SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Chromium
Emissions
From
Hard
and
Decorative
Chromium
Electroplating
and
Chromium
Anodizing
Tanks
(
40
CFR
part
63,
subpart
N)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Chromium
Emissions
From
Hard
and
Decorative
Chromium
Electroplating
and
Chromium
Anodizing
Tanks
(
40
CFR
part
63,
subpart
N)

1(
b)
Short
Characterization/
Abstract
The
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
using
maximum
achievable
control
technology
(
MACT)
for
control
of
chromium
emissions
from
hard
and
decorative
chromium
electroplating
and
chromium
anodizing
tanks
were
proposed
on
December
16,
1993
and
promulgated
on
January
25,
1995.
This
rule
applies
to
sources
performing
hard
chromium
electroplating,
decorative
chromium
electroplating,
and
chromium
anodizing.
The
affected
source
is
each
chromium
electroplating
or
chromium
anodizing
tank.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
63,
subpart
N.

In
general,
all
NESHAP­
MACT
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Respondents
that
are
not
required
to
conduct
an
initial
performance
test
(
i.
e.,
decorative
chromium
electroplating
or
chromium
anodizing
operations
that
use
a
wetting
agent
and
meet
the
surface
tension
limit
in
the
NESHAP,
and
decorative
chromium
electroplating
operations
that
use
a
trivalent
chromium
bath)
are
required
to
notify
the
Administrator
of
the
initial
compliance
status
of
the
source.
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.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
NESHAP­
MACT.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
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.

OMB
Terms
of
Clearance
In
the
development
of
this
Information
Collection
Request
(
ICR),
we
reviewed
the
Office
of
Management
and
Budget
(
OMB)
"
Terms
of
Clearance"
(
TOC)
section
on
the
active
ICR.
The
TOC
section
stated:

This
collection
is
approved
for
three
years.
EPA
should
ensure
that
2
a
mechanism
is
available
to
permit
electronic
reporting
of
the
requested
information.
When
it
next
submits
this
ICR
to
OMB
for
revision
or
renewal,
EPA
should
review
the
cost
and
burden
estimates
to
ensure
that
they
are
consistent
with
respondents'
experience
in
complying
with
the
collection.

There
are
approximately
5,020
chromium
electroplating
and
anodizing
operations
nationwide.
Of
this
total,
approximately
1,540
are
hard
chromium
electroplating
operations,
2,800
are
decorative
chromium
electroplating
operations,
and
680
are
chromium
anodizing
operations.
No
net
growth
is
predicted
for
this
industry.
It
is
expected
that
new
tanks
will
only
be
added
to
replace
or
expand
existing
capacity
and
that
few
new
facilities
will
be
constructed.
The
ongoing
monitoring,
reporting,
and
recordkeeping
for
new
tanks
are
the
same
as
those
for
existing
tanks.
Information
regarding
the
number
of
affected
facilities
was
derived
from
the
National
Metal
Finishing
Resource
Center,
an
Internet
site
developed
through
a
partnership
between
the
Federal
government
and
the
metal
finishing
industry
which
provides
a
continuous
forum
to
discuss
the
implementation
of
regulatory
requirements,
including
the
NESHAP
subpart
N:
Chromium
Emissions
from
Hard
and
Decorative
Chromium
Electroplating
and
Chromium
Anodizing
Tanks.

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:

(
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,
chromium
emissions
from
hard
and
decorative
chromium
3
electroplating
and
chromium
anodizing
tanks
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP­
MACT
standards
were
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
N.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
chromium
emissions
from
hard
and
decorative
chromium
electroplating
and
chromium
anodizing
tanks
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
chromium
from
hard
and
decorative
chromium
electroplating
and
chromium
anodizing
tanks
are
the
result
of
operation
of
the
chromium
electroplating
and
chromium
anodizing
tanks.
The
subject
standards
are
achieved
by
the
capture
of
chromium
emissions
using
control
technology
such
as
composite
mesh
pads,
packed
bed
scrubbers
and
fiber
bed
mist
eliminators,
and
the
control
of
chromium
emissions
using
fume
suppressants.
The
notifications
required
in
the
applicable
regulations
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.
Performance
test
reports
are
needed
as
these
form
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
ongoing
compliance
status
reports
(
i.
e.,
semiannual
reports
for
major
sources
and
annual
reports
for
area
sources)
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
NESHAP­
MACT
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
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
N.

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
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.
4
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
(
68
FR
27059)
on
May
19,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
the
estimated
number
of
respondents
and
the
burden
associated
with
reporting
and
recordkeeping
were
based
on
information
available
from
consultation
with
staff
in
EPA's
Office
of
Air
Quality
Planning
and
Standards
including
Phil
Mulrine;
EPA
data
gathered
on
the
industry
sector
during
the
development
of
the
rule,
which
is
available
on
the
Air
Toxics
website,
and
for
the
Air
Program,
available
on
the
EPA's
Air
Facility
System
(
AFS)
database
through
the
Online
Tracking
Information
System
(
OTIS);
and
industry
data
on
the
National
Metal
Finishing
Resource
Center,
an
Internet
site
developed
through
a
partnership
between
the
Federal
government
and
the
metal
finishing
industry
which
provides
a
continuous
forum
to
discuss
the
implementation
of
regulatory
requirements.

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
part
1320,
Section
1320.5.
These
standards
require
affected
facilities
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
fiveyear
records
retention
requirement
is
consistent
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.
5
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
(
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
performing
hard
chromium
electroplating,
decorative
chromium
electroplating,
and
chromium
anodizing.
The
United
States
Standard
Industrial
Classification
(
SIC)
codes
for
the
respondents
affected
by
the
standard
with
the
corresponding
North
American
Industry
Classification
System
(
NAICS)
codes
are
listed
below.

SIC
Code
NAIC
Code
Source
Description
3471
332813
Electroplating,
Plating,
Polishing,
Anodizing,
and
Coloring
3423
332212
Hand
and
Edge
Tool
Manufacturing
3479
332812
Metal
Coating,
Engraving
(
except
Jewelry
and
Silverware),
and
Allied
Services
to
Manufacturers
3593
333995
Power
Cylinder
and
Actuator
Manufacturing
4(
b)
Information
Requested
(
i)
Data
Items
All
data
recorded
and/
or
reported
in
this
ICR
are
required
by
NESHAP
for
Chromium
Emissions
From
Hard
and
Decorative
Chromium
Electroplating
and
Chromium
Anodizing
Tanks
(
40
CFR
part
63,
subpart
N).
6
A
source
must
make
the
following
reports:

Notification
Reports
Notification
of
construction/
reconstruction
63.5(
a);
63.5(
b);
63.5(
e);
63.345
Notification
of
initial
performance
test
63.347(
d)

Reschedule
of
initial
performance
test
63.7(
b)(
2)

Notification
of
compliance
status
63.347(
e)

Request
for
extension
of
compliance
status,
adjustments
to
time
periods,
and
changes
in
information
63.9(
c);
63.9(
i);
63.9(
j);
63.343(
a)(
6)

Reports
Initial
performance
test
results
63.347(
f)

Operation
and
maintenance
plan
63.342(
f)(
3);
63.347(
g)(
3)

Submission
of
site
specific
test
plan
upon
request
63.344(
a)

Ongoing
semiannual
compliance
status
reports
for
major
sources,
unless
the
source
is
required
to
submit
it
a
more
frequent
basis
(
e.
g.,
quarterly
reports
are
required
when
an
emission
limit
is
exceeded),
except
for
sources
using
trivalent
chromium
baths
63.347(
g)

Ongoing
annual
compliance
status
reports
for
area
sources,
unless
the
source
is
required
to
submit
it
a
more
frequent
basis
(
e.
g.,
semiannual
reports
are
required
when
the
duration
of
an
excess
emissions
is
one
percent
or
greater
of
the
total
operating
time),
except
for
sources
using
trivalent
chromium
baths
63.347(
h)

Request
to
reduce
reporting
frequency
of
ongoing
compliance
status
reports
63.347(
g)(
2);
63.347(
h)(
2)

Reports
associated
with
trivalent
chromium
baths
63.347(
i)
7
A
source
must
keep
the
following
records:

Recordkeeping
General
recordkeeping
requirements
(
e.
g.,
startups,
shutdowns
and
malfunctions
including
process
equipment,
air
pollution
control
equipment,
maintenance
performed,
and
actions
taken
outside
of
the
scope
of
the
existing
plans,
records
of
monitoring
data
used
to
demonstrate
compliance,
performance
test
results,
documentation
supporting
notifications
and
reports)
63.346(
a);
63.346(
b)

Records
for
sources
with
continuous
monitoring
systems
63.346(
b)

Records
are
required
to
be
retained
for
5
years.
The
first
2
years
of
records
must
be
kept
onsite.
63.10(
b)(
1);
63.346(
c)

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
monitoring
system
for
pressure
drop
for
composite
mesh
pad
systems
and
fiber
bed
mist
eliminators;
pressure
drop
and
velocity
pressure
for
packed
bed
scrubbers,
surface
tension
for
wetting
agents,
or
the
appropriate
parameter
for
an
alternative
control
option.

Perform
initial
performance
test,
Reference
Method
306,
306(
a)
or
306(
b),
and
repeat
performance
tests
if
necessary.

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.
8
Respondent
Activities
Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way
(
e.
g.,
pressure
drop
and
temperature
monitors).
Although
personnel
at
the
source
still
need
to
evaluate
the
data,
this
type
of
monitoring
equipment
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically,
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
estimated
that
approximately
10
percent
of
the
respondents
use
electronic
reporting.

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
and
to
note
the
operating
conditions
under
which
compliance
was
achieved.
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.
9
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
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
the
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
years.

5(
c)
Small
Entity
Flexibility
The
majority
of
affected
facilities
subject
to
this
regulation
are
small
businesses.
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutant.
The
impact
on
small
businesses
was
accounted
for
in
the
regulation
development.
Reduction
in
reporting
was
provided
to
small
businesses
subject
to
this
regulation.
Small
(
area
source)
businesses
are
only
required
to
prepare
annual
compliance
status
reports
and
may
retain
these
reports
on
site.
These
reports
must
be
submitted
to
the
Agency
or
a
delegated
authority
on
a
semiannual
basis
only
where
the
duration
of
excess
emissions
and
air
pollution
control
device
malfunctions
exceeds
specified
thresholds.
Large
(
major
source)
facilities
must
prepare
and
submit
these
reports
on
a
semiannual
or
quarterly
basis
depending
on
their
performance.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
NESHAP­
MACT
for
Chromium
Emissions
From
Hard
and
Decorative
Chromium
Electroplating
and
Chromium
Anodizing
Tanks
(
40
CFR
part
63,
subpart
N)

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
NESHAP­
MACT
subpart
N.
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
495,774
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
10
regulation,
Agency
knowledge
and
experience
with
the
NESHAP­
MACT
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:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
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.

Managerial
$
93.09
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
both
labor
costs,
which
are
addressed
elsewhere
in
this
ICR,
and
the
costs
associated
with
continuous
monitoring
of
operating
parameters
associated
with
the
following
control
options:
fume
suppressants;
packed
bed
scrubbers;
composite
mesh
pads;
fiber
bed
mist
eliminators.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
annual
operations
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors
and
other
costs
such
as
photocopying
and
postage.
The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.

(
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/
Sta
rtup
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Sta
rtup
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondent
s
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

Operating
Parameter
Monitoring
Systems
$
0.00
0
$
0.00
$
15,000
5,020
$
75,300,0001
There
are
no
total
capital/
startup
costs
for
this
ICR
since
we
have
assumed
that
there
will
11
be
no
industry
growth
over
the
period
of
this
ICR.
This
is
the
total
of
column
D
in
the
above
table.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
75,300,000.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
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
is
estimated
to
be
$
75,300,000.
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
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
$
545,818.
This
cost
is
based
on
the
following
hourly
labor
breakdown
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:

Managerial
$
53.22
(
GS­
13,
Step
5,
$
33.26
x
1.6)
Technical
$
39.49
(
GS­
12,
Step
1,
$
24.68
x
1.6)
Clerical
$
21.38
(
GS­
6,
Step
3,
$
13.36
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Burden
and
Cost
for
The
Federal
Government:
NESHAP­
MACT
for
Chromium
Emissions
From
Hard
and
Decorative
Chromium
Electroplating
and
Chromium
Anodizing
Tanks
(
40
CFR
part
63,
subpart
N).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
5,020
chromium
electroplating
and
anodizing
operations
nationwide
are
currently
subject
to
the
standard.
Of
this
total,
approximately
1,540
are
hard
chromium
electroplating
operations,
2,800
are
decorative
chromium
electroplating
operations,
and
680
are
chromium
anodizing
operations.
It
is
estimated
that
no
new
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years
since
no
net
growth
is
predicted
for
this
industry.
12
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
(
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
4,740
280
0
5,020
2
0
4,740
280
0
5,020
3
0
4,740
280
0
5,020
Average
0
4,740
280
0
5,020
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
5,020.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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

Total
Annual
Responses
(
A)
Number
of
New
Respondents
(
B)
Number
of
Reports
for
New
Respondent
s
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Respondents
(
F)
Number
of
Existing
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
E=(
AxB)+(
CxD)+
F
13
Total
Annual
Responses
1
We
have
assumed
that
all
sources
are
area
sources.
Area
sources,
except
for
chromium
anodizing
plants
(
4,740),
are
required
to
submit
an
annual
compliance
status
report.
However,
sources
are
required
to
submit
these
reports
on
a
more
frequent
basis
if
excess
emissions
occurs
(
i.
e.,
semiannually
for
area
sources).
We
have
further
assumed
that
80
percent
of
the
sources
(
0.80
times
4,740
yields
3,792)
will
have
no
excess
emissions
and
20
percent
of
the
sources
(
0.20
times
4,740
yields
948)
will
have
excess
emissions.
0
6
3,792
1
1
280
5,968
948
2
The
number
of
Total
Annual
Responses
is
5,968.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
31,362,892.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1,
Annual
Respondent
Burden
and
Cost,
NESHAP­
MACT
for
Chromium
Emissions
From
Hard
and
Decorative
Chromium
Electroplating
and
Chromium
Anodizing
Tanks
(
40
CFR
part
63,
subpart
N).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
75,300,000.
This
number,
rounded
to
thousands,
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.
Operation
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
83
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
a
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
The
decrease
in
labor
hours
is
mainly
the
result
of
changing
the
percentage
from
10
percent
to
5
percent
of
the
technical
person­
hours
to
calculate
the
management
person­
hours
used
to
comply
with
the
rule
requirements.
We
believe
this
estimate
is
more
accurate
than
that
of
the
active
ICR.
This
change
to
the
burden
calculation
offsets
the
burden
associated
with
adding
a
requirement
that
was
omitted
in
the
active
ICR.
Specifically,
the
renewal
of
this
ICR
includes
the
burden
associated
with
sources
requesting
the
regulatory
agency
to
reduce
the
frequency
of
ongoing
compliance
status
reports
since
sources
must
report
on
a
more
frequent
basis
when
excess
emissions
have
occurred
at
the
plant.
This
requirement
added
an
additional
948
annuals
hours
to
14
the
existing
burden
based
on
474
sources
submitting
such
requests
to
the
regulatory
agency.
Another
change
to
the
burden
calculation
which
affected
the
total
cost
associated
with
this
ICR
is
that
we
used
the
most
recent
labor
rates
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics
dated
June
2004,
which
are
higher
than
those
used
in
the
active
ICR,
resulting
in
an
increased
cost
to
industry.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
83
hours
per
response.
Burdens
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
nine
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
a
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2003­
0034,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
D.
C.
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
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0034
and
OMB
Control
Number
2060­
0327
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1.
Annual
Respondent
Burden
and
Cost:

NESHAP­
MACT
for
Chromium
Emissions
From
Hard
and
Decorative
Chromium
Electroplating
and
Chromium
Anodizing
Tanks
(
40
CFR
part
63,
subpart
N)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost
b
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Acquisition,
Installation,

and
Utilization
of
Technology
and
Systems
N/
A
4.
Reporting
Requirements
A.
Read
instructions
1
1
1
6
6.0
0.3
0.6
$
436.50
B.
Required
activities:

i.
Performance
tests
c
Included
in
4E
ii.
Monitoring
of
operations
and
equipment
d
Included
in
5E
C.
Create
Information
Included
in
4B
and
5E
D.
Gather
Existing
Information
Included
in
4B
and
5E
E.
Write
report
a,
e
16
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost
b
Notification
of
compliance
status
2
1
2
0
0.0
0.0
0.0
$
0.00
Notification
of
actual
startup
2
1
2
0
0.0
0.0
0.0
$
0.00
Notification
of
construction/

reconstructiona
2
1
2
0
0.0
0.0
0.0
$
0.00
Notification
of
Performance
Test
2
1
2
0
0.0
0.0
0.0
$
0.00
Notification
of
actual
startup
2
1
2
0
0.0
0.0
0.0
$
0.00
Reports
of
performance
test
results
4
1
4
0
0.0
0.0
0.0
$
0.00
Operation
and
maintenance
plan
10
1
10
0
0.0
0.0
0.0
$
0.00
Annual
compliance
status
reports
for
area
sources
f
4
1
4
3,792
15,168.0
758.4
1,516.8
$
1,103,464.42
Semiannual
reports
of
g
exceedances
for
area
sources
8
2
16
948
15,168.0
758.4
1,516.8
$
1,103,464.42
Semiannual
compliance
status
reports
for
major
sources
h
8
2
16
0
0.0
0.0
0.0
$
0.00
17
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost
b
Quarterly
compliance
status
reports
for
major
sources
g,

h
8
2
16
0
0.0
0.0
0.0
$
0.00
Request
to
reduce
report
Frequency
g
2
1
2
474
948.0
47.4
94.8
68,966.53
5.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
4A
B.
Plan
activities
Included
in
4B
C.
Implement
activities
Included
in
4B
D.
Develop
record
system
40
1
40
0.0
0.0
0.0
0.0
$
0.00
E.
Time
to
enter
and
transmit
information
i.
Records
of
monitoring:

­
Composite
mesh
pad/
packed
bed
scrubber
i
0.5
250
125
2,122
265,250
13,262.5
26,525.0
19,296,804.88
­
Wetting
agents
(
normal
schedule)
j,
k
0.25
1000
250
262
65,500
3,275.0
6,550.0
4,765,092.25
­
Wetting
agents
(
reduced
frequency
schedule
j,
k
0.25
100
25
2,356
58,900
2,945.0
5,890.0
4,284,945.55
18
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost
b
­
Foam
Blankets
(
normal
schedule)
l
0.25
4,000
1,000
0.0
0.0
0.0
0.0
$
0.00
­
Foam
Blankets
(
reduced
frequency
schedule)
l
0.25
500
125
0.0
0.0
0.0
0.0
$
0.00
­
Excess
emissions
Included
in
4E
ii.
Records
of
operations:

­
Operation
and
maintenance
m
1
4
4
2,142
8,488.0
424.4
848.8
617,497.76
­
Cumulative
rectifier
capacity
Included
in
4E
­
Operating
time
Included
in
4E
­
Records
of
trivalent
chromium
bath
purchases
n
0.5
12
6
280
1,680.0
84.0
168.0
$
122,219.16
F.
Time
to
train
personnel
N/
A
G.
Time
for
audits
N/
A
TOTAL
LABOR
BURDEN
AND
COST
(
Rounded)
431,108.0
21,555.4
43,110.8
$
31,362,892
TOTAL
LABOR
HOURS
495,774
Assumptions:
19
a
There
are
an
estimated
total
of
5,020
chromium
electroplating
and
anodizing
operations
nationwide.
Of
this
total,
approximately
1,540
are
hard
chromium
electroplating
operations,
2,800
are
decorative
chromium
electroplating
operations,
and
680
are
chromium
anodizing
operations.
No
net
growth
is
predicted
for
this
industry.
It
is
expected
that
new
tanks
will
only
be
added
to
replace
or
expand
existing
capacity.
The
ongoing
monitoring,
reporting,
and
recordkeeping
for
new
tanks
is
the
same
as
that
for
existing
tanks.

b
This
ICR
uses
the
following
labor
rates:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group".
The
rates
are
from
column
1,
"
Total
compensation."
These
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

c
Sources
are
required
to
conduct
performance
tests
using
Methods
306
or
306A
of
Appendix
A,
or
the
California
Air
Resources
Board
(
CARB)
Method
425,

as
an
alternative,
Method
306B,
and
alternate
methods
if
the
method
has
been
validated
using
Method
301
of
Appendix
A.

d
Sources
are
required
to
follow
work
practice
standards
at
composite­
mesh­
pad
(
CMP)
systems,
packed­
bed
scrubbers
(
PBS),
PBS/
CMP
systems,
fiber­
bed
mist
eliminators,
and
other
air
pollution
control
devices
not
listed
in
the
rule,
as
well
as
monitoring
operational
parameters
(
i.
e.,
pressure
drop
for
composite
mesh
pad
systems
and
fiber
bed
mist
eliminators;
pressure
drop
and
velocity
pressure
for
packed
bed
scrubbers,
surface
tension
for
wetting
agents,
or
the
appropriate
parameter
for
an
alternative
control
option)
and
monitoring
equipment.

e
We
have
assumed
that
all
existing
sources
are
in
compliance
with
the
initial
rule
requirements.

f
All
sources,
except
decorative
chromium
electroplating
plants
using
trivalent
chromium
bath
(
5,020
less
280
yields
4,740),
are
required
to
submit
compliance
status
reports.
Area
sources
are
required
to
submit
an
annual
compliance
status
report
and
major
sources
a
semiannual
compliance
status
report.
However,
we
have
assumed
that
80
percent
of
the
sources
(
0.80
times
4,740
yields
3,792)
will
have
no
excess
emissions
and
20
percent
of
the
sources
(
0.20
times
4,740
yields
948)
will
have
excess
emissions.

g
If
excess
emissions
occur
at
the
plant,
sources
are
required
to
submit
these
reports
on
a
more
frequent
basis
(
i.
e.,
semiannually
for
area
sources
and
quarterly
for
major
sources)
until
the
regulatory
agency
has
approved
the
source
request
to
reduce
frequency
of
ongoing
compliance
status
reports.

h
We
have
assumed
that
all
sources
are
area
sources.
We
have
further
assumed
that
half
of
the
area
sources
submitting
semiannual
reports
due
to
excess
emissions
(
0.5
times
948
yields
474)
will
request
the
regulatory
agency
to
approve
a
reduction
in
frequency
for
ongoing
compliance
status
reports
(
i.
e.,
annual
reporting).

i
We
have
assumed
that
the
monitoring
required
for
composite
mesh
pad/
packed
bed
scrubbers
occurs
once
per
day,
5
five
days
a
week,
50
weeks
per
year
for
all
plants
with
add­
on
control
devices.
The
number
of
facilities
with
add­
on
control
devices
is
estimated
to
be
1,222
based
on
the
assumption
that
all
hard
chromium
electroplating
facilities
(
1,540),
15
percent
of
the
decorative
chromium
electroplating
that
use
hexavalent
chromium
bath
(
0.15
percent
times
2,520
yields
378)
and
30
percent
of
chromium
anodizing
facilities
(
0.30
times
680
yields
204)
will
use
add­
on
control
devices.

j
We
have
assumed
that
85
percent
of
decorative
chromium
electroplating
plants
that
use
hexavalent
chromium
bath
(
0.85
times
2,520
yields
2,142)
and
70
percent
of
chromium
anodizing
plants
(
0.70
times
680
yields
476)
will
use
wetting
agents
for
a
total
of
2,618
sources.

k
We
have
assumed
that
area
sources
using
wetting
agents
will
be
required
to
monitor
once
every
four
hours
and
at
least
twice
per
shift,
five
days
a
week,
50
weeks
per
year
per
operating
schedule
if
the
source
is
on
a
regular
monitoring
schedule.
If
the
source
is
on
a
reduced
monitoring
schedule,
it
will
be
required
to
monitor
once
every
40
hours
for
16­
hour
day,
five
days
a
week,
50
weeks
per
year
per
operating
schedule.
We
have
assumed
that
90
percent
of
the
sources
(
0.90
times
2,618
yields
2,356)
will
be
on
a
normal
schedule
and
10
percent
of
the
sources
(
0.10
times
2,618
yields
262)
are
on
a
reduced
schedule.

l
We
have
assumed
that
sources
will
not
elect
to
use
foam
blankets
because
the
rule
requires
them
to
do
compliance
testing.
If
sources
elect
to
use
foam
blankets,
the
reduced
monitoring
schedule
will
required
them
to
monitor
once
every
8
hours,
per
16­
hour
day,
five
days
a
week,
50
weeks
per
year
per
20
operating
schedule.
If
the
source
is
on
a
normal
monitoring
schedule
it
will
be
required
to
monitor
once
every
hour,
per
16­
hour
day,
five
days
a
week,
50
weeks
per
year
per
operating
schedule.

m
We
have
assumed
that
all
facilities
with
add­
on
control
devices
(
1,222)
would
be
required
to
have
an
approved
Operation
and
Maintenance
Plan
for
their
operations.

n
We
have
assumed
that
10
percent
of
the
decorative
chromium
electroplating
plants
(
0.10
x
2,800
yields
280)
use
trivalent
chromium
baths.
21
Table
2.
Annual
Burden
and
Cost
for
The
Federal
Government:

NESHAP­
MACT
for
Chromium
Emissions
From
Hard
and
Decorative
Chromium
Electroplating
and
Chromium
Anodizing
Tanks
(
40
CFR
part
63,
subpart
N)

Activity
(
A)
EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)
EPA
personhours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost
b
Notification
of
compliance
c
status
2
1
2
0
0
0
0
$
0.00
Notification
of
actual
startup
c
2
1
2
0
0
0
0
$
0.00
Notification
of
construction/

reconstruction
c
2
1
2
0
0
0
0
$
0.00
Notification
of
actual
startup
c
2
1
2
0
0
0
0
$
0.00
Operation
and
maintenance
plan
c,
d
2
1
2
0
0
0
0
$
0.00
Notification
of
Performance
Test
c
2
1
2
0
0
0
0
$
0.00
Reports
of
performance
test
results
c
2
1
2
0
0
0
0
$
0.00
Annual
compliance
status
reports
for
area
sources
f
2
1
2
3,793
7,584
379.2
758.4
$
335,887.78
22
Activity
(
A)
EPA
personhours
per
occurrence
(
B)

No.
of
occurrences
per
plant
per
year
(
C)
EPA
personhours
per
plant
per
year
(
C=
AxB)
(
D)
Plants
per
year
a
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Cost
b
Semiannual
reports
of
exceedances
for
area
sources
g
2
2
4
948
3,792
189.6
379.2
$
167,943.89
Semiannual
compliance
status
reports
for
major
sources
h
2
1
2
0
0
0
0
$
0.00
Quarterly
compliance
status
reports
for
major
sources
2
1
2
0
0
0
0
$
0.00
Request
to
reduce
report
frequency
g
2
1
2
474
948
47.4
94.8
$
41,985.97
Attend
performance
tests
h
80
1
80
0
0
0
0
$
0.00
136
1
136
0
0
0
0
$
0.00
Travel
Expenses
h
(
1
person
x
0
plant/
yr
x
2
days/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
0
round
trips/
yr)
$
0.00
TOTAL
ANNUAL
COST
(
rounded)
TOTAL
ANNUAL
COST
=
$
545,818
Assumptions:

a
We
have
assumed
that
there
are
approximately
59
existing
slabstock
foam
producers
and
73
existing
rebond/
molded
foam
producers
for
a
total
of
132
sources.
We
have
further
assumed
that
about
6
existing
sources
a
year
will
be
conducting
some
type
of
modification
at
their
facilities
and
that
there
will
be
no
new
sources
over
the
period
of
this
ICR
Therefore,
the
average
number
of
respondents
per
year
is
estimated
to
be
132.
These
rates
are
from
the
Office
of
Planning
and
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.

b
This
cost
is
based
on
the
following
labor
rates
which
incorporates
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:

Managerial
rate
of
$
53.22
(
GS­
13,
Step
5,
$
33.26
x
1.6),
Technical
rate
of
$
39.49
(
GS­
12,
Step
1,
$
24.68
x
1.6),
and
Clerical
rate
of
$
21.38
(
GS­
6,
Step
3,

$
13.36
x
1.6)
23
c
Assumes
that
all
existing
sources
are
in
compliance
with
the
initial
rule
requirements.

d
There
will
be
no
periodic
burden
for
the
regulatory
agency
associated
with
this
requirement
although
we
have
assumed
that
all
facilities
with
add­
on
control
devices
(
1,222)
would
be
required
to
have
an
approved
Operation
and
Maintenance
Plan
for
its
operations.

e
All
sources,
except
decorative
chromium
electroplating
plants
using
trivalent
chromium
bath
(
5,020
less
280
yields
4,740),
are
required
to
submit
compliance
status
reports.
Area
sources
are
required
to
submit
an
annual
compliance
status
report
and
major
sources
a
semiannual
compliance
status
report.
However,
we
have
assumed
that
80
percent
of
the
sources
(
0.80
times
4,740
yields
3,792)
will
have
no
excess
emissions
and
20
percent
of
the
sources
(
0.20
times
4,740
yields
948).

f
If
excess
emissions
occur
at
the
plant,
sources
are
required
to
submit
these
reports
on
a
more
frequent
basis
(
i.
e.,
semiannually
for
area
sources
and
quarterly
for
major
sources)
until
the
regulatory
agency
has
approves
the
source
request
to
reduce
frequency
of
ongoing
compliance
status
reports.
We
have
assumed
that
all
sources
are
area
sources.

g
We
have
further
assumed
that
half
of
the
area
sources
submitting
semiannual
reports
due
to
excess
emissions
(
0.5
times
948
yields
474)
will
request
the
regulatory
agency
to
approve
a
reduction
in
frequency
for
ongoing
compliance
status
reports
(
i.
e.,
annual
reporting).

h
It
would
take
an
inspector
at
least
80
hours
to
observe
a
performance
test
per
facility
and
about
120
per
facility
to
attend
a
retesting.
However,
there
will
be
no
Agency
burden
associated
with
performance
tests
since
we
have
assumed
that
there
will
be
no
new
sources
over
the
period
of
this
ICR.

N/
A
=
Not
applicable.
