SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Epoxy
Resin
and
Non­
Nylon
Polyamide
Production
(
40
CFR
part
63,
subpart
W)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Epoxy
Resin
and
Non­
Nylon
Polyamide
Production
(
40
CFR
part
63,
subpart
W)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP),
for
Epoxy
Resin
and
Non­
Nylon
Polyamide
Production
were
proposed
on
May
16,
1994,
and
promulgated
on
March
8,
1995.
This
standard
applies
to
all
facilities
that
manufacture
polymers
and
resins
from
epichlorohydrin.
These
sources
include
existing
and
new
facilities
producing
basic
liquid
epoxy
resin
(
BLR)
and
epichlorohydrin­
modified
non­
nylon
polyamide
resins,
also
known
as
wet
strength
resins
(
WSR).
The
source
subject
to
this
provision
emits
the
hazardous
air
pollutants
(
HAPs)
epichlorohydrin,
and
in
lesser
amounts,
hydrochloric
acid
and
methanol.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
63,
subpart
W.

Owners
or
operators
of
the
affected
sources
described
must
make
a
one­
time­
only
notification
of
any
physical
or
operational
change
to
an
existing
facility
which
may
increase
the
regulated
pollutant
emission
rate,
notification
of
initial
performance
tests,
including
information
necessary
to
determine
the
conditions
of
the
performance
test,
performance
test
measurements
and
results,
and
notification
of
demonstration
of
the
continuous
monitoring
system
(
CMS).
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.
Quarterly
reports
of
excess
emissions
are
required.
Quarterly
reporting
may
be
reduced
to
semiannually
if
continuous
compliance
is
achieved
for
12
months.
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
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
EPA
Regional
Office.

Approximately
seven
sources
are
currently
subject
to
the
standard,
three
basic
liquid
epoxy
resins
(
BLR)
plants
and
four
wet
strength
resins
(
WSR)
plants.
The
growth
rate
for
this
2
industry
is
estimated
to
be
zero,
so
no
new
sources
are
likely
to
become
subject
to
the
standard
in
the
next
three
years.
A
thorough
review
of
current
information
for
the
industry
verifies
a
decrease
of
sources
as
compared
to
the
active
ICR.
The
cost
of
this
ICR
will
be
$
243,711
per
year.

OMB
approved
the
currently
active
ICR
without
any
"
Terms
of
Clearance."

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
will
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
pollutants
emissions
from
epichlorohydrin,
methanol
and
hydrochloric
acid
from
epoxy
resin
and
non­
nylon
polyamide
resin
production,
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
was
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
W.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
hazardous
air
pollutants
(
HAP)
from
epichlorohydrin,
methanol
and
hydrochloric
acid
from
epoxy
resin
and
non­
nylon
polyamide
resin
production
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAP
from
manufacture
of
basic
liquid
epoxy
resins
(
BLR)
and
wet
strength
resins
(
WSR)
are
the
result
of
operation
of
those
facilities.
The
subject
3
standards
are
achieved
by
the
reduction
of
HAP
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
leaks
are
being
detected
and
repaired
and
the
regulations
are
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
records
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
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
NESHAP
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
W).

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
68
FR
62289
on
November
3,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
referenced
the
most
recent
ICR,
the
preparer
of
the
active
ICR,
and
accessed
the
most
recent
data
available
on
the
Air
Facility
System
(
AFS)
database
4
as
maintained
by
the
Office
of
Compliance.
We
reviewed
information
available
from
the
United
States
Census
Bureau,
and
other
websites
covering
epoxy
resin
and
non­
nylon
polyamide
resin.
We
consulted
with
the
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer,
the
Program
Integration
Division
and
Georgia
Pacific
Corporation
Resin
Division,
Mr.
Randy
Roden,
(
229)
268­
2523.

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
five­
year
record's
retention
requirement
is
consistent
with
Part
70
permit
programs
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.

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
5
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
basic
liquid
epoxy
resins
(
BLR)
and
wet
strength
resins
(
WSR)
facilities.
The
United
States
Standard
Industrial
Classification
(
SIC
)
code
for
the
respondents
affected
by
the
standards
is
2821
which
corresponds
to
the
North
American
Industry
Classification
System
(
NAICS
)
325211
for
Epoxy
Resin
and
Non­
Nylon
Polyamide
Production.
4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Epoxy
Resin
and
Non­
Nylon
Polyamide
Production
(
40
CFR
part
63,
subpart
W).

A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Notification
and
application
of
construction
or
reconstruction
63.05(
d)
and
63.520
Initial
notification
63.09(
b)

Notification
of
actual
startup
63.06
Initial
performance
test
results
63.7(
b),
63.10(
d)(
2),
and
63.09(
e)

Emissions
tests
and
results
63.520,
63.09(
e),
63.09(
g)
and
63.10(
d)(
2).

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

Production
capacity
and
exceedances
63.520,
63.09
(
b)
and
63.09(
h)

No
excess
emissions
63.520,
63.10(
d)
and
63.09(
e)
6
Continuous
monitoring
system
performance
and
summary
report
63.520,
63.10(
e)(
3)
and
63.09(
g)

Compliance
status
63.09(
h)

Physical
or
operational
changes
63.520
and
63.5(
b)(
6)

Waiver
applications
63.520
and
63.07(
h)

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

Values
of
monitored
parameters
when
average
values
are
outside
approved
ranges
63.528(
1)
and
63.10(
e)

Duration
of
periods
when
monitoring
data
is
not
collected
for
each
excursion
caused
by
insufficient
monitoring
data
63.528(
2)
and
63.10(
e)

A
source
must
keep
the
following
records:

Recordkeeping
Startup,
shutdown,
malfunction
and
malfunction
plans,
excursions,
and
periods
where
the
continuous
monitoring
system
is
inoperative
63.527,
63.528,
63.10(
b)(
2)
and
63.06
Emission
test
results,
engineering
assessments,
and
other
data
needed
to
determine
emissions
63.524,
63.526,
63.527
and
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)

Records
are
required
to
be
retained
for
5
years.
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
and
63.10(
e)

Equipment
leaks
­
monitoring,
equipment
modification
and
repair
records
63.526
Electronic
Reporting
7
Presently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
fashion,
e.
g.,
leaks
and
spills
of
liquid
epoxy
resin
and
wet
strength
resins.
Although
personnel
at
the
source
are
still
required
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.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS.

Perform
initial
performance
test,
Reference
Methods
1,
1A,
2,
2A,
2C,
2D,
18
and
25A
test,
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.

Currently,
sources
are
using
automated
monitoring
equipment
that
provides
parameter
data.
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.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
8
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
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
the
AFS
which
is
operated
and
maintained
by
the
EPA's
Office
of
Compliance.
AFS
is
the
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
more
than
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
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
9
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Industry
Burden
for
NESHAP
for
Epoxy
Resin
and
Non­
Nylon
Polyamide
Production
(
40
CFR
part
63,
subpart
W).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
Subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burdens
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
3,853
hours
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

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

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.
10
(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
cost
associated
with
the
information
collection
activities
in
the
subject
standard
are
both
labor
costs
which
are
addressed
elsewhere
in
this
ICR
and
the
costs
associated
with
continuous
monitoring.
The
capital/
startup
costs
are
one
time
cost
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitors
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startu
p
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

Computers,
software
and
monitoring
devices
$
2,500
0
$
0
$
3,000
3
$
9,000
The
total
capital/
startup
costs
for
this
ICR
are
$
0.
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
$
9,000.
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
cost
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(
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.
The
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.
11
The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
11,324.
This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.02
(
GS­
13,
Step
5,
$
33.76
x
1.6)
Technical
$
40.08
(
GS­
12,
Step
1,
$
25.05
x
1.6)
Clerical
$
21.70
(
GS­
6,
Step
3,
$
13.56
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Average
Annual
EPA
Burden
­
NESHAP
for
Epoxy
Resin
and
Non­
Nylon
Polyamide
Production
(
40
CFR
part
63,
subpart
W).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
seven
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

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

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
1
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
That
Keep
Records
but
Do
Not
Submit
Reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
1
7
0
1
7
2
1
7
0
1
7
3
1
7
0
1
7
Average
1
7
0
1
7
1
New
respondents
include
sources
with
constructed,
reconstructed
and
modified
affected
facilities.

.
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
seven.
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:
12
Total
Annual
Responses
(
A)
Information
Collection
Activity
(
B)
Number
of
Respondents
(
C)
Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Notification
of
physical
and
operational
changes
1
1
N/
A
1
Startup,
shutdown,
malfunction
report
1
1
N/
A
1
Report
of
monitoring
exceedances
and
periods
of
noncompliance
1
4
N/
A
4
Report
of
no
excess
emissions
6
2
N/
A
12
Total
18
The
number
of
Total
Annual
Responses
is
18.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.
Note
that
two
respondents
have
been
double
counted
in
the
above
table
because
they
have
both
been
existing
affected
facilities
and
new
affected
facilities.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
243,711.
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
for
Epoxy
Resin
and
Non­
Nylon
Polyamide
Production
(
40
CFR
part
63,
subpart
W).

Note
that
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),
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
is
estimated
to
average
214
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
adjustment
decrease
in
the
hourly
burden
from
the
most
recently
approved
ICR
is
due
in
part
to
a
decrease
in
the
number
of
sources.
There
are
thirteen
sources
in
the
active
ICR
compared
to
seven
sources
in
the
renewal,
thus
reflecting
the
change
in
the
hourly
burden.
Even
13
though
there
is
a
decrease
in
the
number
of
sources
in
the
renewal
ICR,
the
total
burden
and
cost
show
a
slight
increase.
This
increase
in
cost
is
due
to
a
revised
hourly
labor
rate
from
the
United
States
Department
of
Labor.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
214
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
9
and
48
CFR
Chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
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
0140,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
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
and
Information
Center
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.
When
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0140
and
OMB
Control
Number
2060­
0290
in
any
correspondence.

Part
B
of
the
Supporting
Statement
14
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1:
Annual
Respondent
Burden
and
Cost
­
NESHAP
for
Epoxy
Resin
and
Non­
Nylon
Polyamide
Production
(
40
CFR
part
63,
subpart
W)
(
Renwal).

Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
instructions
1
1
1
0b,
c
0
0
0
$
0
B.
Required
activities
Basic
liquid
resins
(
BLR)
1,050
1
1,050
0b,
c
0
0
0
$
0
Repeat
initial
performance
test
­
process
vents
1,050
1
1,050
0b,
c
0
0
0
$
0
Initial
performance
test
­

wastewater
270
1
270
0b,
c
0
0
0
$
0
Repeat
initial
performance
test
­
wastewater
270
1
270
0b,
c
0
0
0
$
0
Wet
strength
resins
(
WSR)
270
1
270
0b,
c,
d
0
0
0
$
0
C.
Create
information
Included
in
3B,
4D,
4E
D.
Gather
existing
information
Included
in
3B,
4D,
4E
E.
Write
Report
16
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
Notification
of
construction/

reconstruction/
startup
2
1
2
0b,
c
0
0
0
$
0
Notification
of
physical
and
operational
changes
2
1
2
1
e
2
0.1
0.2
$
145.50
Notification
of
anticipated
startup
0
0
0
0b,
c
0
0
0
$
0
Notification
of
actual
startup
2
1
2
0b,
c
0
0
0
$
0
Notification
of
applicability
of
the
standard
­
existing
sources
2
1
2
0b,
c
0
0
0
$
0
Notification
of
applicability
of
the
standard
­
new
sources
2
1
2
0b,
c
0
0
0
$
0
Notification
of
initial
performance
test
2
1
2
0b,
c
0
0
0
$
0
Report
of
initial
test
(
including
CMS
performance
evaluation
and
results)
6
1
6
0b,
c
0
0
0
$
0
Submit
quality
control
plan
for
CMS
2
1
2
0b,
c,
f
0
0
0
$
0
Submit
startup,
shutdown,

malfunction
plan
2
1
2
1
2
0.1
0.2
$
145.50
Report
of
monitoring
exceedances
and
periods
of
noncompliance
16
4
64
1g
64
3.2
6.4
$
4,655.97
17
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
Report
of
no
excess
emissions
8
2r
16
6h
96
4.8
9.6
$
6,983.95
Report
of
area
source
becoming
major
6
1
6
0
i
0
0
0
$
0
Waiver
application
6
1
6
1j
6
0.3
0.6
$
436.50
Compliance
status
information
report
4
1
4
0b,
c
0
0
0
$
0
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
3A
B.
Plan
activities
N/
A
C.
Implement
activities
Included
in
4D
and
4E
D.
Develop
record
system
40
1
40
0b,
c
0
0
0
$
0
E.
Time
to
enter
information
a.
Records
of
startup,

shutdown,
malfunction,
etc.
2
1
2
1
2
0.1
0.2
$
145.50
18
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
b.
Records
of
control
device
monitoring
parameters:

­
Continuously
monitored
parameters
­
LDAR
program
reporting
and
recordkeeping
­
BLR
­
LDAR
program
reporting
and
recordkeeping
­
WSR
­
Wastewater
parameters
12
311
11
2
52
1
1
12
624
311
11
24
3k,
l
3k
4m
3k,
n
1,872
933
44
72
93.6
46.65
2.2
3.6
187.2
93.3
4.4
7.2
$
136,187.06
$
67,875.28
$
3,200.98
$
5,237.96
F.
Other
recordkeeping
activities
a.
Maintain
records
of
occurrence
and
duration
of
each
SSM
of
process
and
control
equipment
2
8
16
7h,
o
112
5.6
11.2
$
8,147.94
19
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
b.
Maintain
records
of
all
maintenance
performed
on
air
pollution
control
equipment.

c.
Maintain
records
of
all
actions
taken
during
periods
of
SSM
that
differ
from
the
sources'
SSM
plan.

d.
Maintain
records
of
each
period
during
which
a
CMS
is
malfunctioning
or
inoperative
e.
Maintain
records
of
results
of
all
performance
tests
and
performance
evaluations.

f.
Maintain
all
initial
notification
and
compliance
status
notifications.

g.
Submit
semiannual
SSM
reports.

h.
Submit
immediate
reports
of
inconsistent
procedures
monitored
at
each
affected
source.

i.
Submit
a
CMS
summary
report
for
HAP
monitored
at
each
affected
source.
2
2
2
2
1
2
2
2
4
1
1
1
1
2
1
1
8
2
2
2
1
4
2
2
7h
7h,
p
3k
7h
7h
7h,
q
7h
3k
56
14
6
14
7
28
14
6
2.8
0.7
0.3
0.7
0.35
1.4
0.7
0.3
5.6
1.4
0.6
1.4
0.7
2.8
1.4
0.6
$
4,073.97
$
1,018.49
$
436.50
$
1,018.49
$
509.24
$
2,036.99
$
1,018.49
$
436.50
G.
Time
to
train
personnel
N/
A
H.
Time
for
audits
N/
A
Subtotal
Labor
Burden
3,350
167.5
335
$
243,710.81
20
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)
Technical
Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Management
person­
hours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
3,853
$
243,711
Assumptions:

a
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."

b
Assume
that
there
will
be
no
new
sources
over
the
next
three
years
subject
to
this
rule.

c
Assume
that
this
is
a
one­
time­
only
cost.

d
For
all
wet
strength
resins
(
WSR)
facilities,
as
an
alternative
to
implementing
the
standards
for
process
vents,
storage
tanks,
and
wastewater,
these
facilities
may
elect
to
comply
with
the
requirements
of
40
CFR
part
63,
subpart
H
­
leak
detection
and
repair
program
for
equipment
leaks.
Because
of
it
being
more
cost­
effective,

it
is
assumed
that
all
WSR
facilities
will
choose
to
comply
with
the
alternative
standard.
These
facilities
are
not
required
to
have
the
continuous
monitoring
systems
(
CMS)
installed.

e
Assume
that
one
facility
will
have
a
physical
or
operational
change.

f
It
will
require
one
test
each
for
wastewater
and
process
vents.

g
It
is
assumed
that
one
facility
will
have
excess
emissions.

h
Assume
that
there
are
seven
sources
that
are
subject
to
this
regulation,
so
the
number
of
sources
without
excess
emission
reports
is
six.

i
It
is
assumed
that
no
area
sources
are
expected
to
become
major
sources.

j
Assume
that
one
facility
will
request
a
waiver.

k
Assume
that
there
are
three
basic
liquid
resins
(
BLR)
manufacturing
facilities
l
These
parameters
will
automatically
be
recorded
with
a
data
logger.

m
Assume
that
there
are
four
WSR
facilities
subject
to
the
rule.

n
Assume
it
will
take
two
hours
to
record
wastewater
parameters
during
the
monthly
monitoring.

o
Assume
startup,
shutdown,
and/
or
malfunction
(
SSM)
will
occur
eight
times
per
facility.

p
Assume
it
takes
one
deviation
from
SSM
plan
per
year
per
facility.

q
Assume
it
will
take
two
hours
to
submit
semiannual
(
SSM)
reports.

r
Quarterly
reporting
may
be
reduced
to
semiannual
reporting
for
sources
that
are
in
compliance
for
one
year.
21
Table
2:
Average
Annual
EPA
Burden
­
NESHAP
for
Epoxy
Resin
and
Non­
Nylon
Polyamide
Production
(
40
CFR
part
63,
subpart
W)

Burden
Item
(
A)
Technical
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Plant
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)

Plants
Per
Year
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
a
Costs,

Per
Year
Initial
Performance
Test
60
0
0
0b,
c
0
0
0
$
0
Repeat
initial
performance
test
60
0
0
0b,
c
0
0
0
$
0
1.
Retesting
preparation
16
0
0
0b,
c
0
0
0
$
0
2.
Retesting
60
0
0
0b,
c
0
0
0
$
0
Report
Review
Notification
of
construction
reconstruction
and
startup
2
0
0
0b,
c
0
0
0
$
0
Notification
of
Physical
and
operational
changes
2
1
2
1
d
2
0.1
0.2
$
89.90
Notification
of
actual
startup
2
0
0
0b
0
0
0
$
0
Notification
of
anticipated
startup
0
0
0
0
b
0
0
0
$
0
Notification
of
applicability
of
the
standard­
new
sources
2
0
0
0
b
0
0
0
$
0
Notification
of
initial
performance
test
2
0
0
0
b
0
0
0
$
0
Report
of
initial
test
8
0
0
0b
0
0
0
$
0
Startup,
shutdown,

malfunction
(
SSM)
plan
4
0
0
0
b
0
0
0
$
0
22
Burden
Item
(
A)
Technical
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Plant
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)

Plants
Per
Year
(
E)
Technical
Hours
Per
Year
(
E=
CxD)
(
F)
Management
Hours
Per
Year
(
F=
0.05xE)
(
G)
Clerical
Hours
Per
Year
(
G=
0.1xE)
(
H)
Total
a
Costs,

Per
Year
Quality
control
plan
for
CMS
4
0
0
0b,
c
0
0
0
$
0
Semiannual
SSM
reports
4
2
8
6e,
f
48
2.4
4.8
$
2,243.81
CMS
summary
report
for
HAP
4
3
12
7e
84
4.2
8.4
$
3,775.88
Compliance
status
information
report
4
1
4
7
e
28
1.4
2.8
$
1,258.63
Report
of
monitoring
exceedances
and
periods
of
noncompliance
8
4
32
1g
32
1.6
3.2
$
1,438.43
Report
of
no
excess
emission
2
4
8
6e
48
2.4
4.8
$
2,157.65
Waiver
application
8
1
8
1h
8
0.4
0.8
$
359.61
Subtotal
250
12.5
25
$
11,323.91
Travel
Expenses
(
1
person
x
0
plant/
yr
x
1
day/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
0
round
trips/
yr)
=
$
0
TOTAL
LABOR
BURDEN
and
COST
(
rounded)
288
$
11,324
Assumptions:

a
This
cost
is
based
on
the
following
hourly
labor
rates
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses:
$
54.02
for
Managerial
(
GS­
13,
Step
5,
$
33.76
x
1.6),
$
40.08
for
Technical
(
GS­
12,
Step
1,
$
25.05
x
1.6)
and
$
21.70
Clerical
(
GS­
6,
Step
3,
$
13.56
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.

b
Assume
that
there
will
be
no
new
sources
over
the
next
three
years.

c
Assume
that
this
is
a
one­
time­
only
cost.

d
Assume
that
one
facility
will
conduct
some
form
of
physical
or
operational
change.

e
Assume
that
there
are
six
sources
that
are
subject
to
this
regulation
that
report
semiannually.

f
It
will
take
four
hours
to
review
semiannual
reports.
23
g
It
is
assumed
that
one
facility
will
have
excess
emissions.

h
Assume
that
one
facility
will
request
a
waiver.
