SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Source Categories: Generic Maximum Achievable Control
Technology Standards (40 CFR Part 63, Subpart YY) (Renewal)

1.  Identification of the Information Collection						

1(a)  Title of the Information Collection

NESHAP for Source Categories: Generic Maximum Achievable Control
Technology Standards (40 CFR part 63, subpart YY) (Renewal), EPA ICR
Number 1871.05, OMB Control Number 2060-0420

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Source Categories: Generic Maximum Achievable Control Technology
(hereafter, this subpart is referred to as the "Generic MACT”) were
proposed on October 14, 1998 (63 FR 55178) and promulgated on June 29,
1999 (64 FR 34854).  These regulations apply to hazardous air pollutant
(HAP) emission sources in four categories including: Polycarbonates (PC)
Production, Acrylic and Modacrylic Fibers (AMF) Production, Acetal
Resins (AR) Production and Hydrogen Fluoride (HF) Production.  This
Information Collection Request (ICR) addresses these four source
categories.  On November 2, 2001, the Agency promulgated wastewater
provisions amendments to the Generic MACT applicable to wastewater
streams for the PC, AMF, and AR production source categories.  The HF
production source category does not have wastewater streams.  On June 7,
2002, the Agency made additional amendments as a direct ruling to the
Generic MACT to clarify definitions and the recordkeeping provisions
related to how readily accessible records should be maintained.  This
information is being collected to assure compliance with the provisions
of 40 CFR part 63, subpart YY.

In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports.  Owners or operators are also
required to maintain records of the occurrence and duration of any
startup, shutdown, or malfunction in the operation of an affected
facility, or any period during which the monitoring system is
inoperative.  The specific monitoring and recordkeeping requirements
vary for each source category depending on the types of emissions
control equipment and monitoring equipment used to comply with the
Generic MACT standards for their category.  These notifications,
reports, and records are essential in determining compliance, and are
required of all sources subject to NESHAP.

Any owner or operator subject to the provisions of this subpart will
maintain a file of these measurements, and retain the file for at least
five years following the date of such measurements, maintenance reports,
and records.  All reports are sent to the delegated state or local
authority.  In the event that there is no such delegated authority, the
reports are sent directly to the United States Environmental Protection
Agency (EPA) regional office.

Based on our consultations with industry representatives, there is an
average of one affected facility at each plant site and that each plant
site has only one respondent (i.e., the owner/operator of the plant
site).

There are, approximately, 10 respondents in four categories that are
currently subject to the regulation and they are: 1) Polycarbonates (PC)
Production - four sources; 2) Acrylic and Modacrylic Fibers (AMF)
Production - three sources; 3) Acetal Resins (AR) Production - two
sources; and 4) Hydrogen Fluoride (HF) Production - one source.  It is
estimated that no additional respondents per year will become subject to
the regulation in the next three years.

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants.  These
standards are applicable to new or existing sources of hazardous air
pollutants and shall require the maximum degree of emission reduction. 
In addition, section 114(a) states that the Administrator may require
any owner/operator subject to any requirement of this 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, at 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.

In the Administrator's judgment, hazardous air pollutant (HAP) emissions
from PC, AMF, AR and HF source categories cause or contribute to air
pollution that may reasonably be anticipated to endanger public health
or welfare.  Therefore, the NESHAP were promulgated for this source
category at 40 CFR part 63, subpart YY.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure
compliance with  the applicable regulations which were promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard. 
Continuous emission monitors are used to ensure compliance with the
standard at all times.  During the performance test a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

The notifications required in the standard are used to inform the Agency
or delegated authority when a source becomes subject to the requirements
of the regulations.  The reviewing authority may then inspect the source
to ensure that the pollution control devices are properly installed and
operated, that leaks are being detected and repaired, and that the
standard is being met.  The performance test may be observed as well.

The required semiannual reports are used to determine periods of excess
emissions, to identify problems at the facility, to verify
operation/maintenance procedures, and for compliance determinations.

3.  Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart YY.

3(a)  Non-duplication

If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

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

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register (73 FR 31088) on May 30, 2008.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

For this information collection, we referenced the most recent ICR,
consulted with the preparer of the active ICR, and used other resources
to obtain the most recent data available.  We reviewed information
available from the United States Census Bureau, the Air Facility System
(AFS), and websites covering PC, AMF, AR and HF source categories.  We
also consulted with the EPA’s Office of Air Quality Planning and
Standards, Information Transfer, the Program Integration Division, and
one EPA regional office.

After reviewing our internal data sources and industry experts, we have
determined that additional consultations with industry are inappropriate
for this ICR renewal.

The standard was developed with the participation and/or consultation
with industry representatives.  The Agency has performed additional
reviews to determine additional burden reduction opportunities.  The
Agency currently collects the minimum amount of information necessary to
ensure compliance with the standard.

3(d)  Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of
assurance that facilities are continuing to meet the standards. 
Requirements for information gathering and recordkeeping are useful
techniques to ensure that good operation and maintenance practices are
applied and emission limitations are met.  If the information required
by these standards was collected less frequently, the likelihood of
detecting poor operation and maintenance of control equipment and
noncompliance decreases.

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

These standards require the respondents to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year records retention requirement is consistent
with the Part 70 permit program and the five-year statute of limitations
on which the permit program is based.  Also, the retention of records
for five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for the purpose of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  If records were retained for less than five
years, EPA would be prevented from pursuing the worst violators due to
the destruction or nonexistence of records.

3(f)  Confidentiality

Any 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 (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents NAICS and SIC Codes

The respondents to the recordkeeping and reporting requirements are HAP
emissions in four categories: Polycarbonates (PC) Production, Acrylic
and Modacrylic Fibers (AMF) Production, Acetal Resins (AR) Production
and Hydrogen Fluoride (HF) Production.  The Standard Industrial
Classification (SIC) codes for the respondents affected by the
standards, which correspond to the North American Industry
Classification System (NAICS) codes, are listed below for source
category description.

Standard (40 CFR part 61, subpart N)	

SIC Codes	

NAICS Codes



Polycarbonates (PC) Production (Synthetic Rubber Manufacturing)	

2822	

325212



Acrylic and Modacrylic Fibers (AMF) Production (Manmade Organic Fibers,
Except Cellulosic)	

2824	

325222



Acetal Resins (AR) Production (Plastic Materials, Synthetic and Resins,
and Nonvulcanizable Elastomers)	

2821	

325211



Hydrogen Fluoride (HF) Production (Industrial Inorganic Chemicals, Not
Elsewhere Classified)	

2819	

325188



4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
NESHAP for Source Categories: Generic Maximum Achievable Control
Technology (40 CFR part 63, subpart YY) (Renewal).

A source must make the following reports:

Notification Reports	

Standard Citation by Section



Application for approval of construction/reconstruction	

63.5(d), 63.1110(a)



Notification of initial startup	

63.1110(b)



Notification of initial applicability	

63.09(b), 63.1110(a), and 63.1110(c)



Notification of compliance status	

63.9(h), 63.1110(a), and 63.1110(d)



Notification of performance test and performance evaluation results	

63.7(b), 63.9(e), 63.10(d)(2), 63.1110(d), and 63.1110(a)



Rescheduled initial performance test	

63.7(b)(2)



Demonstration of continuous monitoring system	

63.9(g)



Physical or operational change	

63.8(a)



Opacity or visible emissions	

63.10(d)(3)



Develop startup, shutdown, malfunction plan and periodic reports	

63.10(d)(5)(i), 63.1110(b), and 63.1111



Excess emissions and continuous parameter monitoring systems (CPMS)
performance reports	

63.1110(a)



Reports



Periodic reports (Semiannual or according to the schedule for Title V)
with information on excess emissions and on the implementation of leak
detection and repair standard provisions	

63.1110(e), 63.1108(a), and 63.1109



Startup, shutdown and malfunction reports	

63.1110(a), and 63.1111(b)



A source must keep the following records:



Recordkeeping



Maintain records of startup, shutdown, malfunctions periods when excess
emissions have occurred during the reporting period	

63.10(b)(2) and 63.1109(a)



Maintain records of performance test and performance evaluation results	

63.1109(a)



Maintain records of all reports and notifications	

63.10(b) and 63.1109(a)



Maintain record of applicability	

63.10(b)(3) and 63.1109(d)



Maintain records of initial and compliance status notifications	

63.9(h), 63.1109(d)



Records of CPMS operation adjustments, calibration checks, and
maintenance	

63.10(b)(2)(vii) and 63.1109(a)



Records of implementation of leak detection and repair (LDAR) standards
provision	

63.1107



Records are required to be retained for five years	

63.10(b)(2)



Electronic Reporting

Currently, respondents are using monitoring equipment that automatically
records parameter data.  Although personnel at the affected facility
must evaluate the data, this internal automation has significantly
reduced the burden associated with monitoring and recordkeeping at the
plant site.

Also, regulatory agencies in cooperation with the respondents, continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are still not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities

Respondent Activities



Read instructions.



Conduct control device performance tests.



Conduct a performance evaluation of the CPMS.



Inspect and monitor closed-vent system.



Monitor control devices.



Write the notifications and reports listed above.



Enter information required to be recorded above.



Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.



Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.



Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.



Train personnel to be able to respond to a collection of information.



Transmit, or otherwise disclose the information.



5.  The Information Collected:  Agency Activities, Collection
Methodology, and Information Management

5(a)  Agency Activities

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities



Observe initial performance tests and repeat performance tests if
necessary.



Review notifications and reports, including performance test reports,
and excess emissions reports, required to be submitted by industry.



Audit facility records.



Input, analyze, and maintain data in the Air Facility System (AFS).



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority might
inspect the source to determine whether the pollution control devices
are properly installed and operated.  Performance test reports are used
by the Agency to discern a source’s initial capability to comply with
the emission standard.  Data and records maintained by the respondents
are tabulated and published for use in compliance and enforcement
programs.  The semiannual reports are used for problem identification,
as a check on source operation and maintenance, and for compliance
determinations.

Information contained in the reports is entered into the AFS which is
operated and maintained by EPA's Office of Compliance.  AFS is EPA’s
database for the collection, maintenance, and retrieval of compliance
data for approximately 125,000 industrial and government-owned
facilities.  EPA uses the AFS for tracking air pollution compliance and
enforcement by local and state regulatory agencies, EPA headquarters and
EPA regional offices. EPA and its delegated Authorities can edit, store,
retrieve and analyze the data.

The records required by this regulation must be retained by the
owner/operator for five years.

5(c)  Small Entity Flexibility

All of the respondents are large entities (i.e., large businesses). 
However, the impact on small entities (i.e., small businesses) was taken
into consideration during the development of the regulation.  Due to
technical considerations involving the process operations and the types
of control equipment employed, the recordkeeping and reporting
requirements are the same for both small and large entities.  The Agency
considers these requirements the minimum needed to ensure compliance
and, therefore, cannot reduce them further for small entities.  To the
extent that larger businesses can use economies of scale to reduce their
burden, the overall burden will be reduced. According to the Paperwork
Reduction Act Submission for the NESHAP for Source Categories: Generic
Maximum Achievable Control Technology Standards, this ICR does not have
a significant impact on small entities. The Agency assumes that zero
percent of the 10 facilities affected by this ICR, or zero facilities,
are small entities.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Source Categories: Generic Maximum Achievable Control Technology
Standards (40 CFR part 63, subpart YY) (Renewal), attached.

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burden under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

The 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.

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 4,004
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the NESHAP program, the previously
approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs

This ICR uses the following labor rates:

Managerial	$97.46   ($46.41 + 110%)

Technical	$83.71   ($39.86 + 110%)

Clerical	$42.55   ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, “Table 2: Civilian Workers, by
Occupational and Industry group.”  The rates are from column 1,
“Total Compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry cost associated with the information collection
activities in the subject standard are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one-time costs when a
facility becomes subject to the regulation.  The annual operation and
maintenance costs are the ongoing costs to maintain the monitor and
other costs such as photocopying and postage.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

Capital/Startup vs. Operation and Maintenance (O&M) Costs



(A)

Continuous Monitoring Device	

(B)

Capital/Startup Cost for One Respondent	

(C)

Number of New Respondents 	

(D)

Total Capital/ Startup Cost, 

(B X C)	

(E)

Annual O&M Costs for One Respondent 1	

(F)

Number of Respondents with O&M 	

(G)

Total O&M,

(E X F)



PC (use of non-contractor)	

$0	

0	

$0	

$144.55	

2	

$289.10



PC (use of contractor) 2	

$0	

0	

$0	

$53,128.85	

2	

$106,257.70



AMF	

$0	

0	

$0	

$144.55	

3	

$433.65



AR	

$0	

0	

$0	

$144.55	

2	

$289.10



HF	

$0	

0	

$0	

$144.55	

1	

$144.55



Total	

	

	

$0	

	

	

$107,414.10



Total rounded	

	

	

	

	

	

$107,414.00

1 We have assumed that each source will respond 5 times per year to
comply with the rule at a total cost of $144.55 per source to cover O&M
costs.  This estimate is based on the assumption that it takes 0.5 hours
to conduct these tasks at a clerical labor rate of $42.55 per hour for a
total labor cost of $21.28 per response.  First-class postage is
estimated at $7.63 per response.  Thus, the total storage, filing,
photocopying, and postage cost per response is $28.91.

2 Based on information we obtained, we have determined that two PC
sources out of a total of four sources will use contractor support for
CPMS O&M, at a total cost of approximately $53,000 per source.

The total capital/startup costs for this ICR are zero.

The total operation and maintenance (O&M) costs for this ICR are
$107,414.

The average annual cost for capital/startup and operation and
maintenance cost to industry over the next three years of the ICR is
estimated to be $107,414.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  EPA's overall compliance and enforcement
program includes activities such as the examination of records
maintained by the respondents, periodic inspection of sources of
emissions, and the publication and distribution of collected
information.

The average annual Agency cost during the three years of the ICR is
estimated to be $2,797, for 69 hours.

This cost is based on the average hourly labor rate as follows:

Managerial	$56.02   (GS-13, Step 5, $35.01 x 1.6)

Technical	$41.57   (GS-12, Step 1, $25.98 x 1.6)

Clerical	$22.50   (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) (2005
General Schedule( which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Burden - NESHAP for Source Categories: Generic Maximum Achievable
Control Technology Standards (40 CFR part 63, subpart YY) (Renewal),
attached.

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

Based on our research for this ICR, on average over the next three
years, approximately 10 existing respondents will be subject to the
standard.  It is estimated that no additional respondents per year will
become subject to the standard.  The overall average number of
respondents, as shown in the table below is 10 per year (see table
below).

The number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents



	

Respondents That Submit Reports	

Respondents That Do Not Submit Any Reports	





Year	

(A)

Number of New Respondents 1	

(B)

Number of Existing Respondents	

(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	

(D)

Number of Existing Respondents That Are Also New Respondents	

(E)

Number of Respondents

(E=A+B+C-D)



1	

0	

10	

0	

0	

10



2	

0	

10	

0	

0	

10



3	

0	

10	

0	

0	

10



Average	

0	

10	

0	

0	

10

.

To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 10.

The total number of annual responses per year is calculated using the
following table:



Total Annual Responses



(A)

Information Collection Activity	

(B)

Number of Respondents	

(C)

Number of Responses	

(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	

(E)

Total Annual Responses 

E=(BxC)+D



Initial requirements for PC Production	

0	

1	

N/A	

0



Initial requirements for AMF Production	

0	

1	

N/A	

0



Initial requirements for AR Production	

0	

1	

N/A	

0



Initial requirements for HF Production	

0	

1	

N/A	

0



SSM reports for PC Production	

4	

1	

N/A	

4



SSM reports for AMF Production	

3	

1	

N/A	

3



SSM reports for AR Production	

2	

1	

N/A	

2



SSM reports for HF Production	

1	

1	

N/A	

1



Periodic reports for PC Production	

4	

2	

N/A	

8



Periodic reports for AMF Production	

3	

2	

N/A	

6



Periodic reports for AR Production	

2	

2	

N/A	

4



Periodic reports for HF Production	

1	

2	

N/A	

2



LDAR reports for PC Production	

0	

2	

N/A	

0



LDAR reports for AMF Production	

0	

2	

N/A	

0



LDAR reports for AR Production	

0	

2	

N/A	

0



LDAR reports for HF Production	

0	

2	

N/A	

0



	

	

	

Total	

30



The number of Total Annual Responses is 30.

The total annual labor costs are $331,146 for 4,004 hours.  Details
regarding these estimates may be found in Table 1: Annual Respondent
Burden and Cost, NESHAP for Source Categories: Generic Maximum
Achievable Control Technology Standards (40 CFR part 63, subpart YY)
(Renewal), attached.

6(e)  Bottom Line Burden Hours and Cost Tables

Details of the bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

(i) Respondent Tally

The total annual labor costs are $331,146.  Details regarding these
estimates may be found in Table 1: Annual Respondent Burden and Cost,
NESHAP for Source Categories: Generic Maximum Achievable Control
Technology Standards (40 CFR part 63, subpart YY) (Renewal), attached. 
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information are estimated to average 133 hours per
response.

The total annual capital/startup and O&M costs to the regulated entity
are $107,414.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over the next three years is
estimated to be 69 labor hours at a cost of $2,797.  See Table 2: Annual
Agency Burden and Cost, NESHAP for Source Categories: Generic Maximum
Achievable Control Technology Standards (40 CFR part 63, subpart YY)
(Renewal), attached.

6(f)  Reasons for Change in Burden

The annual non-labor cost burden was increased by $414 due to an
omission in the previous ICR renewal.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 133 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; to 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; to adjust the existing ways to
comply with any previously applicable instructions and requirements; to
train personnel to be able to respond to a collection of information; to
search data sources; complete and review the collection of information;
and to 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 valid OMB
Control Number.  The OMB Control Numbers for EPA’s regulations are
listed at 40 CFR part 9 and 48 CFR chapter 15.

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 Number
EPA-HQ-OECA-2008-0428. An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the docket, and to
access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the docket ID number identified in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 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
Enforcement and Compliance Docket and Information Center Docket is (202)
566-1514.  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 Number EPA-HQ-OECA-2008-0428 and OMB Control Number
2060-0420 in any correspondence.						

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.

Table 1:  Annual Respondent Burden and Cost - NESHAP for Source
Categories: Generic Maximum Achievable Control Technology Standards (40
CFR part 63, subpart YY) (Renewal)

	Burden item	

(A)

Technical

Person-

hours per

occurrence	

(B)   

No.  of

occurrences

per respondent

per year	

(C)

Technical

Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year  a	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours per

year

(Ex0.05)	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Total Cost

 per year b



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Reporting Requirements 	

	

	

	

	

	

	

	





  A.  Read Instructions c	

	

	

	

	

	

  	

	





  Polycarbonated (PC) Production	

4	

1	

4	

0	

0	

0	

0	

$0



  Acrylic and Modacrylic Fibers (AMF) Production 	

4	

1	

4	

0	

0	

0	

0	

$0



  Acetal Resins (AR) Production	

4	

1	

4	

0	

0	

0	

0	

$0



  Hydrogen Fluoride (HF) Production	

4	

1	

4	

0	

0	

0	

0	

$0



  B.  Required Activities for PC, AMF, AR, & HF c	

Included in 4C	

	

	

	

	

	





  C.  Create Information for PC, AMF, AR, & HF c	

Included in 4 C	

	

	

	

	

	





  D.  Gather existing information for PC, AMF, AR & HF c	

Included in 4C	

	

	

	

	

	





  E.  Write report	

	

	

	

	

	

	

	





    i  Initial requirements: notifications, initial                     
         compliance determination, performance tests c	

	

	

	

	

	

	

	





                PC Production	

52	

1	

52	

0	

0	

0	

0	

$0



                AMF Production	

52	

1	

52	

0	

0	

0	

0	

$0



                AR Production	

52	

1	

52	

0	

0	

0	

0	

$0



                HF Production	

52	

1	

52	

0	

0	

0	

0	

$0



    ii  Startup, Shutdown malfunction reports d	

	

	

	

	

	

	

	





                PC Production	

2	

1	

2	

4	

8	

0.4	

0.8	

$742.70



                AMF Production	

2	

1	

2	

3	

6	

0.3	

0.6	

$557.03



                AR Production	

2	

1	

2	

2	

4	

0.2	

0.4	

$371.35



                HF Production	

2	

1	

2	

1	

2	

0.1	

0.2	

$185.68



    iii  Periodic reports e	

	

	

	

	

	

	

	





                PC Production	

8	

2	

16	

4	

64	

3.2	

6.4	

$5,941.63



                AMF Production	

8	

2	

16	

3	

48	

2.4	

4.8	

$4,456.22



                AR Production	

8	

2	

16	

2	

32	

1.6	

3.2	

$2,970.82



                HF Production	

8	

2	

16	

1	

16	

0.8	

1.6	

$1,485.41



    iv  Leak detection and repair (LDAR) reports  c, f	

	

	

	

	

	

	

	





                PC Production	

8	

2	

16	

0	

0	

0	

0	

$0



                AMF Production	

8	

2	

16	

0	

0	

0	

0	

$0



                AR Production	

8	

2	

16	

0	

0	

0	

0	

$0



                HF Production	

8	

2	

18	

0	

0	

0	

0	

$0



4.  Recordkeeping Requirements a	

	

	

	

	

	

	

	





  A.  Read Instructions for c	

4	

1	

4	

0	

0	

0	

0	

$0



                PC Production	

4	

1	

4	

0	

0	

0	

0	

$0



                AMF Production	

4	

1	

4	

0	

0	

0	

0	

$0



                AR Production	

4	

1	

4	

0	

0	

0	

0	

$0



                HF Production	

4	

1	

4	

0	

0	

0	

0	

$0



  B.  Plan Activities for c	

40	

1	

40	

0	

0	

0	

0	

$0



                PC Production	

40	

1	

40	

0	

0	

0	

0	

$0



                AMF Production	

40	

1	

40	

0	

0	

0	

0	

$0



                AR Production	

40	

1	

40	

0	

0	

0	

0	

$0



                HF Production	

40	

1	

40	

0	

0	

0	

0	

$0



  C.  Implement Activities a	

	

	

	

	

	

	

	





    i   Material determinations c	

	

	

	

	

	

	

	





                PC Production	

N/A	

	

	

	

	

	

	





                AMF Production	

N/A	

	

	

	

	

	

	





                AR Production	

N/A	

	

	

	

	

	

	





                HF Production	

N/A	

	

	

	

	

	

	





    ii  Control equipment inspection	

	

	

	

	

	

	

	





        a.  Tanks	

	

	

	

	

	

	

	





                PC Production	

N/A	

	

	

	

	

	

	





                AMF Production	

2	

12	

24	

3	

72	

3.6	

7.2	

$6,684.34



                AR Production	

2	

12	

24	

2	

48	

2.4	

4.8	

$4,456.22



                HF Production	

N/A	

	

	

	

	

	

	





        b.  Closed-vent system	

	

	

	

	

	

	

	





                PC Production	

2	

2	

4	

2	

8	

0.4	

0.8	

$742.70



                AMF Production	

2	

2	

4	

3	

12	

0.6	

1.2	

$1,094.56



                AR Production	

2	

2	

4	

2	

8	

0.4	

0.8	

$742.70



                HF Production	

2	

2	

4	

1	

4	

0.2	

0.4	

$371.35



    iii  Control equipment leak monitoring	

	

	

	

	

	

	

	





        a.  Cover vented to control device	

	

	

	

	

	

	

	





                PC Production	

1	

2	

2	

2	

4	

0.2	

0.4	

$371.35



                AMF Production	

1	

2	

2	

3	

6	

0.3	

0.6	

$547.28



                AR Production	

1	

2	

2	

2	

4	

0.2	

0.4	

$371.35



                HF Production	

1	

2	

2	

1	

2	

0.1	

0.2	

$185.68



        b.  Closed-vent system	

	

	

	

	

	

	

	





                PC Production	

1	

2	

2	

2	

4	

0.2	

0.4	

$371.35



                AMF Production	

1	

2	

2	

3	

6	

0.3	

0.6	

$547.28



                AR Production	

1	

2	

2	

2	

4	

0.2	

0.4	

$371.35



                HF Production	

1	

2	

2	

1	

2	

0.1	

0.2	

$185.68



    iv.  Control devices	

	

	

	

	

	

	

	





        a.  Initial requirements design analysis, performance c 

             Test	

	

	

	

	

	

	

	





                PC Production	

80	

1	

80	

0	

0	

0	

0	

$0



                AMF Production	

80	

1	

80	

0	

0	

0	

0	

$0



                AR Production	

80	

1	

80	

0	

0	

0	

0	

$0



                HF Production	

80	

1	

80	

0	

0	

0	

0	

$0



        b.  Operate and maintain CMS	

	

	

	

	

	

	

	





                PC Production	

8	

12	

96	

2	

192	

9.6	

19.2	

$17,824.90



                AMF Production	

8	

12	

96	

3	

288	

14.4	

28.8	

$26,737.34



                AR Production	

8	

12	

96	

2	

192	

9.6	

19.2	

$17,824.90



                HF Production	

8	

12	

96	

1	

96	

4.8	

9.6	

$8,912.45



    v.  LDAR Program	

	

	

	

	

	

	

	





        a.  Initial requirement: Identify all effected streams c	

	

	

	

	

	

	

	





                PC Production	

20	

1	

20	

0	

0	

0	

0	

$0



                AMF Production	

20	

1	

20	

0	

0	

0	

0	

$0



                AR Production	

20	

1	

20	

0	

0	

0	

0	

$0



                HF Production	

20	

1	

20	

0	

0	

0	

0	

$0



        b.  Perform monitoring/repairs	

	

	

	

	

	

	

	





                PC Production               	

	

	

	

	

	

	

	





                   1)  In-house g	

0.1	

1,092	

192	

2	

384	

19.2	

38.4	

$35,649.79



                   2) Use of contractor support h	

	

	

	

2	

	

	

	

$8,000.00



                AMF Production	

16	

12	

192	

3	

576	

28.8	

57.6	

$53,474.69



                AR Production	

16	

12	

192	

2	

384	

19.2	

38.4	

$35,649.79



                HF Production g	

0.1	

1,092	

192	

1	

192	

9.6	

19.2	

$17,824.90



    vi.  Container vapor tightness certification	

	

	

	

	

	

	

	





                PC Production	

N/A	

	

	

	

	

	

	





                AMF Production	

N/A	

	

	

	

	

	

	





                AR Production	

N/A	

	

	

	

	

	

	





                HF Production	

N/A	

	

	

	

	

	

	





  D.  Develop Record System	

	

	

	

	

	

	

	





    i.  Develop startup, shutdown, malfunction plan c	

	

	

	

	

	

	

	





                PC Production	

20	

1	

20	

0	

0	

0	

0	

$0



                AMF Production	

20	

1	

20	

0	

0	

0	

0	

$0



                AR Production	

20	

1	

20	

0	

0	

0	

0	

$0



                HF Production	

20	

1	

20	

0	

0	

0	

0	

$0



    ii.  Control equipment c	

	

	

	

	

	

	

	





                PC Production	

16	

1	

16	

0	

0	

0	

0	

$0



                AMF Production	

16	

1	

16	

0	

0	

0	

0	

$0



                AR Production	

16	

1	

16	

0	

0	

0	

0	

$0



                HF Production	

16	

1	

16	

0	

0	

0	

0	

$0



    iii.  LDAR Program c	

	

	

	

	

	

	

	





                PC Production	

40	

1	

40	

0	

0	

0	

0	

$0



                AMF Production	

40	

1	

40	

0	

0	

0	

0	

$0



                AR Production	

40	

1	

40	

0	

0	

0	

0	

$0



                HF Production	

40	

1	

40	

0	

0	

0	

0	

$0



 E.  Record Information (all information required by                
standard)	

	

	

	

	

	

	

	





    i.  Initial requirements: cover design, control device c            
 design, and control equipment testing	

	

	

	

	

	

	

	





                PC Production	

17	

1	

17	

0	

0	

0	

0	

$0



                AMF Production	

17	

1	

17	

0	

0	

0	

0	

$0



                AR Production	

17	

1	

17	

0	

0	

0	

0	

$0



                HF Production	

17	

1	

17	

0	

0	

0	

0	

$0



    ii.  Control equipment inspection	

	

	

	

	

	

	

	





                PC Production	

1	

2	

2	

2	

4	

0.2	

0.4	

$371.35



                AMF Production	

1	

2	

2	

3	

6	

0.3	

0.6	

$557.03



                AR Production	

1	

2	

2	

2	

4	

0.2	

0.4	

$371.35



                HF Production	

1	

2	

2	

1	

2	

0.1	

0.2	

$185.68



    iii.  Control equipment monitoring i	

	

	

	

	

	

	

	





                PC Production	

1	

52	

52	

2	

104	

5.2	

10.4	

$9,655.15



                AMF Production	

1	

52	

52	

3	

156	

7.8	

15.6	

$14,482.73



                AR Production	

1	

52	

52	

2	

104	

5.2	

10.4	

$9,655.15



                HF Production	

1	

52	

52	

1	

52	

2.6	

5.2	

$4,827.58



     iv.  Control device CMS   	

	

	

	

	

	

	

	





                PC Production	

1	

12	

12	

2	

24	

1.2	

2.4	

$2,228.11



                AMF Production	

1	

12	

12	

3	

36	

1.8	

3.6	

$3,342.17



                AR Production	

1	

12	

12	

2	

24	

1.2	

2.4	

$2,228.11



                HF Production	

1	

12	

12	

1	

12	

0.6	

1.2	

$1,114.06



    v.  LDAR program	

	

	

	

	

	

	

	





                PC Production g	

0.02	

1,092	

21.84	

2	

43.7	

2.19	

4.37	

$4,057.51



                AMF Production               	

2	

12	

24	

3	

72	

3.6	

7.2	

$6,684.34



                AR Production	

2	

12	

24	

2	

48	

2.4	

4.8	

$4,456.22



                HF Production g	

0.02	

1,092	

21.84	

1	

21.8	

1.09	

2.18	

$2,023.87



  F.  Time to Train Personnel	

	

	

	

	

	

	

	





    i.  Material determination methods	

	

	

	

	

	

	

	





                PC Production	

N/A	

	

	

	

	

	

	





                AMF Production	

N/A	

	

	

	

	

	

	





                AR Production	

N/A	

	

	

	

	

	

	





                HF Production	

N/A	

	

	

	

	

	

	





    ii.  Control equipment inspection and monitoring j	

	

	

	

	

	

	

	





                PC Production	

8	

1	

8	

4	

32	

1.6	

3.2	

$2,939.98



                AMF Prduction	

8	

1	

8	

3	

24	

1.2	

2.4	

$2,228.11



               AR Production	

8	

1	

8	

2	

16	

0.8	

1.6	

$1,485.41



                HF Production	

8	

1	

8	

1	

8	

0.4	

0.8	

$742.70



    iii.  LDAR program f, j	

	

	

	

	

	

	

	





                PC Production	

2	

1	

2	

4	

8	

0.4	

0.8	

$742.70



                AMF Production	

2	

1	

2	

3	

6	

0.3	

0.6	

$557.03



                AR Production	

2	

1	

2	

2	

4	

0.2	

0.4	

$371.35



                HF Production	

2	

1	

2	

1	

2	

0.1	

0.2	

$185.68



    iv.  Container leak tight method	

	

	

	

	

	

	

	





                PC Production	

N/A	

	

	

	

	

	

	





                AMF Production	

N/A	

	

	

	

	

	

	





                AR Production	

N/A	

	

	

	

	

	

	





                HF Production	

N/A	

	

	

	

	

	

	





Subtotal Labor Burden	

	

	

	

	

3481.5	

174.08	

348.15	

$331,146.16



TOTAL LABOR  BURDEN AND COST (rounded)	

	

	

	

	

4,004	

$331,146



Assumptions:

a  We have assumed that there are 10 existing sources, and that no
additional new sources will become subject to the rule over the next
three years.  It is also assumed that affected facility owners and
operators have already complied with the initial requirements including
the installation of any required equipment.  In addition, we have
assumed that two sources under this category will hire contractors to
comply with the monitoring and recordkeeping requirements of the rule
while reports are developed by the source personnel.

b  This ICR uses the following labor rates:  $97.46 per hour for
Executive, Administrative, and Managerial labor; $83.71 per hour for
Technical labor, and $42.55 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, March 19, 2005, “Table 2. Civilian Workers, by
occupational and industry group.”  The rates are from column 1,
“Total Compensation.”  The rates have been increased by 110% to
account for the benefit packages available to those employed by private
industry.

c  We have assumed that there will be no new sources over the next three
years of this ICR.  We have also assumed that all existing sources have
already complied with this one-time activity.

d  All major sources must submit startup, shutdown, malfunction reports
semiannually when actions are taken in the event of a startup, shutdown,
or malfunction that are consistent with the source’s SSM plans. 
Sources can submit this information with the periodic reports.

e  The rules requires that all sources submit periodic reports
(semiannually or according to the schedule for Title V). 

f  The standards for equipment leak requires the submittal of an initial
report and semiannual reports of leak detection and repair (LDAR) and
any changes to the processes, monitoring frequency and initiation of a
quality improvement program.  We have assumed that sources are
submitting the required LDAR information with the periodic reports.

g  Visual inspections are required once per shift with a total of three
shifts per day, at seven days per week, for 52 weeks per year. (3x7x52)
for a total of 1,092 inspections per year.

h  We have determined that, based on the industry representative in the
PC category, the two sources’ use of contractor support to complete
the LDAR related monitoring will cost an estimated $8,000.

i  We have assumed that control equipment monitoring should be done on a
weekly basis.		

j We have assumed that there will be some labor hours associated with
rule analysis and training per year.



Table 2:  Average Annual Agency Burden and Cost-  NESHAP for Source
Categories: Generic Maximum Achievable Control Technology Standards (40
CFR part 63, subpart YY) (Renewal)

	Burden item	

(A)

Technical

Person

Hours Per

Occurrence	

(B)   

Number  of

Occurrences

Per Year	

(C)

Technical

Person Hours Per Plant Per

Year

(C=AxB)	

(D)

Plants Per  Year a	

(E)

Technical Hours 

Per Year

(E=CxD)	

(F)

Management   Hours Per Year

(F=0.05xE)	

(G)

Clerical

Hours Per

Year

(G=0.1xE)	

(H)

Total

Cost, 

Per Yearb





Review Reports  	

	

	

	

	

	

	

	





     1.  Initial requirements 	

	

	

	

	

	

	

	





         a.  Initial notification c	

2	

1	

2	

0	

0	

0 	

0	

$0



         b.  Performance test c, d 	

2	

1	

2	

0	

0	

0	

0	

$0



         c.  Compliance status c	

4	

1	

4	

0	

0	

0	

0	

$0



         d.  Performance test reports c, d	

4	

1	

4	

0	

0	

0	

0	

$0



     2.  Periodic requirements	

	

	

	

	

	

	

	





         a.  Startup, shutdown, malfunction reports e	

2	

1	

2	

0	

0	

0	

0	

$0



         b.  Periodic reports e	

3	

2	

6	

10	

60	

3	

6	

$2,797.26



         c.  Leak detection and repair (LDAR) reports f	

3	

2	

6	

0	

0	

0	

0	

$0



 Subtotals Labor Burden and Cost	

	

	

	

	

60	

3	

6	

$2,797.26



TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	

	

69	

	

$2,797



Assumptions:

a  We have assumed that there are 10 existing sources, and that no
additional new sources will become subject to the rule over the next
three years.

b  This cost is based on the following hourly labor rates times a 1.6
benefits multiplication factor to account for government overhead
expenses: $56.02 for Managerial (GS-13, Step 5, $35.01 x 1.6), $41.57
for Technical (GS-12, Step 1, $25.98 x 1.6) and $22.50 Clerical (GS-6,
Step 3, $14.06 x 1.6).  These rates are from the Office of Personnel
Management (OPM) “2005 General Schedule” which excludes locality
rates of pay.

c  We have assumed that there will be no new sources over the next
three years of this ICR, We have also assumed that all existing sources
have already complied with this one-time activity.								

d   We have assumed that the Agency will not have additional burden from
sources conducting performance tests due to a process change that may or
may not result in the source meeting additional requirements.

e  We have assumed that all sources have already developed a startup,
shutdown and malfunction (SSM) plan.  We have further assumed that
sources are submitting their information on SSM with the periodic report
which is submitted on a semiannual basis.

f  The equipment leak standards require the submittal of an initial
report and semiannual report of leak detection and repair (LDAR) program
experiencing any changes to the processes, monitoring frequency and
initiation of a quality improvement program.  We have assumed that
sources are submitting the required LDAR information with the periodic
reports.

  Paperwork Reduction Act Submission for the NESHAP for Source
Categories: Generic Maximum Achievable Control Technology Standards,
U.S. EPA, June 1999.

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