SF tc \l2 "SF -83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Epoxy Resin and Non-Nylon Polyamide Production

(40 CFR part 63, subpart W) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40 CFR part
63, subpart W) (Renewal)

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP),
for Epoxy Resin and Non-Nylon Polyamide Production were proposed on May
16, 1994, and promulgated on March 8, 1995.  This standard applies to
all facilities that manufacture polymers and resins from
epichlorohydrin.  These sources include existing and new facilities
producing basic liquid epoxy resin (BLR) and epichlorohydrin-modified
non-nylon polyamide resins, also known as wet strength resins (WSR). 
The source subject to this provision emits the hazardous air pollutants
(HAPs) epichlorohydrin, and in lesser amounts, hydrochloric acid and
methanol.  This information is being collected to assure compliance with
40 CFR part 63, subpart W.

Owners or operators of the affected sources described must make a
one-time-only notification of any physical or operational change to an
existing facility which may increase the regulated pollutant emission
rate, notification of initial performance tests, including information
necessary to determine the conditions of the performance test,
performance test measurements and results, and notification of
demonstration of the continuous monitoring system (CMS). 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.  Quarterly reports of excess emissions are required.
Quarterly reporting may be reduced to semiannually if continuous
compliance is achieved for 

12 months.  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 part 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 EPA Regional Office.

Approximately seven sources are currently subject to the standard,
three basic liquid epoxy resins (BLR) plants and four wet strength
resins (WSR) plants.  The growth rate for this industry is estimated to
be zero, so no new sources are likely to become subject to the standard
in the next three years.  A thorough review of current information for
the industry verifies a decrease of sources as compared to the active
ICR.  The cost of this ICR will be $243,711 

per year.

OMB approved the currently active ICR without any (Terms of Clearance.(

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants.  These
standards are applicable to new or existing sources of hazardous air
pollutants and will require the maximum degree of emission reduction. 
In addition, 

section 114(a) states that the Administrator may require any owner or
operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data 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 pollutants emissions from
epichlorohydrin, methanol and hydrochloric acid from epoxy resin and
non-nylon polyamide resin production, cause or contribute to air
pollution that may reasonably be anticipated to endanger public health
or welfare.  Therefore, the NESHAP was promulgated for this source
category at 40 CFR part 63, subpart W.

2(b)  Practical Utility/Users of the Data

The control of emissions of hazardous air pollutants (HAP) from
epichlorohydrin, methanol and hydrochloric acid from epoxy resin and
non-nylon polyamide resin production requires not only the installation
of properly designed equipment, but also the operation and maintenance
of that equipment.  Emissions of HAP from manufacture of basic liquid
epoxy resins (BLR) and wet strength resins (WSR) are the result of
operation of those facilities.  The subject standards are achieved by
the reduction of HAP emissions using control technology and leak
detection and repair procedures.

The notifications required in the applicable regulations are used to
inform the Agency or delegated authority when a source becomes subject
to the requirements of the regulations.  The reviewing authority may
then inspect the source to check if the pollution control devices are
properly installed and operated and leaks are being detected and
repaired and the regulations are being met.  Performance test reports
are needed as these are the Agency's records of a source's initial
capability to comply with the emission standards, and serve as a record
of the operating conditions under which compliance was achieved.  The
semiannual and quarterly reports are used for problem identification, as
a check on source operation and maintenance, and for compliance
determinations.  The information generated by the monitoring,
recordkeeping and reporting requirements described in this ICR is used
by the Agency to ensure that facilities affected by the NESHAP continue
to operate the control equipment in compliance with the regulation. 
Adequate monitoring, recordkeeping, and reporting are necessary to
ensure compliance with the applicable regulations, as required by the
Clean Air Act.  The information collected from recordkeeping and
reporting requirements is also used for targeting inspections, and is of
sufficient quality to be used as evidence in court.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under (40 CFR
part 63, 

subpart W).

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 their 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 68 FR 62289 on November 3, 2003. 
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, the
preparer of the active ICR, and accessed the most recent data available
on the Air Facility System (AFS) database as maintained by the Office of
Compliance.  We reviewed information available from the United States
Census Bureau, and other websites covering epoxy resin and non-nylon
polyamide resin.  We consulted with the EPA(s Office of Air Quality
Planning and Standards, Information Transfer, the Program Integration
Division and Georgia Pacific Corporation Resin Division, Mr. Randy
Roden, (229) 268-2523.		

3(d)  Effects of Less Frequent Collection

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

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR Part 1320, Section 1320.5.

These standards require affected facilities to maintain all records,
including reports and notifications for at least five years.  This is
consistent with the General Provisions as applied to the standards.  EPA
believes that the five-year record(s retention requirement is consistent
with Part 70 permit programs and the five-year statute of limitations on
which the permit program is based.  Also, the retention of records for
five years would allow EPA to establish the compliance history of a
source and any pattern of compliance for purposes of determining the
appropriate level of enforcement action.  Historically, EPA has found
that the most flagrant violators frequently have violations extending
beyond the five years.  EPA would be prevented from pursuing the worst
violators due to the destruction or nonexistence of records if records
were retained for less than five years.

3(f)  Confidentiality

Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to the Agency
policies set forth in Title 40, Chapter 1, part 2, subpart B -
Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR
42251, 

September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested



4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
basic liquid epoxy resins (BLR) and wet strength resins (WSR)
facilities.  The United States Standard Industrial Classification (SIC )
code for the respondents affected by the standards is 2821 which
corresponds to the North American Industry Classification System (NAICS
) 325211 for Epoxy Resin and Non-Nylon Polyamide Production.

4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR 1320.5.

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by the
National Emission Standards for Hazardous Air Pollutants for Epoxy Resin
and Non-Nylon Polyamide Production (40 CFR part 63, subpart W).

A source must make the following reports:

Notification Reports	

Standard Citation by Section



Notification and application of construction or reconstruction	

63.05(d)and 63.520



Initial notification	

63.09(b)



Notification of actual startup	

63.06



Initial performance test results	

63.7(b), 63.10(d)(2), and 63.09(e)



Emissions tests and results	

63.520, 63.09(e), 63.09(g) and 63.10(d)(2).



Monitoring exceedances and excess emissions	

63.520, 63.528(a), 63.10(d) and 63.10(e)



Production capacity and exceedances	

63.520, 63.09 (b) and 63.09(h)



No excess emissions	

63.520, 63.10(d) and 63.09(e)



Continuous monitoring system performance and summary report	

63.520, 63.10(e)(3) and 63.09(g)



Compliance status	

63.09(h)



Physical or operational changes	

63.520 and 63.5(b)(6)



Waiver applications	

63.520 and 63.07(h)



Periodic startup, shutdown, malfunction reports	

63.10(d)(5)(I)



Values of monitored parameters when average values are outside approved
ranges	

63.528(1) and 63.10(e)



Duration of periods when monitoring data is not collected for each
excursion caused by insufficient monitoring data	

63.528(2) and 63.10(e)



A source must keep the following records:

Recordkeeping



Startup, shutdown, malfunction and malfunction plans, excursions, and
periods where the continuous monitoring system is inoperative	

63.527, 63.528, 63.10(b)(2) and 63.06



Emission test results, engineering assessments, and other data needed to
determine emissions	

63.524, 63.526, 63.527 and 63.10(b)(2)



All reports and notifications	

63.10(b)



Record of applicability	

63.10(b)(3)



Records for sources with continuous monitoring systems	

63.10(3)



Records are required to be retained for 5 years.  The first two years of
records must be kept onsite	

63.10(b)(1)



Reports of process changes which change the status of de minimis
emission points	

63.528 and 63.10(e)



Equipment leaks - monitoring, equipment modification and 

repair records	

63.526



Electronic Reporting

Presently, sources are using monitoring equipment that provides
parameter data in an automated fashion, e.g., leaks and spills of liquid
epoxy resin and wet strength resins.  Although personnel at the source
are still required to evaluate the data, this type of monitoring
equipment has significantly reduced the burden associated with
monitoring and recordkeeping.  In addition, some regulatory agencies are
setting up electronic reporting systems to allow sources to report
electronically, which is reducing the reporting burden.  However,
electronic reporting systems are still not widely used by the regulatory
agencies.  It is estimated that approximately 10 percent of the
respondents use electronic reporting.

(ii)  Respondent Activities	

Respondent Activities



Read instructions.



Install, calibrate, maintain, and operate CMS.



Perform initial performance test, Reference Methods 1, 1A, 2, 2A, 2C,
2D, 18 and 25A test, and repeat performance tests if necessary.



Write the notifications and reports listed above.



Enter information required to be recorded above.



Submit the required reports developing, acquiring, installing, and
utilizing technology and systems for the purpose of collecting,
validating, and verifying information.



Develop, acquire, install, and utilize technology and systems for the
purpose of processing and maintaining information.



Develop, acquire, install, and utilize technology and systems for the
purpose of disclosing and providing information.



Adjust the existing ways to comply with any previously applicable
instructions 

and requirements.



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



Transmit, or otherwise disclose the information.



Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the source still need to
evaluate the data, this type of monitoring equipment has significantly
reduced the burden associated with monitoring and recordkeeping.

5.  The Information Collected:  Agency Activities, Collection
Methodology, and Information Management

5(a)  Agency Activities

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities



Observe initial performance tests and repeat performance tests if
necessary.



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



Audit facility records.



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



5(b)  Collection Methodology and Management

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

Information contained in the reports is entered into the AFS which is
operated and maintained by the EPA's Office of Compliance.  AFS is the
EPA(s database for the collection, maintenance, and retrieval of
compliance and annual emission inventory data for more than 100,000
industrial and government-owned facilities.  EPA uses the AFS for
tracking air pollution compliance and enforcement by local and state
regulatory agencies, EPA regional offices and EPA headquarters.  EPA and
its delegated Authorities can edit, store, retrieve and analyze 

the data.

The records required by this regulation must be retained by the owner or
operator for

five years.

5(c)  Small Entity Flexibility

A majority of the affected facilities are large entities (e.g., large
businesses).  However, the impact on small entities (i.e., small
businesses) was taken into consideration during the development of the
regulation.  Due to technical considerations involving the process
operations and the types of control equipment employed, the
recordkeeping and reporting requirements are the same for both small and
large entities.  The Agency considers these requirements the minimum
needed to ensure compliance and, therefore, cannot reduce them further
for small entities.  To the extent that larger businesses can use
economies of scale to reduce their burden, the overall burden will be
reduced.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Epoxy Resin and Non-Nylon Polyamide Production (40 CFR part 63, subpart
W).

6.  Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the industry for
the Subpart included in this ICR.  The individual burdens are expressed
under standardized headings believed to be consistent with the concept
of burdens under the Paperwork Reduction Act.  Where appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

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

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 3,853
hours ( Total Labor Hours from Table 1). These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the NESHAP program, the previously
approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates:

Managerial	$93.09    ($44.33 + 110%)

Technical	$64.13    ($30.54 + 110%)

Clerical	$39.65    ($18.88 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, 

June 2003, (Table 10. Private industry, by occupational and industry
group.(  The rates are from column 1, (Total compensation.(  The rates
have been increased by 110% to account for the benefit packages
available to those employed by private industry.

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The types of industry cost associated with the information collection
activities in the subject standard are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  The capital/startup costs are one time cost when a facility
becomes subject to the regulation.  The annual operation and maintenance
costs are the ongoing costs to maintain the monitors and other costs
such as photocopying and postage.

(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/Startup 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	

(F)

Number of Respondents with O&M	

(G)

Total O&M,

(E X F)



Computers,

software and monitoring devices	

$2,500	

0	

$0	

$3,000	

3	

$9,000

 	

The total capital/startup costs for this ICR are $0.  This is the total
of column D in the above table.  These costs are shown on the OMB 83-I
form in block 14(a), Total annualized capital/startup costs.

The total operation and maintenance (O&M) costs for this ICR are $9,000.
 This is the total of column G.  These costs are shown on the OMB 83-I
form in block 14(b), Total annual costs (O&M).

The total respondent costs in block 14 have been calculated as the
addition of the capital/startup 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 $9,000.  This cost is shown on the OMB 83-I
form in block 14(c), Total annualized cost requested.  The numbers in
block 14 of the OMB 83-I form are rounded to show the cost in thousands
of dollars.

6(c)  Estimating Agency Burden and Cost

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

The average annual Agency cost during the three years of the ICR is
estimated to be $11,324.  This cost is based on the average hourly labor
rate as follows:

Managerial	$54.02   (GS-13, Step 5, $33.76 x 1.6)

Technical	$40.08   (GS-12, Step 1, $25.05 x 1.6)

Clerical	$21.70   (GS-6, Step 3, $13.56 x 1.6)

These rates are from the Office of Personnel Management (OPM) (2004
General Schedule( which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Burden - NESHAP for Epoxy Resin and Non-Nylon Polyamide Production (40
CFR part 63, subpart W).

6(d)  Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, approximately seven existing sources
are currently subject to the standard.  It is estimated that no
additional sources per year will become subject to the standard in the
next three years.

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

Number of Respondents



	

Respondents That Submit Reports	

Respondents That Do Not Submit Any Reports	





Year	

(A)

Number of New Respondents 1	

(B)

Number of Existing Respondents	

(C)

Number of Existing Respondents That Keep Records but Do Not Submit
Reports	

(D)

Number of Existing Respondents That Are Also New Respondents	

(E)

Number of Respondents

(E=A+B+C-D)



1	

1	

7	

0	

1	

7



2	

1	

7	

0	

1	

7



3	

1	

7	

0	

1	

7



Average	

1	

7	

0	

1	

7

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.

.

To avoid double-counting respondents, column D is subtracted.   As shown
above, the average Number of Respondents over the three-year period of
this ICR is seven.  This number appears on the OMB 83-I form in block
13(a), Number of respondents.

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

Total Annual Responses



(A)

Information Collection Activity	

(B)

Number of Respondents	

(C)

Number of Responses	

(D)

Number of Existing Respondents That Keep Records But Do Not Submit
Reports	

(E)

Total Annual Responses 

E=(BxC)+D



Notification of physical and operational changes	

1	

1	

N/A	

1



Startup, shutdown, malfunction report	

1	

1	

N/A	

1



Report of monitoring exceedances and periods of noncompliance	

1	

4	

N/A	

4



Report of no excess emissions 	

6	

2	

N/A	

12



	

Total	

18



The number of Total Annual Responses is 18.  This number is shown on the
OMB 83-I form in block 13(b), Total annual responses.  Note that two
respondents have been double counted in the above table because they
have both been existing affected facilities and new affected facilities.

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The total annual labor costs are $243,711.  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 Epoxy
Resin and Non-Nylon Polyamide Production (40 CFR part 63, subpart W).

Note that the total annual capital and O&M costs to the regulated entity
are $9,000.  This number is shown on the OMB 83-I form in block 14(c),
Total annualized cost requested.  These costs are detailed in Section
6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the agency and the
respondents are attached.  The annual public reporting and recordkeeping
burden for this collection of information is estimated to average 214
hours per response.

6(f)  Reasons for Change in Burden

The adjustment decrease in the hourly burden from the most recently
approved ICR is due in part to a decrease in the number of sources. 
There are thirteen sources in the active ICR compared to seven sources
in the renewal, thus reflecting the change in the hourly burden.  Even
though there is a decrease in the number of sources in the renewal ICR,
the total burden and cost show a slight increase.  This increase in cost
is due to a revised hourly labor rate from the United States Department
of Labor.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information are estimated to average 214 hours per response.  Burdens
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, or disclose or provide information to or
for a Federal agency.  This includes the time needed to review
instructions; develop, acquire, install, and utilize technology and
systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a valid OMB
Control Number.  The OMB Control Numbers for EPA(s regulations are
listed at 40 CFR part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
a respondent burden, including the use of automated collection
techniques, EPA has established a public docket for this ICR under
Docket ID Number OECA-2003-0140, which is available for public viewing
at the Enforcement and Compliance Docket and Information Center in the
EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution
Avenue, NW, Washington, D.C.  The EPA Docket Center Public Reading Room
is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding
legal holidays.  The telephone number for the Reading Room is (202)
566-1744, and the telephone number for the Enforcement and Compliance
Docket and Information Center Docket is (202) 566-1752.  An electronic
version of the public docket is available through EPA Dockets (EDOCKET)
at http://www.epa.gov/edocket.  Use EDOCKET to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select (search,( then key in the
Docket ID Number identified above.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 

725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Office for
EPA.  Please include the EPA Docket ID Number OECA-2003-0140 and OMB
Control Number 2060-0290 in 

any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting

this information.

Table 1:  Annual Respondent Burden and Cost - NESHAP for Epoxy Resin
and Non-Nylon Polyamide Production 

(40 CFR part 63, subpart W) (Renwal).

	Burden item	

	(A)

Technical Person-

hours per

occurrence	

(B)   

No.  of

occurrences

per respondent

per year	

(C)

Technical Person-

hours per

respondent

per year

(C=AxB)	

(D)

Respondents

per year 	

(E)

Technical

person-

hours per

year

(E=CxD)	

(F)

Management

person-hours per

year

(Ex0.05)	

(G)

Clerical

person-

hours per year

(Ex0.1)	

(H)

Total Cost

Per Year  a



1.  Applications	

N/A	

	

	

	

	

	

	





 2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Reporting Requirements	

	

	

	

	

	

	

	





    A.  Read instructions	

1	

1	

1	

0b,c	

0	

0	

0	

$0



    B.  Required activities	

	

	

	

	

	

	

	





      Basic liquid resins (BLR)	

1,050	

1	

1,050	

0b,c	

0	

0	

0	

$0



      Repeat initial performance                  test - process vents	

1,050	

1	

1,050	

0b,c	

0	

0	

0	

$0



      Initial performance test  -                   wastewater	

270	

1	

270	

0b,c	

0	

0	

0	

$0



      Repeat initial performance                  test - wastewater	

270	

1	

270	

0b,c	

0	

0	

0	

$0



      Wet strength resins (WSR)	

270	

1	

270	

0b,c,d	

0	

0	

0	

$0



    C.  Create information	

Included in 3B, 4D, 4E	

	

	

	

	

	

	





    D.  Gather existing information	

Included in 3B, 4D, 4E	

	

	

	

	

	

	





    E.  Write Report	

	

	

	

	

	

	

	





      Notification of construction/               reconstruction/startup


2	

1	

2	

0b,c	

0	

0	

0	

$0



     Notification of physical and               operational changes	

2	

1	

2	

1e	

2	

0.1	

0.2	

$145.50



    Notification of anticipated startup	

0	

0	

0	

0b,c	

0	

0	

0	

$0



     Notification of actual startup	

2	

1	

2	

0b,c	

0	

0	

0	

$0



     Notification of applicability of           the standard - existing
sources	

2	

1	

2	

0b,c	

0	

0	

0	

$0



     Notification of applicability of           the standard - new
sources    	

2	

1	

2	

0b,c	

0	

0	

0	

$0



     Notification of initial                          performance test	

2	

1	

2	

0b,c	

0	

0	

0	

$0



     Report of initial test (including           CMS performance
evaluation             and results)	

6	

1	

6	

0b,c	

0	

0	

0	

$0



     Submit quality control plan for           CMS	

2	

1	

2	

0b,c,f	

0	

0	

0	

$0



     Submit startup, shutdown,                  malfunction plan 	

2	

1	

2	

1	

2	

0.1	

0.2	

$145.50



     Report of monitoring                          exceedances and
periods of                noncompliance	

16	

4	

64	

1g	

64	

3.2	

6.4	

$4,655.97



     Report of no excess emissions	

8	

2r	

16	

6h	

96	

4.8	

9.6	

$6,983.95



     Report of area source                          becoming major	

6	

1	

6	

0i	

0	

0	

0	

$0



     Waiver application	

6	

1	

6	

1j	

6	

0.3	

0.6	

$436.50



     Compliance status information           report	

4	

1 	

4	

0b,c	

0	

0	

0	

$0



4.  Recordkeeping Requirements	

	

	

	

	

	

	

	





A.  Read instructions	

Included in 3A	

	

	

	

	

	

	





B.  Plan activities	

N/A	

	

	

	

	

	

	





C.  Implement activities	

Included in 4D and 4E	

	

	

	

	

	

	





D.  Develop record system	

40	

1	

40	

0b,c	

0	

0	

0	

$0



E.  Time to enter information	

	

	

	

	

	

	

	





     a.  Records of startup,                         shutdown,
malfunction, etc.	

2	

1	

2	

1	

2	

0.1	

0.2	

$145.50



     b.  Records of control device               monitoring parameters:

          -  Continuously monitored                  parameters

          -  LDAR program reporting               and recordkeeping -
BLR

          -  LDAR program reporting               and recordkeeping -
WSR

          -  Wastewater parameters	

12

311

11

2	

52

1

1

12	

624

311

11

24	

3k,l

3k

4m

3k,n	

1,872

933

44

72	

93.6

46.65

2.2

3.6	

187.2

93.3

4.4

7.2	

$136,187.06

$67,875.28

$3,200.98

$5,237.96



F.  Other recordkeeping activities

     a.  Maintain records of

     occurrence and duration of 

     each SSM of process and                    control equipment

	

2	

8	

16	

7h,o	

112	

5.6	

11.2	

$8,147.94



     b.  Maintain records of all

     maintenance performed on air

     pollution control equipment.

     c.  Maintain records of all                   actions taken during
periods               of SSM that differ from the               
sources( SSM plan.

     d.  Maintain records of each               period during which a
CMS is            malfunctioning or inoperative

     e.  Maintain records of results            of all performance tests
and                performance evaluations.

     f.  Maintain all initial                          notification and
compliance               status notifications.

     g.  Submit semiannual SSM               reports.

     h.  Submit immediate reports              of inconsistent
procedures                  monitored at each affected                 
source.

     i.  Submit a CMS summary                report for HAP monitored at
              each affected source.	

2

2

2

2

1

2

2

2	

4

1

1

1

1

2

1

1	

8

2

2

2

1

4

2

2	

7h

7h,p

3k

7h

7h

7h,q

7h

3k	

56

14

6

14

7

28

14

6

	

2.8

0.7

0.3

0.7

0.35

1.4

0.7

0.3	

5.6

1.4

0.6

1.4

0.7

2.8

1.4

0.6	

$4,073.97

$1,018.49

$436.50

$1,018.49

$509.24

$2,036.99

$1,018.49

$436.50



G.  Time to train personnel	

N/A	

	

	

	

	

	

	





H.  Time for audits	

N/A	

	

	

	

	

	

	





Subtotal Labor Burden	

	

	

	

	

3,350	

167.5	

335	

$243,710.81



TOTAL LABOR  BURDEN AND COST (rounded)	

	

	

	

	

3,853	

$243,711

Assumptions:

a  This ICR uses the following labor rates: $93.09 per hour for
Executive, Administrative, and Managerial labor; $64.13 per hour for
Technical labor, and $39.65 per hour for Clerical labor.  These rates
are from the United States Department of Labor, Bureau of Labor
Statistics, June 2003, (Table 10. Private industry, by occupational and
industry group.(

b  Assume that there will be no new sources over the next three years
subject to this rule.

c  Assume that this is a one-time-only cost.

d  For all wet strength resins (WSR) facilities, as an alternative to
implementing the standards for process vents, storage tanks, and
wastewater, these facilities may elect to comply with the requirements
of 40 CFR part 63, subpart H - leak detection and repair program for
equipment leaks.  Because of it being more cost-effective, it is assumed
that all WSR facilities will choose to comply with the alternative
standard.  These facilities are not required to have the continuous
monitoring systems (CMS) installed.

e  Assume that one facility will have a physical or operational change.

f   It will require one test each for wastewater and process vents.

g  It is assumed that one facility will have excess emissions.

h  Assume that there are seven sources that are subject to this
regulation, so the number of sources without excess emission reports is
six.

i  It is assumed that no area sources are expected to become major
sources.

j   Assume that one facility will request a waiver.

k  Assume that there are three basic liquid resins (BLR) manufacturing
facilities

l  These parameters will automatically be recorded with a data logger.

m  Assume that there are four WSR facilities subject to the rule.

n  Assume it will take two hours to record wastewater parameters during
the monthly monitoring.

o  Assume startup, shutdown, and/or malfunction (SSM) will occur eight
times per facility.

p   Assume it takes one deviation from SSM plan per year per facility.	

q  Assume it will take two hours to submit semiannual (SSM) reports.

r  Quarterly reporting may be reduced to semiannual reporting for
sources that are in compliance for one year.		

Table 2:  Average Annual EPA Burden - NESHAP for Epoxy Resin and
Non-Nylon Polyamide Production

(40 CFR part  63, subpart W)

	Burden Item	

(A)

Technical Person

Hours Per

Occurrence	

(B)   

Number  of

Occurrences

Per Plant

Per Year	

(C)

Technical

Person

Hours Per Plant Per

Year

(C=AxB)	

(D)

Plants Per  Year 	

(E)

Technical Hours 

Per Year

(E=CxD)	

	(F)

Management   Hours Per Year

(F=0.05xE)	

(G)

Clerical

Hours Per

Year

(G=0.1xE)	

(H)

Total a

Costs,    

Per Year 





Initial Performance Test             	

60	

0	

0	

0b,c	

0	

0	

0	

$0



Repeat initial performance test	

60	

0	

0	

0b,c	

0	

0	

0	

$0



     1.  Retesting preparation	

16	

0	

0	

0b,c	

0	

0	

0	

$0



     2.  Retesting	

60	

0	

0	

0b,c	

0	

0	

0	

$0



Report Review	

	

	

	

	

	

	

	





   Notification of construction         reconstruction and startup	

2	

0	

0	

0b,c	

0   	

0	

0	

$0



   Notification of Physical and        operational changes	

2	

1	

2	

1d	

2	

0.1	

0.2	

$89.90



   Notification of actual startup	

2	

0	

0	

0b	

0	

0	

0	

$0



   Notification of anticipated           startup	

0	

0	

0	

0b	

0	

0	

0	

$0



   Notification of applicability        of the standard-new sources	

2	

0	

0	

0b	

0	

0	

0	

$0



   Notification of initial                   performance test	

2	

0	

0	

0b	

0	

0	

0	

$0



   Report of initial test	

8	

0	

0	

0b	

0	

0  	

0	

$0



   Startup, shutdown,                       malfunction (SSM) plan	

4	

0	

0	

0b	

0	

0	

0	

$0



   Quality control plan for CMS	

4	

0	

0	

0b,c	

0	

0	

0	

$0



   Semiannual SSM reports	

4	

2	

8	

6e,f	

48	

   2.4   	

4.8	

$2,243.81



   CMS summary report

   for HAP	

4	

3	

12	

7e	

84	

4.2	

8.4	

$3,775.88



   Compliance status                        information report	

4	

1	

4	

7e	

28	

1.4	

2.8	

$1,258.63



   Report of monitoring                   exceedances and periods of    
    noncompliance	

8	

4	

32	

1g	

32	

1.6	

3.2	

$1,438.43



   Report of no excess emission	

2	

4	

8	

6e	

48	

2.4	

4.8	

$2,157.65



    Waiver application	

8	

1	

8	

1h	

8	

0.4	

0.8	

$359.61



Subtotal	

	

	

	

	

250	

12.5	

25	

$11,323.91



Travel Expenses 	

 (1 person x 0 plant/yr x 1 day/plant x $50 per diem) + ($400/round trip
x 0 round trips/yr) =                                    $0



TOTAL LABOR BURDEN and COST (rounded)	

	

	

288	

$11,324



Assumptions:

a   This cost is based on the following hourly labor rates times a 1.6
benefits multiplication factor to account for government overhead
expenses: $54.02 for Managerial (GS-13, Step 5, $33.76 x 1.6), $40.08
for Technical (GS-12, Step 1, $25.05 x 1.6) and $21.70 Clerical (GS-6,
Step 3, $13.56 x 1.6).  These rates are from the Office of Personnel
Management (OPM) (2003 General Schedule( which excludes locality rates
of pay.

b  Assume that there will be no new sources over the next three years.

c  Assume that this is a one-time-only cost.

d  Assume that one facility will conduct some form of physical or
operational change.

e  Assume that there are six sources that are subject to this regulation
that report semiannually. 

f  It will take four hours to review semiannual reports.

g  It is assumed that one facility will have excess emissions.

h  Assume that one facility will request a waiver.



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