	SF-83 SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Vinyl Chloride (40 CFR part 61, subpart F) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Vinyl Chloride (40 CFR part 61, subpart F) (Renewal)

1(b)  Short Characterization/Abstract

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

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

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

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

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


be $754,515.

The Office of Management and Budget (OMB) approved the currently active
ICR without any (Terms of Clearance.(

2.  Need for and Use of the Collection

2(a)  Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants.  These
standards are applicable to new or existing sources of hazardous air
pollutants and will require the maximum degree of emission reduction. 
In addition, section 114(a) states that the Administrator may require
any owner/operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C)
install, use, and maintain such monitoring equipment, and use such audit
procedures, or methods; (D) sample such emissions (in accordance with
such procedures or methods, at such locations, at such intervals, during
such periods, and in such manner as the Administrator shall prescribe);
(E) keep records on control equipment parameters, production variables
or other indirect data when direct monitoring of emissions is
impractical; (F) submit compliance certifications in accordance with
Section 114(a)(3); and (G) provide such other information as the
Administrator may reasonably require.

In the Administrator's judgment, vinyl chloride plants which produce: 1)
ethylene dichloride by reaction of oxygen and hydrogen chloride with
ethylene; 2) vinyl chloride by any process; and/or 3) one or more
polymers containing any fraction of polymerized vinyl chloride - cause
or contribute to air pollution that may reasonably be anticipated to
endanger public health or welfare.  Therefore, the NESHAP was
promulgated for this source category at 40 CFR part 61, subpart F.

2(b)  Practical Utility/Users of the Data

The control of emissions of vinyl chloride from plants which produce: 1)
ethylene dichloride by reaction of oxygen and hydrogen chloride with
ethylene; 2) vinyl chloride by any process; and/or 3) one or more
polymer containing any fraction of polymerized vinyl chloride - requires
not only the installation of properly designed equipment, but also the
operation and maintenance of that equipment.  Emissions of vinyl
chloride from these plants are the result of the operation of the
affected facilities.  The subject standards are achieved by the
reduction of vinyl chloride using control technology and leak detection
and repair procedures.

The notifications required in the applicable regulations are used to
inform the Agency or delegated authority when a source becomes subject
to the requirements of the regulations.  The reviewing authority may
then inspect the source to check if the pollution control devices are
properly installed and operated and the regulations are being met. 
Performance test reports are needed as these are the Agency's records of
a source's initial capability to comply with the emission standards, and
serve as a record of the operating conditions under which compliance was
achieved.

The information generated by the monitoring, recordkeeping and reporting
requirements described in this ICR is used by the Agency to ensure that
facilities affected by the NESHAP continue to operate the control
equipment in compliance with the regulation.  Adequate monitoring,
recordkeeping, and reporting are necessary to ensure compliance with the
applicable regulations, as required by the Clean Air Act.  The
information collected from recordkeeping and reporting requirements is
also used for targeting inspections, and is of sufficient quality to be
used as evidence in court.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
61, subpart F.

3(a)  Nonduplication

If the subject standards have not been delegated, the information is
sent directly to the appropriate EPA regional office.  Otherwise, the
information is sent directly to the delegated state or local agency.  If
a state or local agency has adopted its own similar standards to
implement the Federal standards, a copy of the report submitted to the
state or a local agency can be sent to the Administrator in lieu of the
report required by the Federal standards.  Therefore, no duplication
exists.

3(b)  Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR
was published in the Federal Register 69 FR 29718 on May 25, 2004.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

For this information collection, we referenced the most recent ICR and 
the preparer of the active ICR, and accessed the most recent data
(August 18, 2004) available on the Air Facility System (AFS) database as
maintained by the Office of Compliance.  We reviewed information
available from the Office of Compliance Sector Notebook (Profile of the
Inorganic Chemical Industry,( the United States Census Bureau, and other
websites covering vinyl chloride plants. We also consulted with the
EPA(s Office of Air Quality Planning and Standards, Information Transfer
and Program Integration Division, and Kimberly Bennett, Formosa Plastics
Corporation (302) 836-2225.

3(d)  Effects of Less Frequent Collection

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

3(e)  General Guidelines

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

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

3(f)  Confidentiality

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

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

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

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

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

4(b)  Information Requested

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

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
National Emission Standards for Hazardous Air Pollutants for Vinyl
Chloride (40 CFR part 61, subpart F).

A source must make the following reports:

Notification Reports	

Standard Citation by Section



Notification and application of construction or modification.	

61.07



Notification of anticipated date of initial startup.	

61.09(a)(1)



Notification of actual startup.	

61.09(a)(2)



Notification of physical or operational change which may increase the
emission rate.	

61.15



Notification of performance tests.	

61.13(f)



Notification of emissions testing.	

61.13(c)



Application for waiver of testing.	

61.13(i)(1), and 61.13(i)(2)



Application for equivalent equipment and procedures.	

61.66



Initial report.	

61.69



Quarterly report.	

61.70(a)(1)



Manual vent valve (MVV) discharge report.	

61.64(a)(3)



Relief valve discharge (RVD) report.	

61.65(a)



A source must keep the following records:

Recordkeeping



Startup, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative.	

61.14(f)



Emission test results and other data needed to determine emissions.	

61.13(g) and 61.71(a)(3)



Records of leak detected.	

61.71(a)(1), and 61.71(a)(2)



Performance test records, leaks detected, emissions records, and daily
operating records are required to be retained on-site for 

three years.	

61.67(f) and 61.71(a)



Electronic Reporting

Currently, sources are using monitoring equipment that provides
automated parameter data, e.g., leaks and spills of ethylene dichloride,
vinyl chloride, and polyvinyl chloride.  Although personnel at the
affected facility must evaluate the data, this type of monitoring
equipment has significantly reduced the burden associated with
monitoring and recordkeeping.  In addition, some regulatory agencies are
setting up electronic reporting systems to allow sources to report
electronically, which is reducing the reporting burden.  However,
electronic reporting systems are still not widely used by the regulatory
agencies.  It is estimated that approximately 10 percent of the
respondents use electronic reporting.

(ii)  Respondent Activities	

Respondent Activities



Read instructions.



Perform initial performance test, Reference Method 106, 107, and/or 601
test, and repeat performance tests if necessary.



Write the notifications and reports listed above.



Enter information required to be recorded above.



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



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



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



Adjust the existing ways to comply with any previously applicable
instructions 

and requirements.



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



Transmit, or otherwise disclose the information.



Use of automated monitoring equipment has significantly reduced the
burden associated with monitoring and recordkeeping.

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

5(a)  Agency Activities

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

Agency Activities



Observe initial performance tests and repeat performance tests if
necessary.



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



Audit facility records.



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



5(b)  Collection Methodology and Management

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

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

5(c)  Small Entity Flexibility

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

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in Table 1: Annual Industry Burden for NESHAP for
Vinyl Chloride (40 CFR part 61, subpart F).

6.  Estimating the Burden and Cost of the Collection

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

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

6(a)  Estimating Respondent Burden

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 11,825
hours (Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of the regulation,
Agency knowledge and experience with the NESHAP program, the previously
approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs

This ICR uses the following labor rates:

Managerial	$95.32   ($45.39 + 110%)

Technical	$64.60   ($30.76 + 110%)

Clerical	$40.09   ($19.09 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, December 2003, (Table 10. Private industry, by
occupational and industry group.(  The rates are from column 1, (Total
compensation.(  The rates have been increased by 110% to account for the
benefit packages available to those employed by private industry.

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

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

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs



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)



Continuous Emission Monitor (CEM) 	

$150,000	

0	

$0	

$45,000	

28	

$1,260,000



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

The total operation and maintenance (O&M) costs for this ICR are
$1,260,000.  This is the total of column G.  These costs are shown on
the OMB 83-I form in block 14(b), Total annual costs (O&M).

The total respondent costs in block 14 have been calculated as the
addition of the capital/startup cost, and the annual operation and
maintenance costs.  The average annual cost for capital/startup and
operation and maintenance to the industry over the next three years of
the ICR is estimated to be $1,260,000.  This cost is shown on the OMB
83-I form in block 14(c), Total annualized cost requested.  The numbers
in block 14 of the OMB 83-I form are rounded to show the cost in
thousands of dollars.

6(c)  Estimating Agency Burden and Cost

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

The average annual Agency cost during the three years of the ICR is
estimated to be $112,082.  This cost is based on the average hourly
labor rate as follows:

Managerial	$54.66   (GS-13, Step 5, $34.16 x 1.6)

Technical	$40.56   (GS-12, Step 1, $25.35 x 1.6)

Clerical	$21.95   (GS-6,   Step 3, $13.72 x 1.6)

These rates are from the Office of Personnel Management (OPM) (2004
General Schedule( which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2. Average Annual EPA
Burden - NESHAP for Vinyl Chloride (40 CFR part 61, subpart F).

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

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

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

Number of Respondents



	

Respondents That Submit Reports	

Respondents That Do Not Submit Any Reports	





Year	

(A)

Number of New Respondents 1	

(B)

Number of Existing Respondents	

(C)

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

(D)

Number of Existing Respondents That Are Also New Respondents	

(E)

Number of Respondents

(E=A+B+C-D)



1	

0	

28	

0	

0	

28



2	

0	

28	

0	

0	

28



3	

0	

28	

0	

0	

28



Average	

0	

28	

0	

0	

28

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

To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 28.  This number appears on the OMB 83-I form in block
13(a), Number of respondents.

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

Total Annual Responses



(A)

Information Collection Activity	

(B)

Number of Respondents	

(C)

Number of Responses	

(D)

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

(E)

Total Annual Responses

E=(BxC)+D



Quarterly report	

28	

4	

N/A	

112



Manual vent valve/relief valve discharge (MVV/RVD) report	

28	

3	

N/A	

 84



	

	

	

Total	

196





The number of Total Annual Responses is 196.  This number is shown on
the OMB 83-I form in block 13(b), Total annual responses.

The total annual capital/startup and O&M costs to the regulated entities
are $1,260,000. This number is shown on the OMB 83-I form in block
14(c), Total annualized cost requested.  The cost calculations are
detailed in Section 6(b)(iii), Capital/Startup vs. Operation and
Maintenance (O&M) Costs.

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

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

The detailed bottom line burden hours and cost calculations for the
respondents and the Agency are shown in Tables 1 and 2, respectively,
and summarized below.

(i) Respondent Tally

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The total annual hours are 11,825, and labor costs are $754,515.  The
annual labor costs are not shown on the OMB 83-I form. Details regarding
these estimates may be found in Table 1. Annual Respondent Burden and
Cost, NESHAP for Vinyl Chloride (40 CFR part 61, subpart F), which is
attached.  Furthermore, the annual public reporting and recordkeeping
burden for this collection of information is estimated to average 60
hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $1,260,000. This number is shown on the OMB 83-I form in block
14(c), Total annualized cost requested.  The cost calculations are
detailed in Section 6(b)(iii), Capital/Startup vs. Operation and
Maintenance (O&M) Costs.

(ii) The Agency Tally

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

6(f)  Reasons for Change in Burden

The adjusted decrease in the burden from the most recently approved ICR
is due to a decrease in the number of existing sources.  There are
forty-four sources in the active ICR compared to twenty-eight sources in
this ICR, reflected in the change in the hourly burden.

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

6(g)  Burden Statement

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

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
OECA-2004-0011, which is available for public viewing at the Enforcement
and Compliance Docket and Information Center in the EPA Docket Center
(EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, Washington,
DC. The EPA Docket Center Public Reading Room  is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Enforcement and Compliance Docket and
Information Center is (202) 566-1752.  An electronic version of the
public docket is available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket.  Use EDOCKET to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  Once in the system, select (search,( then key in the
docket ID number identified above.  Also, you can send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number OECA-2004-0011
and OMBC number 2060-0071 in any correspondence. 

Part B of the Supporting Statement

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

this information.

Table 1: Annual Respondent Burden and Cost - NESHAP for Vinyl Chloride
(40 CFR part 61, subpart F)(Renewal)

	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 a	

(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  b



1.  Applications	

N/A	

	

	

	

	

	

	





2.  Survey and Studies	

N/A	

	

	

	

	

	

	





3.  Reporting requirements 	

	

	

	

	

	

	

	





  A.  Read Instructions	

1	

1	

1	

0	

0	

0	

0	

$0



  B.  Required Activities	

	

	

	

	

	

	

	





       Initial performance tests        	

60c	

1	

60	

0	

0	

0	

0	

$0



       Repeat performance tests d      	

60	

0.20	

12	

0	

0	

0	

0	

$0



  C.  Create Information		

Included in 3B	

	

	

	

	

	





  D.  Gather Existing information 	

Included in 3B	

	

	

	

	

	





  E.  Write report	

	

	

	

	

	

	

	





       Notification of                                
construction/reconstruction	

2	

1	

2	

0	

0	

0	

0	

$0



       Notification of anticipated              startup	

2	

1	

2	

0	

0	

0	

0	

$0



       Notification of actual startup	

2	

1	

2	

0	

0	

0	

0	

$0



       Notification of emissions                testing	

2	

1	

2	

0	

0	

0	

0	

$0



       Emissions of test report	

2	

1	

2	

0	

0	

0	

0 	

$0



       Notification of physical or e             operational change	

2	

1	

2	

0	

0	

0	

0	

$0



       Application for waiver of f               testing	

8	

1	

8	

0	

0	

0	

0	

$0



       Application of equivalency g	

40	

1	

40	

0	

0	

0	

0	

$0



       Initial report	

24	

1	

24	

0	

0	

0	

0	

$0



       Quarterly report h	

50	

4	

200	

28	

5,600	

280	

560	

$410,900.00



       MVV/RVD report i	

8	

 3i	

24	

28	

672	

33.6	

67.2	

$49,308.00



4.  Recordkeeping Requirements 	

	

	

	

	

	

	

	





  A.  Read instructions	

Included in3A	

	

	

	

	

	





  B.  Plan activities	

Included in3B	

	

	

	

	

	





  C.  Implement activities	

Included in3B	

	

	

	

	

	





  D.  Develop record system	

N/A	

	

	

	

	

	

	





  E.  Time to enter information     	

	

	

	

	

	

	

	





       Records of reactor                           parameters and
emission      	

0.25	

365j	

91.25	

28	

2,555	

127.75	

255.5	

$187,473.13



       Records of leaks detected      	

1	

52k	

52	

28	

1,456	

72.8	

145.6	

$106,834.00



  F.  Time to train personnel	

N/A	

	

	

	

	

	

	





  G.  Time for audits	

N/A	

	

	

	

	

	

	





Subtotal Labor Burden	

	

	

	

	

10,283	

514.15	

1,028.3	

$754,515.13



TOTAL LABOR  BURDEN AND COST (rounded)	

	

	

	

	

11,825	

$754,515



Assumptions:

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

b  This ICR uses the following labor rates:  $95.32 per hour for
Executive, Administrative, and Managerial labor; $64.60  per hour for
Technical labor, and $40.09

per hour for Clerical labor.  These rates are from the United States
Department of Labor, Bureau of Labor Statistics, December 2003, (Table
10. Private industry, by occupational and industry group.(  The rates
are from column 1, (Total compensation.(  The rates have been increased
by 110% to account for the benefit packages available to those employed
by private industry.

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

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

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

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

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

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

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

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

k  It is estimated that it will occur fifty-two times per year to enter
records of leak detection.

Table 2: Average Annual EPA Burden - NESHAP for Vinyl Chloride (40 CFR
part 61, subpart F)(Renewal)

	Burden item	

(A)

Technical

Person

Hours Per

Occurrence	

(B)   

Number  of

Occurrences

Per Year	

(C)

Technical

Person Hours Per Plant Per

Year

(C=AxB)	

(D)

Plants Per  Year a	

(E)

Technical Hours 

Per Year

(E=CxD)	

(F)

Management   Hours Per Year

(F=0.05xE)	

(G)

Clerical

Hours Per

Year

(G=0.1xE)	

(H)

Total

Cost, 

Per Yearb



Activity	

	

	

	

	

	

	

	





1.  Initial performance tests c	

24	

1	

24	

0	

0	

0	

0	

$0



2.  Repeat performance test d	

24	

0.20	

4.8	

0	

0	

0	

0	

$0



3.  Report review	

	

	

	

	

	

	

	





      Notification of                            
construction/reconstruction	

1	

1	

1	

0	

0	

0	

0	

$0



      Notification of anticipated           startup	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



      Notification of actual                   startup	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



      Notification of emissions             testing	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



      Notification of physical or e         operational change	

0.5	

1	

0.5	

0	

0	

0	

0	

$0



      Emissions test report f	

24	

1	

24	

0	

0	

0	

0	

$0



      Application for waiver of g          testing	

24	

1	

24	

0	

0	

0	

0	

$0



      Application for equivalency	

24	

1	

24	

0	

0	

0	

0	

$0



      Initial report	

24	

1 	

24	

0	

0	

0	

0	

$0



      Quarterly report h	

4	

4	

16	

28	

448	

22.4	

44.8	

$20,378.62



      MVV/RVD report i	

24	

3i	

72	

28	

2,016	

100.8	

201.6	

$91,703.81



Subtotal 	

	

	

	

	

2,464	

123.2	

246.4	

$112,082.43



TOTAL LABOR BURDEN and COST (rounded)	

	

	

2,834	

$112,082



Assumptions:

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

b  This cost is based on the following hourly labor rates times a 1.6
benefits multiplication factor to account for government overhead
expenses: $54.66 for Managerial (GS-13, Step 5, $34.16 x 1.6), $40.56
for Technical (GS-12, Step 1, $25.35 x 1.6) and $21.95 Clerical (GS-6,
Step 3, $13.72 x 1.6).  These rates are from the Office of Personnel
Management (OPM) (2004 General Schedule( which excludes locality rates
of pay.

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

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

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

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

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

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

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

 PAGE  20 

