual
Agency
burden
hours
and
costs
are
summarized
as
follows:

Total
burden,
hours
Total
costs,
$

Table
2
(
fourth
year)
961
$
42,795
Table
2
(
fifth
year)
966
$
43,000
Table
2
(
sixth
year)
978
$
43,512
Total
2,905
$
129,307
Bottom
line
annual
burden
968
$
43,102
The
bottom
line
annual
burden,
averaged
over
the
3­
year
period,
is
968
labor
hours,
at
a
cost
of
$
43,102.

(
d)
Burden
Statement
(
i)
The
total
annual
reporting
and
recordkeeping
burden
and
cost
for
this
collection
averaged
over
the
fourth,
fifth,
and
sixth
years
after
the
effective
date
of
the
rule
were
estimated
to
be
179,264
labor
hours
and
$
7,979,648.
The
average
burden
and
cost,
per
respondent,
are
1,358
labor
hours
and
$
60,452.

During
these
3
years,
new
facilities
are
required
to
submit
notifications
of
construction/
reconstruction,
notifications
of
anticipated
and
actual
startup,
and
notifications
of
compliance
status.
Both
existing
and
new
facilities
are
required
to
submit
semi­
annual
compliance
reports
to
indicate
their
ongoing
compliance
status.
Each
respondent
also
must
keep
necessary
records
of
data
to
determine
compliance
with
the
rule.

In
the
fourth
year
after
the
effective
date,
the
collection
requirements
will
be
applicable
to
an
estimated
131
respondents
(
127
existing
facilities
as
of
the
effective
date,
4
facilities
constructed
as
of
the
fourth
year
after
the
effective
date).
An
Attachment
4
20
estimated
1
additional
facility
will
be
subject
to
the
rule
in
each
subsequent
year.

(
ii)
The
total
capital
cost
in
the
fourth
year
after
the
effective
date
of
the
rule
is
$
3,911,545;
this
cost
includes
$
3,881,435
for
monitoring
equipment
and
$
30,080
for
file
cabinets.
The
total
capital
cost
in
each
of
the
fifth
and
sixth
years
after
the
effective
date
is
$
30,221,
which
includes
$
29,986
for
monitoring
equipment
and
$
235
for
file
cabinets.
The
annualized
capital
cost
for
the
monitoring
equipment,
file
cabinets,
and
performance
tests
is
$
607,602
for
the
fourth,

fifth,
and
sixth
years
after
the
effective
date.
The
average
annual
O&
M
cost,
which
includes
monitoring
labor,
maintenance
materials
and
supplies,
and
overhead
for
the
monitoring
equipment,
as
well
as
photocopying
and
postage
for
the
reports,

is
$
2,108,663
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
Combining
the
annualized
capital
cost
with
the
annual
O&
M
cost
gives
a
total
annualized
cost
of
$
2,716,265
for
the
fourth,
fifth,
and
sixth
years
after
the
effective
date.
