OMB­
83I
FORM
SUPPORTING
STATEMENT
FOR
OMB
REVIEW
OF
ICR
NO.
2025.01
INFORMATION
COLLECTION
REQUEST
FOR
THE
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
(
NESHAP)
FOR
THE
FRICTION
MATERIALS
MANUFACTURING
SOURCE
CATEGORY
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NORTH
CAROLINA
27711
MAY
2001
2
PART
A
OF
THE
SUPPORTING
STATEMENT
1.0
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
Reporting
and
Recordkeeping
Requirements
for
the
Friction
Materials
Manufacturing
NESHAP."
This
is
a
new
ICR.
The
EPA
tracking
number
is
2025.01.

(
b)
Short
Characterization.

Potential
respondents
are
owners
or
operators
of
friction
materials
manufacturing
facilities.
Friction
materials
manufacturing
facilities
manufacture
friction
material
using
a
solvent­
based
process.
Friction
material
is
subsequently
used
to
manufacture
friction
products
that
include,
but
are
not
limited
to,
disc
brake
pucks,
disc
brake
pads,
brake
linings,
brake
shoes,

brake
segments,
brake
blocks,
brake
discs,
clutch
facings,
and
clutches.
The
NESHAP
contains
an
emission
limitation
for
solvent
mixers
at
friction
materials
manufacturing
facilities.
Solvent
mixers
are
the
affected
source.

Consistent
with
the
General
Provisions
for
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Source
Categories
(
40
CFR
Part
63,
Subpart
A),
respondents
do
not
include
the
owner
or
operator
of
any
facility
that
is
not
a
major
source
of
HAP
emissions
or
any
facility
that
does
not
operate
affected
solvent
mixers,
even
if
the
facility
is
a
major
source.

Respondents
must
submit
a
one­
time
notification
of
applicability
of
the
standard
and
a
one­
time
notification
of
compliance
status.
Facilities
must
develop
and
implement
a
startup,

shutdown,
and
malfunction
plan
and
submit
semiannual
reports
of
any
event
where
the
plan
was
not
followed.
Semiannual
reports
for
periods
of
operation
during
which
the
emission
limitation
is
exceeded
(
or
reports
certifying
that
no
exceedances
have
occurred)
also
are
required.
General
requirements
applicable
to
all
NESHAP
require
records
of
applicability
determinations;

deviations;
periods
of
startups,
shutdowns,
or
malfunctions;
monitoring
records;
and
all
other
information
needed
to
determine
compliance
with
the
applicable
standard.
Records
and
reports
must
be
retained
for
a
total
of
5
years
(
2
years
at
the
site;
the
remaining
3
years
of
records
may
be
retained
off­
site).
The
files
may
be
maintained
in
electronic
form
such
as
microfilm,
computer
disks,
or
magnetic
tape.

The
friction
materials
manufacturing
NESHAP
requires
respondents
to
reduce
the
total
3
organic
HAP
emissions
from
their
solvent
mixers
by
preventing
emission
of
no
more
than
15
percent
(
based
on
a
7­
day
block
average)
of
the
HAP
solvent
that
is
loaded
into
the
solvent
mixer.

Respondents
will
likely
use
a
solvent
recovery
system
to
reduce
the
amount
of
HAP
solvent
that
is
emitted.
To
show
compliance
with
the
HAP
solvent
emission
limitation,
respondents
are
required
to
use
a
weight
measurement
system
(
e.
g.,
floor
scale
system
for
measuring
weight
of
liquid
contained
in
a
small
tank)
to
measure
and
record
the
weight
of
HAP
solvent
loaded
into
the
solvent
mixer
and
the
weight
of
HAP
solvent
recovered
for
each
mix
batch.
No
performance
testing
is
required.
However,
respondents
would
be
required
to
conduct
an
initial
compliance
demonstration,
which
consists
of
measuring
and
recording
the
weight
of
HAP
solvent
loaded
into
each
solvent
mixer
and
the
weight
of
HAP
solvent
recovered
for
each
mix
batch
over
the
first
7
consecutive
days
after
the
compliance
date.
Respondents
also
must
maintain
records
of
specific
information
needed
to
determine
that
the
standards
are
being
achieved
and
maintained.
These
proposed
requirements
are
described
in
Attachment
1.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.

The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
NESHAP
for
new
or
existing
major
sources
or
area
sources
that
reflect:

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

This
level
of
control
is
commonly
referred
to
as
the
maximum
achievable
control
technology
(
MACT).
Certain
records
and
reports
are
necessary
for
the
Administrator
to
confirm
the
compliance
status
of
major
sources
and
identify
new
or
reconstructed
sources
subject
to
the
standards.
Specific
information
needed
by
EPA
for
the
friction
materials
manufacturing
NESHAP
includes
documentation
that
HAP
emissions
from
affected
solvent
mixers
are
reduced
according
to
the
emission
limitation.
Such
documentation
necessitates
measuring
and
recording
the
weight
of
HAP
solvent
loaded
into
the
solvent
mixer
and
the
weight
of
HAP
solvent
recovered
for
each
mix
batch.
These
recordkeeping
and
reporting
requirements
are
specifically
authorized
by
section
114
of
the
Act
(
42
U.
S.
C.
7414)
and
set
out
in
the
NESHAP
General
Provisions.
4
(
b)
Practical
Utility/
Users
of
the
Data.

The
information
will
be
used
by
Agency
enforcement
personnel
to:
(
1)
identify
major
sources
and
new,
modified,
or
reconstructed
sources
subject
to
the
standards;
(
2)
ensure
that
MACT
is
being
properly
applied;
and
(
3)
ensure
that
the
required
emission
limitation
is
achieved
on
a
continuous
basis.
Based
on
the
reported
information,
EPA
can
decide
which
facilities,

records,
or
processes
should
be
inspected.
The
records
that
facilities
maintain
will
indicate
to
EPA
whether
the
required
emission
limitation
is
achieved.

3.
Nonduplication,
Consultation,
and
Other
Collection
Criteria
(
a)
Nonduplication.

A
search
of
existing
standards
and
outgoing
ICR's
revealed
no
duplication
of
information­
gathering
efforts.
However,
certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
the
standards.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards.
The
EPA
has
issued
guidance
to
State
and
local
agencies
encouraging
them
to
consolidate
duplicative
requirements
into
a
single
element
to
be
reported.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB.

This
section
is
not
applicable
because
this
is
a
rule­
related
ICR.

(
c)
Consultations.

Participants
in
the
development
process
for
this
proposed
NESHAP
included
the
Friction
Material
Standards
Institute,
Brake
Manufacturers
Council,
Motor
and
Equipment
Manufacturers
Association,
Automotive
Parts
Rebuilders
Association,
and
representatives
from
numerous
friction
materials
manufacturing
companies.
These
participants
were
contacted
for
information
and
were
invited
to
meetings.
In
addition,
several
States,
including
Colorado,
Georgia,
Indiana,

North
Carolina,
Tennessee,
and
Wisconsin,
were
contacted
for
information.
Consultations
with
these
organizations
and
others
will
continue
following
proposal.
A
60­
day
public
comment
period
will
be
provided
after
proposal,
during
which
the
public
will
be
given
the
opportunity
to
comment
on
the
proposed
NESHAP.
All
comments
received
will
be
considered,
and
some
may
be
reflected
in
the
development
of
the
final
NESHAP.
5
(
d)
Effects
of
Less
Frequent
Collection.

If
the
relevant
information
were
collected
less
frequently,
EPA
could
not
be
reasonably
assured
that
a
facility
is
in
compliance
with
the
standards.
In
addition,
our
authority
to
take
administrative
action
would
be
significantly
reduced.
Section
113(
d)
of
the
CAA
limits
the
assessment
of
administrative
penalties
to
violations
which
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.
Since
administrative
proceedings
are
less
costly
and
require
use
of
fewer
resources
than
judicial
proceedings,
both
we
and
the
regulated
community
benefit
from
preservation
of
our
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
friction
materials
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
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
facilities
subject
to
this
rule
will
be
required
to
obtain
operating
permits
either
through
the
State­
approved
permitting
program
or,
if
one
does
not
exist,
in
accordance
with
the
provisions
of
40
CFR
part
71.
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
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;

amended
by
43
FR
39999,
September
28,
1978;
43
FR
42251,
September
28,
1978;
44
FR
17674,
March
23,
1979).
6
(
g)
Sensitive
Questions.

The
information
to
be
reported
consists
of
emissions
calculations
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.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
Codes.

Respondents
are
owners
or
operators
of
friction
materials
manufacturing
facilities
that
are
major
sources
of
HAP
emissions
and
use
solvent
mixers.
Four
facilities
with
existing
solvent
mixers
are
required
to
comply
with
the
emission
limitations
in
the
proposed
rule.
Two
of
these
facilities
already
have
the
solvent
recovery
systems
necessary
to
meet
the
emission
limitations.
No
new
friction
materials
manufacturing
facilities
or
solvent
mixers
are
expected
to
be
constructed
during
the
3­
year
ICR
clearance
period.
The
respondents
are
classified
under
the
Standard
Industrial
Classification
(
SIC)
codes
3714,
3299,
3499,
3568,
and
3743;
and
North
American
Industrial
Classification
System
(
NAICS)
codes
33634,
327999,
and
333613.
Only
certain
processes
classified
in
the
SIC
or
NAICS
codes
listed
above
will
be
regulated
by
the
friction
materials
manufacturing
NESHAP.

(
b)
Information
Requested.

(
i)
Data
items,
Including
Recordkeeping
Requirements.
Attachment
1
summarizes
the
reporting
and
recordkeeping
requirements,
including
the
required
retention
time
for
all
records.

(
ii)
Respondent
activities.
The
respondent
activities
required
by
the
standards
are
identified
in
Table
1
and
introduced
in
Section
6(
a).
To
the
extent
practicable,
the
activities
required
by
respondents
were
designed
to
make
use
of
or
to
be
consistent
with
existing
reporting
and
recordkeeping
practices.

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

A
list
of
Agency
activities
is
provided
in
Table
2
and
introduced
in
Section
6(
c).

(
b)
Collection
Methodology
and
Management.
7
Information
contained
in
the
one­
time
only
reports
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
our
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
Information
contained
in
the
periodic
reports
submitted
to
us
will
be
reviewed
for
accuracy
and
completeness.
Data
obtained
during
periodic
visits
by
our
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
use
in
compliance
and
enforcement
programs.

(
c)
Small
Entity
Flexibility.

Information
available
to
the
EPA
indicates
that
only
four
friction
materials
manufacturing
facilities
are
subject
to
the
NESHAP
because
they
are
major
sources
of
HAP
and
operate
solvent
mixers.
Only
one
of
the
four
facilities
subject
to
the
NESHAP
is
a
small
business
based
on
one
of
the
definitions
used
by
the
Small
Business
Administration
(
500
or
fewer
company
employees
for
SIC
codes
3499
and
3568).
The
EPA
does
not
expect
that
this
small
business
facility
will
experience
adverse
impacts
due
to
the
proposed
rule.
This
facility
already
operates
the
solvent
recovery
system
necessary
to
control
solvent
mixer
emissions.
Furthermore,
this
facility
already
has
the
monitoring
equipment
required
by
the
proposed
rule.
The
only
additional
costs
that
this
facility
will
incur
as
a
result
of
the
proposed
rule
are
reporting
and
recordkeeping
costs.
The
capital
costs
that
this
facility
will
experience
as
a
result
of
the
proposed
rule
are
minimal
(
e.
g.,

cost
of
a
file
cabinet
for
storing
records).

The
monitoring,
reporting,
and
recordkeeping
costs
resulting
from
the
proposed
rule
have
been
minimized
for
all
facilities
because
the
proposed
rule
does
not
include
emission
testing
requirements.
The
monitoring,
reporting,
and
recordkeeping
requirements
included
in
the
proposed
rule
are
necessary
for
facilities
and
the
EPA
to
insure
that
the
facilities
are
in
compliance
with
the
emission
limitations.
It
is
not
expected
that
any
facilities
will
experience
adverse
cost
impacts
due
to
the
proposed
rule.

(
d)
Collection
Schedule.

Collection
of
data
will
begin
after
the
effective
date
of
the
final
friction
materials
manufacturing
NESHAP.
The
compliance
date
for
existing
sources
is
2
years
after
the
effective
date.
The
compliance
date
for
new
or
reconstructed
sources
is
the
effective
date
if
the
source
startup
date
is
before
the
effective
date
or
upon
startup
if
the
startup
date
is
on
or
after
the
8
effective
date.
No
new
or
reconstructed
sources
are
anticipated
during
the
3­
year
ICR
clearance
period.
The
schedule
for
notifications
and
reports
required
by
the
rule
is
summarized
below.

For
facilities
with
existing
solvent
mixers,
the
initial
notification
stating
that
the
facility
is
subject
to
the
rule
must
be
submitted
no
later
than
120
days
after
the
effective
date
of
the
rule.

Facilities
with
new
or
reconstructed
affected
sources
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.
Facilities
must
demonstrate
initial
compliance
with
the
emission
limitation
for
solvent
mixers
by
conducting
an
initial
compliance
demonstration
within
7
days
after
the
compliance
date.
Facilities
must
submit
an
initial
notification
of
compliance
status
no
later
than
30
days
following
the
completion
of
the
initial
compliance
demonstration.
Records
necessary
to
determine
continuous
compliance
must
be
compiled
on
a
daily
basis,
and
compliance
reports
must
be
submitted
to
the
Administrator
on
a
semiannual
basis.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.

The
annual
burden
estimates
for
reporting
and
recordkeeping
are
presented
in
Table
1.

These
numbers
were
derived
from
estimates
based
on
EPA's
experience
with
other
standards.

(
b)
Estimating
Respondent
Costs.

The
information
collection
activities
for
sources
subject
to
the
standards
are
presented
in
Table
1.
Labor
costs
for
reporting
and
recordkeeping
activities
were
estimated
based
on
the
most
recently
available
labor
rate
data
from
the
U.
S.
Bureau
of
Labor
Statistics
(
BLS)

(
http://
stats.
bls.
gov/
news.
release).
Labor
costs
are
divided
into
the
following
three
categories:
(
1)

technical,
(
2)
management,
and
(
3)
clerical.
The
base
labor
rates,
including
fringe
benefits,

reported
by
BLS
for
March
2000
are
$
28.59
per
hour
($
28.59/
hr)
for
technical
personnel,

$
43.46/
hr
for
managerial
personnel,
and
$
18.07/
hr
for
clerical
personnel.
The
base
labor
rates
were
adjusted
by
an
overhead
and
profit
rate
of
167
percent.
The
resulting
average
hourly
labor
rates
are
$
48/
hr
for
technical
personnel,
$
73/
hr
for
management
personnel,
and
$
30/
hr
for
clerical
personnel.
In
addition
to
labor
costs,
capital/
startup
costs
include
the
costs
of
installing
the
necessary
monitoring
equipment
and
purchasing
file
cabinets
for
storing
records.
Operation
and
maintenance
(
O&
M)
costs
include
the
O&
M
costs
for
monitoring
equipment
and
photocopy
and
9
postage
costs
associated
with
reporting
requirements.
The
capital/
startup
costs
were
estimated
and
annualized
as
described
in
the
footnotes
to
Table
1.

(
c)
Estimating
Agency
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
standards
development,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.
Because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
the
General
Provisions
for
the
MACT
standards,
no
operational
costs
will
be
incurred
by
the
Federal
Government.
Publication
and
distribution
of
the
information
are
part
of
the
Compliance
Data
System,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources
that
is
part
of
EPA's
overall
compliance
and
enforcement
program,
and,
therefore,
is
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
presented
in
Table
2.
Labor
rates
for
Federal
employees
are
based
on
the
January
2001,
Office
of
Personnel
Management
labor
rates
for
General
Schedule
employees
(
http://
www3.
opm.
gov/
oca/
01tables/
gshrly/
html/
01gshr.
htm).
The
base
labor
rates
are
$
26.19/
hr
for
technical
personnel
(
GS­
12,
step
5),
$
43.29
for
management
personnel
(
GS­
15,
step
5),
and
$
14.76/
hr
for
clerical
personnel
(
GS­
7,
step
5).
The
base
labor
rates
were
multiplied
by
the
standard
government
benefits
multiplication
factor
of
1.6.
The
resulting
average
hourly
labor
costs
are
$
42/
hr
for
technical
personnel,
$
69/
hr
for
management
personnel,
and
$
24/
hr
for
clerical
personnel.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs.

The
EPA
has
identified
a
total
of
four
solvent­
based
friction
materials
manufacturing
facilities
as
major
sources
of
HAP
emissions
operating
affected
solvent
mixers
subject
to
the
friction
materials
manufacturing
NESHAP.
No
new
friction
materials
manufacturing
facilities
are
anticipated
to
be
constructed
during
the
3­
year
ICR
clearance
period.
Details
on
the
number
of
respondents
affected
by
each
individual
burden
item
are
provided
in
the
footnotes
of
Table
1.

(
e)
Bottom
Line
Burden
Hours
and
Costs/
Master
Tables.

(
i)
Respondent
tally.
The
bottom
line
respondent
burden
hours
and
costs,
presented
in
10
Table
1,
are
calculated
by
adding
person­
hours
per
year
down
each
column
for
technical,

managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
The
total
annual
number
of
responses
is
five.
The
estimated
total
annual
hours
are
577
at
an
annual
labor
cost
of
$
26,657.

The
estimated
total
capital/
startup
costs
that
would
be
incurred
over
the
3
years
following
proposal
are
$
15,912.
The
annualized
capital/
startup
costs
are
$
2,235.
The
total
annual
O&
M
cost
is
estimated
to
be
$
261.
The
total
annualized
cost
requested
(
including
the
annualized
capital/
startup
and
O&
M
costs)
is
$
2,496.

(
ii)
The
Agency
tally.
The
bottom
line
Agency
burden
hours
and
costs,
presented
in
Table
2,
are
calculated
as
in
the
respondent
table,
by
adding
person­
hours
per
year
down
each
column
for
technical,
managerial,
and
clerical
staff,
and
by
adding
down
the
cost
column.
In
this
case,
the
total
cost
is
the
sum
of
the
total
salary
cost
and
total
travel
expenses
for
facilities
visited.

The
total
annual
hours
are
116.
The
total
annual
cost
is
$
4,883.

(
iii)
Variations
in
the
annual
bottom
line.
This
section
does
not
apply
since
no
significant
variation
is
anticipated.

(
f)
Reasons
for
Change
in
Burden.

This
section
does
not
apply
because
this
is
a
new
collection.

(
g)
Burden
Statement.

The
average
annual
respondent
burden
for
the
four
existing
affected
friction
materials
manufacturing
facilities
is
estimated
at
577
hours.
This
estimate
includes
time
for
preparing
and
submitting
notices,
gathering
information,
submitting
reports,
and
maintaining
records.

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
(
1)
review
instructions;
(
2)
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
maintaining
information,
and
disclosing
and
providing
information;
(
3)
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
(
4)
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
(
5)
search
data
sources;
(
6)
complete
and
review
the
collection
of
information;
and
(
7)
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
11
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

Send
comments
on
the
EPA's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
to
the
Director,
Collection
Strategies
Division,
U.
S.
Environmental
Protection
Agency
(
2822T),
1200
Pennsylvania
Avenue
NW,

Washington,
DC
20460,
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street
NW,
Washington,
DC
20503,
marked
"
Attention:
Desk
Officer
for
EPA."
Include
the
EPA
ICR
number
and
OMB
control
number
in
any
correspondence.

PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
data
collection
associated
with
this
regulation.
12
TABLE
1.
ANNUAL
RESPONDENT
BURDEN
AND
COST
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
OF
THE
PROPOSED
RULE
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,$
b
1.
Applications
NA
2.
Survey
and
Studies
NA
3.
Acquisition,
Installation,
and
Utilization
of
Technology
and
Systems
54
1
54
1.3
72
3.6
7.2
$
3,935
4.
Reporting
Requirements
A.
Read
instructions
0.5
1
0.5
1.3
0.7
0.0
0.1
$
36
B.
Required
activities
Startup,
shutdown,
malfunction
plan
32
1
32
1.3
43
2
4
$
1,577
C.
Create
information
See
4B
D.
Gather
existing
information
See
4B
E.
Write
report
Notification
of
applicability
2
1
2
1.3
3
0.1
0.3
$
146
Notification
of
constr./
reconstr.
2
1
2
0
0
0.0
0.0
$
0
Notification
of
anticipated
startup
2
1
2
0
0
0.0
0.0
$
0
Notification
of
actual
startup
2
1
2
0
0
0.0
0.0
$
0
Notification
of
compliance
status
4
1
4
1.3
5
0.3
0.5
$
291
Semi­
annual
compliance
reports:

Deviations
c
8
1
8
0.20
1.6
0.1
0.2
$
87
No
deviations
d
8
2
16
1.1
18
0.9
2
$
991
TABLE
1.
(
continued)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,$
b
13
Startup,
shutdown,
malfunction
report
e
8
2
16
0.13
2
0.1
0.2
$
117
5.
Recordkeeping
Requirements
A.
Read
instructions
4
1
4
1.3
5
0.3
0.5
$
291
B.
Plan
activities
See
5E
C.
Implement
activities
See
5E
D.
Develop
record
system
See
5E
E.
Time
to
enter
information
Records
of
solvent
weight
measurements
f
0.033
2600
86
1.3
114
6
11
$
6,252
Records
of
block
average
solvent
weight
g
2
52
104
1.3
139
7
14
$
7,578
Records
of
startup,
shutdown,

malfunction
g
1
52
52
1.3
69
3
7
$
3,789
Copies
of
notifications/
reports
h
0.25
3
0.75
1.3
1
0
0
$
55
F.
Time
to
train
personnel
20
1
20
1.3
27
1.3
3
$
1,457
G.
Time
to
adjust
existing
ways
to
comply
with
previously
applicable
requirements
NA
H.
Time
to
transmit
or
disclose
information
h
0.25
3
0.75
1.3
1.0
0.1
0.1
$
55
I.
Time
for
audits
NA
TABLE
1.
(
continued)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C
=
A
x
B)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,$
b
14
TOTAL
ANNUAL
BURDEN
AND
COST
(
SALARY)
502
25.1
50.2
$
26,657
TOTAL
ANNUAL
NUMBER
OF
RESPONSES
i
5
ANNUAL
CAPITAL
COSTS:

Monitoring
equipment
j
$
14,973
File
cabinets
k
$
940
Total
annual
capital
$
19,912
ANNUALIZED
CAPITAL
COSTS:
l
Monitoring
equipment
(
10
year
life,
7%
interest
­>
CRF
=
0.1424)
$
2,132
File
cabinets
(
15
year
life,
7%
interest
­>
CRF
=
0.1098)
$
103
Total
annualized
capital
$
2,235
TOTAL
ANNUAL
COSTS
(
O
&
M)
m
$
261
TOTAL
ANNUALIZED
COSTS
(
Annualized
capital
+
O&
M
costs)
$
2,496
a
A
total
of
4
major
sources
with
a
total
of
7
existing
solvent
mixers
are
expected
to
comply
during
the
3­
year
ICR
clearance
period,
for
an
average
of
4/
3
=

1.3
plants
per
year
and
7/
4
=
1.75
solvent
mixers
per
plant.
No
new
facilities
and
no
new
solvent
mixers
are
expected
to
be
constructed
during
the
ICR
clearance
period.

b
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
48,
management
at
$
73,
and
clerical
at
$
30.
Management
person­
hours
and
clerical
personhours
are
assumed
to
be
5
percent
and
10
percent
of
technical
person­
hours,
respectively.

c
Assumes
15%
of
respondents
report
deviations
once
a
year.

d
Assumes
85%
of
respondents
report
no
deviations
semiannually.

e
Assumes
10%
of
respondents
will
have
a
startup,
shutdown,
or
malfunction
occur
in
a
year
that
is
not
managed
according
to
the
plan.

f
Assumes
solvent
weights
recorded
once
per
hour
(
2
minutes
[
0.033
hr]
per
record)
for
2,600
hr/
yr
(
the
industry
average
solvent
mixer
annual
operating
TABLE
1.
(
continued)

15
hours).

g
Assumes
information
is
entered
1
time
per
week
for
52
weeks/
yr.

h
Assumes
typical
plant
transmits
one­
time
notifications
of
applicability
and
compliance
status;
the
startup,
shutdown,
and
malfunction
plan;
and
6
semiannual
reports
of
excess
emissions
(
or
no
excess
emissions)
over
the
3­
year
period,
for
a
total
of
9
items
or
an
average
of
3
items
per
year.

i
The
total
annual
number
of
responses
is
calculated
by
summing
the
product
of
columns
B
and
D
for
each
of
the
reports
listed
in
4E.

j
The
capital
costs
for
monitoring
equipment
is
estimated
at
$
2,139
per
solvent
mixer
for
a
floor
scale
system.
(
7
mixers
x
$
2,139
=
$
14,973).

k
Assumes
one
standard
four­
drawer
file
cabinet
per
facility
at
a
cost
of
$
235
per
cabinet
(
4
cabinets
x
$
235
=
$
940).

l
Annualized
costs
are
calculated
by
multiplying
the
capital
recovery
factor
(
CRF)
by
the
capital
cost.
CRF
=
(
i)
x
(
1
+
i)^
t/((
1
+
i)^
t
­
1)
where
i
=
interest
rate
(%)
and
t
=
equipment
life
(
years).

m
O&
M
costs
include
the
following:
(
1)
O&
M
for
monitoring
equipment
estimated
as
20%
of
the
annual
cost
for
monitors,
and
(
2)
photocopy
and
postage
costs
estimated
as
$
22/
report.

N/
A
=
Not
Applicable.
16
TABLE
2.
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL
GOVERNMENT
OF
THE
PROPOSED
RULE
Activity
(
A)

EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)

EPA
personhours
per
plant
per
year
(
C
=
A
x
B)
(
D)
Plants
per
year
a
(
E)
Technical
person­
hours
per
year
(
E
=
C
x
D)
(
F)
Management
person­
hours
per
year
(
F
=
E
x
0.05)
(
G)
Clerical
personhours
per
year
(
G
=
E
x
0.1)
(
H)
Cost,$
b
Litigation
c
2,080
1
2,080
0.013
28
1
3
$
1,327
Excess
Emissions
Enforcement
Activities
d
48
1
48
0.067
3
0
0
$
153
Report
Review
Notification
of
applicability
2
1
2
1.3
3
0
0
$
128
Notification
of
constr./
reconstr.
2
1
2
0
0
0
0
$
0
Notification
of
anticipated
startup
2
1
2
0
0
0
0
$
0
Notification
of
actual
startup
2
1
2
0
0
0
0
$
0
Notification
of
compliance
status
40
1
40
1.3
53
3
5
$
2,552
Semi­
annual
compliance
reports:

Deviations
e
20
1
20
0.20
4
0
0
$
191
No
deviations
f
2
2
4
1.1
5
0
0
$
217
Startup,
shutdown,
malfunction
report
g
20
2
40
0.13
5
0
1
$
255
Onsite
inspection
of
plant
records
8
1
8
0.13
1
0
0
$
51
TOTAL
BURDEN
AND
COST
(
SALARY)
101
5
10
$
4,823
Travel
Expenses
for
Plants
Visited
h,
i
$
60
TOTAL
ANNUAL
COST
(
SALARY
+
EXPENSES)
$
4,883
a
A
total
of
4
major
sources
with
a
total
of
7
existing
solvent
mixers
are
expected
to
comply
during
the
3­
year
ICR
clearance
period,
for
an
average
of
4/
3
=

1.3
plants
per
year
and
7/
4
=
1.75
solvent
mixers
per
plant.
No
new
facilities
and
no
new
solvent
mixers
are
expected
to
be
constructed
during
the
ICR
clearance
period.
TABLE
2.
(
continued)

17
b
Costs
are
based
on
the
following
hourly
rates:
technical
at
$
42,
management
at
$
69,
and
clerical
at
$
24.
Management
person­
hours
and
clerical
personhours
are
assumed
to
be
5
percent
and
10
percent
of
technical
person­
hours,
respectively.

c
Assumes
1%
of
plants
will
be
involved
in
litigation.

d
Assumes
5%
of
the
plants
will
be
involved
in
excess
emissions
enforcement
activities.

e
Assumes
15%
of
respondents
report
deviations
once
a
year.

f
Assumes
85%
of
respondents
report
no
deviations
semiannually.

g
Assumes
10%
of
respondents
will
have
a
startup,
shutdown,
or
malfunction
occur
in
a
year
that
is
not
managed
according
to
the
plan.

h
Assumes
Agency
personnel
will
inspect
records
at
10%
of
plants.

i
Assumes
Agency
personnel
(
1
person)
will
spend
1
day
per
plant,
at
$
50
per
diem
per
day,
and
$
400
transportation
expense
per
round
trip
to
inspect
records
at
plant.
18
ATTACHMENT
1
SUMMARY
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
19
SUMMARY
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
Requirements
Regulation
Reference
Notifications
Initial
notifications
(
including
construction/
reconstruction)
63.5,
63.9(
b),
and
63.9535(
a)­(
d)

Notification
of
compliance
status
63.9(
h)
and
63.9535(
e)

Records
Record
retention
63.10(
b)(
1)
and
63.9550
Documentation
supporting
initial
notifications
and
notifications
of
compliance
status
63.10(
b)(
2)(
xiv)
and
63.9545(
a)(
1)

Records
related
to
startup,
shutdown,
and
malfunction
63.6(
e)(
3)
and
63.9545(
a)(
2)

Monitoring
records
showing
solvent
mixers
meet
the
emission
limitation
63.10(
b)(
2)(
vi),
(
x),
and
(
xi);
63.9530;
and
63.9545(
b)

Reports
Semiannual
compliance
report:
°
Startup,
shutdown,
and
malfunction
reports
°
No
deviations/
no
out­
of­
control
monitoring
system
°
Deviations/
out­
of­
control
monitoring
system
63.9540
63.10(
d)(
5)
and
63.9540(
b)(
4)
and
(
d)
63.9540(
b)(
5)­(
6)
63.9540(
c)
