83­
I
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
(
40
CFR
Part
63,
Subpart
YY)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
The
title
of
this
Information
Collection
Request
(
ICR)
is
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
(
40
CFR
Part
63,
Subpart
YY).
This
title
differs
slightly
from
the
title
of
the
currently
approved
ICR,
National
Emission
Standards
for
Hazardous
Air
Pollutants:
Generic
Maximum
Achievable
Control
Technology.
The
title
of
the
ICR
was
changed
to
more
closely
resemble
the
title
of
the
standard.

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
at
63
FR
55178
and
promulgated
on
June
29,
1999
at
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
December
6,
2000
at
63
FR
76408,
the
Agency
added
four
additional
source
categories
to
the
Generic
MACT
rule
including:
Cyanide
Chemicals
Manufacturing,
Carbon
Black
Production,
Ethylene
Production,
and
Spandex
Production,
which
are
being
addressed
by
ICR
Number
1983.02.
An
OMB
Control
Number
has
not
been
assigned
yet
to
this
other
ICR.
On
November
2,
2001,
the
Agency
promulgated
wastewater
provisions
amendments
to
the
Generic
MACT
applicable
to
wastewater
streams
for
the
AR,
AMF,
and
PC
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
2
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
part
shall
maintain
a
file
of
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
purposes
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.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.
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.

There
are
a
total
of
ten
sources,
within
the
four
source
categories
listed
above,
currently
subject
to
the
Generic
MACT
rule,
and
it
is
estimated
that
no
new
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
The
total
number
of
sources
subject
to
the
Generic
MACT
rule
has
decreased
by
one
when
compared
with
the
active
ICR
due
to
one
PC
source
closing
its
facility.
The
breakdown
of
number
of
sources
per
source
category
is:
the
AR
production
source
category
has
two
facilities,
the
AMF
production
source
category
has
three
facilities,
the
HF
production
source
category
has
one
facility,
and
the
PC
production
source
category
has
four
facilities.
This
estimate
is
based
on
information
gathered
during
the
development
of
the
rule
and
consultation
with
the
Office
of
Air
Quality,
Planning
and
Standards
(
OAQPS)
rule
lead
for
each
source
category
and
industry
representatives
within
all
four
source
categories.

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
or
operator
subject
to
any
requirement
of
this
Act
to:
3
(
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
a
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
emissions
from
the
AMF,
AR,
HF
and
PC
source
categories
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
was
promulgated
for
this
source
category
at
40
CFR
Part
63,
Subpart
YY.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
hazardous
air
pollutant
(
HAP)
emissions
from
the
AMF,
AR,
HF
and
PC
source
categories
require
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAPs
(
including
total
organic
HAP
emissions
and
acrylonitrile
emissions)
from
these
sources
are
the
result
of
the
operation
of
the
affected
facilities.
The
Generic
MACT
standards
are
achieved
by
the
capture
and/
or
reduction
of
HAP
emissions
from
storage
vessels,
front
end
and
back
end
process
vents
from
continuous
unit
operations,
equipment
as
defined
in
the
rule,
production
process
units
that
generate
process,
or
maintenance
wastewater,
and
fiber
spinning
lines,
by
using
the
applicable
control
technology
specified
in
the
rule
including
using
a
flare
and/
or
venting
emissions
through
a
closed
vent
system
to
any
control
device
or
combination
of
control
devices
meeting
the
requirements
of
Subparts
SS
or
WW
of
Part
63,
venting
emissions
through
a
closed
vent
system
to
a
recovery
system
or
wet
scrubber,
venting
emissions
through
a
closed
vent
system
to
a
halogen
reduction
device
meeting
the
requirements
of
Subpart
SS,
enclosing
the
spinning
and
washing
areas,
as
well
as,
following
the
equipment
leaks
requirements
under
Subparts
TT
(
control
level
1)
and
UU
(
control
level
2)
of
Part
63.
The
notifications
required
by
this
regulation
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
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
leaks
are
being
detected
and
repaired
and
the
regulations
are
being
met.

Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
periodic
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
Generic
MACT
standards
continue
to
operate
the
control
equipment
and
achieve
compliance
with
4
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
Part
63,
Subpart
YY.

3(
a)
Nonduplication
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
their
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
on
October
29,
2001.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
The
burden
estimate
for
this
Information
Collection
Request
(
ICR),
was
determined
in
consultation
with
the
rule
leads
for
each
source
category
for
the
Office
of
Air
Quality,
Planning
and
Standards
(
OAQPS)
and
EPA
Regional
contacts,
who
provided
updated
information
on
the
industry
growth
rate,
the
current
number
of
facilities,
the
rule
requirements
and
other
rule­
related
information.
We
also
consulted
industry
representatives.
Following
is
a
list
of
contacts.
5
Organization
Contact
Information
Type
Phone
Number
OAQPS
David
W.
Markwordt
General
rule­
related
(
919)
541­
0837
OAQPS
Richard
Colyer
HF
source
category
(
919)
541­
5262
OAQPS
Mark
Morris
PC
source
category
(
919)
541­
5416
OAQPS
John
Schaefer
AR
source
category
(
919)
541­
0296
OAQPS
Tony
Wayne
AMF
source
category
(
919)
541­
5439
General
Electric/
Industry
Stephen
Capone
PC
capital/
operation
and
maintenance
costs
(
413)
448­
7609
Dupont/
Industry
John
Dege
HF
capital/
operation
and
maintenance
costs
(
302)
773­
0900
Dupont/
Industry
Robert
Ritchey
AR
capital/
operation
and
maintenance
costs
(
304)
863­
4271
EPA
Region
IV
Leonardo
Ceron
AMF
affected
facilities
(
404)
562­
9129
Dow
Chemical/
Industry
Steve
Knis
PC
capital/
operation
and
maintenance
costs
(
979)
238­
2011
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
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.
6
3(
f)
Confidentiality
The
required
information
has
been
determined
not
to
be
confidential.
However,
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
(
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/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
sources
of
HAP
emissions
in
four
categories:
Polycarbonates
(
PC)
Production,
Acrylic
and
Modacrylic
Fibers
(
AMF)
Production,
Acetal
Resins
(
AR)
Production
and
Hydrogen
Fluoride
(
HF)
Production.
The
following
table
summarizes
the
SIC
(
United
States
Standard
Industrial
Classification)
codes
and
their
corresponding
NAICS
(
The
North
American
Industry
Classification
System)
codes
for
each
source
category
subject
to
40
CFR
Part
63,
Subpart
YY.

Source
Category
SIC
Code
(
Description)
NAICS
Code
(
Description)

Hydrogen
Fluoride
Production
2819
(
Industrial
Inorganic
Chemicals,
Not
Elsewhere
Classified)
325188
(
All
Other
Basic
Inorganic
Chemical
Manufacturing)

Acetal
Resins
Production
2821
(
Plastics
Materials,
Synthetic
Resins,
and
Nonvulcanizable
Elastomers)
325211
(
Plastics
Material
and
Resin
Manufacturing)

Acrylic
and
Modacrylic
Fiber
Production
2824
(
Manmade
Organic
Fibers,
Except
Cellulosis)
325222
(
Noncellulosic
Organic
Fiber
Manufacturing)

Polycarbonates
Production
2822
(
Synthetic
Rubber
Vulcanizable
Elastomers)
325212
(
Synthetic
Rubber
Manufacturing)
7
4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR,
PART
63,
Subpart
YY.

A
source
must
make
the
following
reports:

Reports
for
40
CFR,
Part
63,
Subpart
YY
Approval
for
construction/
reconstruction
63.5(
d),
63.1110(
a)

Initial
notification
of
startup
63.110(
b)

Initial
notification
of
applicability
63.9(
b),
63.1110(
a)
63.1110(
c)

Compliance
Status
Report
63.9(
h),
63.1110(
a),
63.1110(
d)

Notification
of
performance
test
and
performance
evaluation
results
63.7(
b),
63.9(
e),
63.10(
d)(
2),
63.1110(
d),
63.1110(
a)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Demonstration
of
continuous
monitoring
system
63.9(
g)

Physical
or
operational
change
63(
a)(
8)

Opacity
or
visible
emissions
63.10(
d)(
3)

Develop
start­
up,
shutdown,
malfunction
plan
and
periodic
reports
63.10(
d)(
5)(
i),
63.1110(
b),
63.1111
Excess
emissions
and
continuous
parameter
monitoring
systems
(
CPMS)
performance
reports
63.1110(
a)
8
Reports
for
40
CFR,
Part
63,
Subpart
YY
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
(
LDAR)
standard
provisions
63.1110(
e),
63.1018(
a),
63.1039
Startup,
Shutdown
and
Malfunction
Reports
63.1110(
a),
63.1111(
b)

A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR,
Part
63,
Subpart
YY
Start­
ups,
shutdowns,
malfunctions,
periods
when
excess
emissions
have
occurred
during
the
reporting
period
63.10(
b)(
2),
63.1109(
a)

Records
of
performance
test
and
performance
evaluation
results
63.1109(
a)

All
reports
and
notifications
63.10(
b),
63.1109(
a)

Record
of
applicability
63.10(
b)(
3),
631109(
d)

Records
of
initial
and
compliance
status
notifications
63.998(
a),
631109(
a)

Records
of
CPMS
operation,
adjustments,
calibration
checks,
and
maintenance
63.10(
b)(
2)(
vii),
631109(
a)

Records
of
implementation
of
LDAR
standards
provisions
63.107
Records
are
required
to
be
retained
for
five
of
years.
The
first
two
years
of
records
must
be
retained
at
the
facility.
63.10(
b)(
2)
9
(
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.

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.

Transmit,
or
otherwise
disclose
the
information.

The
information
on
sources
of
HAP
emissions
for
the
AMF,
AR,
HF
and
PC
source
categories
is
gathered
by
EPA
and
the
States
through
inspections
and
reports
submitted
by
industry.
Presently,
several
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
enable
facilities
to
report
electronically,
which
will
further
reduce
labor
costs.
10
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
periodic
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
database.

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
periodic
reports
(
semiannual
or
according
to
the
schedule
for
Title
V
reporting)
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
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AFS
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.
EPA
uses
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
State
regulatory
agencies,
EPA
Regional
Offices
and
EPA
Headquarters.
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
or
operator
for
five
11
years.

5(
c)
Small
Entity
Flexibility
There
is
a
distribution
of
business
sizes
subject
to
this
regulation.
Minimizing
the
information
collection
burden
for
all
sizes
of
businesses
is
a
continuing
effort
on
the
EPA's
part.
Therefore,
the
EPA
has
reduced
the
recordkeeping
and
reporting
requirement
respondent
burden
to
include
only
the
information
needed
by
the
EPA
to
determine
compliance
with
the
Generic
MACT
standards.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
required
by
the
Generic
MACT
rule
for
each
source
category
are
shown
in
Tables
2a
through
2d,
Annual
(
Source
Category)
Industry
Burden
and
Cost:
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
(
40
CFR
Part
63,
Subpart
YY)
standards.
Specifically,
the
tables
address
each
category
as
follows:
Table
2a
­
Annual
AMF
Production
Industry
Burden
and
Cost,
Table
2b
­
Annual
AR
Production
Industry
Burden
and
Cost,
Table
2c
­
Annual
HF
Production
Industry
Burden
and
Cost,
and
Table
2d
­
Annual
PC
Production
Industry
Burden
and
Cost.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Tables
2a
through
2d
document
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
each
of
the
four
source
categories
addressed
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
in
the
tables.
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
4,077
labor
hours
(
The
sum
of
the
"
Total
Labor
Hours"
from
Tables
2a
through
Table
2d,
as
summarized
below).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
the
most
12
recently
approved
ICR
and
consultation
with
the
OAQPS
lead
for
each
source
category
and
industry
representatives
in
each
source
category.

Table
Number
Major
Source
Category
Total
Labor
Hours
(
Rounded)
Total
Cost
(
Rounded)

2a
AMF
1,511
$
85,459
2b
AR
1,007
$
56,973
2c
HF
474
$
26,783
2d
PC
1,085
$
69,377
Total
Burden
and
Cost
4,077
$
238,592
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:
$
85.81
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
57.12
per
hour
for
Technical
labor,
and
$
36.27
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
2001,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
Column
1,
"
Total
compensation."
The
wage
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
85.81
($
40.86
+
110%)
Technical
$
57.12
($
27.20
+
110%)
Clerical
$
36.27
($
17.27
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
cost
associated
with
the
information
collection
activity
in
the
regulations
are
for
labor
and
operation
and
maintenance
of
continuous
parameter
monitoring
systems
(
CPMS)
for
the
PC
source
category
only.
The
capital/
startup
costs
are
a
one
time
cost
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors
and
other
costs
such
as
contractor
support
cost,
13
1
We
have
assumed
that
each
source
will
have
five
responses
per
year
to
comply
with
the
rule
reporting
requirements
at
a
total
cost
per
source
of
$
128.85
for
storage,
filing,
photocopying,
and
postage.
This
estimate
is
based
on
the
assumption
that
it
takes
0.5
hrs
to
conduct
these
tasks
at
a
clerical
labor
rate
of
$
36.27
per
hour
for
a
total
labor
cost
of
$
18.14
per
response.
First
class
postage
is
estimated
at
$
7.63
per
response
for
mailing
of
an
one
pound
package
and
two
one­
half
pound
packages
to
regulatory
agencies.
Thus,
the
total
storage,
filing,
photocopying,
and
postage
cost
per
response
is
$
25.77.

2
Based
on
information
we
obtained
from
industry,
we
have
determined
that
two
PC
sources
of
a
total
of
four
sources
within
the
PC
source
category
will
use
contractor
support
for
CPMS
O&
M
at
a
total
cost
of
approximately
$
53,000
per
source.
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Source
Category
(
B)
Startup
Cost
($)
for
One
Affected
Facility
(
C)
Number
of
New
Affected
Facilities
to
Startup
(
D)
Total
Startup
Cost
(
B
X
C)
(
E)
Annual
O&
M
Costs
($)
for
One
Affected
Facility
1
(
F)
Number
of
Affected
Facilities
with
O&
M
(
G)
Total
O&
M
(
E
X
F)

AMF
$
0
0
$
0
$
128.85
3
$
386.55
AR
$
0
0
$
0
$
128.85
2
$
257.70
HF
$
0
0
$
0
$
128.85
1
$
128.85
PC2
$
0
0
$
0
$
53,128.85
2
$
106,257.70
$
128.85
2
$
257.70
Total
Number
$
0
$
107,289
(
Rounded)

We
have
determined
that
there
are
no
capital/
startup
costs
for
this
ICR
since
all
sources
within
the
four
source
categories
have
already
purchased
the
necessary
monitoring
equipment
to
comply
with
the
rule
requirements.
This
estimate
was
made
based
on
consultation
with
industry
and
OAQPS.
Therefore,
zero
is
shown
in
block
14(
a),
Total
annualized
capital/
startup
costs,
on
the
OMB
83­
I
form.
14
The
total
annual
operation
and
maintenance
costs
for
this
ICR
are
approximately
$
107,289.
This
estimate
is
based
on
consultation
with
industry
and
OAQPS
staff.
We
have
determined
that
sources
within
the
AMF,
AR
and
HF
source
categories
had
the
necessary
CPMS
at
the
time
of
rule
promulgation.
The
one
HF
source
subject
to
this
rule
is
a
large
facility
that
had
the
necessary
monitoring
equipment
at
the
time
of
rule
promulgation
because
of
established
workpractices
to
ensure
workers
safety.
The
two
AMF
source
sources
subject
to
this
rule
had
the
necessary
monitoring
equipment
at
the
time
of
rule
promulgation
due
to
compliance
with
the
requirements
of
the
Standards
of
Performance
for
Synthetic
Fiber
Production
Facilities
(
40
CFR
Part
60,
Subpart
HHH),
addressed
by
ICR
Number
1156.09,
OMB
Control
Number
2060­
0059),
and
the
Standard
of
Performance
for
Volatile
Organic
Compound
(
VOC)
Emissions
From
Synthetic
Organic
Chemical
Manufacturing
Industry
(
SOCMI)
Air
Oxidation
Unit
Processes
(
40
CFR
Part
60,
Subpart
III),
addressed
by
ICR
Number
0998.06,
OMB
Control
Number
2060­
0197.
The
two
AR
sources
subject
to
this
rule
had
the
necessary
monitoring
equipment
at
the
time
of
rule
promulgation
due
to
compliance
with
the
requirements
of
the
Hazardous
Organic
NESHAP
(
HON)
from
the
SOCMI
for
Process
Vents,
Storage
Vessels,
Transfer
Operations,
and
Wastewater
rule
(
40
CFR
Part
63,
Subparts
F,
G,
H
and
I),
addressed
by
ICR
Number
1414.05,
OMB
Control
Number
2060­
0282.
This
ICR
is
now
included
as
part
of
the
Consolidated
Air
Rule
(
CAR)
ICR
Number
1854.03,
OMB
Control
Number
2060­
0443.
Therefore,
the
operation
and
maintenance
costs
for
CPMS
for
the
AMF,
AR
and
HF
have
already
been
addressed
in
the
above
ICRs.
For
the
PC
source
category,
we
have
determined
that
two
sources
have
operation
and
maintenance
costs
associated
with
CPMS.

It
should
be
noted
that
the
industry
costs
in
block
14
of
the
OMB
83­
I
form
of
the
most
recently
approved
ICR
were
erroneously
based
on
the
assumption
that
PC
sources
did
not
incur
any
capital/
startup
costs
and
did
not
have
incremental
cost
for
operation
and
maintenance.
For
this
ICR,
there
are
no
capital/
startup
costs
because
the
CPMS
have
already
been
installed
but
there
are
continuing
operation
and
maintenance
costs
(
i.
e.,
53,000
per
source).
See
Footnote
number
2
regarding
contractor
support
costs
for
the
PC
category.
The
total
O&
M
cost
estimate
is
the
total
of
column
G.
These
costs
are
shown
in
block
14(
b),
Total
annual
costs
(
O&
M),
on
the
OMB
83­
I
form.

The
total
respondent
non­
labor
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
are
estimated
to
be
$
107,289.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
Agency
burden
and
cost
are
mainly
associated
with
the
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.
15
The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
9,055,
as
described
in
Table
1:
Annual
Agency
Burden
and
Cost:
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
(
40
CFR
Part
63,
Subpart
YY),
attached.
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
38.30.

This
rate
is
from
the
Office
of
Planning
and
Management
(
OPM)
"
2002
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Annual
Agency
Burden
and
Cost:
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
(
40
CFR
Part
63,
Subpart
YY),
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
and
Number
of
Responses
Per
Year
Source
Category
(
A)
Average
Number
of
New
Respondents
per
Year
(
B)
Number
of
Reports
for
New
Sources
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Sources
(
F)
Number
of
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
=
(
AxB)+(
CxD)+
F
AMF
0
0
3
3
0
9
AR
0
0
2
3
0
6
HF
0
0
1
3
0
3
PC
0
0
4
3
0
12
Total
Number
10
30
The
number
of
total
respondents
is
10
since
one
PC
source
has
closed
and
is
no
longer
subject
to
the
Generic
MACT
rule.
This
number
is
the
sum
of
column
A
and
column
C
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period
(
i.
e.,
number
of
new
respondents
per
year
multiplied
by
three
years
divided
by
two).
It
is
shown
in
block
13
(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

The
number
of
Total
Annual
Responses
is
30.
This
is
the
number
in
column
E
of
the
Respondent
Universe
and
Number
of
Responses
Per
Year
table.
It
is
shown
in
block
13
(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.
16
The
total
annual
labor
costs
are
$
238,592
which
includes
$
8,000
for
contractor
labor
support
used
by
two
PC
sources.
This
number
is
not
shown
on
the
OMB
83­
I
form
in
block
13(
c),
Total
hours
requested.
Only
the
burden
hours
are
reflected
in
block
13(
c).
Details
upon
which
this
estimate
is
based
appear
in
Tables
2a
through
2d,
Annual
(
Source
Category)
Industry
Burden
and
Cost:
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
(
40
CFR
Part
63,
Subpart
YY)
standards.
Specifically,
these
tables
address
each
source
category
as
follows:
Table
2a
­
Annual
AMF
Production
Industry
Burden
and
Cost,
Table
2b
­
Annual
AR
Production
Industry
Burden
and
Cost,
Table
2c
­
Annual
HF
Production
Industry
Burden
and
Cost,
and
Table
2d
­
Annual
PC
Production
Industry
Burden
and
Cost.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
approximately
$
107,289.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
section
6(
b)(
iii),
Capital/
Startup
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.

6(
f)
Reasons
for
Change
in
Burden
The
industry
hour
burden
in
block
13
of
the
OMB
83­
I
form
has
decreased
from
the
most
recently
approved
ICR
due
to
an
adjustment
based
on
the
assumption
that
all
existing
sources
have
complied
with
the
initial
monitoring,
recordkeeping
and
reporting
requirements
of
the
Generic
MACT
rule.
We
have
also
determined
that
one
source
within
the
PC
source
category
has
closed
based
on
industry
consultation.

The
industry
cost
burden
in
block
14
of
the
OMB
83I
form
have
increased
since
we
have
determined
that
two
sources
in
the
PC
source
category
have
continuing
operation
and
maintenance
costs
(
i.
e.,
$
53,000
per
source).

We
have
used
the
most
recent
labor
rates
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics
for
year
2001
which
are
slightly
higher
than
the
labor
rates
for
the
most
recently
approved
ICR.

6(
g)
Burden
Statement
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
17
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
Number.
The
OMB
Control
Numbers
for
EPA's
standards
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency'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
Ms.
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822T),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
Number
and
OMB
Control
Number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
18
Attachment
1
TABLE
1:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENTS
AS
A
RESULT
OF
STANDARDS
A
B
C
D
E
F
Activity
Person
hours
per
response
or
Annual
number
of
responses
Total
annual
person
Annual
labor
cost(
C
x
Annual
direct
costs
Total
annual
cost
(
D
+
E)

1.
Review
reports
a.
Initial
notification
NA
b.
Performance
test
2
0
0
0
0
$
0
c.
Compliance
status
4
0
0
0
0
0
d.
Performance
test
reports
4
0
0
0
0
0
e.
2
22
44
1,470
0
1,470
f.
Semi­
annual
summary
2
22
44
1,470
0
1,470
2.
Compliance
inspections
a.
Select
site
and
review
4
1
4
134
0
134
b.
Travel
to/
from
site
8
1
8
267
500
767
c.
On­
site
inspection
4
1
4
134
0
134
d.
Prepare
inspection
16
1
16
534
0
534
3.
Enforcement
action
a.
Notice
of
non­
compliance
160
1
160
5,344
0
5,344
b.
Follow­
up
compliance
32
1
32
1,069
0
1,069
c.
Litigation
NA
Total
312
$
10,421
$
500
$
10,921
NA
­
Not
Applicable.
19
20
