SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

 NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart
HHH) (Renewal)

1.  Identification of the Information Collection

	1(a)  Title of the Information Collection

NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart
HHH) (Renewal)

EPA ICR Number 1156.11, OMB Control Number 2060-0059

	1(b)  Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Synthetic Fiber
Production Facilities were proposed on November 23, 1982, and
promulgated on April 5, 1984, and amended on October 17, 2000 (65 FR
61768).  These standards apply to affected facilities at synthetic fiber
production plants including each solvent-spun synthetic fiber process
that produces more than 500 megagrams of fiber per year that commenced
construction or reconstruction after November 23, 1982.  The provisions
of this subpart do not apply to any facility that uses the reaction
spinning process to produce spandex fiber, or the viscose process to
produce rayon fiber, or to facilities that commence modification but not
reconstruction after November 23, 1982.  Volatile organic compounds
(VOCs) are the pollutants regulated under this subpart.  This
information is being collected to assure compliance with 40 CFR part 60,
subpart HHH.

	In general, all NSPS 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.  These notification, reports, and records are essential in
determining compliance, and are required of all sources subject to NSPS.

	Any owner/operator subject to the provisions of this part shall
maintain a file of these measurements, and retain the file for at least
two 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 U.S. Environmental Protection Agency
(EPA) regional office.

	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 22 existing sources that are currently
associated with the rule, and it is estimated that no new sources will
become subject to the standard in the next three years.

The Office of Management and Budget (OMB) approved the current
Information Collection Request (ICR) without any “Terms of
Clearance.”

The burden to the “Affected Public” may be found below in Table 1:
Annual Respondent Burden and Cost – NSPS for Synthetic Fiber
Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal).  The
burden to the “Federal Government” is attributed entirely to work
performed by federal employees or government contractors; this burden
may be found below in Table 2: Average Annual EPA Burden - NSPS for
Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH)
(Renewal).     

2.  Need for and Use of the Collection

	2(a)  Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as
amended, to establish standards of performance for new stationary
sources that reflect: 

. . . application of the best technological system of continuous
emissions reduction which (taking into consideration the cost of
achieving such emissions reduction, or any non-air quality health and
environmental impact and energy requirements) the Administrator
determines has been adequately demonstrated.  Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated
technology (BDT).  Section 111 also requires that the Administrator
review and, if appropriate, revise such standards every four years.

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, pollutant emissions from volatile
organic compounds (VOCs) cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NSPS were promulgated for this source category at 40 CFR
part 60, subpart HHH.

	2(b)  Practical Utility/Users of the Data

	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 check if the pollution control devices are
properly installed and operated, that leaks are being detected and
repaired, and that the standards are being met.  The performance test
may also be observed.

3.  Non-duplication, Consultations, and Other Collection Criteria

	The requested recordkeeping and reporting are required under 40 CFR
part 60, subpart HHH.

	3(a)  Non-duplication

	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 (74 FR 38004) on July 30, 2009. 
No comments were received on the burden published in the Federal
Register.

	3(c)  Consultations

Consultation with an industry representative (i.e., respondent) was
conducted during a previous ICR renewal to determine if there is anyway
for EPA to reduce the recordkeeping and reporting burden or improve the
language in the standard to make it easier to comply.  Our contact was:
Mr. Robert Barker, American Fiber Manufacturers Association Incorporated
(AFMA), (727) 772-1685.

During a previous renewal, the most recent ICR was referenced and the
preparer of the active ICR was consulted.  In addition, other resources
were used to obtain the most recent data available.  Available
information from the following sources were reviewed: the United States
Census Bureau, the AIRS Facility Subsystem (AFS), the primary source of
information regarding the number of existing sources, and websites
covering synthetic fiber production facilities.  EPA's Office of Air
Quality Planning and Standards, Information Transfer and Program
Integration Division was also consulted.

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 that 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

	These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB at 5 CFR part 1320, section 1320.5.

	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 (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

	3(g)  Sensitive Questions

	The reporting or recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

	4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
synthetic fiber production facilities.  The United States Standard
Industrial Classification (SIC) codes for the respondents affected by
the standards, which corresponds to the North American Industry
Classification System (NAICS) codes, are listed below for source
category descriptions.

Standard (40 CFR part 60, subpart HHH)	SIC Codes	NAICS Codes

Manmade Organic Fibers, Except Cellulosic	2824	325222

Cellulosic Manmade Fibers	2823	3252211



	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

In this ICR, all the data that is recorded or reported is required by
NSPS for Synthetic Fiber Production Facilities (40 CFR part 60, subpart
HHH).

	A source must make the following reports:

Notifications	Standard Citation by Sections

Notification of construction/reconstruction	60.7(a)(1)

Notification of initial startup including compliance method	60.7(a)(3)

Notification of initial performance test	60.8(d), 60.604(a)

Performance test results	60.8(a), 60.604(a)(1)

Demonstration of continuous monitoring system	60.7(a)(5)

Physical or operational change	60.7(a)(4)

Quarterly reports of exceedances or semiannual report of no exceedances
60.604(a)(2)

Reports within 30 days whenever extruded fiber for the preceding twelve
calendar months exceeds 551 tons, if exempt from standard under Section
60.600	60.604(b)



	A source must make the following reports:

Recordkeeping 

Record of startup, shutdown, and malfunctions	60.7(b)

Records are required to be retained for two years	60.7(f)



Electronic Reporting

	Some of the respondents use monitoring equipment that automatically
records parameter data.  Although personnel at the affected facility
must evaluate the data, internal automation has significantly reduced
the burden associated with monitoring and recordkeeping at a plant site.

	Also, regulatory agencies in cooperation with the respondents continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems are 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.

Install, calibrate, maintain, and operate monitoring devices that
continuously measure and record for each calendar month the amount of
makeup solvent and solvent feed.

Perform performance test to determine and record monthly the VOC
emissions per unit mass solvent feed from each affected facility for the
current and preceding five consecutive calendar months, and using these
values to calculate the 6-month average emissions by using the equations
provided by the standard.

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.



	Currently, sources are using automated monitoring equipment that
provides parameter data.  Although personnel at the sources 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 AIRS Facility Subsystem (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.

	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 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/operator for two 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.  An estimate of the number of small entities affected could
not be determined, based on review of available Federal Register notices
and background documents for 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 below in Table 1: Annual Industry Burden - NSPS
for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH)
(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

	The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 1,859
(Total Labor Hours from Table 1).  These hours are based on Agency
studies and background documents from the development of this
regulation, Agency knowledge and experience with the NSPS 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 during a previous renewal of this ICR.

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

	The type of industry costs 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 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 Respondent with O&M	(G)

Total O&M,

(E X F)

Flow indicator for solvent feed	$3,300	0	0	$7,500	22	$165,000



The total capital/startup costs for this ICR are zero.  This is the
total of column D in the above table.  

The total operation and maintenance (O&M) costs for this ICR are
$165,000.  This is the total of column G.  

The total respondent costs in block 14 have been calculated as the
addition of the capital/startup costs, and the annual operation and
maintenance costs.  The average annual cost for capital/startup and
operation and maintenance costs to industry over the next three years of
the ICR is estimated to be $165,000.  

	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
emission, and the publication and distribution of collected information.

	The average annual Agency cost during the three years of the ICR is
estimated to be $5,237.  This cost is based on the average hourly labor
rate as follows:

		Managerial	$57.20   (GS-13, Step 5, $35.75 x 1.6)

		Technical	$42.45   (GS-12, Step 1, $26.53 x 1.6)

		Clerical	$22.96   (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2006
General Schedule” which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Burden  - NSPS for Synthetic Fiber Production Facilities (40 CFR Part
60, Subpart HHH) (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 22 existing respondents will be subject to the
standard.  It is estimated that no additional respondents per year will
become subject.  The overall average number of respondents as shown in
the table below is 22 per year.

The number of respondents is calculated using the following table that
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	(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	22	0	0	22

2	0	22	0	0	22

3	0	22	0	0	22

Average	0	22	0	0	22



	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 22.  

 

	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 construction/reconstruction	18	0	0	0

Notification of actual startup	18	0	0	0

Notification of initial performance test	18	0	0	0

Report of performance test	18	0	0	0

Report of repeat of performance test	3.6	0	0	0

Quarterly report of VOCs emission exceedances	22	0.50	0	11

Semiannual report of no exceedances	22	2	0	44

Notification of noncompliance	22	0	0	0



	Total	55



	The number of Total Annual Responses is 55.  

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

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

		

(i) Respondent Tally

The Total Hours Requested is 1,859.  The total annual labor costs are
$150,119.  Details regarding these estimates may be found below in Table
1: Annual Respondent Burden and Cost - NSPS for Synthetic Fiber
Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal). 
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information is estimated to average 34 hours per
response.

	The total annual capital/startup and O&M costs to the regulated entity
are $165,000.   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 126 labor hours at a cost of $5,237.  See Table 2.
Annual Agency Burden and Cost, NSPS for Synthetic Fiber Production
Facilities (40 CFR Part 60, Subpart HHH).

	

	6(f)  Reasons for Change in Burden

	

There is no change in the labor hours or cost to the respondents in this
ICR compared to the previous ICR.  This is due to two considerations. 
First, the regulations have not changed over the past three years and
are not anticipated to change over the next three years.  Secondly, the
growth rate for respondents is very low, negative, or non-existent. 
Therefore, the labor hours and cost figures in the previous ICR reflect
the current burden to the respondents and are reiterated in this ICR.  

	6(g)  Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 34 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 valid OMB
Control Number.  The OMB Control Numbers for EPA 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 burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA–HQ–OECA–2009–0529.  An electronic version of the public
docket is available at http://www.regulations.gov/ which may be used to
obtain a copy of the draft collection of information, submit or view
public comments, access the index listing of the contents of the 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 in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 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
docket center is (202) 566-1752.  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
EPA–HQ–OECA–2009–0529 and OMB Control Number 2060-0059 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 – NSPS for Synthetic Fiber
Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal)

Burden item	

(A)

Person-

hours per

occurrence	

(B)

No.  of

occurrences

per respondent

per year	

(C)

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)

Cost, $  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 test	72	1	72	0	0	0	0	$0

       Repeat performance test c	72	1	72	0	0	0	0	$0

   C.  Create information	See 3B







	   D.  Gather existing information	See 3B







	   E.  Write report









  New Sources









    Notification of construction/                       reconstruction d
2	1	2	0	0	0	0	$0

    Notification of actual startup d	2	1	2	0	0	0	0	$0

    Notification of initial performance test d	2	1	2	0	0	0	0	$0

    Notification of demonstration of CMS d	2	1	2	0	0	0	0	$0

    Report of initial performance test d	See 3B







	  Existing Sources









    Quarterly report of VOCs emission            exceedances  e     	8
0.50	4	22	88	4.4	8.8	$8,169.74

    Semiannual report of no exceedances f	2	2	4	22	88	4.4	8.8	$8,169.74

    Notification of noncompliance g	2	1	2	0	0	0	0	$0

Subtotal Reporting	Subtotal burden hours = 202 (rounded)	$16,339.48

4.  Recordkeeping requirements









   A. Read instructions 	See 3A







	   B. Plan activities	See 4C







	   C. Implement activities 	See 3B







	   D. Develop record system	See 4E





	 

   E. Time to enter information









          Records of operating parameters h	0.25	250	62.5	22	1,375	68.75
137.5	$127,652.24

          Records of monthly VOC emission i	0.25	12	3	22	66	3.3	6.6
$6,127.31

   F.  Time to train personnel 	N/A







	  G.  Time for audits	N/A







	Subtotal Recordkeeping	Subtotal burden hours = 1,657 (rounded)
$133,779.55

Subtotals Labor Burden and cost  



	1,617	80.85	161.7	$150,119.03

TOTAL LABOR BURDEN AND COST (rounded)	

	

	

	

	1,859	$150,119



Assumptions:

a  We have assumed that the average number of respondents that will be
subject to the rule will be 22.  There will be no additional new source
that will become subject to the rule over the three-year period of this
ICR. 

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 20 percent of initial performance tests will be
repeated.

d  We have assumed that there will be no new sources over the three-year
period of this ICR.

e  We have assumed that each respondent will submit one quarterly report
every other year due to excess of volatile organic compounds (VOCs)
emissions.

f  Semiannual reports are required of all respondents.

g  We have assumed that there are no existing solvent-spun synthetic
fiber producing facility subject to the exemption under section
60,600(a) that has exceeded the annual requirement of 500 mg. 
Therefore, no existing solvent-spun synthetic fiber producing facility
will submit a notification of exceeding the limits over the three-year
period of the ICR.

h  We have assumed that respondents will enter information on records of
operating parameters 250 days per year.

i  Respondents are required to conduct monthly calculation of the 6
months VOC average emission which is considered a performance test. 
Respondents will have to determine this value by calculating the VOC
emissions per unit of mass solvent feed from each affected facility for
the current and proceeding five consecutive calendar months.

Table 2:  Average Annual EPA Burden - NSPS for Synthetic Fiber
Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal) 

	Activity	

(A)

EPA person-

hours per

occurrence	

(B)

No. of

occurrences

per plant

 per year	

(C)

EPA person

hours per

plant  per year

(C=AxB)	

(D)

Plants 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)

Cost, $ b

Required Activities









    New Plant









        Initial performance test	24	1	24	0	0	0	0	$0

        Repeat performance test c	24	0.2	4.8	0	0	0	0	$0

Report review









    New Plant









        Notification of  construction	2	1	2	0	0	0	0	$0

        Notification of actual startup	0.5	1	0.5	0	0	0	0	$0

        Notification of initial test	0.5	1.2	0.6	0	0	0	0	$0

        Review test results	8	1.2	9.6	0	0	0	0	$0

        Notification of demonstration of             CMS	0.5	1	0.5	0	0	0
0	$0

    Existing Plant









        Quarterly report of VOCs emission         exceedances d	2	0.50	1
22	22	1.1	2.2	$1,047.33

        Semiannual report of no VOC                 emission exceedances
e	2	2	4	22	88	4.4	8.8	$4,189.33

        Notification of noncompliance	2	0	0	0	0	0	0	$0

Subtotals Labor Burden and cost



	110	5.5	11	$5,236.66

TOTAL ANNUAL BURDEN AND COST (rounded)	

	

	

	

	126	$5,237



Assumptions:

    a  We have assumed that the average number of respondents that will
be subject to the rule will be 22.  There will be no additional new
source that will become subject to the rule over the three-year period
of this ICR. 

b  This cost is based on the following labor rates which incorporates a
1.6 benefits multiplication factor to account for government overhead
expenses:  Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6),
Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical
rate of $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.

c  We have assumed that 20 percent of initial performance tests will be
repeated.

    d  We have assumed that each respondent will submit one quarterly
report every other year due to excess of volatile organic compounds
(VOCs) emissions.

.   e  Semiannual reports are required of all respondents.

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