SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards
(
40
CFR
part
63,
subpart
YY)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards
(
40
CFR
part
63,
subpart
YY)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
(
hereafter,
this
subpart
is
referred
to
as
the
"
Generic
MACT")
were
proposed
on
October
14,
1998,
at
63
FR
55178
and
promulgated
on
June
29,
1999,
at
64
FR
34854.
These
regulations
apply
to
hazardous
air
pollutant
(
HAP)
emission
sources
in
four
categories
including:
Polycarbonates
(
PC)
Production,
Acrylic
and
Modacrylic
Fibers
(
AMF)
Production,
Acetal
Resins
(
AR)
Production
and
Hydrogen
Fluoride
(
HF)
Production.
This
Information
Collection
Request
(
ICR)
addresses
these
four
source
categories.
On
November
2,
2001,
the
Agency
promulgated
wastewater
provisions
amendments
to
the
Generic
MACT
applicable
to
wastewater
streams
for
the
PC,
AMF,
and
AR
production
source
categories.
The
HF
production
source
category
does
not
have
wastewater
streams.
On
June
7,
2002,
the
Agency
made
additional
amendments
as
a
direct
ruling
to
the
Generic
MACT
to
clarify
definitions
and
the
recordkeeping
provisions
related
to
how
readily
accessible
records
should
be
maintained.
This
information
is
being
collected
to
assure
compliance
with
the
provisions
of
40
CFR
part
63,
subpart
YY.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
The
specific
monitoring
and
recordkeeping
requirements
vary
for
each
source
category
depending
on
the
types
of
emissions
control
equipment
and
monitoring
equipment
used
to
comply
with
the
Generic
MACT
standards
for
their
category.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
sources
subject
to
NESHAP.

Any
owner
or
operator
subject
to
the
provisions
of
this
subpart
will
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.
2
Based
on
our
consultations
with
industry
representatives,
there
is
an
average
of
one
affected
facility
at
each
plant
site
and
that
each
plant
site
has
only
one
respondent
(
i.
e.,
the
owner/
operator
of
the
plant
site).

There
are,
approximately,
ten
respondents
in
four
categories
that
are
currently
subject
to
the
regulation,
they
are:
1)
Polycarbonates
(
PC)
Production
­
four
sources;
2)
Acrylic
and
Modacrylic
Fibers
(
AMF)
Production
­
three
sources;
3)
Acetal
Resins
(
AR)
Production
­
two
sources;
and
4)
Hydrogen
Fluoride
(
HF)
Production
­
one
source.
It
is
estimated
that
no
additional
respondents
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.

The
Office
of
Management
and
Budget
(
OMB)
approved
the
current
Information
Collection
Request
(
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
shall
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
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
hazardous
air
pollutant
(
HAP)
emissions
from
PC,
AMF,
AR
and
HF
source
categories
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
YY.

2(
b)
Practical
Utility/
Users
of
the
Data
3
The
recordkeeping
and
reporting
requirements
in
the
standard
ensure
compliance
with
the
applicable
regulations
which
were
promulgated
in
accordance
with
the
Clean
Air
Act.
The
collected
information
is
also
used
for
targeting
inspections
and
as
evidence
in
legal
proceedings.

Performance
tests
are
required
in
order
to
determine
an
affected
facility's
initial
capability
to
comply
with
the
emission
standard.
Continuous
emission
monitors
are
used
to
ensure
compliance
with
the
standard
at
all
times.
During
the
performance
test
a
record
of
the
operating
parameters
under
which
compliance
was
achieved
may
be
recorded
and
used
to
determine
compliance
in
place
of
a
continuous
emission
monitor.

The
notifications
required
in
the
standard
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
ensure
that
the
pollution
control
devices
are
properly
installed
and
operated,
that
leaks
are
being
detected
and
repaired,
and
that
the
standard
is
being
met.
The
performance
test
may
be
observed
as
well.

The
required
semiannual
reports
are
used
to
determine
periods
of
excess
emissions,
to
identify
problems
at
the
facility,
to
verify
operation/
maintenance
procedures,
and
for
compliance
determinations.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
YY.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
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.
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
(
70
FR
24020)
on
May
6,
2005.
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,
consulted
with
the
4
preparer
of
the
active
ICR,
and
used
other
resources
to
obtain
the
most
recent
data
available.
We
reviewed
information
available
from
the
United
States
Census
Bureau,
the
Air
Facility
System
(
AFS),
and
websites
covering
PC,
AMF,
AR
and
HF
source
categories.
We
also
consulted
with
the
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer,
the
Program
Integration
Division,
and
one
EPA
regional
office.

After
reviewing
our
internal
data
sources
and
industry
experts,
we
have
determined
that
additional
consultations
with
industry
are
inappropriate
for
this
ICR
renewal.

The
standard
was
developed
with
the
participation
and/
or
consultation
with
industry
representatives.
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
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
decreases.

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
records
retention
requirement
is
consistent
with
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
the
purpose
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.
If
records
were
retained
for
less
than
five
years,
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records.

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
5
­
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
HAP
emissions
in
four
categories:
Polycarbonates
(
PC)
Production,
Acrylic
and
Modacrylic
Fibers
(
AMF)
Production,
Acetal
Resins
(
AR)
Production
and
Hydrogen
Fluoride
(
HF)
Production.
The
Standard
Industrial
Classification
(
SIC)
codes
for
the
respondents
affected
by
the
standards,
which
correspond
to
the
North
American
Industry
Classification
System
(
NAICS)
codes,
are
listed
below
for
source
category
description.

Standard
(
40
CFR
part
61,
subpart
N)
SIC
Codes
NAICS
Codes
Polycarbonates
(
PC)
Production
(
Synthetic
Rubber
Manufacturing)
2822
325212
Acrylic
and
Modacrylic
Fibers
(
AMF)
Production
(
Manmade
Organic
Fibers,
Except
Cellulosic)
2824
325222
Acetal
Resins
(
AR)
Production
(
Plastic
Materials,
Synthetic
and
Resins,
and
Nonvulcanizable
Elastomers)
2821
325211
Hydrogen
Fluoride
(
HF)
Production
(
Industrial
Inorganic
Chemicals,
Not
Elsewhere
Classified)
2819
325188
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
NESHAP
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
(
40
CFR
part
63,
subpart
YY)
(
Renewal).
6
A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
Application
for
approval
of
construction/
reconstruction
63.5(
d),
63.1110(
a)

Notification
of
initial
startup
63.1110(
b)

Notification
of
initial
applicability
63.09(
b),
63.1110(
a),
and
63.1110(
c)

Notification
of
compliance
status
63.9(
h),
63.1110(
a),
and
63.1110(
d)

Notification
of
performance
test
and
performance
evaluation
results
63.7(
b),
63.9(
e),
63.10(
d)(
2),
63.1110(
d),
and
63.1110(
a)

Rescheduled
initial
performance
test
63.7(
b)(
2)

Demonstration
of
continuous
monitoring
system
63.9(
g)

Physical
or
operational
change
63.8(
a)

Opacity
or
visible
emissions
63.10(
d)(
3)

Develop
startup,
shutdown,
malfunction
plan
and
periodic
reports
63.10(
d)(
5)(
i),
63.1110(
b),
and
63.1111
Excess
emissions
and
continuous
parameter
monitoring
systems
(
CPMS)
performance
reports
63.1110(
a)

Reports
Periodic
reports
(
Semiannual
or
according
to
the
schedule
for
Title
V)
with
information
on
excess
emissions
and
on
the
implementation
of
leak
detection
and
repair
standard
provisions
63.1110(
e),
63.1108(
a),
and
63.1109
Startup,
shutdown
and
malfunction
reports
63.1110(
a),
and
63.1111(
b)

A
source
must
keep
the
following
records:
7
Recordkeeping
Maintain
records
of
startup,
shutdown,
malfunctions
periods
when
excess
emissions
have
occurred
during
the
reporting
period
63.10(
b)(
2)
and
63.1109(
a)

Maintain
records
of
performance
test
and
performance
evaluation
results
63.1109(
a)

Maintain
records
of
all
reports
and
notifications
63.10(
b)
and
63.1109(
a)

Maintain
record
of
applicability
63.10(
b)(
3)
and
63.1109(
d)

Maintain
records
of
initial
and
compliance
status
notifications
63.9(
h),
63.1109(
d)

Records
of
CPMS
operation
adjustments,
calibration
checks,
and
maintenance
63.10(
b)(
2)(
vii)
and
63.1109(
a)

Records
of
implementation
of
leak
detection
and
repair
(
LDAR)
standards
provision
63.1107
Records
are
required
to
be
retained
for
five
years
63.10(
b)(
2)

Electronic
Reporting
Currently,
respondents
are
using
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
10
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Conduct
control
device
performance
tests.

Conduct
a
performance
evaluation
of
the
CPMS.

Inspect
and
monitor
closed­
vent
system.
8
Respondent
Activities
Monitor
control
devices.

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.

Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

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.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
9
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
headquarters
and
EPA
regional
offices.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner/
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
respondents
are
large
entities
(
i.
e.,
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
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards
(
40
CFR
part
63,
subpart
YY)
(
Renewal).

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
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
10
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
4,004
(
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
$
97.46
($
46.41
+
110%)
Technical
$
83.71
($
39.86
+
110%)
Clerical
$
42.55
($
20.26
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
19,
2005,
"
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
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
type
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
when
a
facility
becomes
subject
to
the
regulation.
The
annual
operation
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
monitor
and
other
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
(
A)
Continuous
Monitoring
Device
(
B)
Capital/
Startu
p
Cost
for
One
Respondent
(
C)
Number
of
New
Respondents
(
D)
Total
Capital/
Startup
Cost,
(
B
X
C)
(
E)
Annual
O&
M
Costs
for
One
Respondent
1
(
F)
Number
of
Respondents
with
O&
M
(
G)
Total
O&
M,
(
E
X
F)

PC
(
use
of
noncontractor
$
0
0
$
0
$
144.55
2
$
289.10
PC
(
use
of
contractor)
2
$
0
0
$
0
$
53,128.85
2
$
106,257.70
11
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
AMF
$
0
0
$
0
$
144.55
3
$
433.65
AR
$
0
0
$
0
$
144.55
2
$
289.10
HF
$
0
0
$
0
$
144.55
1
$
144.55
Total
$
0
$
107,414.10
Total
rounded
$
107,414.00
1
We
have
assumed
that
each
source
will
respond
5
times
per
year
to
comply
with
the
rule
at
a
total
cost
of
$
144.55
per
source
to
cover
O&
M
costs.
This
estimate
is
based
on
the
assumption
that
it
takes
0.5
hours
to
conduct
these
tasks
at
a
clerical
labor
rate
of
$
42.55
per
hour
for
a
total
labor
cost
of
$
21.28
per
response.
First­
class
postage
is
estimated
at
$
7.63
per
response.
Thus,
the
total
storage,
filing,
photocopying,
and
postage
cost
per
response
is
$
28.91.

2
Based
on
information
we
obtained,
we
have
determined
that
two
PC
sources
out
of
a
total
of
four
sources
will
use
contractor
support
for
CPMS
O&
M,
at
a
total
cost
of
approximately
$
53,000
per
source.

The
total
capital/
startup
costs
for
this
ICR
are
zero.
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
$
107,414.
This
is
the
total
of
column
G.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
cost
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
107,414.
This
cost
is
shown
(
rounded)
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
2,797,
for
69
hours.

This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:
12
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)
"
2005
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
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards
(
40
CFR
part
63,
subpart
YY)
(
Renewal).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
on
average
over
the
next
three
years,
approximately
10
existing
respondents
will
be
subject
to
the
standard.
It
is
estimated
that
no
additional
respondents
per
year
will
become
subject
to
the
standard.
The
overall
average
number
of
respondents,
as
shown
in
the
table
below
is
10
per
year
(
see
table
below).

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

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

1
0
10
0
0
10
2
0
10
0
0
10
3
0
10
0
0
10
Average
0
10
0
0
10
.
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
10.
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:
13
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
Initial
requirements
for
PC
Production
0
1
N/
A
0
Initial
requirements
for
AMF
Production
0
1
N/
A
0
Initial
requirements
for
AR
Production
0
1
N/
A
0
Initial
requirements
for
HF
Production
0
1
N/
A
0
SSM
reports
for
PC
Production
4
1
N/
A
4
SSM
reports
for
AMF
Production
3
1
N/
A
3
SSM
reports
for
AR
Production
2
1
N/
A
2
SSM
reports
for
HF
Production
1
1
N/
A
1
Periodic
reports
for
PC
Production
4
2
N/
A
8
Periodic
reports
for
AMF
Production
3
2
N/
A
6
Periodic
reports
for
AR
Production
2
2
N/
A
4
Periodic
reports
for
HF
Production
1
2
N/
A
2
LDAR
reports
for
PC
Production
0
2
N/
A
0
LDAR
reports
for
AMF
Production
0
2
N/
A
0
LDAR
reports
for
AR
Production
0
2
N/
A
0
LDAR
reports
for
HF
Production
0
2
N/
A
0
Total
30
The
number
of
Total
Annual
Responses
is
30.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
331,146
for
4,004
hours.
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
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards
(
40
CFR
part
63,
subpart
YY)
(
Renewal).

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
Details
of
the
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.
14
(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
331,146.
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
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards
(
40
CFR
part
63,
subpart
YY)
(
Renewal).
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
are
estimated
to
average
133
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
107,414.
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
is
estimated
to
be
69
labor
hours
at
a
cost
of
$
2,797.
See
Table
2.
Annual
Agency
Burden
and
Cost,
NESHAP
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards
(
40
CFR
part
63,
subpart
YY)
(
Renewal).

6(
f)
Reasons
for
Change
in
Burden
There
is
no
change
in
the
number
of
respondents
identified
in
the
active
ICR;
however,
there
is
a
decrease
of
73
hours
in
the
estimated
burden
currently
identified
in
the
OMB
Inventory
of
Approved
ICR
Burdens.
This
was
due
to
calculation
errors
in
the
active
ICR.

There
is
an
increase
in
the
labor
costs
associated
with
this
ICR,
which
is
due
to
the
fact
that
we
use
the
updated
hourly
wage
rate
which
is
provided
by
the
United
States
Department
of
Labor,
Bureau
of
Statistics.

Because
there
are
no
new
sources
with
reporting
requirements,
no
capital/
startup
costs
are
incurred.
The
cost
that
is
incurred
is
for
the
operation
and
maintenance
(
O&
M)
associated
with
this
ICR,
as
compared
with
the
active
ICR
currently
identified
in
the
OMB
inventory.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
133
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;
to
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
15
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;
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.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burdens,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2005­
0030,
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
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2005­
0030
and
the
OMB
Control
Number
2060­
0420
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
16
Table
1:
Annual
Respondent
Burden
and
Cost
­
NESHAP
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards
(
40
CFR
part
63,
subpart
YY)
(
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)
Management
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
c
Polycarbonated
(
PC)
Production
4
1
4
0
0
0
0
$
0
Acrylic
and
Modacrylic
Fibers
(
AMF)
Production
4
1
4
0
0
0
0
$
0
Acetal
Resins
(
AR)
Production
4
1
4
0
0
0
0
$
0
Hydrogen
Fluoride
(
HF)
Production
4
1
4
0
0
0
0
$
0
B.
Required
Activities
for
PC,
AMF,
AR,
&
HF
c
Included
in
4C
C.
Create
Information
for
PC,
AMF,
AR,
&
HF
c
Included
in
4
C
D.
Gather
existing
information
for
PC,
AMF,
AR
&
HF
c
Included
in
4C
E.
Write
report
i
Initial
requirements:
notifications,
initial
compliance
determination,
performance
tests
c
PC
Production
52
1
52
0
0
0
0
$
0
AMF
Production
52
1
52
0
0
0
0
$
0
AR
Production
52
1
52
0
0
0
0
$
0
HF
Production
52
1
52
0
0
0
0
$
0
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)
Management
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
b
ii
Startup,
Shutdown
malfunction
reports
d
PC
Production
2
1
2
4
8
0.4
0.8
$
742.70
AMF
Production
2
1
2
3
6
0.3
0.6
$
557.03
AR
Production
2
1
2
2
4
0.2
0.4
$
371.35
HF
Production
2
1
2
1
2
0.1
0.2
$
185.68
iii
Periodic
reports
e
PC
Production
8
2
16
4
64
3.2
6.4
$
5,941.63
AMF
Production
8
2
16
3
48
2.4
4.8
$
4,456.22
AR
Production
8
2
16
2
32
1.6
3.2
$
2,970.82
HF
Production
8
2
16
1
16
0.8
1.6
$
1,485.41
iv
Leak
detection
and
repair
(
LDAR)
reports
c,
f
PC
Production
8
2
16
0
0
0
0
$
0
AMF
Production
8
2
16
0
0
0
0
$
0
AR
Production
8
2
16
0
0
0
0
$
0
HF
Production
8
2
18
0
0
0
0
$
0
4.
Recordkeeping
Requirements
a
A.
Read
Instructions
for
c
4
1
4
0
0
0
0
$
0
PC
Production
4
1
4
0
0
0
0
$
0
AMF
Production
4
1
4
0
0
0
0
$
0
AR
Production
4
1
4
0
0
0
0
$
0
18
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

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

Total
Cost
per
year
b
HF
Production
4
1
4
0
0
0
0
$
0
B.
Plan
Activities
for
c
40
1
40
0
0
0
0
$
0
PC
Production
40
1
40
0
0
0
0
$
0
AMF
Production
40
1
40
0
0
0
0
$
0
AR
Production
40
1
40
0
0
0
0
$
0
HF
Production
40
1
40
0
0
0
0
$
0
C.
Implement
Activities
a
i
Material
determinations
c
PC
Production
N/
A
AMF
Production
N/
A
AR
Production
N/
A
HF
Production
N/
A
ii
Control
equipment
inspection
a.
Tanks
PC
Production
N/
A
AMF
Production
2
12
24
3
72
3.6
7.2
$
6,684.34
AR
Production
2
12
24
2
48
2.4
4.8
$
4,456.22
HF
Production
N/
A
b.
Closed­
vent
system
PC
Production
2
2
4
2
8
0.4
0.8
$
742.70
19
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

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

Total
Cost
per
year
b
AMF
Production
2
2
4
3
12
0.6
1.2
$
1,094.56
AR
Production
2
2
4
2
8
0.4
0.8
$
742.70
HF
Production
2
2
4
1
4
0.2
0.4
$
371.35
iii
Control
equipment
leak
monitoring
a.
Cover
vented
to
control
device
PC
Production
1
2
2
2
4
0.2
0.4
$
371.35
AMF
Production
1
2
2
3
6
0.3
0.6
$
547.28
AR
Production
1
2
2
2
4
0.2
0.4
$
371.35
HF
Production
1
2
2
1
2
0.1
0.2
$
185.68
b.
Closed­
vent
system
PC
Production
1
2
2
2
4
0.2
0.4
$
371.35
AMF
Production
1
2
2
3
6
0.3
0.6
$
547.28
AR
Production
1
2
2
2
4
0.2
0.4
$
371.35
HF
Production
1
2
2
1
2
0.1
0.2
$
185.68
iv.
Control
devices
a.
Initial
requirements
design
analysis,
performance
c
Test
PC
Production
80
1
80
0
0
0
0
$
0
AMF
Production
80
1
80
0
0
0
0
$
0
AR
Production
80
1
80
0
0
0
0
$
0
20
Burden
item
(
A)
Technical
Personhours
per
occurrence
(
B)

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

Total
Cost
per
year
b
HF
Production
80
1
80
0
0
0
0
$
0
b.
Operate
and
maintain
CMS
PC
Production
8
12
96
2
192
9.6
19.2
$
17,824.90
AMF
Production
8
12
96
3
288
14.4
28.8
$
26,737.34
AR
Production
8
12
96
2
192
9.6
19.2
$
17,824.90
HF
Production
8
12
96
1
96
4.8
9.6
$
8,912.45
v.
LDAR
Program
a.
Initial
requirement:
Identify
all
effected
streams
c
PC
Production
20
1
20
0
0
0
0
$
0
AMF
Production
20
1
20
0
0
0
0
$
0
AR
Production
20
1
20
0
0
0
0
$
0
HF
Production
20
1
20
0
0
0
0
$
0
b.
Perform
monitoring/
repairs
PC
Production
1)
In­
house
g
0.1
1,092
192
2
384
19.2
38.4
$
35,649.79
2)
Use
of
contractor
support
h
2
$
8,000.00
AMF
Production
16
12
192
3
576
28.8
57.6
$
53,474.69
AR
Production
16
12
192
2
384
19.2
38.4
$
35,649.79
HF
Production
g
0.1
1,092
192
1
192
9.6
19.2
$
17,824.90
vi.
Container
vapor
tightness
certification
21
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)
Management
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
b
PC
Production
N/
A
AMF
Production
N/
A
AR
Production
N/
A
HF
Production
N/
A
D.
Develop
Record
System
i.
Develop
startup,
shutdown,
malfunction
plan
c
PC
Production
20
1
20
0
0
0
0
$
0
AMF
Production
20
1
20
0
0
0
0
$
0
AR
Production
20
1
20
0
0
0
0
$
0
HF
Production
20
1
20
0
0
0
0
$
0
ii.
Control
equipment
c
PC
Production
16
1
16
0
0
0
0
$
0
AMF
Production
16
1
16
0
0
0
0
$
0
AR
Production
16
1
16
0
0
0
0
$
0
HF
Production
16
1
16
0
0
0
0
$
0
iii.
LDAR
Program
c
PC
Production
40
1
40
0
0
0
0
$
0
AMF
Production
40
1
40
0
0
0
0
$
0
AR
Production
40
1
40
0
0
0
0
$
0
HF
Production
40
1
40
0
0
0
0
$
0
22
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)
Management
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
b
E.
Record
Information
(
all
information
required
by
standard)

i.
Initial
requirements:
cover
design,
control
device
c
design,
and
control
equipment
testing
PC
Production
17
1
17
0
0
0
0
$
0
AMF
Production
17
1
17
0
0
0
0
$
0
AR
Production
17
1
17
0
0
0
0
$
0
HF
Production
17
1
17
0
0
0
0
$
0
ii.
Control
equipment
inspection
PC
Production
1
2
2
2
4
0.2
0.4
$
371.35
AMF
Production
1
2
2
3
6
0.3
0.6
$
557.03
AR
Production
1
2
2
2
4
0.2
0.4
$
371.35
HF
Production
1
2
2
1
2
0.1
0.2
$
185.68
iii.
Control
equipment
monitoring
i
PC
Production
1
52
52
2
104
5.2
10.4
$
9,655.15
AMF
Production
1
52
52
3
156
7.8
15.6
$
14,482.73
AR
Production
1
52
52
2
104
5.2
10.4
$
9,655.15
HF
Production
1
52
52
1
52
2.6
5.2
$
4,827.58
iv.
Control
device
CMS
PC
Production
1
12
12
2
24
1.2
2.4
$
2,228.11
AMF
Production
1
12
12
3
36
1.8
3.6
$
3,342.17
23
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)
Management
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
b
AR
Production
1
12
12
2
24
1.2
2.4
$
2,228.11
HF
Production
1
12
12
1
12
0.6
1.2
$
1,114.06
v.
LDAR
program
PC
Production
g
0.02
1,092
21.84
2
43.7
2.19
4.37
$
4,057.51
AMF
Production
2
12
24
3
72
3.6
7.2
$
6,684.34
AR
Production
2
12
24
2
48
2.4
4.8
$
4,456.22
HF
Production
g
0.02
1,092
21.84
1
21.8
1.09
2.18
$
2,023.87
F.
Time
to
Train
Personnel
i.
Material
determination
methods
PC
Production
N/
A
AMF
Production
N/
A
AR
Production
N/
A
HF
Production
N/
A
ii.
Control
equipment
inspection
and
monitoring
j
PC
Production
8
1
8
4
32
1.6
3.2
$
2,939.98
AMF
Prduction
8
1
8
3
24
1.2
2.4
$
2,228.11
AR
Production
8
1
8
2
16
0.8
1.6
$
1,485.41
HF
Production
8
1
8
1
8
0.4
0.8
$
742.70
iii.
LDAR
program
f,
j
PC
Production
2
1
2
4
8
0.4
0.8
$
742.70
24
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)
Management
personhours
per
year
(
Ex0.05)
(
G)
Clerical
personhours
per
year
(
Ex0.1)
(
H)

Total
Cost
per
year
b
AMF
Production
2
1
2
3
6
0.3
0.6
$
557.03
AR
Production
2
1
2
2
4
0.2
0.4
$
371.35
HF
Production
2
1
2
1
2
0.1
0.2
$
185.68
iv.
Container
leak
tight
method
PC
Production
N/
A
AMF
Production
N/
A
AR
Production
N/
A
HF
Production
N/
A
Subtotal
Labor
Burden
3481.5
174.08
348.15
$
331,146.16
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
4,004
$
331,146
Assumptions:

a
We
have
assumed
that
there
are
10
existing
sources,
and
that
no
additional
new
sources
will
become
subject
to
the
rule
over
the
next
three
years.
It
is
also
assumed
that
affected
facility
owners
and
operators
have
already
complied
with
the
initial
requirements
including
the
instalation
of
any
required
equipment.
In
addition,
we
have
assumed
that
two
sources
under
this
category
will
hire
contractors
to
comply
with
the
monitoring
and
recordkeeping
requirements
of
the
rule
while
reports
are
developed
by
the
source
personnel.

b
This
ICR
uses
the
following
labor
rates:
$
97.46
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
83.71
per
hour
for
Technical
labor,
and
$
42.55
per
hour
for
Clerical
labor.

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
March
19,
2005,
"
Table
2.
Civilian
Workers,
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
there
will
be
no
new
sources
over
the
next
three
years
of
this
ICR.
We
have
also
assumed
that
all
existing
sources
have
already
complied
with
this
one­
time
activity.

d
All
major
sources
must
submit
startup,
shutdown,
malfunction
reports
semiannually
when
actions
are
taken
in
the
event
of
a
startup,
shutdown,
or
malfunction
that
are
consistent
with
the
source's
SSM
plans.
Sources
can
submit
this
information
with
the
periodic
reports.

e
The
rules
requires
that
all
sources
submit
periodic
reports
(
semiannually
or
according
to
the
schedule
for
Title
V).

f
The
standards
for
equipment
leak
requires
the
submittal
of
an
initial
report
and
semiannual
reports
of
leak
detection
and
repair
(
LDAR)
and
any
changes
to
the
processes,
monitoring
frequency
and
initiation
of
a
quality
improvement
program.
We
have
assumed
that
sources
are
submitting
the
required
LDAR
information
with
the
periodic
reports.

g
Visual
inspections
are
required
once
per
shift
with
a
total
of
three
shifts
per
day,
at
seven
days
per
week,
for
52
weeks
per
year.
(
3x7x52)
for
a
total
of
1,092
inspections
per
year.

h
We
have
determined
that,
based
on
the
industry
representative
in
the
PC
category,
the
two
sources'
use
of
contractor
support
to
complete
the
LDAR
related
monitoring
will
cost
an
25
estimated
$
8,000.

i
We
have
assumed
that
control
equipment
monitoring
should
be
done
on
a
weekly
basis.

j
We
have
assumed
that
there
will
be
some
labor
hours
associated
with
rule
analysis
and
training
per
year.

Table
2:
Average
Annual
Agency
Burden
and
Cost­
NESHAP
for
Source
Categories:
Generic
Maximum
Achievable
Control
Technology
Standards
(
40
CFR
part
63,
subpart
YY)
(
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
Review
Reports
1.
Initial
requirements
a.
Initial
notification
c
2
1
2
0
0
0
0
$
0
b.
Performance
test
c,
d
2
1
2
0
0
0
0
$
0
c.
Compliance
status
c
4
1
4
0
0
0
0
$
0
d.
Performance
test
reports
c,
d
4
1
4
0
0
0
0
$
0
2.
Periodic
requirements
a.
Startup,
shutdown,
malfunction
reports
e
2
1
2
0
0
0
0
$
0
b.
Periodic
reports
e
3
2
6
10
60
3
6
$
2,797.26
c.
Leak
detection
and
repair
(
LDAR)
reports
f
3
2
6
0
0
0
0
$
0
Subtotals
Labor
Burden
and
Cost
60
3
6
$
2,797.26
26
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
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
69
$
2,797
Assumptions:

a
We
have
assumed
that
there
are
10
existing
sources,
and
that
no
additional
new
sources
will
become
subject
to
the
rule
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:
$
56.02
for
Managerial
(
GS­
13,

Step
5,
$
35.01
x
1.6),
$
41.57
for
Technical
(
GS­
12,
Step
1,
$
25.98
x
1.6)
and
$
22.50
Clerical
(
GS­
6,
Step
3,
$
14.06
x
1.6).
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2005
General
Schedule"
which
excludes
locality
rates
of
pay.

c
We
have
assumed
that
there
will
be
no
new
sources
over
the
next
three
years
of
this
ICR,
We
have
also
assumed
that
all
existing
sources
have
already
complied
with
this
one­
time
activity.

d
We
have
assumed
that
the
Agency
will
not
have
additional
burden
from
sources
conducting
performance
tests
due
to
a
process
change
that
may
or
may
not
result
in
the
source
meeting
additional
requirements.

e
We
have
assumed
that
all
sources
have
already
developed
a
startup,
shutdown
and
malfunction
(
SSM)
plan.
We
have
further
assumed
that
sources
are
submitting
their
information
on
SSM
with
the
periodic
report
which
is
submitted
on
a
semiannual
basis.

f
The
equipment
leak
standards
require
the
submittal
of
an
initial
report
and
semiannual
report
of
leak
detection
and
repair
(
LDAR)
program
experiencing
any
changes
to
the
processes,
monitoring
frequency
and
initiation
of
a
quality
improvement
program.
We
have
assumed
that
sources
are
submitting
the
required
LDAR
information
with
the
periodic
reports.
