1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
FOR
EPOXY
RESIN
PRODUCTION
AND
NON­
NYLON
POLYAMIDE
RESIN
PRODUCTION,
SUBPART
W
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP,
Subpart
W,
Epoxy
Resin
Production
and
Non­
nylon
Polyamide
Resin
Production
1(
b)
Short
Characterization/
Abstract
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.
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
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
EPA
Regional
Office.

The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP),
for
Epoxy
Resin
Production
and
Non­
nylon
Polyamide
Resin
Production
were
promulgated
on
March
8,
1995.
These
standards
apply
to
the
following
facilities
in
Subpart
W.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
63
Subpart
W.

Approximately
13
sources
are
currently
subject
to
the
standard,
and,
the
growth
rate
for
this
industry
is
estimated
to
be
very
low,
so
no
new
sources
are
likely
to
become
subject
to
the
standard
in
the
next
three
years.
This
low
growth
rate
was
projected
in
the
original
ICR
and
is
borne
out
by
a
review
of
current
information.
The
cost
of
this
ICR
will
be
$
247250.
per
year.
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
EPA
Regional
Office.

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
2
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,
hazardous
air
pollutant
emissions,
including
epichlorohydrin,
methanol
and
hydrochloric
acid
from
epoxy
resin
and
non­
nylon
polyamide
resin
production,
regulated
by
this
National
Emission
Standard
for
Hazardous
Air
Pollutants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
Maximum
Achievable
Control
Technologies
(
MACT)
were
promulgated
for
this
source
category
at
40
CFR
Part
63,
Subpart
W.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
hazardous
air
pollutants
including
epichlorohydrin
from
epoxy
resin
and
non­
nylon
polyamide
production
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
hazardous
air
pollutants
(
HAP)
from
manufacture
of
basic
liquid
epoxy
resin
(
BLR)
and
wet
strength
resins
(
WSR)
are
the
result
of
operation
of
the
those
facilities
including
all
HAP
emission
points
within
a
facility
that
are
related
to
the
production
of
BLR
or
WSR,
including
process
vents,
storage
tanks,
wastewater
systems
and
equipment
leaks.
These
standards
rely
on
the
reduction
of
HAP
emissions
by
limiting
the
total
emissions
of
HAP
from
all
process
vents,
storage
tanks,
and
wastewater
systems
to
the
production­
based
parameters
set
in
the
rule,
(
or,
as
an
option
for
WSR,
by
complying
with
requirements
of
Subpart
H
to
control
emissions
from
equipments
leaks).
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
standard
is
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
standard,
and
to
note
the
operating
conditions
under
which
compliance
was
achieved.
The
semiannual
and
quarterly
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
MACT
continue
to
operate
the
control
equipment
used
to
achieve
compliance
with
the
MACT.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
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
3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63,
Subpart
W.

3(
a)
Nonduplication
If
the
standard
has
not
been
delegated,
the
information
is
sent
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
regulation
to
implement
the
Federal
Regulation,
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
Standard.
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
February
1,
2001
(
i.
e.,
the
first
Federal
Register
notice).
No
comments
were
received
as
a
result
of
this
notice.
However,
comments
were
received
from
a
major
manufacturer
subject
to
the
requirements
of
the
rule
after
the
publication
of
the
second
Federal
Register
notice.
The
comments
focused
primarily
on
the
general
provision
requirements
at
40
CFR
Part
63,
Subpart
A
rather
than
at
the
requirements
at
40
CFR
Part
63,
Subpart
W
(
the
rule
addressed
by
this
ICR).
EPA
has
drafted
amendments
to
Subpart
A
and
published
a
notice
in
the
Federal
Register
asking
for
comments.
The
manufacturer
provided
essentially
the
same
comments
to
this
notice
as
to
the
notice
for
this
ICR
renewal.
EPA
is
addressing
those
comments
in
conjunction
with
the
Subpart
A
revisions.
It
should
be
noted
that
any
changes
that
would
occur
would
be
due
to
any
revisions
of
Subpart
A
would
not
affect
this
ICR
renewal.

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.
However,
the
Society
of
the
Plastics
Industries
(
SPI),
a
trade
association
representing
this
industry,
was
contacted
regarding
information
in
this
ICR.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
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
4
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
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
of
the
recordkeeping
and
reporting
requirements
are
owners
or
operators
of
new,
reconstructed,
and
existing
facilities
at
a
plant
site
that
is
a
major
source
as
defined
in
section
112(
a)
of
the
Clean
Air
Act,
that
manufacture
basic
liquid
epoxy
resins
(
BLR)
and
wet
strength
resins
(
WSR)
since
promulgation
of
this
MACT
(
a
subset
of
SIC
Code
2821
or
NAICS
Code
325211).

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
W,
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Epoxy
Resin
Production
and
Non­
nylon
Polyamide
Resin
Production
A
source
must
make
the
following
notifications/
reports:

Reports
for
NESHAP
SUBPART
W
Startup,
construction
or
modification
63.520,
63.6(
e),
(
63.5(
b)
&
(
d),
63.10(
d)(
5)

Initial
notifications
63.9(
b)

Initial
performance
test
and
results
63.7(
b),
63.10(
d)(
2),
63.9(
e)
Reports
for
NESHAP
SUBPART
W
5
Emissions
tests
and
results
63.520,
63.9(
e)
&
(
g),
63.10(
d)(
2)

Monitoring
exceedances
&
excess
emissions
63.520,
63.10(
d)
&
(
e),
63.528(
a)

Production
capacity
and
exceedances
63.520,
63.9(
b)
&
(
h)

No
excess
emissions
63.520,
63.10(
d)
&
(
e)

Continuous
monitoring
system
performance
and
summary
report
63.520,
63.10(
e)(
3),
63.9(
g)

Compliance
status
63.9(
h)

Physical
or
operational
change
63.520,
63.5(
b)(
6)

Waiver
applications
63.520,
63.7(
h)

Periodic
startup,
shutdown,
malfunction
reports
63.10(
d)(
5)(
I)

Values
of
monitored
parameters
when
average
values
are
outside
approved
ranges
63.528,
63.10(
e)

Duration
of
periods
when
monitoring
data
is
not
collected
for
each
excursion
caused
by
insufficient
monitoring
data
63.528,
63.10(
e)

A
source
must
maintain
the
following
records
Recordkeeping
for
NESHAP
SUBPART
W
Startups,
shutdowns,
malfunctions
&
malfunction
plan,
excursions,
and
periods
where
the
continuous
monitoring
system
is
inoperative
63.10(
b)(
2),
63.6,
63.527,
63.528
Emission
test
results
,
engineering
assessments,
and
other
data
needed
to
determine
emissions
63.524,
63.526,
63.527,
63.10(
b)(
2)

All
reports
and
notifications
63.10(
b)

Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.10(
3)
Recordkeeping
for
NESHAP
SUBPART
W
6
Records
are
required
to
be
retained
for
5
of
Years.
(
All
MACT
standards
require
five
years
of
record
retention).
The
first
two
years
of
records
must
be
kept
onsite.
63.10(
b)(
1)

Reports
of
process
changes
which
change
the
status
of
de
minimis
emission
points
63.528,
63.10(
e)

Equipment
leaks
 
monitoring,
equipment
modification
and
repair
records
63.526
ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
Perform
initial
performance
test,
Reference
Method
1
or
1A,
2,
2A,
2C,
or
2D,
of
40
CFR
part
60
appendix
A,
as
appropriate,
or
Method
25A
and
or
Methods
18
and
25A
of
40
CFR
Part
60,
appendix
A,
if
applicable,
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.

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
7
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
Aerometric
Information
Retrieval
System
(
AIRS)
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,
and
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.

Information
contained
in
the
reports
is
entered
into
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
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
There
are
no
small
businesses
affected
by
this
standard.
As
an
alternative
to
implementing
the
standards
for
process
vents,
storage
tanks,
and
wastewater,
WSR
facilities
may
elect
to
comply
with
the
requirements
of
40
CFR
63,
Subpart
H
(
a
leak
detection
and
repair
program)
for
equipment
leaks.
In
addition,
for
affected
BLR
sources,
uncontrolled
emission
points
emitting
less
than
one
pound
per
year
of
HAP
are
not
subject
to
the
monitoring
requires
in
CFR63.526(
a)(
2)
through
(
a)(
6).

5(
d)
Collection
Schedule
8
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
each
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
(
Section
112,
CAAA;
40
CFR
PART
63,
Subpart
W).
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
at
4525
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
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
Technical
labor
rates
of
$
55.34
per
hour;
$
78.54
per
hour
for
Executive,
Administrative,
and
Managerial;
and
$
35.64
per
hour
for
Clerical.
These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rates
are
from
column
1:
Total
compensation.
The
wage
rates
have
been
loaded
by
adding
110%
overhead:
Executive,
Administrative,
and
Managerial
$
78.54
($
37.40
+
110%)
Technical
$
55.34
($
26.35
+
110%)
Clerical
$
35.64
($
16.97
+
110%))

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
Because
the
growth
rate
for
this
industry
is
so
low,
the
capital
start
up
costs
for
this
regulation
is
zero
dollars.
The
annual
operations
and
maintenance
costs
are
$
9000.
dollars.
This
is
based
on
only
3
existing
sources
which
have
continuous
monitoring
equipment
multiplied
by
$
3,000
per
year
for
upkeep
of
the
computer
equipment
and
monitoring
devices
and
calibration
costs.
(
Only
the
three
BLR
facilities
are
expected
to
have
continuous
emissions
monitoring
because
it
is
optional
for
WSR
facilities).
The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
The
average
annual
burden
for
capital
and
9
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
9,000.
The
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
and
CEMs..
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
monitor.
Total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
(
A)

Continuous
Monitoring
device
(
B)

Start
up
cost
($)
for
1
affected
facility
(
C)

#
of
new
affected
facilities
to
start
up
(
D)

Total
start
up
(
B
X
C)
(
E)

Annual
O&
M
costs
($)
for
1
affected
facility
(
F)

#
of
affected
facilities
with
O&
M
(
G)

Total
O&
M
(
E
X
F)

Computer,
software,
&
monitoring
devices
$
3,000
0
$
0
$
3,000
3
$
9,000
The
total
capital/
start­
up
costs
for
this
ICR
are
$
0.
This
is
the
total
of
column
D.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
a:
Total
annualized
capital/
startup
costs.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.

The
total
operating
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
9,000.
This
is
the
total
of
column
G.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
b:
Total
annual
costs
(
O&
M).
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.

The
total
respondent
costs
have
been
calculated
on
the
addition
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
The
average
annual
cost
for
capital
and
operations
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
9,000
.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
c:
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
truncated
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
10
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AIRS
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.

The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
14131.
(
from
table
1).
This
cost
is
based
on
an
hourly
labor
rate
plus
110%
overhead
of
$
68.19
for
managerial
staff,
$
36.86
for
technical
staff,
and
$
27.36
for
administrative/
clerical
staff.
These
rates
are
from
OPM's
2001
General
Schedule
(
GS)
base
annual
salary
data,
excluding
locality
pay,
basic
rates,
and
travel
associated
with
compliance
activities.
Details
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
Regulation
Title
(
A)
#
new
sources
per
year
(
B)
#
of
initial
reports
for
new
sources
(
C)
#
existing
sources
(
D)
#
of
reports
for
existing
sources
(
E)
total
annual
responses
(
A.
xB.)+(
CxD)

NESHAP
for
HAPs
for
Epoxy
Resin
&
Non­
nylon
Polyamide
Production,
Subpart
W
0
0
13
2.2
29
The
number
of
total
respondents
is
13.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
a.
This
is
the
number
of
existing
sources
plus
the
number
of
new
sources
anticipated
in
one
year.

The
total
annual
responses
is
29.
This
number
is
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
b.
The
total
annual
labor
hours
are
4525
.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13
c.
Details
upon
which
this
estimate
is
based
11
appear
in
Table
2:
Industry
Burden.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
9,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
c.
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
See
attachments.

6(
f)
Reasons
for
Change
in
Burden
There
is
no
change
in
burden.

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
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
regulations
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
the
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,
Mail
code
2822,
1200
Pennsylvania
Avenue,
Washington,
D.
C.
20460­
0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget
(
OMB),
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
No.
1681.04
and
OMB
Control
No.
2060­
0290
in
any
correspondence.
Attachments
Table
1.
ESTIMATE
OF
ANNUAL
BURDEN
AND
COST
TO
THE
FEDERAL
GOVERNMENT
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
Activity
(
A)

EPAHours
Per
Operation
(
B)
Operations
Per
Year
(
C)
Technical
Personhours
Per
Year
(
C=
AxB)
(
D)
Management
Person­
Hours
Per
Year
(
D=
Cx0.05)
(
E)

Clerical
Person­

Hours
Per­
Year
(
E=
Cx0.1)
(
F)
Cost
($)

Initial
performance
test
d,
e
60
0
0
0
0
0
Repeat
initial
performance
test
d,
e
60
0
0
0
0
0
1.
Retesting
preparation
16
0
0
0
0
0
2.
Retesting
60
0
0
0
0
0
Report
review
Notification
of
constr./
reconstr./
startup
2
1
2
.1
0.2
108
Notification
of
Phys./
oper.
Changes
f
2
1
2
0.1
0.2
108
Notification
of
anticipated
startup
d
2
0
0
0
0
0
Actual
Startup
Notification
d
2
0
0
0
0
0
Notification
of
applicability
of
the
standard
­

existing
sources
d
200
0
00
Notification
of
applicability
of
the
standard­
new
sources
d
2
0
0
0
0
0
Notification
of
initial
performance
test
d,
e,
2
0
0
0
0
0
Report
of
initial
test
d,
e
8
0
0
0
0
0
Startup,
shutdown,
malfunction
(
SSM)
plan
d,
e
4
0
0
0
0
0
Quality
control
plan
for
CMS
d,
e
4
0
0
0
0
0
Semiannual
SSM
reports
g,,
h,
j,
l
4
15
60
3.0
6.0
5900
CMS
Summary
report
for
HAP
g,
j,
k
4
3
12
0.6
1.2
516
Compliance
status
information
report
c,
g,
j
4
1
4
0.2
0.4
172
Report
of
monitoring
exceedances
j,
l
and
periods
of
noncompliance
8
4
32
1.6
3.2
2358
Report
of
no
excess
emissions
j,
l
2
56
112
2.8
11.2
4625
Waiver
application
c,
j
8
1
8
0.4
0.8
344
TOTAL
BURDEN
AND
COST
(
SALARY)
232
8.8
23.2
$
14131
TABLE
2.
ESTIMATED
ANNUAL
BURDEN
AND
COST
TO
INDUSTRY
TO
IMPLEMENT
REPORTING
AND
RECORDKEEPING
Burden
Item
(
A)

Person­
Hours
Per
Occurrence
(
B)
Number
of
Occurrences
Per
Year
(
C)
Personhours
Per
Respondent
Per
Year
(
C=
AxB)
(
D)
Respondents
Per
Year
(
E)
Technica
l
Person­

Hours
Per­
Year
(
E=
CxD)
(
F)
Management
Person
Hours
Per
Year
(
F=
Ex0.05)
(
G)
Clerical
Person­

Hours
Per
Year
(
G=
Ex0.1)
(
H)
Cost
($)

1.
Applications
N/
A
2.
Surveys
and
studies
N/
A
3.
Reporting
Requirements
(
Initial
Performance
Tests
­
all,
d,
e)
)

A.
Read
instructions
1
1
1
0
0
0
0
0
B..
Required
activities
Basic
liquid
resins
(
BLR)
1050
1
1050
0
0
0
0
0
Repeat
of
initial
performance
test­­

process
vents
1050
1
1050
0
0
0
0
0
Initial
performance
test­­
wastewater
270
1
270
0
0
0
0
0
Repeat
of
initial
performance
test­­

wastewater
270
1
270
0
0
0
0
0
Wet
strength
resins(
WSR)
k
270
1
270
0
0
0
0
0
C.
Create
information
included
in
3B,
4D,
4E
included
in
3B
and
4E
D.
Gather
existing
information
included
in
3B,
4D,
4E
included
in
3B
and
4E
E.
Write
report
Notification
of
constr./
reconstr./
startup
d,
e
2
1
2
1
2
0.1
0.2
126
Notification
of
phys./
oper.
changes
f
2
1
2
1
2
0.1
0.2
126
Notification
of
anticipated
startup
d,
e
2
1
2
0
0
0
0
0
Actual
start­
up
notification
d,
e
2
1
2
0
0
0
0
0
Notification
of
applicability
of
the
Standard­­
existing
sources
e
2
1
2
0
0
0
0
0
Notification
of
applicability
of
the
standard­­
new
sources
d,
e
2
1
2
0
0
0
0
0
Notification
of
initial
performance
test
d,
e
2
1
2
0
0
0
0
0
Report
of
initial
test
(
including
CMS
performance
evaluation
and
results)
6
1
6
0
0
0
0
0
Submit
quality
control
plan
for
continuous
monitoring
systems
d,
e,
l
2
1
2
0
0
0
0
0
Submit
startup,
shutdown,
malfunction
plan
(
SSM)
d,
e
2
1
2
1
2
0.1
.2
126
Compliance
status
information
report
b,
c,
d,
e
4
1
4
0
0
0
0
0
Report
of
monitoring
exceedances
and
periods
of
noncompliance
g
16
4
64
1
64
3.2
6.4
4020
Report
of
no
excess
emissions
g
8
4
32
13
416
21
42
26167
Report
of
area
source
becoming
major
h
6
1
6
0
0
0.0
0.0
0
Waiver
application
e,
i
6
1
6
1
6
0.3
0.6
376
4.
Recordkeeping
Requirements
A.
Read
instructions
included
in
3A
B.
Plan
Activities
N/
A
C.
Implement
activities
included
in
4D,
4E
D.
Develop
record
system
d,
e
40
1
40
0
0
0
0
0
E.
Time
to
enter
information
­­
Records
of
startup,
shutdown,

malfunction
etc.
2
1
2
1
2
0.1
0.2
126
­­
Records
of
control
device
monitoring
parameters:

 
Continuously
monitored
parameters
j
12
52
624
3
1872
93.6
187
117612
­­
LDAR
program
recordkeeping
&

reporting­­
BLR
b
311
1
311
3
933
46.7
93.3
58624
­­
LDAR
program
recordkeeping
&

reporting
­­
WSR
c,
d,
k
11
1
11
10
110
5.5
11
6910
­­
Wastewater
parameters
b,
k,
o
2
12
24
3
72
3.6
7.2
4523
F.
Other
recordkeeping
activities
Maintain
records
of
occurrence
and
duration
of
each
SSM
of
process
and
control
equipment
b,
c,
m
2
8
16
13
208
10.4
20.8
13067
Maintain
records
of
all
maintenance
performed
on
air
pollution
control
equipment
b,
c
2
4
8
13
104
5.2
10.4
6533
Maintain
records
of
all
actions
taken
during
periods
of
SSM
that
differ
from
the
sources'
SSM
plan
b,
c,
n
2
1
1
13
13
0.65
1.3
871
Maintain
records
of
each
period
during
which
a
CMS
is
malfunctioning
or
inoperative
b,
k
2
1
2
3
6
0.3
0.6
376
Maintain
records
of
results
of
all
performance
tests
and
performance
evaluations
b,
c,
k
2
1
2
13
26
1.3
2.6
1632
Maintain
all
initial
notification
and
compliance
status
notifications
b,
c
1
1
1
13
13
0.65
1.3
871
Submit
semiannual
SSM
reports
b,
c,
d
2
2
4
13
52
2.5
5.2
3258
Submit
immediate
reports
of
inconsistent
procedures
monitored
at
each
affected
source
b,
c
2
1
2
13
26
1.3
2.6
1632
Submit
a
CMS
summary
report
for
HAP
monitored
at
each
affected
source
b,
k
2
1
2
3
6
0.3
0.6
376
G.
Time
to
train
personnel
N/
A
H.
Time
for
audits
N/
A
TOTAL
BURDEN
AND
COST
(
SALARY)
NATIONWIDE
3935
196.9
393
247250
Costs
assume
a
rate
for
industry
of
$
55.34/
hour
for
technical,
$
78.54/
hour
for
management
and
$
35.64/
hour
for
clerical
labor.
For
Government,
costs
assume
a
rate
of
$
36.86/
hour
for
technical,
$
68.19
for
management,
and
$
27.36
for
clerical.

b
Assumes
there
are
3
BLR
(
basic
liquid
resins)
manufacturing
facilities.

c
Assumes
there
are
10
WSR
(
wet
strength
resins)
facilities
that
are
major
sources.

d
Because
growth
rate
for
industry
is
so
low,
assumes
no
new
facilities
on
an
annual
basis.

e
One
time
only
costs
f
Assumes
physical/
operational
change
at
one
facility
g
It
is
assumed
that
one
facility
will
have
excess
emissions
h
No
area
sources
are
expected
to
become
major
sources
i
Assumes
10%
of
subject
facilities
will
request
a
waiver
j
These
parameters
will
be
automatically
recorded
with
a
data
logger
k
For
WSR
facilities,
as
an
alternative
to
implementing
the
standards
for
process
vents,
storage
tanks,
and
wastewater,
facilities
may
elect
to
comply
with
the
requirements
of
40
CFR
63,
Subpart
H
(
a
leak
detection
and
repair
program)
for
equipment
leaks).
Because
it
is
more
cost­
effective
than
the
emission
limit,
it
is
assumed
that
all
WSR
facilities
will
choose
to
comply
with
the
alternative
standard.
These
facilities
will
not
have
continuous
monitoring
systems
(
CMS).

l
One
test
each
for
wastewater
and
process
vents
m
Assumes
8
startup,
shutdown,
and/
or
malfunction
(
SSM)
events
per
facility
n
Assumes
1
deviation
from
SSM
plan
per
year
per
facility
o
Assumes
2
hours
to
record
parameters,
monthly
monitoring
