SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Carbon
Black,
Ethylene,
Cyanide,
and
Spandex
(
40
CFR
part
63,
subpart
YY)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Carbon
Black,
Ethylene,
Cyanide,
and
Spandex
(
40
CFR
Part
63,
Subpart
YY)

1(
b)
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
is
for
hazardous
air
pollutant
(
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.

All
existing
sources
must
be
in
compliance
with
the
requirements
of
the
Generic
Maximum
Achievable
Control
Technology
(
MACT)
National
Emissions
Standard
for
Hazardous
Air
Pollutants
(
NESHAP)
within
three
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
(
GMACT)
NESHAP
upon
startup
or
prior
to
the
promulgation
date
of
standards
for
an
affected
source,
whichever
is
later.
Compliance
is
assumed
through
initial
performance
testing
or
design
analysis,
as
appropriate,
and
ongoing
compliance
is
demonstrated
through
parametric
monitoring.
Types
of
parameters
monitored
are
incinerator
temperature,
scrubber
flow
rate,
carbon
adsorber
regeneration
frequency,
as
well
as
others.
The
appropriate
parameter
to
monitor
depends
on
the
type
of
control
device
with
the
owner
or
operator
chooses
to
comply.

The
NESHAP
for
CB,
ET,
CY
and
SP
consists
of
72
existing
facilities
that
would
be
subject
to
the
major
source
provisions
specified
under
the
GMACT
NESHAP.
This
consists
of:
18
existing
facilities
for
the
CB
production
source
category,
14
facilities
for
the
CY
production
source
category,
37
facilities
for
the
ET
production
source
category
and
3
facilities
in
the
SP
production
source
category.
We
do
not
anticipate
any
new
sources
for
any
of
the
source
categories.
We
anticipate
that
all
of
these
facilities
will
conduct
all
monitoring,
inspection,
recordkeeping,
and
reporting
(
MIRR)
requirements.
Based
on
these
estimates,
the
total
MIRR
cost
of
the
rulemaking
for
the
NESHAP
for
CB,
ET,
CY
and
SP
is
estimated
to
be
$
1,080,150
annually
for
the
next
three
years.
See
section
6
of
this
ICR
for
more
details.

Since
there
are
no
new
sources
in
any
of
the
source
categories
covered
by
this
ICR
renewal,
there
will
be
no
performance
test
provisions.
If
the
new
source
requirements
are
triggered,
the
affected
source
would
have
to
fulfill
the
appropriate
design
analysis
or
performance
2
test
requirements.
These
requirements
vary
depending
on
what
type
of
emission
stream
is
regulated;
for
example,
process
vents,
storage
tanks,
wastewater
or
equipment
leaks.

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
Clean
Air
Act
(
Act)
provides
authority
to
the
Agency
to
establish
standards
to
control
air
pollution
and
to
ensure
compliance
with
promulgated
regulations
through
adequate
recordkeeping
and
reporting
by
the
affected
industries
(
i.
e.,
respondents).
The
regulations
include
the
New
Source
Performance
Standards
(
NSPS)
under
section
111
of
the
Act,
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
which
includes
the
original
NESHAP
standards
and
the
more
recent
Maximum
Achievable
Control
Technology
(
MACT)
or
NESHAP­
MACT
standards
under
section
112
of
the
Act,
and
emission
guidelines
for
the
designated
types
incinerators
under
section
129
of
the
Act.

2(
b)
Practical
Utility/
Users
of
the
Data
The
recordkeeping
and
reporting
requirements
in
the
standard(
s)
are
used
by
regulatory
agencies,
the
public
and
the
regulated
community
for
a
variety
of
reasons
including
the
determination
of
the
respondent's
compliance
status,
analytical
studies
to
demonstrate
compliance
trends,
and
evaluations
regarding
the
efficacy
of
the
promulgated
regulations.

The
required
recordkeeping
and
reporting
are
also
used
to:
1)
certify
compliance
with
the
regulations;
2)
determine
the
respondent's
compliance
with
the
designated
emission
limitation(
s);
3)
notify
regulatory
agencies
when
a
standard
is
violated;
4)
evaluate
continuous
compliance
through
the
use
of
emission
or
operational
parameter
monitors;
and
5)
ensure
that
plant
personnel
are
following
the
required
procedures
and
are
periodically
trained,
as
indicated.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
standards
do
not
require
duplication
in
the
collection
and
reporting
of
information.
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
Environmental
Protection
Agency
(
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
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
3
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
69909)
on
December
1,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
In
estimating
the
burden
associated
with
this
standard,
EPA
consulted
with
Mr.
Todd
Miller
of
Continental
Carbon
Company
at
(
281)
647­
3858
for
information
on
CB
manufacturing,
Mr.
Bruce
Raff
of
Syngenta
Corporation
at
(
225)
642­
1686
for
information
on
CY
manufacturing,
Ms.
Karen
Smidt
of
the
American
Chemistry
Council
at
(
703)
741­
5165
for
information
on
the
ET
manufacturing,
and
Mr.
Bob
Daniels
of
Invista
at
(
540)
949­
2933
for
information
on
SP
manufacturing.
As
part
of
these
consultations,
the
persons
contacted
provided
an
estimate
of
the
affected
number
of
sources
subject
to
the
standard
and
provided
information
on
the
expected
growth
rate
of
the
industry.

The
standard
was
developed
with
the
participation
and/
or
consultation
with
industry
representatives.
In
addition,
the
Agency
has
performed
additional
reviews
to
determine
additional
burden
reduction
opportunities.
The
Agency
currently
collects
the
minimum
amount
of
information
necessary
to
ensure
compliance
with
the
standard.

3(
d)
Effects
of
Less
Frequent
Collection
The
effect
of
less
frequent
collection
would
be
a
decrease
in
the
margin
of
assurance
that
facilities
are
achieving
the
emission
reductions
mandated
by
the
CAA
through
the
promulgation
of
the
applicable
regulations.
In
addition,
the
likelihood
of
detecting
the
poor
operation
and
maintenance
of
control
equipment
decreases
and
the
detection
of
noncompliance
becomes
problematic.

3(
e)
General
Guidelines
Neither
the
reporting
nor
recordkeeping
requirements
violate
the
regulations
established
by
Office
of
Management
and
Budget
(
OMB)
at
5
CFR
Part
1320,
Section
1320.5.
However,
most
NESHAP
standards
and
a
few
NSPS
standards
require
records
to
be
kept
more
than
three
years.
In
general,
these
standards
require
the
respondents
to
maintain
all
records,
including
reports
and
notifications,
for
five
years.
The
five­
year
record
retention
requirement
is
consistent
with
the
permit
program
at
40
CFR
part
70,
and
the
five­
year
statute
of
limitations
on
which
the
permit
program
is
based.

The
retention
of
records
for
five
years
allows
EPA
to
establish
the
compliance
history
of
the
respondent
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
notes
that
the
most
flagrant
violations
have
extended
beyond
a
five­
year
period.
4
If
records
are
retained
for
less
than
five
years,
EPA
would
be
deterred
from
pursuing
the
most
flagrant
violations
due
to
the
destruction
of
records
documenting
noncompliance.

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
The
recordkeeping
and
reporting
requirements
do
not
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
Standard
Industrial
Classification
(
SIC)
codes
and
corresponding
North
American
Industry
Classification
System
(
NAICS)
for
the
respondents
are
listed
below.

Source
Category
SIC
Code
NAICS
Code
Carbon
Black
2895
325182
Cyanide
2819
and
2869
325188
and
325199
Ethylene
2869
325110
Spandex
2824
325222
This
table
is
not
meant
to
be
exhaustive,
but
rather
provides
a
guide
for
readers
regarding
the
entities
likely
to
be
regulated
by
this
standard.
To
determine
whether
the
standard
applies
to
a
particular
entity,
please
see
the
applicability
provisions
in
the
standard.

4(
b)
Information
Requested
(
i)
Data
Items
Requirement
Regulation
Citation
Monitoring
&
Inspection
5
Requirement
Regulation
Citation
Install,
maintain,
adjust,
and
calibrate
continuous
parametric
monitoring
systems
(
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
(
SS&
M)
plan
§
63.1110(
b),
§
63.1111
Recordkeeping
Records
of
maintenance
§
63.1088(
b),
§
63.1090(
c),
§
63.1089,
§
63.1109(
a)

Records
of
startup,
shutdown
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
Notification
of
construction
or
reconstruction
§
63.5
Notification
of
anticipated
date
of
initial
startup
§
63.5
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)
6
Requirement
Regulation
Citation
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)

Electronic
Reporting
At
the
present,
many
respondents
to
CAA
standards
use
monitoring
equipment
that
automatically
records
parameter
data.
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.

Also
regulatory
agencies,
in
cooperation
with
the
respondents,
continue
to
create
reporting
systems
to
transmit
data
electronically.
However,
electronic
reporting
systems
are
still
not
widely
used.
At
this
time,
it
is
estimated
that
approximately
20
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CPMS
for
the
appropriate
control
device
Perform
initial
performance
test
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
in
Table
1
Enter
information
required
to
be
recorded
in
Table
1.
7
Respondent
Activities
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.

At
the
present,
many
respondents
to
CAA
standards
use
monitoring
equipment
that
automatically
records
parameter
data.
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
one
or
more
of
the
activities
provided
in
Tables
3
through
6
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.
These
tables
are
introduced
in
Section
6(
c)
of
this
ICR.

5(
b)
Collection
Methodology
and
Management
The
required
data
and
reports
can
be
evaluated
on­
site
by
conducting
a
partial
compliance
evaluation,
full
compliance
evaluation
or
inspection,
or
thru
an
off­
site
review
of
compliance
monitoring
records
and
reports.
Evaluation
reports
and
inspection
results
are
maintained
by
the
Agency
or
delegated
authority.

The
results
of
these
evaluations
are
entered
into
the
Air
Facility
Subsystem
(
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
delegated
authorities
can
retrieve
and
analyze
the
data.
8
5(
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.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1,
attached.

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

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

6(
a)
Estimating
Respondent
Burden
The
respondent
burden
is
shown
in
Table
1.
The
labor
hours
in
Table
1
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
standard,
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
$
96.41
($
45.91
+
110%)
Technical
$
82.74
($
39.40
+
110%)
Clerical
$
42.25
($
20.12
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2004,
"
Table
2.
Civilian
Workers,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110
percent
to
account
9
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
There
are
no
capital/
startup
costs
for
the
GMACT
because
there
are
no
new
sources.
The
total
annual
estimated
operating
and
maintenance
costs
(
O&
M)
are
calculated
based
on
the
costs
for
the
equipment
required
for
CPMS.
The
total
annual
estimated
O&
M
cost
is
$
171,822
for
the
CB
production
source
category
based
on
18
responses,
$
133,640
for
the
CY
production
source
category
based
on
14
annual
responses,
$
27,169
for
the
ET
production
source
category
based
on
37
responses,
and
$
26,434
for
the
SP
source
category
based
upon
three
responses,
for
an
annual
estimated
total
of
$
359,065.

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)

CB
N/
A
0
0
9545
18
$
171,822
CY
N/
A
0
0
9545
14
$
133,640
ET
N/
A
0
0
734
37
$
27,169
SP
N/
A
0
0
8811
3
$
26,434
TOTAL
$
359,065
(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
There
are
no
capital
and
startup
costs
for
ICR
since
there
are
no
new
sources.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

See
the
above
Table
for
an
explanation
of
O&
M
costs.
The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
the
totals
of
column
G.
This
cost
is
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
costs
to
industry
over
the
next
three
years
of
the
ICR
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
Costs
10
The
only
costs
to
the
Agency
are
those
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
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
shown
in
Tables
3
­
6,
attached.

This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
56.02
(
GS­
13,
Step
5,
$
35.01
x
1.6)
Technical
$
41.57
(
GS­
12,
Step
1,
$
25.98
x
1.6)
Clerical
$
22.50
(
GS­
6,
Step
3,
$
14.06
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Since
there
are
no
new
sources
to
average
over
the
three
years
covered
by
this
ICR,
the
number
of
respondents
is
the
simple
arithmetic
sum
of
respondents
for
each
of
the
source
categories,
or
72.
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
Table
2.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
determined
from
Table
1
and
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
cost
is
determined
from
Table
1.

The
average
annual
Agency
burden
and
cost
over
next
three
years
is
shown
in
Tables
3
­
6.

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
3
­
6,
respectively.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
annual
labor
cost
is
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
11
information
is
estimated
to
average
90
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
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)
Cost.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
hours
and
cost
over
next
three
years
is
shown
in
Tables
3
­
6.

6(
f)
Reasons
for
Change
in
Burden
There
is
a
decrease
of
20,393
hours
in
the
total
estimated
burden
currently
identified
in
the
OMB
Inventory
of
Approved
ICR
Burdens.
This
decrease
is
because
the
previous
ICR
included
some
items
in
the
inventory
(
e.
g.,
control
equipment
related)
that
are
not
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Additionally,
the
previous
ICR
overestimated
the
time
and
frequency
to
prepare
startup,
shutdown
and
malfunction
(
SS&
M)
reports,
and
the
time
to
store,
file
and
maintain
records
and
to
retrieve
records
and
reports.

The
Capital/
Startup
costs
as
calculated
in
this
ICR's
section
6(
b)(
iii)
compared
with
the
costs
in
the
previous
ICR
have
decreased.
Since
the
previous
ICR
covered
initial
compliance
with
the
standard,
the
costs
were
mostly
associated
with
the
purchase
of
monitoring
equipment.
Since
there
are
no
new
sources
for
the
three
years
covered
by
this
ICR,
the
costs
will
be
only
be
O&
M
costs.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
90
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
disclose,
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
to
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;
to
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
to
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
to
search
data
sources;
to
complete
and
review
the
collection
of
information;
and
to
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.
12
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
0048,
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
OECA
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,
to
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.
You
can
also
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
the
EPA
Docket
ID
Number,
OECA­
2004­
0048
and
OMB
Control
Number
2060­
0489
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
