STANDARD
FORM
83­
I
SUPPORTING
STATEMENT
FOR
OMB
REVIEW
OF
ICR
NO.
1983.02
INFORMATION
COLLECTION
REQUEST
FOR
THE
CHANGES
TO
GENERIC
MACT
TO
INCORPORATE
THE
CARBON
BLACK
PRODUCTION
SOURCE
CATEGORY
CYANIDE
CHEMICALS
MANUFACTURING
SOURCE
CATEGORY
ETHYLENE
PRODUCTION
SOURCE
CATEGORY
AND
SPANDEX
PRODUCTION
SOURCE
CATEGORY
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NORTH
CAROLINA
27711
December
8,
2004
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection.

"
Recordkeeping
and
Reporting
Requirements
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards."
This
is
a
new
information
collection
request
(
ICR).

This
is
a
new
information
collection
request
(
ICR)
and
the
tracking
number
is
EPA
ICR
No.
1983.02.

(
b)
Short
Characterization.

This
ICR
is
prepared
for
a
U.
S.
Environmental
Protection
Agency
(
EPA)
proposed
rulemaking
being
developed
under
authority
of
Section
112
of
the
Clean
Air
Act
(
Act).
The
proposed
rulemaking
would
amend
title
40,
chapter
I,
part
63
of
the
Code
of
Federal
Regulations
(
CFR)
by
adding
additional
standards
to
the
existing
subpart
YY
­­
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards
(
this
subpart
is
referred
to
as
the
"
generic
MACT
NESHAP").
The
generic
MACT
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutants
(
HAP).
Respondents
are
owners
or
operators
of
source
category
affected
sources
regulated
under
the
generic
MACT
NESHAP.

This
ICR
is
for
HAP
emission
sources
in
the
carbon
black
(
CB)
production,
cyanide
(
CY)
chemicals
manufacturing,
ethylene
(
ET)
production,
and
spandex
(
SP)
production
source
categories.

For
the
purposes
of
this
ICR
the
phrases
"
cyanide
chemicals
manufacturing,"
"
cyanide
production,"
and
"
CY
production"
have
the
same
meaning.

The
CB
production
source
category
consists
of
20
facilities
that
would
(
and
2
facilities
that
would
not)
be
subject
to
the
major
source
provisions
specified
under
the
generic
MACT
NESHAP.

We
anticipate
that
5
of
these
facilities
will
conduct
all
2
monitoring,
inspection,
recordkeeping,
and
reporting
(
MIRR)

requirements,
including
testing
activities.
The
estimated
MIRR
costs
per
facility
to
conduct
all
MIRR
activities
is
$
47,790.

Fifteen
facilities
will
conduct
all
MIRR
requirements,
except
testing
activities.
The
estimated
MIRR
costs
per
facility
to
conduct
all
MIRR
activities,
except
testing
and
related
tasks,
is
$
45,740.
The
two
facilities
that
are
not
major
sources
will
read
the
rule.
The
estimated
costs
for
this
one
activity
is
$
410
per
facility.
Based
on
these
estimates,
the
total
MIRR
cost
of
the
proposed
rulemaking
for
the
carbon
black
production
source
category
is
estimated
to
be
$
925,830
for
the
first
three
years
after
promulgation
of
the
proposed
standards.
See
Section
6
for
more
details.

The
CY
production
source
category
consists
of
14
facilities
that
would
(
and
2
facilities
that
would
not)
be
subject
to
the
major
source
provisions
specified
under
the
generic
MACT
NESHAP.

We
anticipate
that
only
1
of
these
facilities
will
be
subject
to
all
monitoring,
inspection,
recordkeeping,
reporting
(
MIRR)

requirements,
including
testing
and
control
device
design
analysis
activities,
excluding
those
associated
with
the
development
of
a
new
leak
detection
program.
The
estimated
MIRR
costs
per
facility
to
conduct
these
activities
is
$
58,460.
Eight
facilities
will
be
subject
to
all
monitoring,
inspection,

recordkeeping,
reporting,
and
leak
detection
system
requirements,

excluding
those
associated
with
control
equipment
design
analysis.
The
estimated
MIRR
costs
to
conduct
these
activities
is
$
59,076
per
facility.
Five
facilities
will
be
subject
to
general
reporting
and
recordkeeping
requirements,
excluding
those
associated
with
control
device
design
analysis
and
implementation
of
a
new
leak
detection
system.
The
estimated
MIRR
costs
to
conduct
these
activities
is
$
56,414
per
facility.
The
two
facilities
that
are
not
major
sources
will
read
the
rule
and
3
review
rule
information.
The
estimated
costs
for
these
two
activities
is
$
614
per
facility.
Based
on
these
estimates,
the
total
MIRR
cost
of
the
proposed
rulemaking
for
the
cyanide
chemicals
manufacturing
source
category
is
estimated
to
be
$
814,366
for
the
first
three
years
after
promulgation
of
the
proposed
standards.
See
section
6
for
more
details.

The
ET
production
source
category
consists
of
37
facilities
that
would
be
subject
to
the
major
source
provisions
specified
under
the
generic
MACT
NESHAP.
We
anticipate
that
all
37
of
these
facilities
are
major
sources
and
will
conduct
all
monitoring,
inspection,
recordkeeping,
and
reporting
(
MIRR)

requirements,
including
testing
activities.
The
estimated
MIRR
costs
per
facility
to
conduct
all
MIRR
activities
is
$
72,383.

Based
on
these
estimates,
the
total
MIRR
cost
of
the
proposed
rulemaking
for
this
source
category
is
estimated
to
be
$
2,678,184
for
the
first
three
years
after
promulgation
of
the
proposed
standards.
See
section
6
for
more
details.

The
SP
production
source
category
consists
of
2
facilities
that
would
be
subject
to
the
major
source
provisions
specified
under
the
generic
MACT
NESHAP.
We
anticipate
that
these
2
facilities
will
conduct
all
monitoring,
inspection,

recordkeeping,
and
reporting
(
MIRR)
requirements,
including
testing
activities.
The
estimated
MIRR
costs
per
facility
to
conduct
all
MIRR
activities
is
$
56,050.
This
gives
total
MIRR
costs
of
$
112,110
for
the
spandex
production
source
category
during
the
first
three
years
after
promulgation
of
a
NESHAP
for
this
source
category.
See
section
6
for
more
details.

All
existing
sources
must
be
in
compliance
with
the
requirements
of
the
generic
MACT
NESHAP
within
3
years
of
the
effective
date
(
promulgation
date)
of
standards
for
an
affected
source.
All
new
sources
must
be
in
compliance
with
the
requirements
of
the
generic
MACT
NESHAP
upon
startup
or
the
4
promulgation
date
of
standards
for
an
affected
source,
whichever
is
later.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection.

The
EPA
has
been
directed
by
section
112
of
the
Act
to
regulate
the
emission
of
HAP
from
stationary
sources.
Carbon
black,
cyanide,
ethylene
and
spandex
production
source
categories;
and
any
source
categories
that
may
be
regulated
under
the
generic
MACT
NESHAP
in
the
future
are
major
sources
of
HAP
emissions
included
on
the
EPA's
list
of
categories
scheduled
for
regulation.

Section
114
of
the
Act
gives
the
EPA
authority
to
collect
data
and
information
necessary
to
enforce
standards
established
under
section
112
of
the
Act.
Certain
records
and
reports
are
necessary
to
enable
the
Administrator
to
(
1)
identify
existing
and
new
sources
subject
to
the
generic
MACT
NESHAP
and
(
2)
ensure
that
the
requirements
specified
for
an
affected
source
subject
to
the
generic
MACT
NESHAP,
which
are
based
on
MACT,
are
being
achieved.

(
b)
Use/
Users
of
the
Data.

The
information
will
be
used
by
the
EPA's
enforcement
personnel
to
(
1)
identify
existing
and
new
HAP
emission
points
subject
to
the
generic
MACT
NESHAP,
(
2)
identify
the
emission
control
devices
and
methodologies
being
applied,
and
(
3)
ensure
that
the
emission
control
devices
and
methodologies
are
being
properly
operated
and
maintained
on
a
continuous
basis.

Records
and
reports
are
necessary
to
enable
the
EPA
to
identify
facilities
subject
to
the
generic
MACT
NESHAP
that
may
not
be
in
compliance.
Based
on
reported
information,
the
EPA
can
decide
whether
to
inspect
a
facility
and
which
records
or
processes
to
inspect.
The
records
that
facilities
maintain
would
5
indicate
to
the
EPA
whether
facility
personnel
are
operating
and
maintaining
emission
control
devices
and
methodologies
properly.

3.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
and
NAICS
Codes.

Respondents
are
owners
or
operators
of
HAP­
emitting
affected
sources
in
the
CB
production,
CY
production,
ET
production,
and
SP
production
source
categories;
and
HAP­
emitting
affected
sources
in
source
categories
with
a
limited
population
of
major
sources
that
may
be
regulated
under
the
generic
MACT
standards
in
the
future.
The
source
categories
and
affected
sources
regulated
with
the
initial
proposal
of
the
generic
MACT
NESHAP
are
classified
in
the
four­
digit
Standard
Industrial
Classification
(
SIC)
Codes:
2895
for
CB
productiuon;
2819
and
2869
for
CY
production;
2869
for
ET
production;
and,
2824
for
SP
production.

The
source
category
and
affected
sources
regulated
with
this
proposal
are
also
classified
in
the
six­
digit
North
American
Industrial
Classification
System
(
NAICS)
codes:
325182
for
CB
productiuon;
325188
and
325199
for
CY
production;
325110
for
ET
production;
and,
325222
for
SP
production.
Not
all
processes
and
facilities
classified
under
these
SIC
and
NAICS
codes
would
be
regulated
under
the
generic
MACT
NESHAP.

(
b)
Information
Requested.

(
i)
Data
items,
including
recordkeeping
requirements.
The
generic
MACT
NESHAP
would
require
that
an
owner
or
operator
of
a
major
source
reduce
specified
affected
source
HAP
emissions.
The
affected
source
and
emissions
control
requirements
are
determined
on
a
source
category­
specific
basis.
Attachment
1,
Source
Data
and
Information
Requirement,
summarizes
the
recordkeeping
and
reporting
requirements,
and
specific
rule
provisions
that
require
them,
for
the
CB
production,
CY
production,
ET
production,
and
SP
production
source
categories.
Information
requirements
being
proposed
under
the
generic
MACT
NESHAP
that
would
apply
to
all
6
source
categories
that
would
be
regulated
with
this
proposal
are
discussed
in
the
following
paragraphs.

Respondents
are
required
to
submit
one­
time
reports
of
the
(
1)
start
of
construction
for
new
facilities,
(
2)
anticipated
and
actual
start­
up
dates
for
new
facilities,
and
(
3)
physical
or
operational
changes
to
existing
facilities.
Owners
and
operators
must
also
submit
semi­
annual
reports
of
the
monitoring
results
under
the
leak
detection
and
repair
program
(
if
applicable
for
a
subject
source
category).
All
records
are
to
be
maintained
by
the
facility
for
a
period
of
at
least
5
years.

An
affected
source
with
an
initial
startup
date
before
the
promulgation
date
of
standards
for
an
affected
source
under
the
generic
MACT
NESHAP
must
submit
a
one­
time
initial
notification.

This
initial
notification
must
be
submitted
within
one
year
after
the
promulgation
date
of
standards
for
an
affected
source
under
the
generic
MACT
NESHAP
(
or
within
1
year
after
the
affected
source
becomes
subject
to
the
generic
MACT
NESHAP).

For
sources
constructed
or
reconstructed
after
the
promulgation
date
of
standards
for
an
affected
source
under
the
generic
MACT
NESHAP,
the
source
must
submit
an
application
for
approval
of
construction
or
reconstruction.
The
application
is
required
to
contain
information
on
the
air
pollution
control
that
will
be
used
for
each
potential
HAP
emission
point.

The
information
in
the
initial
notification
and
the
application
for
construction
or
reconstruction
will
enable
enforcement
personnel
to
identify
the
number
of
sources
subject
to,
or
are
already
in
compliance
with,
the
standards.

Affected
sources
subject
to
standards
under
the
generic
MACT
NESHAP
must
submit
a
notification
of
compliance
status.
This
notification
must
be
signed
by
a
responsible
company
official
who
certifies
its
accuracy
and
that
the
affected
source
has
complied
with
the
relevant
standards.
Performance
test
results
(
as
7
applicable)
are
included
as
part
of
the
compliance
status
report.

The
notification
of
compliance
status
must
be
submitted
within
60
days
after
the
compliance
date
specified
for
an
affected
source
subject
to
the
generic
MACT
NESHAP.

In
addition,
affected
sources
subject
to
the
proposed
generic
MACT
NESHAP
that
would
be
required
to
install
continuous
parameter
monitoring
systems
(
CPMS)
are
required
to
conduct
a
performance
evaluation
of
the
CPMS.
A
report
of
the
performance
evaluation
results
is
required
to
be
submitted
to
the
delegated
authority.
Excess
emissions
and
CPMS
performance
reports
documenting
excess
emissions
and
parameter
monitoring
exceedances
are
required
to
be
submitted
to
the
delegated
authority
semiannually
Submittal
of
these
reports
is
required
quarterly
when
the
CPMS
data
are
used
to
demonstrate
compliance
and
the
facility
experiences
excess
emissions.

The
generic
MACT
NESHAP
requires
owners
or
operators
of
affected
sources
to
develop
startup,
shutdown,
and
malfunction
plans,
documenting
procedures
that
will
be
taken
in
the
case
of
any
of
these
events.
Startup,
shutdown,
and
malfunction
reports
demonstrating
the
actions
taken
by
an
owner
or
operator
in
the
event
of
a
startup,
shutdown,
or
malfunction
are
required
to
be
submitted.
Reports
are
required
semi­
annually
when
actions
taken
are
consistent
with
the
plan.
Immediate
reports
are
required
when
actions
taken
are
inconsistent
with
the
plan.

The
generic
MACT
NESHAP
would
require
owners
or
operators
of
an
affected
source
to
retain
records
for
5
years,
which
exceeds
the
three
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.6.
The
5
year
retention
period
is
consistent
with
the
provisions
of
the
General
Provisions
of
40
CFR
Part
63
and
the
retention
requirement
in
the
operating
permit
program
under
Title
V
of
the
Act.

(
ii)
Respondent
Activities.
8
Respondent
activities
for
major
sources
are
shown
for
each
of
the
first
3
years
following
promulgation
of
the
rule.
The
respondent
activities
required
by
the
generic
MACT
NESHAP
for
the
CB
production,
CY
production,
ET
production,
and
SP
production
source
categories
for
existing
sources
are
presented
in
the
first
column
of
Tables
1a,
1b,
and
1c
for
CB
production;
Tables
2a,
2b,

and
2c
for
CY
production;
Tables
3a,
3b,
and
3c
for
ET
production;
and
Tables
4a,
4b,
and
4c
for
SP
production.
There
are
no
new
sources
anticipated
for
any
of
these
source
categories
within
the
first
3
years
after
promulgation
of
standards
for
subject
affected
sources.
These
tables
are
introduced
in
Section
6(
a)
of
this
ICR.

4.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities.

A
list
of
the
EPA's
activities
is
provided
in
Tables
5a
through
5d.
These
tables
are
introduced
in
Section
6(
c)
of
this
ICR.

(
b)
Collection
Methodology
and
Management.

Information
contained
in
the
one­
time
only
reports
will
be
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)

Facility
Subsystem
(
AFS)
that
is
maintained
and
operated
by
the
EPA's
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS).
Data
obtained
during
periodic
visits
by
EPA
personnel
from
records
maintained
by
the
respondents
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
and
enforcement
programs.

(
c)
Small
Entity
Flexibility.

Minimizing
the
information
collection
burden
for
all
sizes
of
organizations
is
a
continuing
effort
on
the
EPA's
part.
The
EPA
has
reduced
the
recordkeeping
and
reporting
requirement
respondent
burden
to
include
only
the
information
needed
by
the
EPA
to
determine
compliance
with
the
generic
MACT
NESHAP.
9
(
d)
Collection
Schedule.

Collection
of
data
will
begin
after
promulgation
of
standards
under
the
generic
MACT
NESHAP.
The
schedule
for
reports
required
by
the
generic
MACT
NESHAP
for
the
CB
production,
CY
production,
ET
production,
and
SP
production
source
categories;
and
source
categories
that
may
be
regulated
under
the
generic
MACT
NESHAP
in
the
future
are
summarized
below.

The
initial
notification
is
due
one
year
after
the
date
of
promulgation
for
existing
sources.
The
notification
of
compliance
status
would
be
submitted
60
days
following
completion
by
the
source
of
the
compliance
demonstration
specified
in
the
regulation.

Major
sources
would
be
required
to
submit
periodic
excess
emissions
and
CPMS
performance
summary
reports
on
a
semi­
annual
basis.
Major
sources
must
submit
startup,
shutdown,
malfunction
reports
semi­
annually
when
actions
taken
in
the
event
of
a
startup,
shutdown,
or
malfunction
are
consistent
with
the
source's
startup,
shutdown,
malfunction
plan.
If
actions
taken
are
not
consistent
with
the
source's
plan,
an
immediate
report
must
be
submitted.

The
equipment
leak
standards
would
require
the
submittal
of
an
initial
report
and
semi­
annual
reports
of
LDAR
experiences
and
any
changes
to
the
processes,
monitoring
frequency
and
initiation
of
a
quality
improvement
program.
The
schedule
for
submission
of
these
reports
is
detailed
below.

For
existing
sources,
the
owner
or
operator
would
be
required
to
submit
the
initial
report
within
90
days
after
the
applicability
date
of
standards
for
an
affected
source
under
the
generic
MACT
NESHAP.
For
new
sources,
the
initial
report
would
be
submitted
with
the
application
for
construction.

Every
6
months
after
the
initial
report,
a
report
would
be
submitted
that
summarizes
the
monitoring
results
from
the
LDAR
10
program
and
provides
a
notification
of
initiation
of
monthly
monitoring,
if
applicable.

5.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication.

A
search
of
the
EPA's
existing
standards
and
ongoing
ICRs
revealed
no
duplication
of
information
gathering
efforts.

However,
certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
under
the
generic
MACT
NESHAP.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
can
be
provided
to
the
Administrator
in
lieu
of
the
report
required
by
the
generic
MACT
NESHAP.

(
b)
Consultations.

Consultations
with
numerous
representatives
of
companies
involved
in
CB
production,
CY
production,
ET
production,
and
SP
production
source
categories
were
conducted
in
the
presumptive
MACT
development
process
and
the
generic
MACT
NESHAP
development
process
which
establishes
MACT
for
each
of
these
source
categories.
Tables
9,
10,
11,
and
12
present
the
names,

affiliation,
and
telephone
numbers
of
persons
that
provided
input
during
the
development
of
the
proposed
generic
MACT
NESHAP
for
the
CB
production,
CY
production,
ET
production,
and
SP
production
source
categories.
For
future
source
categories
that
would
be
regulated
under
the
generic
MACT
NESHAP
the
EPA
would
consult
with
industry
representatives
and
State
agencies
when
developing
the
presumptive
MACT
and
MACT
for
an
applicable
source
category.

A
90­
day
public
comment
period
will
be
provided
after
proposal,
during
which
all
affected
parties
will
be
given
the
opportunity
to
comment
on
the
generic
MACT
NESHAP.
All
received
comments
will
be
considered
and
some
may
be
reflected
in
the
development
of
the
promulgated
generic
MACT
NESHAP.
11
TABLE
9.
CARBON
BLACK
PRODUCTION
CONSULTATIONS
Name
Affiliation
Telephone
number
Penny
Lassiter
U.
S.
Environmental
Protection
Agency
(
919)
541­
5396
John
Schaefer
U.
S.
Environmental
Protection
Agency
(
919)
541­
0296
Bill
Fleming
Cabot
Corporation
(
678)
297­
1534
Todd
Williams
Chevron
Chemical
Company
(
281)
421­
6386
Roy
Holder
Columbian
Chemicals
Company
(
770)
792­
9432
Todd
N.
Miller
Continental
Carbon
Company
(
281)
647­
3858
John
Tarabocchia
Degussa­
Hüls
Corporation
(
334)
443­
3537
Jimmy
Boyd
Engineered
Carbons,
Incorporated
(
806)
273­
1454
Herb
Harless
Sid
Richardson
Carbon
Company
(
817)
338­
8386
James
Orgeron
Louisiana
DEQ
(
225)
765­
0131
Evelina
Morales
Oklahoma
DEQ
(
405)
702­
4194
Fred
Wilson
Texas
NRCC
(
512)
239­
1285
James
Randall
Texas
NRCC
(
512)
239­
1078
Renu
Chakrabarty
West
Virginia
DEP
(
304)
558­
0885
TABLE
10.
CYANIDE
CHEMICALS
MANUFACTURING
CONSULTATIONS
Name
Affiliation
Telephone
number
Penny
Lassiter
U.
S.
Environmental
Protection
Agency
(
919)
541­
5396
Keith
Barnett
U.
S.
Environmental
Protection
Agency
(
919)
541­
5605
Martin
Brittain
U.
S.
Environmental
Protection
Agency
(
214)
665­
7296
Diane
McConkey
U.
S.
Environmental
Protection
Agency
(
202)
564­
5588
Jeff
Gilman
BP
Amaco
(
630)
420­
5205
Name
Affiliation
Telephone
number
12
Ann
Goulet
BP
Amaco
(
419)
226­
1239
Van
A.
Boone
BP
Chemicals
(
361)
552­
8642
Erica
Dromgolle
BP
Chemicals
(
361)
552­
8642
Rasma
Zvaners
Chemical
Manufacturers
Association
(
703)
741­
5249
Anita
Junker
Cytec
(
504)
431­
6556
Orey
Tanner
Cytec
(
504)
431­
6556
Mark
Armentrout
Degussa
Corporation
(
334)
443­
4250
David
Jelly
The
Dow
Chemical
Company
(
713)
246­
0133
Debbie
Mulrooney
Du
Pont
Chemicals
(
302)
774­
8083
Scott
Collins
Du
Pont
Chemicals
(
361)
572­
1538
Ellen
Lane
Du
Pont
Chemicals
(
409)
882­
3290
Walter
Schrimper
Du
Pont
Chemicals
(
901)
353­
7595
Dale
Clark
FMC
(
307)
872­
2195
Richard
Ober
Louisiana
Department
of
Environmental
Quality
(
225)
765­
0113
Bill
Sprott
Memphis
and
Shelby
County
Health
Department
(
901)
544­
7725
Bruce
Raff
Novartis
(
225)
642­
1686
Dave
Fewell
Rhone­
Poulenc
(
304)
767­
6771
Richard
DiMenna
Rohm
&
Haas
Incorporated
(
281)
592­
2339
Edward
G.
Fiesinger
Solutia
Incorporated
(
281)
228­
4486
Jeffery
S.
Gilbert
Sterling
Chemicals
(
409)
945­
4431
Ruben
Herrera
Texas
Natural
Resource
Conservation
Commission
(
512)
239­
5866
TABLE
11.
ETHYLENE
PRODUCTION
CONSULTATIONS
Name
Affiliation
Telephone
number
Penny
Lassiter
U.
S.
Environmental
Protection
Agency
(
919)
541­
5396
Warren
Johnson
U.
S.
Environmental
Protection
Agency
(
919)
541­
5124
Name
Affiliation
Telephone
number
13
Robert
Todd
U.
S.
Environmental
Protection
Agency
(
214)
665­
2156
Martin
Brittain
U.
S.
Environmental
Protection
Agency
(
214)
665­
7296
Diane
McConkey
U.
S.
Environmental
Protection
Agency
(
202)
564­
5588
Trish
Messenger
Chemical
Manufacturers
Association
(
703)
534­
3582
John
Ogle
Dow
(
409)
238­
2819
Stan
Labat
Exxon
(
225)
359­
7226
James
Orgeron
Louisiana
DEQ
(
225)
765­
3595
Donna
Hathaway
Louisiana
DEQ
(
225)
765­
0182
Dana
Poppa­

Vermillion
Texas
NRCC
(
512)
239­
1280
TABLE
12.
SPANDEX
PRODUCTION
CONSULTATIONS
Name
Affiliation
Telephone
Number
14
Lance
Granger
Bayer
Corporation
(
803)
820­
6201
Ron
Shifflett
DuPont
(
540)
949­
2844
Rodney
Gearhart
Globe
Manufacturing
(
508)
674­
3585
Larry
Brown
Alabama
DEM
(
334)
271­
7861
Tom
Garrett
Alabama
DEM
(
334)
271­
7861
Don
Squires
Massachusetts
DEP
(
617)
292­
5618
Mike
Landis
North
Carolina
DEM
(
704)
663­
1699
Kisha
Thompson
South
Carolina
BAQ
(
803)
734­
5117
Michael
Kiss
Virginia
APC
(
540)
574­
7822
Gordon
Kerby
Virginia
APC
(
540)
574­
7822
Gerald
Potamis
US
EPA
Region
1
(
617)
918­
1651
Dianne
Walker
US
EPA
Region
3
(
215)
566­
3297
Lee
Page
US
EPA
Region
4
(
404)
562­
9131
Kathleen
Reeves
Fornay
US
EPA
Region
4
(
404)
562­
9130
Angela
Catalano
US
EPA
Region
7
(
913)
551­
7411
K.
C.
Hustvedt
US
EPA
(
919)
541­
5395
Elaine
Manning
US
EPA
(
919)
541­
5499
(
c)
Effects
of
Less
Frequent
Collection.
15
If
the
relevant
information
were
collected
less
frequently,

the
EPA
would
not
be
reasonably
assured
that
an
affected
source
is
in
compliance
with
the
generic
MACT
NESHAP.
In
addition,
the
EPA's
authority
to
take
administrative
action
would
be
reduced
significantly.

Section
113(
d)
of
the
Act
limits
the
assessment
of
administrative
penalties
to
violations
which
occur
no
more
than
12
months
before
initiation
of
the
administrative
proceeding.

Since
administrative
proceedings
are
less
costly
and
require
use
of
fewer
resources
than
judicial
proceedings,
both
the
EPA
and
the
regulated
community
benefit
from
preservation
of
the
EPA's
administrative
powers.

(
d)
General
Guidelines.

The
generic
MACT
NESHAP
would
require
owners
or
operators
of
an
affected
source
to
retain
records
for
5
years,
which
exceeds
the
3
year
retention
period
contained
in
the
guidelines
in
5
CFR
1320.6.
The
5
year
retention
period
is
consistent
with
the
provisions
of
the
General
Provisions
of
40
CFR
Part
63
and
the
retention
requirement
in
the
operating
permit
program
under
Title
V
of
the
Act.

(
e)
Confidentiality
and
Sensitive
Questions.

i.
Confidentiality.
All
information
submitted
to
the
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
EPA
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
3999,

September
8,
1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,
March
23,
1979.
Even
when
the
EPA
has
determined
that
data
received
in
response
to
an
ICR
is
eligible
for
confidential
treatment
under
40
CFR
Part
2,
Subpart
B,
the
EPA
may
nonetheless
disclose
the
information
if
it
is
"
relevant
in
any
proceeding"

under
the
statute
[
42
U.
S.
C.
§
7414
(
C);
40
CFR
2.301
(
g)].
This
16
information
collection
complies
with
the
Privacy
Act
of
1974
and
Office
of
Management
and
Budget
(
OMB)
Circular
108.

ii.
Sensitive
Questions.
Information
to
be
reported
consists
of
emissions
data
and
other
information
that
are
not
of
a
sensitive
nature.
No
sensitive
personal
or
proprietary
data
are
being
collected.

6.
Estimating
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden.

The
existing
major
source
annual
burden
estimates
for
recordkeeping
and
reporting
are
presented
in
Tables
1a
through
1d
for
CB
production;
Tables
2a
through
2d
for
CY
production;
Tables
3a
through
3d
for
ET
production;
and
Tables
4a
through
4d
for
SP
production.
There
is
no
annual
burden
estimate
for
new
major
sources
based
on
the
assumption
that
there
will
be
very
few
new
sources
subject
to
the
generic
MACT
NESHAP
in
the
first
3
years
after
promulgation
of
standards
for
these
source
categories.

The
estimates
of
total
technical
labor
hours
per
year
per
source
and
the
number
of
activities
per
respondent
per
year
listed
in
each
table
are
based
upon
experience
with
similar
information
collection
requirements
in
other
standard
development
efforts
and
the
number
of
emission
points
in
each
source.

Activities
that
are
one­
time
only
activities
are
noted
in
the
tables.

[
Table
1a]
17
[
End
Table]

[
Table
1b]
18
[
End
Table]

[
Table
1c]
19
[
End
Table]

[
Table
1d]
20
[
End
Table]

[
Table
2a]
21
[
End
Table]

[
Table
2b]
22
[
End
Table]

[
Table
2c]
23
[
End
Table]

[
Table
2d]
24
[
End
Table]

[
Table
3a]
25
[
End
Table]

[
Table
3b]
26
[
End
Table]

[
Table
3c]
27
[
End
Table]

[
Table
3d]
28
[
End
Table]

[
Table
4a]
29
[
End
Table]

[
Table
4b]
30
[
End
Table]

[
Table
4c]
31
[
End
Table]

[
Table
4d]
32
[
End
Table]

(
b)
Estimating
Respondent
Costs.
33
The
information
collection
activities
for
the
first
3
years
for
affected
sources
subject
to
the
generic
MACT
NESHAP
with
this
proposal
are
presented
in
Tables
1a
through
4d.
The
costs
of
these
activities
are
based
on
the
1992
Comprehensive
Assessment
and
Information
Rule
(
CAIR)
economic
analysis
with
estimated
wage
rates
of
$
66.73
per
hour
($
66.73/
hr)
for
management
labor,

$
45.04/
hr
for
technical
labor,
and
$
28.14/
hr
for
administrative
labor.
For
the
purposes
of
this
analysis,
it
is
assumed
that
each
labor
hour
is
composed
of
5
percent
management,
85
percent
technical,
and
10
percent
administrative.
The
EPA
believes
that
these
estimates
reflect
the
maximum
ICR
burden
that
would
occur
as
a
result
of
the
generic
MACT
NESHAP,
considering
source
categories
that
could
be
potentially
regulated
under
the
generic
MACT
NESHAP
in
the
future.

(
c)
Estimating
the
EPA's
Burden
and
Cost.

Because
the
information
collection
requirements
were
developed
as
an
incidental
part
of
the
generic
MACT
NESHAP,
no
costs
can
be
attributed
to
the
development
of
the
information
collection
requirements.

Because
recordkeeping
and
reporting
requirements
on
the
part
of
the
respondents
are
required
under
section
112
of
the
Act,
no
operational
costs
will
be
incurred
by
the
Federal
government.

Publication
and
distribution
of
the
information
are
part
of
the
AFS
operated
and
maintained
by
OAQPS,
with
the
result
that
no
Federal
costs
can
be
directly
attributed
to
the
ICR.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
affected
sources.
Periodic
inspections
are
part
of
the
EPA's
overall
compliance
and
enforcement
program.
Therefore,
these
examinations
are
not
attributable
to
the
ICR.
The
only
costs
that
the
Federal
government
will
incur
are
user
costs
associated
with
the
analysis
of
the
reported
information,
as
presented
in
34
Tables
5a
through
5d
for
source
categories
regulated
under
the
generic
MACT
NESHAP
with
this
proposal.
These
burden
estimates
assume
that
there
will
be
no
new
sources
in
the
first
3
years
following
promulgation
of
standards
for
the
subject
source
categories.
Labor
rates
and
associated
costs
are
based
on
estimated
wage
rates
$
56/
hr
(
GS­
15/
3
level)
for
management,

$
34/
hr
(
GS­
12/
3
level)
for
technical,
and
$
17/
hr
(
GS­
6/
3
level)

for
administrative.
Labor
rates
include
60
percent
for
overhead
expenses.
35
[
Table
5a]

[
End
Table]
36
[
Table
5b]

[
End
Table]
37
[
Table
5c]

[
End
Table]
38
[
Table
5d]

[
End
Table]
39
[
Table
6a]

[
End
Table]
40
[
Table
6b]

[
End
Table]
41
[
Table
6c]

[
End
Table]
42
[
Table
6d]

[
End
Table]
43
[
Table
7a]

[
End
Table]
44
[
Table
7b]

[
End
Table]
45
[
Table
7c]

[
End
Table]
46
[
Table
7d]

[
End
Table]
47
[
Table
8a]

[
End
Table]
48
[
Table
8b]

[
End
Table]
49
[
Table
8c]

[
End
Table]
50
[
Table
8d]

[
End
Table]
51
(
d)
Bottom
Line
Burden
Hours
and
Costs/
Master
Tables.

i.
The
Simple
Collection.
The
bottom
line
respondent
burden
hours
and
costs,
presented
in
Tables
1a
through
4d,
are
calculated
by
adding
total
person­
hours
and
costs
from
each
of
the
tables.

The
estimated
total
nationwide
burden
for
the
first
3
years
for
regulated
major
sources
being
added
to
the
generic
MACT
NESHAP
would
be
an
estimated
33,926
total
labor
hours
per
year
at
a
cost
of
approximately
$
1,510,000
per
year.

The
total
estimated
annual
labor
hour
reporting
and
recordkeeping
burden
is
33,936.
The
total
annualized
capital
and
startup
costreflects
the
estimated
capital
costs
for
equipment
required
for
monitoring,
inspection,
recordkeeping,
and
reporting
(
MIRR)
activities
associated
with
the
major
source
provisions
of
the
proposed
standards.
The
total
estimated
installed
capital
costs
of
this
equipment
is
$
2,119,000
for
the
CB
production
source
category,
$
53,000
for
the
CY
production
source
category,

$
2,663,000
for
the
ET
production
source
category,
and
$
66,000
for
the
SP
production
source
category,
for
an
annual
estimated
total
of
$
4,901,000.

The
total
annual
estimated
operating
and
maintenance
costs
(
O&
M)
are
calculated
based
on
(
1)
the
estimated
storage,
filing,

photocopying,
and
postage
costs
for
the
estimated
total
number
of
annual
responses
associated
with
the
proposed
provisions
for
each
of
the
source
categories
and
(
2)
the
O&
M
costs
for
the
equipment
required
for
CPMS.
Storage,
filing,
and
photocopying
costs
per
response
is
estimated
at
0.5
hour
of
administrative
labor
at
a
rate
of
$
25/
hr
or
$
12.50
per
response
for
multiple
copies.
First
class
postage
is
estimated
at
$
7.63
per
response
for
mailing
of
an
one
pound
package
and
two
one
half
pound
packages
to
regulatory
agencies.
The
total
storage,
filing,
photocopying,

and
postage
cost
per
response
is
approximately
$
20.13.
The
total
52
annual
estimated
O&
M
cost
is
$
1,900
for
the
CB
production
source
category
based
on
93
responses,
$
1,300
for
the
CY
production
source
category
based
on
65
annual
responses,
$
3,000
for
the
ET
production
source
category
based
on
150
responses,
and
$
9,600
for
the
SP
source
category
based
upon
13
responses
plus
CPMS
costs,

for
an
annual
estimated
total
of
$
15,800
for
312
responses.

ii.
The
EPA
Tally.
The
bottom
line
Federal
government
burden
hours
and
costs
that
would
result
from
this
ICR
are
presented
in
Tables
5a
through
8d
for
the
source
categories
being
proposed
with
this
proposal.
These
estimates
are
calculated
by
adding
total
person­
hours
and
costs
from
each
of
the
tables.

Table
5d
summarizes
the
Federal
government
burden
hours
and
costs
for
existing
CB
production,
CY
production,
ET
production,
and
SP
production
source
categories.

The
estimated
total
annual
labor
hours
and
costs
of
the
generic
MACT
NESHAP
for
the
CB
production,
CY
production,
ET
production,
and
SP
production
source
categories
in
the
first
3
years
after
promulgation
are
approximately
3,465
total
labor
hours
per
year
at
a
cost
of
approximately
$
116,527
per
year.

iii.
The
Complex
Collection.
This
collection
is
a
simple
collection,
therefore,
this
section
does
not
apply.

iv.
Variations
in
the
Annual
Bottom
Line.
Variation
in
the
annual
bottom
line
for
this
regulation
may
occur
(
1)
due
to
the
fact
that
certain
one­
time
activities
would
typically
occur
in
the
first
year
following
promulgation
of
the
rule
and
(
2)
by
the
third
year
following
promulgation
of
the
rule,
when
all
sources
must
be
in
compliance,
and
will
therefore
be
subject
to
recurring
recordkeeping
and
reporting
requirements.

(
e)
Reasons
for
Change
in
Burden.

This
section
does
not
apply
because
this
is
a
new
collection.
53
PART
B
OF
THE
SUPPORTING
STATEMENT
Not
applicable.
No
sampling
or
other
methods
are
used
to
select
respondents
because
all
owners
and
operators
of
facilities
subject
to
the
generic
MACT
NESHAP
would
be
required
to
collect
information.
54
ATTACHMENT
1
SOURCE
DATA
AND
INFORMATION
REQUIREMENTS
REQUIREMENT
REGULATION
CITATION
MONITORING
&
INSPECTION

Install,
maintain,
adjust,
and
calibrate
CPMS
§
63.996(
c)


Inspect
and
monitor
covers
§
63.1063(
c)


Inspect
and
monitor
closed­
vent
or
heat
exchange
system
§
63.983(
b)

§
63.983(
c)

§
63.1084(
a)


Monitor
control
device
§
63.984(
b)

§
63.986(
c)

§
63.987(
c)

§
63.988(
c)

§
63.989(
c)

§
63.990(
c)

§
63.991(
c)

§
63.992(
c)

§
63.993(
c)

§
63.994(
c)

§
63.995(
c)

§
63.996(
c)


Develop
startup,
shutdown,
and
malfunction
plan
§
63.1110(
b)

§
63.1111
REQUIREMENT
REGULATION
CITATION
55
RECORDKEEPING

Records
of
maintenance
§
63.1088(
b)

§
63.1090(
c)

§
63.1089
§
63.1109(
a)


Records
of
startup,
shudown
and
malfunction
and
actions
taken
§
63.998(
d)


Records
of
malfunctioning
or
inoperative
CPMS
§
63.998(
c)


Records
of
CPMS
operation,
adjustments,

calibration
checks,
and
maintenance
§
63.998(
c)


Records
of
performance
test
and
performance
evaluation
results
§
63.998(
a)


Records
of
initial
and
compliance
status
notifications
§
63.998(
a)

REPORTS

Initial
Notification
§
63.1110(
a)

§
63.1110(
c)


Initial
Compliance
Status
Report
§
63.1110(
a)

§
63.1110(
d)


Notification
of
performance
evaluation
and
performance
test
dates
§
63.1110(
a)
REQUIREMENT
REGULATION
CITATION
56

Performance
test
and
performance
evaluation
results
§
63.1090
§
63.1110(
d)


Startup,
shutdown,
and
malfunction
reports
§
63.1110(
a)

§
63.1111

Excess
emissions
and
CPMS
performance
report
§
63.1110(
a)


Excess
emissions
and
CPMS
performance
summary
report
§
63.1110(
a)


Operating
parameter
value
and
rationale
selection
§
63.1110(
a)

§
63.1111

Conduct
control
device
performance
test
§
63.987(
c)

§
63.988(
b)

§
63.989(
b)

§
63.990(
b)

§
63.991(
b)

§
63.992(
b)

§
63.993(
b)

§
63.994(
b)

§
63.995(
b)


Conduct
CPMS
performance
evaluation
§
63.996(
b)
