SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Pesticide
Active
Ingredient
Production
(
40
CFR
part
63,
subpart
MMM)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Pesticide
Active
Ingredient
Production
(
40
CFR
part
63,
subpart
MMM)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
Pesticide
Active
Ingredient
Production
were
promulgated
on
June
23,
1999
(
64
FR
33550).
This
standard
applies
to
all
owners
and
operators
of
new
and
existing
facilities
engaged
in
the
production
of
pesticide
active
ingredients
that
emit
hazardous
air
pollutants
(
HAPs).

Owners
or
operators
of
a
pesticide
active
ingredient
(
PAI)
production
facility
to
which
this
regulation
applies,
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
subject
to
sections
of
subpart
A
of
40
CFR
part
63
relating
to
NESHAP.
These
requirements
include:
those
associated
with
the
applicability
determination;
the
notification
that
the
facility
is
subject
to
the
rule;
the
notification
of
testing
(
control
device
performance
test
and
continuous
monitoring
system
(
CMS)
performance
evaluation);
the
results
of
performance
testing
and
CMS
performance
evaluations;
startup,
shutdown,
and
malfunction
report;
semiannual
or
quarterly
summary
reports
and/
or
excess
emissions
and
CMS
performance
reports.
In
addition
to
the
requirements
of
subpart
A,
many
respondents
are
required
to
submit
precompliance
plan
and
leak
detention
and
repair
(
LDAR)
reports;
and
plants
that
wish
to
implement
emissions
averaging
provisions
must
submit
an
emission
averaging
plan.

Respondents
electing
to
comply
with
the
emission
limit
or
emission
reduction
requirements
for
process
vents,
storage
tanks,
or
wastewater
must
record
the
values
of
equipment
operating
parameters
as
specified
in
section
63.1367
of
the
rule.
Owners
or
operators
are
required
to
install,
operate,
and
maintain
a
continuous
monitoring
system.

If
the
owner
or
operator
identifies
any
deviation
resulting
from
a
known
cause
for
which
no
federally
approved
or
promulgated
exemption
from
an
emission
limitation
or
standard
applies,
the
compliance
report
will
also
include
all
records
that
the
source
is
required
to
maintain
that
pertain
to
the
periods
during
which
such
deviation
occurred,
as
well
as
the
following:
the
magnitude
of
each
deviation;
the
reason
for
each
deviation;
a
description
of
the
corrective
action
taken
for
each
deviation,
including
action
taken
to
minimize
each
deviation
and
action
taken
to
prevent
recurrence;
and
a
copy
of
all
quality
assurance
activities
performed
on
any
element
of
the
2
monitoring
protocol.

Owners
or
operators
of
PAI
production
facilities
subject
to
the
rule
must
maintain
a
copy
of
all
monitored
equipment
operating
parameter
values
that
demonstrate
compliance
with
the
standards.
Those
records
must
be
maintained
for
a
minimum
of
five
years.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.
The
information
is
used
to
determine
whether
or
not
all
sources
subject
to
the
NESHAP
are
achieving
the
standards.

Approximately
88
sources
are
currently
subject
to
the
regulation,
and
it
is
estimated
that
an
additional
two
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years
and
that
one
existing
source
will
be
reconstructed.
The
cost
of
this
Information
Collection
Request
(
ICR)
will
be
$
1,542,049.

In
the
development
of
this
ICR,
we
addressed
the
Office
of
Management
and
Budget
(
OMB)
"
Terms
of
Clearance"
(
TOC)
on
the
active
ICR
which
states:

This
collection
is
approved
for
three
years.
Prior
to
next
submitting
the
collection
to
OMB
for
revision
of
extension,
EPA
should
review
the
burden
estimates
to
ensure
that
they
are
accurate.

EPA
has
addressed
the
item
of
concern
in
the
TOC
as
instructed
by
OMB
in
the
previous
ICR,
and
has
reviewed
the
burden
estimates
for
accuracy.

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.
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
3
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,
HAP
emissions
from
PAI
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
MMM.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
HAPs
from
pesticide
active
ingredient
production
facilities
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAPs
from
pesticide
active
ingredient
production
facilities
are
the
result
of
operation
of
the
affected
facilities.
The
subject
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
ensure
that
the
pollution
control
devices
are
properly
installed
and
operated,
that
leaks
are
being
detected
and
repaired,
and
that
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
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
MMM.

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
4
or
local
agency.
If
a
state
or
local
agency
has
adopted
its
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
a
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
(
69
FR
29718)
on
May
25,
2004.
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,
and
accessed
the
most
recent
data
available
on
the
Air
Facility
System
(
AFS)
database
as
maintained
by
the
Office
of
Compliance.
We
reviewed
information
available
from
the
Office
of
Compliance
Sector
Notebook
"
Profile
of
the
Agricultural
Chemical,
Pesticide,
and
Fertilizer
Industry,"
the
United
States
Census
Bureau,
and
other
websites
covering
pesticide
active
ingredient
production.
We
consulted
with
the
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer,
the
Program
Integration
Division,
and
Mr.
John
Habazin,
Neville
Chemical
Company,
(
412)
331­
4200.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected,
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
1320.5.

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
5
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
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
part
2,
subpart
B
­
Confidentiality
of
Business
Information.
(
See
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
pesticide
active
ingredient
production
facilities.
The
United
States
Standard
Industrial
Classification
(
SIC)
codes
for
the
respondents
affected
by
the
standards,
which
corresponds
to
The
North
American
Industry
Classification
System
(
NAICS)
codes,
are
listed
below
for
source
category
description.

Standard
(
40
CFR
Part
63,
Subpart
MMM)
SIC
Codes
NAICS
Codes
Petrochemical
Manufacturing
2869
325110
All
Other
Basic
Inorganic
Chemical
Manufacturing
2869
325188
Cyclic
Crude
and
Intermediate
Manufacturing
2869
325192
Ethyl
Alcohol
Manufacturing
2869
325193
All
Other
Basic
Organic
Chemical
Manufacturing
2869
325199
Industrial
Gas
Manufacturing
2869
325120
All
Other
Miscellaneous
Chemical
Production
and
Preparation
Manufacturing
2869
325998
Pesticide
and
Other
Agricultural
Chemical
Manufacturing
2879
325320
4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
6
established
by
OMB
at
5
CFR
1320.5.

(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
National
Emission
Standards
for
Hazardous
Air
Pollutants
­
Pesticide
Active
Ingredient
Production
(
40
CFR
part
63,
subpart
MMM).

A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Notification
and
application
of
construction
and
reconstruction
63.5(
d)
and
63.1368(
c)

Initial
notification
63.9
and
63.1368(
b)

Notification
of
CMS
performance
evaluation
63.8(
e)(
2)
and
63.1368(
d)

Notification
of
performance
test
and
test
plan
63.7(
c)
and
63.1368(
m)

Request
for
extension
of
compliance
63.1364(
a)(
2)
and
63.1368(
n)

Precompliance
report
63.1368(
e)

Request
for
approval
to
use
alternative
monitoring
parameters
63.8(
f),
63.1366(
b)(
4),
and
63.1368(
e)(
1)

Notification
of
compliance
status
report
63.9(
h)
and
63.1368(
f)

Periodic
reports
of
excess
emissions
and
noncompliance
63.10(
e)(
3)
and
63.1368(
g)

Notification
of
process
change
63.1368(
h)

Reports
Startup,
shutdown,
and
malfunction
reports
63.10(
d)(
5)
and
63.1368(
i)

Equipment
leaks
reports
63.1363(
h)
and
63.1368(
j)

Emissions
averaging
reports
63.1368(
k)

Heat
exchange
system
reports
63.1368(
l)

A
source
must
keep
the
following
records:
7
Recordkeeping
Control
device
operating
parameters
to
monitor
and
record
63.1366(
b)(
1),
63.1367(
b)(
1),
and
63.1367(
b)(
5)

Monitoring
and
records
for
process
vent
annual
emission
limits
standard
63.10(
c),
63.1366(
b)(
5),
63.1367(
a)(
4),
and
63.1367(
b)(
3)

Monitoring
and
records
for
process
vent
annual
emission
limits
standard
63.1366(
c)
and
63.1367(
b)(
4)

Monitor
and
record
for
equipment
leaks
63.1366(
d)
and
63.1367(
c)

Monitoring
and
records
for
heat
exchanger
systems
63.1362(
f),
63.1366(
e),
and
63.1367(
e)

Monitoring
and
records
for
pollution
prevention
63.1366(
f)
and
63.1367(
b)(
2)

Monitoring
and
records
for
emissions
averaging
63.1366(
g)
and
63.1367(
d)

Records
of
process
operating
parameters
63.1367(
b)(
6)
and
63.1367(
b)(
7)

Applicability
determinations
63.10(
b)(
3)
and
63.1367(
a)(
2)

Startup,
shutdown,
and
malfunction
plan
63.6(
e)(
3)
and
63.1367(
a)(
3)

Application
for
approval
of
construction
or
reconstruction
63.5(
d)
and
63.1367(
a)(
5)

Records
for
vapor
collection
systems
and
closed­
vent
systems
63.1367(
f)

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
automated
parameter
data,
e.
g.,
reduction
requirements
for
process
vents,
storage
tanks
or
wastewater.
Although
personnel
at
the
affected
facility
must
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
20
percent
of
the
respondents
use
electronic
reporting.
8
(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS.

Perform
initial
performance
test,
Reference
Methods
18,
25A,
301
and
1818
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
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.
9
Agency
Activities
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
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
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
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
­
Pesticide
Active
Ingredient
Production
(
40
10
CFR
part
63,
subpart
MMM).

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
24,164
(
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
$
95.32
($
45.39
+
110%)
Technical
$
64.60
($
30.76
+
110%)
Clerical
$
40.09
($
19.09
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December,
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
percent
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
types
of
industry
cost
associated
with
the
information
collection
activities
in
the
subject
standards
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.
11
(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
All
existing
sources
are
in
compliance
and,
therefore,
no
capital
cost
has
been
attributed
to
them.
However,
there
will
still
be
O&
M
costs
associated
with
CMS.

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)

Performance
tests
$
52,2001
3
$
156,600
$
1,325
88
$
116,600
Wastewater
CMS
$
10,690
3
$
32,070
CMS
cost
for
process
vents
$
15,920
3
$
47,760
Total
$
236,430
$
116,600
1
Owners
and
operators
are
required
to
run
two
tests
to
complete
the
process
vent
performance
test
for
each
facility.
Each
run
will
cost
$
26,100
for
a
total
of
$
52,200
per
test.

The
total
capital/
startup
costs
for
this
ICR
are
$
236,000
(
rounded).
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
costs
for
this
ICR
are
$
117,000
(
rounded).
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
$
353,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.
12
The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
50,637.
This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
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
­
Pesticide
Active
Ingredient
Production
(
40
CFR
part
63,
subpart
MMM).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
88
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
an
additional
two
new
sources
and
one
reconstructed
source
per
year
will
become
subject
to
the
standard
in
the
next
three
years.
Furthermore,
the
industry
is
experiencing
a
2
percent
annual
growth
rate
(
i.
e.,
new
respondents).

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
ExistingRespondents
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
3
84
0
1
86
2
3
86
0
1
88
3
3
88
0
1
90
Average
3
86
0
1
88
1
New
respondents
include
sources
that
have
reconstructed.

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
88.
This
number
13
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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

Total
Annual
Responses
(
A)
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
construction/
reconstruction
3
1
N/
A
3
Notification
of
process
changes
9
1
N/
A
9
Notification
of
anticipated
startup
3
1
N/
A
3
Notification
of
actual
startup
3
1
N/
A
3
Notification
of
initial
performance
test
3
1
N/
A
3
Notification
of
initial
CMS
performance
evaluation
3
1
N/
A
3
Quarterly
reporting
9
4
N/
A
36
Semiannual
reporting
79
2
N/
A
158
Leak
detention
and
repair
(
LDAR)
report
88
2
N/
A
176
Emissions
averaging
plan
8
1
N/
A
8
Total
402
The
number
of
Total
Annual
Responses
is
402.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
1,542,049.
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
­
Pesticide
Active
Ingredient
Production
(
40
CFR
part
63,
subpart
MMM).

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entities
are
$
353,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
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
14
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.

(
i)
Respondent
Tally
The
Total
Hours
Requested
are
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
1,542,049.
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
­
Pesticide
Active
Ingredient
Production
(
40
CFR
part
63,
subpart
MMM)
attached.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
60
(
rounded)
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
353,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
are
estimated
to
be
1,265
labor
hours
at
a
cost
of
$
50,637.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NESHAP
­
Pesticide
Active
Ingredient
Production
(
40
CFR
Part
63,
Subpart
MMM)
attached.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
hours
from
the
most
recently
approved
ICR
is
due
to
an
adjustment.
Change
in
the
burden
for
the
existing
facilities
is
due
primarily
to
an
assumption
that
they
are
in
compliance
with
the
initial
requirements
of
the
rule
since
the
previous
ICR
covers
the
first
three
years
prior
to
the
compliance
date
of
the
rule.
To
achieve
compliance
the
respondents
incurred
initial
expenses
they
no
longer
have.

In
addition,
this
assumption
resulted
in
a
significant
reduction
in
capital/
startup
cost
since
CMS
monitors
are
assumed
to
be
purchased
during
the
period
of
the
active
ICR
which
is
a
one
time
cost.
The
Operation
and
Maintenance
(
O&
M)
Costs
increased
slightly
due
to
an
increase
in
the
number
of
sources.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
60
(
rounded)
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;
15
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
2004­
0007,
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
Officer
for
EPA.
Please
include
EPA
Docket
ID
Number
OECA­
2004­
0007
and
OMB
Control
Number
2060­
0370
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
16
Table
1:
Annual
Respondent
Burden
and
Cost
­
NESHAP
for
Pesticide
Active
Ingredient
Production
(
40
CFR
part
63,

subpart
MMM)

Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
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
2
1
2
2b
4
0.2
0.4
$
293.50
B.
Required
Activities
Performance
evaluation
test
(
certification
of
CMS)
13
6
78
2c
156
7.8
15.6
$
11,446.50
C.
Create
information
Included
in
3E
D.
Gather
existing
information
Included
in
3E
E.
Write
Report
Notification
of
construction/
reconstruction
2
1
2
3b,
d
6
0.3
0.6
$
440.25
Notification
of
process
changes
8
1
8
9
e
72
3.6
7.2
$
5,283.00
Notification
of
anticipated
startup
2
1
2
3b,
d
6
0.3
0.6
$
440.25
Notification
of
actual
startup
2
1
2
3b,
d
6
0.3
0.6
$
440.25
17
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
Notification
of
applicability
of
the
standard
­
Existing
source
­
New
source
2
2
1
1
2
2
0f
3b,
d
0
6
0
0.3
0
0.6
$
0
$
440.25
Precompliance
plan
40
1
40
2g
80
4
8
$
5,870.00
Notification
of
initial
performance
test
2
1
2
3
h
6
0.3
0.6
$
440.25
Notification
of
initial
CMS
performance
evaluation
2
1
2
3b,
d
6
0.3
0.6
$
440.25
Notification
of
compliance
status
­
With
performance
test
­
Without
performance
test
80
120
1
1
80
120
3i
0j
240
0
12
0
24
0
$
17,610.00
$
0
F.
Write
periodic
report
­
Quarterly
reporting
­
Semiannual
reporting
­
LDAR
reporting
­
Emissions
averaging
plan
24
8
94
40
4
2
2
1
96
16
188
40
9k
79l
88m
9n
864
1,264
16,544
360
43.2
63.2
827.2
18
86.4
126.4
1,654.4
36
$
63,396.00
$
92,746.00
$
1,213,916.00
$
26,415.00
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in
3A
B.
Plan
activities
N/
A
C.
Implement
activities
N/
A
D.
Develop
record
system
40
1
40
2o
80
4
8
$
5,870.00
18
Burden
item
(
A)

Personhours
per
occurrence
(
B)

No.
of
occurrences
per
respondent
per
year
(
C)

Personhours
per
respondent
per
year
(
C=
AxB)
(
D)
Respondents
per
year
(
E)
Technical
personhours
per
year
(
E=
CxD)
(
F)
Managemen
t
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
Per
Year
a
E.
Develop
startup,
shutdown,

and
malfunction
plans
100
1
100
2p
200
10
20
$
14,675.00
F.
Develop
QA/
QC
plan
for
CMS
40
1
40
2q
80
4
8
$
5,870.00
G.
Time
to
enter
information
­
Records
of
startup,

shutdown,
and
malfunction
Records
of
CMS
data
­
Record
continuously
monitored
parameters
­
Enter/
verify
information
for
semiannual
reports
1.5
1
16
52
320
2
78
320
32
2r
2s
2t
156
640
64
7.8
32
3.2
15.6
64
6.4
$
11,446.50
$
46,960.00
$
4,696.00
F.
Calibration
of
CMS
48
1
48
2u
96
4.8
9.6
$
7,044.00
G.
Time
to
train
personnel
40
1
40
2
80
4
8
$
5,870.00
H.
Time
for
audits
N/
A
Subtotal
Labor
Burden
21,016
1,050.8
2,097.61
$
1,542,049.00
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
24,164
$
1,542,049
Assumptions:

a
This
ICR
uses
the
following
labor
rates:
$
95.32
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.60
per
hour
for
Technical
labor,
and
$
40.09
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December,
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."

b
Assume
that
there
will
be
2
percent
growth
per
year,
which
will
equate
to
two
new
facilities
that
will
be
built
per
year
over
the
three
year
period
of
this
ICR.

c
Assume
that
all
new
sources
are
required
to
report
the
performance
evaluation
test
(
continuous
monitoring
system
certification).
19
d
Assume
that
one
existing
facility
will
be
reconstructed
each
year.

e
Assume
that
10
percent
of
existing
facilities
will
implement
process
changes.

f
Assume
that
rule
only
applies
to
new
sources
and
reconstructed
facilities.

g
Assume
50
percent
of
new
or
reconstructed
facilities
will
submit
a
precompliance
report
with
their
notification
of
construction/
reconstruction.

h
Assume
that
90
percent
of
new
and
reconstructed
facilities
will
conduct
a
performance
test.

i
Assume
that
90
percent
of
facilities
will
conduct
a
performance
test.
The
notification
of
compliance
status
includes
the
report
of
the
performance
test
and
the
CMS
performance
evaluation.

j
Assume
that
10
percent
of
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations
and
report
of
CMS
performance
evaluation.

k
Assume
10
percent
of
facilities
will
have
exceedances
and
periods
of
noncompliance.

l
Assume
90
percent
of
facilities
will
have
no
exceedances.

m
Assume
that
it
will
take
ninety­
four
hours
to
write
a
leak
detention
and
repair
(
LDAR)
report.

n
Assume
that
10
percent
of
existing
facilities
will
comply
with
emissions
averaging
requirements.
New
sources
are
not
allowed
to
use
emissions
averaging.

o
Assume
it
will
take
forty
hours
to
develop
a
record
system
for
recording
parameter
monitoring
information.

p
Assume
one
person
would
require
80
hours
to
draft
the
startup,
shutdown,
and
malfunction
plan
and
another
twenty
hours
to
review/
revisions
for
a
total
of
100
hours.

r
Assume
it
will
take
1.5
hours
to
record
startup,
shutdown,
and
malfunction
information.

s
Assume
it
will
take
one
hour
to
record
continuously
monitored
parameters.

t
Assume
it
will
take
sixteen
hours
to
enter/
verify
information
for
semiannual
report.

u
Assume
that
it
will
take
48
hours
for
the
calibration
of
the
continuous
monitoring
system
(
CMS)
to
be
completed.
20
21
Table
2:
Average
Annual
EPA
Burden
­
NESHAP
for
Pesticide
Active
Ingredient
Production
(
40
CFR
part
63,
subpart
MMM)

Burden
Item
(
A)
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Plant
Per
Year
(
C)
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
40
1
40
2b
80
4
8
$
3,639.04
Repeat
performance
test
40
1
40
0c
0
0
0
$
0
Performance
evaluation
test
(
certification
of
CMS)
2
1
2
1
d
2
0.1
0.2
$
90.98
Report
Review
Notification
of
applicability
2
2
4
2b
8
0.4
0.8
$
363.90
Notification
of
construction
and
reconstruction
2
1
2
3b,
e
6
0.3
0.6
$
272.93
Notification
of
anticipated
startup
2
1
2
3b,
e
6
0.3
0.6
$
272.93
Notification
of
actual
startup
2
1
2
3b,
e
6
0.3
0.6
$
272.93
Notification
of
process
changes
8
1
8
9
f
72
3.6
7.2
$
3,275.14
Review
of
precompliance
report
4
1
4
1
g
4
0.2
0.4
$
181.95
Notification
of
performance
test
2
1
2
3b,
e
6
0.3
0.6
$
272.93
Notification
of
CMS
performance
evaluation
2
1
2
3b,
e
6
0.3
0.6
$
272.93
22
Burden
Item
(
A)
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Plant
Per
Year
(
C)
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
Review
of
notification
of
compliance
status
­
With
performance
test
­
Without
performance
test
40
40
1
0
40
0
3b,
e,
h
0i
120
0
6
0
12
0
$
5,458.56
$
0
Review
of
emission
averaging
plan
20
1
20
9f
180
9
18
$
8,187.84
Review
of
semiannual
2
2
4
79j
316
15.8
31.6
$
14,374.21
Review
of
quarterly
reports
8
4
32
9f
288
14.4
28.8
$
13,100.54
Review
of
NESHAP
waiver
application
N/
A
Subtotal
1,100
55
110
$
50,036.81
Travel
Expenses
(
1
person
x
2
plant/
yr
x
2
day/
plant
x
$
50
per
diem)
+
($
400/
round
trip
x
1
round
trip/
yr)
=

$
600.00
TOTAL
LABOR
BURDEN
and
COST
(
rounded)
1,265
$
50,637
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:
$
54.66
for
Managerial
(
GS­
13,
Step
5,
$
34.16
x
1.6),
$
40.56
for
Technical
(
GS­
12,
Step
1,
$
25.35
x
1.6)
and
$
21.95
Clerical
(
GS­
6,
Step
3,
$
13.72
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

b
Assume
that
there
will
be
2
percent
growth
per
year,
which
will
equate
to
two
new
facilities
that
will
be
built
per
year
over
the
three
year
period
of
this
ICR.

c
Assume
that
5
percent
of
new
facilities
will
repeat
performance
test.

d
Assume
EPA
personnel
will
attend
10
percent
of
these
performance
evaluation
tests.

e
Assume
that
one
existing
facility
will
be
reconstructed
each
year.

f
Assume
10
percent
of
existing
facilities
will
require
process
changes
over
the
three
year
period
of
this
ICR.

g
Assume
50
percent
of
new
facilities
will
submit
a
precompliance
report.

h
Assume
90
percent
of
all
new
sources
will
conduct
a
performance
test
that
covers
the
reviewing
of
compliance
status
report.
23
i
Assume
10
percent
of
facilities
will
comply
by
submitting
engineering
calculations,
design
calculations
and
report
of
CMS
performance
evaluation.

j
Assume
90
percent
of
facilities
will
have
no
exceedances.
