SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Vinyl
Chloride
(
40
CFR
part
61,
subpart
F)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Vinyl
Chloride
(
40
CFR
part
61,
subpart
F)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Vinyl
Chloride
(
VC)
were
proposed
on
December
24,
1975,
promulgated
on
October,
21,
1976,
and
amended
on
June
7,
1977,
September
30,
1986,
September
23,
1988
and
December
23,
1992.
These
standards
apply
to
exhaust
gases
and
oxychlorination
vents
at
ethylene
dichloride
(
EDC)
plants;
exhaust
gases
at
vinyl
chloride
monomer
(
VCM)
plants;
and
exhaust
gases,
reactor
opening
losses,
manual
vent
valves,
and
stripping
residuals
at
polyvinyl
chloride
(
PVC)
plants.
The
standards
also
apply
to
relief
valves
and
fugitive
emission
sources
at
all
three
types
of
plants.
In
the
Administrator's
judgement,
vinyl
chloride
emissions
from
polyvinyl
chloride
(
PVC),
ethylene
dichloride
(
EDC),
and
vinyl
chloride
monomer
(
VCM)
plants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
result
in
an
increase
in
mortality,
serious
irreversible
illness,
and
incapacitating
reversible
illness.
Vinyl
chloride
is
a
known
human
carcinogen
which
causes
cancer
of
the
liver.

In
general,
all
the
NESHAP
standards
implement
Section
112(
b)
of
the
Clean
Air
Act,
as
amended,
and
are
based
on
the
Administrator's
determination
that
vinyl
chloride
emissions
from
polyvinyl
chloride
(
PVC),
ethylene
dichloride
(
EDC),
and
vinyl
chloride
monomer
(
VCM)
plants
cause
or
contribute
to
air
pollution.
The
standards
require
continuous
monitoring
of
the
reactor
pressure
and
temperature.
The
continuous
monitoring
system
monitors
VC
emissions
from
the
stack
to
judge
compliance
with
the
numerical
limits
in
the
standards.
The
parameters
are
used
to
judge
the
operation
of
the
reactor
so
that
the
source
and
EPA
will
be
aware
of
improper
operation
and
maintenance.

All
the
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports
by
the
owners/
operators
of
the
affected
facilities.
They
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
affected
facilities
subject
to
NESHAP.
Adequate
recordkeeping
and
reporting
ensure
that
affected
facilities
will
continue
to
operate
control
equipment
and
use
proper
work
practices
to
achieve
compliance.
In
addition,
reporting
assists
EPA
in
identifying
new
facilities
subject
to
the
standards.
The
standards
implicitly
require
initial
reports
required
by
the
General
Provisions
of
40
2
CFR
61.7
and
61.9.
These
initial
reports
include
application
for
approval
of
construction
or
modification,
the
notification
of
startup,
and
the
notification
of
performance
testing.
The
standards
also
require
quarterly
reporting
of
vinyl
chloride
emissions
from
stripping,
reactor
openings,
and
exhausts.
Reports
must
be
submitted
within
10
days
of
each
valve
discharge
and
manual
vent
valve
discharge.
All
reports
are
sent
to
the
delegated
State
authority.
In
the
event
that
there
is
no
such
delegated
State
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.
Facilities
must
also
maintain
records
of
reactor
parameters
and
emissions
as
well
as
records
related
to
malfunctions,
calibrations,
and
leaks
detected.

Any
owner/
operator
subject
to
the
provisions
of
this
part
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
three
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

Approximately
28
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
there
will
be
no
new
growth
in
the
industry
over
the
next
three
years.
The
average
annual
cost
to
industry
over
the
next
three
years
of
this
Information
Collection
Request
(
ICR)
is
estimated
to
be
$
754,515.

The
Office
of
Management
and
Budget
(
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/
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
3
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
vinyl
chloride
plants
which
produce:
1)
ethylene
dichloride
by
reaction
of
oxygen
and
hydrogen
chloride
with
ethylene;
2)
vinyl
chloride
by
any
process;
and/
or
3)
one
or
more
polymers
containing
any
fraction
of
polymerized
vinyl
chloride
­
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
61,
subpart
F.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
vinyl
chloride
from
plants
which
produce:
1)
ethylene
dichloride
by
reaction
of
oxygen
and
hydrogen
chloride
with
ethylene;
2)
vinyl
chloride
by
any
process;
and/
or
3)
one
or
more
polymer
containing
any
fraction
of
polymerized
vinyl
chloride
­
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
vinyl
chloride
from
these
plants
are
the
result
of
the
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
reduction
of
vinyl
chloride
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
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
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
61,
subpart
F.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
4
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
its
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
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
the
preparer
of
the
active
ICR,
and
accessed
the
most
recent
data
(
August
18,
2004)
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
Inorganic
Chemical
Industry,"
the
United
States
Census
Bureau,
and
other
websites
covering
vinyl
chloride
plants.
We
also
consulted
with
the
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer
and
Program
Integration
Division,
and
Kimberly
Bennett,
Formosa
Plastics
Corporation
(
302)
836­
2225.

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

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

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
ethylene
dichloride,
vinyl
chloride,
and
polyvinyl
chloride
manufacturing
plants.
The
United
States
Standard
Industrial
Classification
(
SIC)
code
for
the
respondents
affected
by
the
standards
is
SIC
2821
which
corresponds
to
The
North
American
Industry
Classification
System
(
NAICS)
code
325211
for
Vinyl
Chloride.

4(
b)
Information
Requested
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
section
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
for
Vinyl
Chloride
(
40
CFR
part
61,
subpart
F).

A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Notification
and
application
of
construction
or
modification.
61.07
Notification
of
anticipated
date
of
initial
startup.
61.09(
a)(
1)
6
Notification
of
actual
startup.
61.09(
a)(
2)

Notification
of
physical
or
operational
change
which
may
increase
the
emission
rate.
61.15
Notification
of
performance
tests.
61.13(
f)

Notification
of
emissions
testing.
61.13(
c)

Application
for
waiver
of
testing.
61.13(
i)(
1),
and
61.13(
i)(
2)

Application
for
equivalent
equipment
and
procedures.
61.66
Initial
report.
61.69
Quarterly
report.
61.70(
a)(
1)

Manual
vent
valve
(
MVV)
discharge
report.
61.64(
a)(
3)

Relief
valve
discharge
(
RVD)
report.
61.65(
a)

A
source
must
keep
the
following
records:

Recordkeeping
Startup,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative.
61.14(
f)

Emission
test
results
and
other
data
needed
to
determine
emissions.
61.13(
g)
and
61.71(
a)(
3)

Records
of
leak
detected.
61.71(
a)(
1),
and
61.71(
a)(
2)

Performance
test
records,
leaks
detected,
emissions
records,
and
daily
operating
records
are
required
to
be
retained
on­
site
for
three
years.
61.67(
f)
and
61.71(
a)

Electronic
Reporting
Currently,
sources
are
using
monitoring
equipment
that
provides
automated
parameter
data,
e.
g.,
leaks
and
spills
of
ethylene
dichloride,
vinyl
chloride,
and
polyvinyl
chloride.
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
7
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.

Perform
initial
performance
test,
Reference
Method
106,
107,
and/
or
601
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.

Use
of
automated
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.
8
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
tests
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
the
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.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
respondents
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
for
Vinyl
Chloride
(
40
CFR
part
61,
subpart
F).

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
each
subpart
included
in
this
ICR.
The
9
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
a
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
Control
Number.
6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
11,825
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
$
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%
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
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
costs
incurred
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
10
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startup
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)

Continuous
Emission
Monitor
(
CEM)
$
150,000
0
$
0
$
45,000
28
$
1,260,000
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
$
1,260,000.
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
cost,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
to
the
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
1,260,000.
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.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
112,082.
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
for
Vinyl
Chloride
(
40
CFR
part
61,
subpart
F).
11
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
twenty­
eight
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+
CD

1
0
28
0
0
28
2
0
28
0
0
28
3
0
28
0
0
28
Average
0
28
0
0
28
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
28.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

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

Total
Annual
Responses
(
A)
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
Quarterly
report
28
4
N/
A
112
Manual
vent
valve/
relief
valve
discharge
(
MVV/
RVD)
report
28
3
N/
A
84
12
Total
Annual
Responses
Total
196
The
number
of
Total
Annual
Responses
is
196.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entities
are
$
1,260,000.
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.

The
average
annual
Agency
burden
and
cost
over
the
next
three
years
are
estimated
to
be
2,834
labor
hours
at
a
cost
of
$
112,082.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NESHAP
for
Vinyl
Chloride
(
40
CFR
part
61,
subpart
F),
which
is
attached.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
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
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
hours
are
11,825,
and
labor
costs
are
$
754,515.
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
Vinyl
Chloride
(
40
CFR
part
61,
subpart
F),
which
is
attached.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
60
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
1,260,000.
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
the
next
three
years
are
estimated
to
be
2,834
labor
hours
at
a
cost
of
$
112,082.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NESHAP
for
Vinyl
Chloride
(
40
CFR
part
61,
subpart
F)
is
attached.

6(
f)
Reasons
for
Change
in
Burden
13
The
adjusted
decrease
in
the
burden
from
the
most
recently
approved
ICR
is
due
to
a
decrease
in
the
number
of
existing
sources.
There
are
forty­
four
sources
in
the
active
ICR
compared
to
twenty­
eight
sources
in
this
ICR,
reflected
in
the
change
in
the
hourly
burden.

The
reason
for
the
decline
of
existing
sources
is
that
it
would
be
economically
unfeasible
to
bring
plants
that
are
more
than
twenty­
five
years
old
into
compliance
with
the
Occupational
Safety
and
Health
Act
(
OSHA)
exposure
standards,
thus
creating
the
steady
decline
in
the
number
of
established
facilities
through
closures.
Due
to
the
low
economic
growth
pattern
in
this
industry
over
the
past
five
years,
it
has
been
extremely
risky
to
construct
new
facilities
and
to
operate
old
inefficient
facilities,
even
though
capacity
has
increased
at
existing
facilities.
No
new
facilities
are
expected
to
be
constructed
over
the
three­
year
period
of
this
ICR.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
60
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
Control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2004­
0011,
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
Ave.,
NW,
Washington,
DC.
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
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
14
2004­
0011
and
OMBC
number
2060­
0071
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
15
Table
1:
Annual
Respondent
Burden
and
Cost
­
NESHAP
for
Vinyl
Chloride
(
40
CFR
part
61,
subpart
F)(
Renewal)

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
a
(
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
b
1.
Applications
N/
A
2.
Survey
and
Studies
N/
A
3.
Reporting
requirements
A.
Read
Instructions
1
1
1
0
0
0
0
$
0
B.
Required
Activities
Initial
performance
tests
60c
1
60
0
0
0
0
$
0
Repeat
performance
tests
d
60
0.20
12
0
0
0
0
$
0
C.
Create
Information
Included
in
3B
D.
Gather
Existing
information
Included
in
3B
E.
Write
report
Notification
of
construction/
reconstruction
2
1
2
0
0
0
0
$
0
Notification
of
anticipated
startup
2
1
2
0
0
0
0
$
0
Notification
of
actual
startup
2
1
2
0
0
0
0
$
0
Notification
of
emissions
testing
2
1
2
0
0
0
0
$
0
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
a
(
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
b
Emissions
of
test
report
2
1
2
0
0
0
0
$
0
Notification
of
physical
or
e
operational
change
2
1
2
0
0
0
0
$
0
Application
for
waiver
of
f
testing
8
1
8
0
0
0
0
$
0
Application
of
equivalency
g
40
1
40
0
0
0
0
$
0
Initial
report
24
1
24
0
0
0
0
$
0
Quarterly
report
h
50
4
200
28
5,600
280
560
$
410,900.00
MVV/
RVD
report
i
8
3i
24
28
672
33.6
67.2
$
49,308.00
4.
Recordkeeping
Requirements
A.
Read
instructions
Included
in3A
B.
Plan
activities
Included
in3B
C.
Implement
activities
Included
in3B
D.
Develop
record
system
N/
A
E.
Time
to
enter
information
Records
of
reactor
parameters
and
emission
0.25
365j
91.25
28
2,555
127.75
255.5
$
187,473.13
Records
of
leaks
detected
1
52k
52
28
1,456
72.8
145.6
$
106,834.00
F.
Time
to
train
personnel
N/
A
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
a
(
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
b
G.
Time
for
audits
N/
A
Subtotal
Labor
Burden
10,283
514.15
1,028.3
$
754,515.13
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
11,825
$
754,515
Assumptions:

a
We
have
assumed
that
there
are
approximately
twenty­
eight
sources
that
are
subject
to
the
standard.
We
have
further
assumed
that
there
will
be
no
new
growth
in
the
industry
over
the
next
three
years.

b
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."
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.

c
We
have
assumed
that
it
will
take
sixty
hours
to
complete
the
performance
tests.

d
We
have
assumed
that
20
percent
of
initial
performance
tests
must
be
repeated
due
to
failure.

e
Assumed
that
there
will
be
no
physical
or
operational
changes
over
the
next
three
years.

f
Assume
it
will
take
eight
hours
to
prepare
application
for
waiver
of
testing.

g
Assume
it
will
take
forty
hours
to
prepare
application
for
equivalency.

h
We
have
assumed
that
it
will
take
fifty
hours
to
prepare
the
quarterly
report.

i
We
have
estimated
that
there
will
be
three
discharges
of
manual
vent
valve/
relief
valve
discharge
(
MVV/
RVD)
per
year.

j
Assume
that
affected
facilities
will
operate
365
days
per
year
as
required
of
all
facilities
that
are
subject
to
the
rule.

k
It
is
estimated
that
it
will
occur
fifty­
two
times
per
year
to
enter
records
of
leak
detection.
18
Table
2:
Average
Annual
EPA
Burden
­
NESHAP
for
Vinyl
Chloride
(
40
CFR
part
61,
subpart
F)(
Renewal)

Burden
item
(
A)
Technical
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)
Plants
Per
Year
a
(
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
Cost,

Per
Yearb
Activity
1.
Initial
performance
tests
c
24
1
24
0
0
0
0
$
0
2.
Repeat
performance
test
d
24
0.20
4.8
0
0
0
0
$
0
3.
Report
review
Notification
of
construction/
reconstruction
1
1
1
0
0
0
0
$
0
Notification
of
anticipated
startup
0.5
1
0.5
0
0
0
0
$
0
Notification
of
actual
startup
0.5
1
0.5
0
0
0
0
$
0
Notification
of
emissions
testing
0.5
1
0.5
0
0
0
0
$
0
Notification
of
physical
or
e
operational
change
0.5
1
0.5
0
0
0
0
$
0
Emissions
test
report
f
24
1
24
0
0
0
0
$
0
Application
for
waiver
of
g
testing
24
1
24
0
0
0
0
$
0
Application
for
equivalency
24
1
24
0
0
0
0
$
0
Initial
report
24
1
24
0
0
0
0
$
0
19
Burden
item
(
A)
Technical
Person
Hours
Per
Occurrenc
e
(
B)
Number
of
Occurrence
s
Per
Year
(
C)
Technical
Person
Hours
Per
Plant
Per
Year
(
C=
AxB)
(
D)
Plants
Per
Year
a
(
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
Cost,

Per
Yearb
Quarterly
report
h
4
4
16
28
448
22.4
44.8
$
20,378.62
MVV/
RVD
report
i
24
3i
72
28
2,016
100.8
201.6
$
91,703.81
Subtotal
2,464
123.2
246.4
$
112,082.43
TOTAL
LABOR
BURDEN
and
COST
(
rounded)
2,834
$
112,082
Assumptions:

a
We
have
assumed
that
are
approximately
twenty­
eight
sources
that
are
subject
to
the
standard.
We
have
further
assumed
that
there
will
be
no
new
growth
in
the
industry
over
the
next
three
years.

b
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.

c
We
have
assumed
that
it
will
take
twenty­
four
hours
to
complete
the
performance
tests.

d
We
have
assumed
that
20
percent
of
initial
performance
test
must
be
repeated
due
to
failure.

e
Assume
that
there
will
be
no
physical
or
operational
changes
over
the
next
three
years.

f
It
is
assume
that
it
will
take
twenty­
fours
hours
to
review
an
emissions
test
report.

g
Assume
that
it
will
take
twenty­
four
hours
to
review
application
for
waiver
of
test.

h
We
have
assume
that
it
will
take
fours
hours
to
review
the
quarterly
report.

i
We
have
assumed
that
there
will
be
three
discharges
of
manual
vent
valve/
relief
valve
discharge
(
MVV/
RVD)
per
year.
