1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
National
Emission
Standards
for
Hazardous
Air
Pollutant
Emissions
for
Polyether
Polyol
Production
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Polyether
Polyols
Production.
This
is
a
continuing
information
collection
request
(
ICR),
and
the
U.
S.

Environmental
Protection
Agency
(
EPA)
tracking
number
for
this
ICR
is
1811.03
and
OMB
is
2060­
0415.

1(
b)
Short
Characterization/
Abstract
The
National
Emissions
Standards
for
Hazardous
Air
Pollutants
for
Polyether
Polyols
Production,
(
40
CFR
Part
63)
was
proposed
on
June
l,
1999.
and
published
January
30,
2002.

These
regulations
apply
to
new
and
existing
facilities
that
engage
in
the
manufacture
of
polyether
polyols
(
which
also
include
polyether
mono­
ols)
and
emit
hazardous
air
pollutants
(
HAP).

Owners
or
operators
of
polyether
polyols
production
facilities
to
which
this
regulation
is
applicable
must
choose
one
of
the
compliance
options
described
in
the
rule
or
install
and
monitor
a
specific
control
system
that
reduces
HAP
emissions
to
the
compliance
level.
The
respondents
are
also
subject
to
sections
of
Subpart
A
relating
to
NESHAP.

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
start­
up,
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.
2
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.
There
are
approximately
79
facilities
that
are
subject
to
the
regulation
and
according
to
the
industry
trade
association,
three
new
facilities
are
expected
to
be
constructed
in
the
next
3
years,
with
existing
plants
not
adding
additional
polyether
polyol
processing
units
which
may
be
considered
a
major
modification
or
reconstruction.
The
predominant
HAP's
used
in
polyether
polyols
production
include
ethylene
oxide,
propylene
oxide,
toluene,
and
hexane.

The
information
will
be
used
by
Agency
enforcement
personnel
to
(
1)
identify
new,
modified,

reconstructed,
and
existing
sources
subject
to
the
standards;
and
(
2)
ensure
that
MACT
is
being
properly
applied
and
that
compliance
is
being
maintained
and
documented.

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
judgement,
the
pollutants
emitted
from
polyester
polyols
production
facilities
cause
or
contribute
significantly
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health.
Therefore,
this
source
category
was
listed
for
regulation
under
section
112,
40
CFR
Part
63,

Subpart
PPP.

TERMS
OF
CLEARANCE:
This
information
collection
request
number
1811.03
OMB
3
number
2060­
0415
is
a
renewal
and
the
annual
report
and
recordkeeping
burden
hours
and
cost
burden
hours
are
reflected
on
the
OMB
form
83­
1­­
blocks
13
and
14
respectively.
These
costs
reflect
projected
facility
growth
of
one
new
facility
per
year
over
the
next
three
years.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAPs
from
polyester,
polyol
production
facilities
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.

Emissions
of
HAPs
from
polyester,
polyol
production
facilities
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
reduce
of
HAPs
emissions
using
control
technology
and
leak
detection
and
repair
procedures.
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
and/
or
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
semiannual
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
NESHAP
continue
to
operate
the
control
equipment
and
achieve
compliance
with
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
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
63
Subpart
PPP.

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
4
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
January
30,
2002.
No
comments
were
received
..

3(
c)
Consultations
We
contacted
the
Society
of
the
Plastic
Industry
(
SPI)
and
the
American
Plastic
Industry
(
API)
regarding
the
number
of
facilities
that
are
or
are
projected
to
be
subject
to
this
rule
and
the
responses
were
inclusive.
For
the
purpose
of
this
Information
Collection
Request,
number
1811.03,

entitled:
NESHAP
for
Polyester
Polyols
Production,
40
CFR
Part
63,
Subpart
PPP,
we
anticipate
facility
growth
rate
at
one
facility
over
the
next
three
years.
No
comments
were
received
from
the
Federal
Register
on
January
30,
2002.

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
1320.6.

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
l,
Part
2,
subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
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
5
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
polyester,
polyols
production
facilities..
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
U.
S.

Standard
Industrial
Classification)
2834
and
2829
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
325613
and
325199
respectively
for
polyester,
polyols
production
facilities.

Regulation
SIC
Codes
NAICS
Codes
National
Emission
Standards
for
Hazardous
Air
Pollutant
Emissions
for
Polyester
Polyol
Production
(
40
CER
63,
Subpart
PPP
2834,2869
325613,325199
(
b)
Information
Requested
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
five
year
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.

(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
National
Emission
Standards
for
Hazardous
Air
Pollutant
Emissions
for
Polyester
Polyols
Production,
40
CFR
Part
63,

Subpart
PPP.

A
source
must
make
the
following
reports:
6
Reports
for
National
Emission
Standards
for
Hazardous
Air
Pollutant
Emissions
for
Polyether
Polyols
Production
Construction/
reconstruction
60.7(
a)(
1),
63.5
Construction
or
modification
application
61.07
Initial
notifications
63.9(
b)

Anticipated
start­
up
60.7(
a)(
2),
61.09(
a)(
1)

Actual
start­
up
60.7(
x)(
3),
61.09(
x)(
2
)

Initial
performance
test
results
60.8
(
a),
61.13(
f),
63.10(
d)(
2)

Initial
performance
test
60.8(
d),
61.13(
c),
63.7(
b),
63.9(
e)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Demonstration
of
continuous
monitoring
system
60.7(
x)(
5),
63.9(
g)

Compliance
status
63.9(
h)

Physical
or
operational
change
60.7(
x)(
4),
61.15,

Opacity
or
visible
emissions
63.10(
d)(
3)

Periodic
start­
up,
shutdown,
malfunction
reports
63.10(
d)(
5)(
I)

Source
status
report
61.10(
x),
63.1439(
e)(
5)
A
source
must
maintain
the
following
records:

Recordkeeping
for
40
CFR,
Part
63.1439,
Subpart
PPP
Start­
ups,
shutdowns,
malfunctions,
periods
where
the
(
60.7(
b),
63.10(
b)(

Emission
test
results
and
other
data
needed
to
determine
emissions
61.13(
g)

All
reports
and
notifications
Record
of
applicability
63.10(
b)(
3)

Records
for
sources
with
continuous
monitoring
systems
63.10(
3)

Records
are
required
to
be
retained
for
5
Years.
63.1439(
a)
7
(
ii.)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
for
opacity,
or
for
pressure
drop
and
liquid
supply
pressure
for
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
otherwise
disclose
the
information.

5.
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
AIRS
(
Aerometric
Information
Retrieval
system)

Facility
subsystem
(
AFS)
database
8
5(
b)
Collection
Methodology
and
Management
Following
notification
of
start­
up,
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
standards.
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.

5(
c)
Small
Entity
Flexibility
Six
of
the
83
affected
facilities
in
this
source
category
are
small
businesses.
The
Agency
does
not
expect
that
any
polyester
polyols
production
facilities,
including
the
small
businesses,,

would
experience
adverse
impacts
related
to
the
cost
of
the
required
reporting
and
recordkeeping.

5(
d)
Collection
Schedule
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
Subpart
PPP
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.

6(
a)
Estimating
Respondent
Burden
9
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
88,860
(
Total
Labor
Hours
from
Table
2).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,

the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
Technical
Labor
Rate
of
$
55.34
per
hour,
$
78.54
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
55.34
per
hour
for
Technical
labor,
and
$
35.64
per
hour
for
Clerical
labor.
These
rate(
s)]
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rate(
s)
have
been
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
Capital
costs
for
information
collection
at
polyester
polyols
production
facilities
are
only
associated
with
purchasing
equipment
an
supplies,
and
equipment
installation
and
maintenance
for
process
vent
monitoring.
Equipment
costs
are
annualized
over
5
years
at
10
percent
interest.

The
capital
costs,
assumed
to
be
a
one­
time
cost
for
the
life
of
the
equipment,
were
estimated
to
be
$
9,385
per
source.
The
total
costs
for
the
first
year
80
plants
are
$
750,800.

The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
labor
costs.
The
capital/
startup
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
10
The
total
capital/
startup
costs
for
this
ICR
are
$
513,051.
These
costs
are
shown
in
block
14(
a),
Total
annualized
capital/
startup
costs,
on
the
OMB
83­
I
form.
It
should
be
noted
that
the
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
Information
Collection
Request
(
ICR)
is
zero.
This
cost
is
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
is
estimated
to
be
$
513,051
.
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.
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.
The
average
annual
Agency
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
16,201.
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs.
The
number
of
total
respondents
is
82.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table.
This
represents
the
number
of
existing
sources
plus
the
number
of
new
sources
averaged
over
the
three­
year
period.
It
is
shown
in
block
13
(
a),
Number
of
respondents,
on
the
OMB
83­
I
form.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
11
The
number
of
Total
Annual
Responses
is
158.
It
is
shown
in
block
13
(
b),
Total
annual
responses,
on
the
OMB
83­
I
form.
The
total
annual
hours
requested
88,680.
Only
the
burden
hours
are
reflected
in
block
13(
c).
Details
upon
which
this
estimate
is
based
appear
in
Table
2.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
513,051.
This
number
is
shown
on
the
OMB
83­
1
form
in
block
14
(
c),
Total
annualized
cost
requested.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
(
i)
Respondent
Tally
­
The
number
of
respondent
tally
is
82.
This
number
reflects
the
number
of
existing
sources
(
79)
plus
one
new
source
over
the
next
three
years.

(
ii)
The
Agency
Tally­
As
shown
in
Table
B
,
the
only
costs
(
16,670)
to
the
Agency
are
those
annual
costs
to
implement
reporting
and
recordkeeping
requirements
associated
with
analysis
of
the
reporting
information.

(
iii)
Variations
in
the
Annual
Bottom
Line
­
The
difference
in
the
adjustment
as
noted
on
OMB
83­
1
form
13(
e)
is
due
to
a
projected
facility
growth
of
one
facility
per
year
over
the
next
three
years.

The
bottom
line
burden
hours
and
cost
tables
for
both
the
Respondents
and
the
Agency
are
attached
.
(
Table
2A
estimated
burden
and
labor
costs
for
respondents
and
Table
2B
estimate
of
annual
burden
and
costs
respectively).

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
increase
in
the
number
of
projected
new
sources
over
the
next
three
years.

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
12
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
the
Ms.
Susan
Auby,
Collection
Strategies
Division
(
Mail
Code
2822T),
Office
of
Environmental
Information,
United
States
Environmental
Protection
Agency,
1200
Pennsylvania
Avenue,
NW,
Washington,
D.
C.
20460­

0001;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.

Include
the
EPA
ICR
number
and
OMB
Control
Number
in
any
correspondence.

ATTACHMENT
1
Source
Data
and
Information
Requirements
13
PART
B
OF
THE
SUPPORTING
STATEMENT
This
section
is
not
applicable
because
statistical
methods
are
not
used
in
the
data
collection
associated
with
this
regulation.

SUMMARY
OF
RECORDKEEPING
REQUIREMENTS
'
Requirements
Regulation
reference
Record
keeping
Requirements
63.10
40
CFR
63
Subpart
A
Notification
of
Compliance
Status
63.9(
h),
40
CFR
63
Subpart
A
Process
changes
63.115(
e),
40
CFR
Subpart
G
Maximum
condenser
outlet
as
temperature
63.1429(
a)

Flare
pilot
flame
presence
63.1140
CFR
63
Subpart
A
63.1255(
b)

Wastewater
management
unit
parameters
to
be
monitored
63.1434
LDAR
records
63.1434
Maximum
exceedances
63.1438
SUMMARY
OF
REPORTING
REQUIREMENTS
Requirement
Relation
Reference
Reporting
results
of
performance
tests
63.10
d
2
40
CFR
63
Subpart
A
Periodic
startup,
shutdown,
and
malfunction
reports
63.10(
d)(
5)
40
CFR
63
Subpart
A
Quarterly
excess
emissions
reports
63.10(
e)(
3)
40
CFR
63
Subpart
A
Process,
vents
reporting
requirements
63.1430
Storage
vessel
reporting
requirements
63.1432
Wastewater
reporting
requirements
63.1433
LDAR
reporting
requirements
63.1434
General
reporting
requirements
63.1439
14
ATTACHMENT
2
Description
of
Respondent
Activities
(
1)
Read
Rule
and
Instructions
are
the
activities,
less
training,
which
involve
comprehending
the
provisions
in
the
standard
and
understanding
how
they
apply
to
the
respective
points
at
a
facility.

(
2)
Plan
Activities
represents
such
burdens
as
design,
redesign,
scheduling
as
well
as
drafting
the
implementation
plan,
and
selecting
methods
of
compliance.

(
3)
Training
represents
the
portion
(
assumed
40%­)
of
activities
from
(
1)
Read
Rule
and
Instruction
which
an
average
facility
would
elect
to
provide
classroom
instructions
for.
The
standard
does
not
require
specific
training
itself.

(
4)
Create,
Test,
and
Research
and
Development
are
the
activities
involving
testing,
retesting,

establishing
operating
range
parameters
and
analyzing
pint
by
point
applicability.
Monitor
related
refit,
calibration,
and
maintenance
activities
are
also
included
under
this
heading.

(
5)
Gather
Information,
Monitor,
and
Inspect
are
the
activities
involving
physical
inspections
of
equipment,
collection
of
monitored
dates
and
other
related
activities.
This
estimate
does
not
include
the
monitoring
of
equipment
leak
components.
The
cost
for
monitoring
equipment
leak
components
is
included
as
part
of
the
cost
of
the
leak
detection
and
repair
program.

(
6)
Process/
Compile
and
Review
are
the
activities
that
involve
analysis
of
the
information
collected
for
accuracy,
compliance,
and
appropriate
reports
and
records
required
as
a
result.

(
7)
Complete
Reports
represents
the
activities
normally
associated
with
filling
out
forms.
Since
the
standard
requires
no
standard
forms,
these
activities
relate
to
the
preparing
of
formal
reports
and
cover
letters
as
appropriate.

(
8)
Record/
Disclose
are
activities
that
are
solely
record
keeping
that
occur
once
the
appropriate
report
information
has
been
extracted.
These
activities
involve
software
translation,
duplication,

or
archival
processes
normally
associated
with
data
management
and
storage
common
to
this
industry.

(
9)
Store/
File
are
again
activities
that
are
solely
record
keeping
that
occur
once
the
appropriate
report
information
has
been
extracted.
The
activities
involve
the
management
life
cycle
of
15
records,
from
the
time
they
are
filed
and
boxed
up
to
the
time
they
are
disposed
of.

TOTAL
BURDEN
AND
COST
is
the
sum
of
each
of
the
columns
(
e),
(
f),
(
g),
and
(
h).
