**SF‑83 SUPPORTING STATEMENT**

**ENVIRONMENTAL PROTECTION AGENCY**

**NESHAP for Pesticide Active Ingredient Production (40 CFR part 63,
subpart MMM)** **(Renewal)**

**1. Identification of the Information Collection**

**1(a) Title of the Information Collection**

**NESHAP for Pesticide Active Ingredient Production (40 CFR part 63,
subpart MMM) (Renewal)**

**1(b) Short Characterization/Abstract**

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
Pesticide Active Ingredient Production were promulgated on June 23, 1999
(64 [FR]{.underline} 33550). This standard applies to all owners and
operators of new and existing facilities engaged in the production of
pesticide active ingredients that emit hazardous air pollutants (HAPs).

Owners or operators of a pesticide active ingredient (PAI) production
facility to which this regulation applies, must choose one of the
compliance options described in the rule or install and monitor a
specific control system that reduces HAP emissions to the compliance
level. The respondents are subject to sections of subpart A of 40 CFR
part 63 relating to NESHAP. These requirements include: those associated
with the applicability determination; the notification that the facility
is subject to the rule; the notification of testing (control device
performance test and continuous monitoring system (CMS) performance
evaluation); the results of performance testing and CMS performance
evaluations; startup, shutdown, and malfunction report; semiannual or
quarterly summary reports and/or excess emissions and CMS performance
reports. In addition to the requirements of subpart A, many respondents
are required to submit precompliance plan and leak detention and repair
(LDAR) reports; and plants that wish to implement emissions averaging
provisions must submit an emission averaging plan.

Respondents electing to comply with the emission limit or emission
reduction requirements for process vents, storage tanks, or wastewater
must record the values of equipment operating parameters as specified in
section 63.1367 of the rule. Owners or operators are required to
install, operate, and maintain a continuous monitoring system.

If the owner or operator identifies any deviation resulting from a known
cause for which no federally approved or promulgated exemption from an
emission limitation or standard applies, the compliance report will also
include all records that the source is required to maintain that pertain
to the periods during which such deviation occurred, as well as the
following: the magnitude of each deviation; the reason for each
deviation; a description of the corrective action taken for each
deviation, including action taken to minimize each deviation and action
taken to prevent recurrence; and a copy of all quality assurance
activities performed on any element of the monitoring protocol.

Owners or operators of PAI production facilities subject to the rule
must maintain a copy of all monitored equipment operating parameter
values that demonstrate compliance with the standards. Those records
must be maintained for a minimum of five years. 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. The
information is used to determine whether or not all sources subject to
the NESHAP are achieving the standards.

Approximately 88 sources are currently subject to the regulation, and it
is estimated that an additional two sources per year will become subject
to the regulation in the next three years and that one existing source
will be reconstructed. The cost of this Information Collection Request
(ICR) will be \$1,542,049.

In the development of this ICR, we addressed the Office of Management
and Budget (OMB) ATerms of Clearance@ (TOC) on the active ICR which
states:

> This collection is approved for three years. Prior to next submitting
> the collection to OMB for revision of extension, EPA should review the
> burden estimates to ensure that they are accurate.

EPA has addressed the item of concern in the TOC as instructed by OMB in
the previous ICR, and has reviewed the burden estimates for accuracy.

**2. Need for and Use of the Collection**

**2(a) Need/Authority for the Collection**

The EPA is charged under section 112 of the Clean Air Act, as amended,
to establish standards of performance for each category or subcategory
of major sources and area sources of hazardous air pollutants. These
standards are applicable to new or existing sources of hazardous air
pollutants and shall require the maximum degree of emission. 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, HAP emissions from PAI 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 MMM.

**2(b) Practical Utility/Users of the Data**

The control of emissions of HAPs from pesticide active ingredient
production facilities requires not only the installation of properly
designed equipment, but also the operation and maintenance of that
equipment. Emissions of HAPs from pesticide active ingredient production
facilities are the result of operation of the affected 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 ensure that the pollution control devices are
properly installed and operated, that leaks are being detected and
repaired, and that 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 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 MMM.

**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]{.underline} (69 [FR]{.underline}
29718) on May 25, 2004. No comments were received on the burden
published in the [Federal Register]{.underline}

**3(c) Consultations**

For this information collection, we referenced the most recent 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 Office of Compliance Sector Notebook
AProfile of the Agricultural Chemical, Pesticide, and Fertilizer
Industry,@ the United States Census Bureau, and other websites covering
pesticide active ingredient production. We consulted with the EPA=s
Office of Air Quality Planning and Standards, Information Transfer, the
Program Integration Division, and Mr. John Habazin, Neville Chemical
Company,

\(412\) 331-4200.

**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 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 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]{.underline} 36902,

September 1, 1976; amended by 43 [FR]{.underline} 40000, September 8,
1978; 43 [FR]{.underline} 42251,

September 20, 1978; 44 [FR]{.underline} 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
pesticide active ingredient 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 description.

  ----------------------------------------------- ---------- ------------
  **Standard (40 CFR Part 63, Subpart MMM)**      **SIC      **NAICS
                                                  Codes**    Codes**

  Petrochemical Manufacturing                     2869       325110

  All Other Basic Inorganic Chemical              2869       325188
  Manufacturing                                              

  Cyclic Crude and Intermediate Manufacturing     2869       325192

  Ethyl Alcohol Manufacturing                     2869       325193

  All Other Basic Organic Chemical Manufacturing  2869       325199

  Industrial Gas Manufacturing                    2869       325120

  All Other Miscellaneous Chemical Production and 2869       325998
  Preparation Manufacturing                                  

  Pesticide and Other Agricultural Chemical       2879       325320
  Manufacturing                                              
  ----------------------------------------------- ---------- ------------

**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 are recorded and/or reported are required by
National Emission Standards for Hazardous Air Pollutants - Pesticide
Active Ingredient Production (40 CFR

part 63, subpart MMM).

A source must make the following reports:

  ------------------------------------------------- ---------------------
  Notification Reports                              Standard Citation by
                                                    Section

  Notification and application of construction and  63.5(d) and
  reconstruction                                    63.1368(c)

  Initial notification                              63.9 and 63.1368(b)

  Notification of CMS performance evaluation        63.8(e)(2) and
                                                    63.1368(d)

  Notification of performance test and test plan    63.7(c) and
                                                    63.1368(m)

  Request for extension of compliance               63.1364(a)(2) and
                                                    63.1368(n)

  Precompliance report                              63.1368(e)

  Request for approval to use alternative           63.8(f),
  monitoring parameters                             63.1366(b)(4), and
                                                    63.1368(e)(1)

  Notification of compliance status report          63.9(h) and
                                                    63.1368(f)

  Periodic reports of excess emissions and          63.10(e)(3) and
  noncompliance                                     63.1368(g)

  Notification of process change                    63.1368(h)
  ------------------------------------------------- ---------------------

  -----------------------------------------------------------------------
  Reports                                           
  ------------------------------------------------- ---------------------
  Startup, shutdown, and malfunction reports        63.10(d)(5) and
                                                    63.1368(i)

  Equipment leaks reports                           63.1363(h) and
                                                    63.1368(j)

  Emissions averaging reports                       63.1368(k)

  Heat exchange system reports                      63.1368(l)
  -----------------------------------------------------------------------

A source must keep the following records:

+------------------------------------------------+---------------------+
| Recordkeeping                                  |                     |
+================================================+=====================+
| Control device operating parameters to monitor | 63.1366(b)(1),      |
| and record                                     | 63.1367(b)(1), and  |
|                                                | 63.1367(b)(5)       |
+------------------------------------------------+---------------------+
| Monitoring and records for process vent annual | 63.10(c),           |
| emission                                       | 63.1366(b)(5),      |
|                                                | 63.1367(a)(4), and  |
| limits standard                                | 63.1367(b)(3)       |
+------------------------------------------------+---------------------+
| Monitoring and records for process vent annual | 63.1366(c) and      |
| emission                                       | 63.1367(b)(4)       |
|                                                |                     |
| limits standard                                |                     |
+------------------------------------------------+---------------------+
| Monitor and record for equipment leaks         | 63.1366(d) and      |
|                                                | 63.1367(c)          |
+------------------------------------------------+---------------------+
| Monitoring and records for heat exchanger      | 63.1362(f),         |
| systems                                        | 63.1366(e), and     |
|                                                | 63.1367(e)          |
+------------------------------------------------+---------------------+
| Monitoring and records for pollution           | 63.1366(f) and      |
| prevention                                     | 63.1367(b)(2)       |
+------------------------------------------------+---------------------+
| Monitoring and records for emissions averaging | 63.1366(g) and      |
|                                                | 63.1367(d)          |
+------------------------------------------------+---------------------+
| Records of process operating parameters        | 63.1367(b)(6) and   |
|                                                | 63.1367(b)(7)       |
+------------------------------------------------+---------------------+
| Applicability determinations                   | 63.10(b)(3) and     |
|                                                | 63.1367(a)(2)       |
+------------------------------------------------+---------------------+
| Startup, shutdown, and malfunction plan        | 63.6(e)(3) and      |
|                                                | 63.1367(a)(3)       |
+------------------------------------------------+---------------------+
| Application for approval of construction or    | 63.5(d) and         |
| reconstruction                                 | 63.1367(a)(5)       |
+------------------------------------------------+---------------------+
| Records for vapor collection systems and       | 63.1367(f)          |
| closed-vent systems                            |                     |
+------------------------------------------------+---------------------+

[Electronic Reporting]{.underline}

Currently, sources are using monitoring equipment that provides
automated parameter data, e.g., reduction requirements for process
vents, storage tanks or wastewater. 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 20 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 18, 25A, 301 and  |
| 1818 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 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 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 -
Pesticide Active Ingredient Production (40 CFR part 63, subpart MMM).

**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 24,164
(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, ATable 10. Private industry, by
occupational and industry group.@ The rates are from column 1, ATotal
compensation.@ The rates have been increased by 110 percent to account
for the benefit packages available to those employed by private
industry.

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

The types of industry cost associated with the information collection
activities in the subject standards 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**

All existing sources are in compliance and, therefore, no capital cost
has been attributed to them. However, there will still be O&M costs
associated with CMS.

+-----------+---------+--------+---------+---------+--------+-------+
| **Capita  |         |        |         |         |        |       |
| l/Startup |         |        |         |         |        |       |
| vs.       |         |        |         |         |        |       |
| Operation |         |        |         |         |        |       |
| and       |         |        |         |         |        |       |
| Ma        |         |        |         |         |        |       |
| intenance |         |        |         |         |        |       |
| (O&M)     |         |        |         |         |        |       |
| Costs**   |         |        |         |         |        |       |
+===========+=========+========+=========+=========+========+=======+
| \(A\)     | \(B\)   | \(C\)  | \(D\)   | \(E\)   | \(F\)  | \(G\) |
|           |         |        |         |         |        |       |
| C         | C       | Number | Total   | Annual  | Number | Total |
| ontinuous | apital/ | of New | C       | O&M     | of     | O&M,  |
| M         | Startup | Respo  | apital/ | Costs   | Respo  |       |
| onitoring | Cost    | ndents | Startup | for One | ndents | (E X  |
| Device    | for One |        | Cost,   | Res     | with   | F)    |
|           | Res     |        |         | pondent | O&M    |       |
|           | pondent |        | (B X C) |         |        |       |
+-----------+---------+--------+---------+---------+--------+-------+
| Pe        | \$52    | 3      | \$      | \$1,325 | 88     | \$11  |
| rformance | ,200^1^ |        | 156,600 |         |        | 6,600 |
| tests     |         |        |         |         |        |       |
+-----------+---------+--------+---------+---------+--------+-------+
| W         | \       | 3      | \       |         |        |       |
| astewater | $10,690 |        | $32,070 |         |        |       |
| CMS       |         |        |         |         |        |       |
+-----------+---------+--------+---------+---------+--------+-------+
| CMS cost  | \       | 3      | \       |         |        |       |
| for       | $15,920 |        | $47,760 |         |        |       |
| process   |         |        |         |         |        |       |
| vents     |         |        |         |         |        |       |
+-----------+---------+--------+---------+---------+--------+-------+
| Total     |         |        | \$      |         |        | \$11  |
|           |         |        | 236,430 |         |        | 6,600 |
+-----------+---------+--------+---------+---------+--------+-------+

^1^ Owners and operators are required to run two tests to complete the
process vent performance test for each facility. Each run will cost
\$26,100 for a total of \$52,200 per test.

The total capital/startup costs for this ICR are \$236,000 (rounded).
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 costs for this ICR are \$117,000
(rounded). 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 \$353,000. 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. 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 \$50,637. 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) A2004
General Schedule@ which excludes locality rates of pay. Details upon
which this estimate is based appear in

Table 2: Average Annual EPA Burden - NESHAP - Pesticide Active
Ingredient Production

(40 CFR part 63, subpart MMM).

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

Based on our research for this ICR, approximately 88 existing sources
are currently subject to the standard. It is estimated that an
additional two new sources and one reconstructed source per year will
become subject to the standard in the next three years. Furthermore, the
industry is experiencing a 2 percent annual growth rate (i.e., new
respondents).

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

+-----+-----------+--------+--------------+------------+------------+
| **  |           |        |              |            |            |
| Num |           |        |              |            |            |
| ber |           |        |              |            |            |
| of  |           |        |              |            |            |
| R   |           |        |              |            |            |
| esp |           |        |              |            |            |
| ond |           |        |              |            |            |
| ent |           |        |              |            |            |
| s** |           |        |              |            |            |
+=====+===========+========+==============+============+============+
|     | Re        |        | Respondents  |            |            |
|     | spondents |        | That Do Not  |            |            |
|     | That      |        | Submit Any   |            |            |
|     | Submit    |        | Reports      |            |            |
|     | Reports   |        |              |            |            |
+-----+-----------+--------+--------------+------------+------------+
| Y   | \(A\)     | \(B\)  | \(C\)        | \(D\)      | \(E\)      |
| ear |           |        |              |            |            |
|     | Number of | Number | Number of    | Number of  | Number of  |
|     | New       | of     | Existin      | Existing   | R          |
|     | Re        | Ex     | gRespondents | R          | espondents |
|     | spondents | isting | That Keep    | espondents |            |
|     | ^1^       | Respo  | Records but  | That Are   | (          |
|     |           | ndents | Do Not       | Also New   | E=A+B+C-D) |
|     |           |        | Submit       | R          |            |
|     |           |        | Reports      | espondents |            |
+-----+-----------+--------+--------------+------------+------------+
| 1   | 3         | 84     | 0            | 1          | 86         |
+-----+-----------+--------+--------------+------------+------------+
| 2   | 3         | 86     | 0            | 1          | 88         |
+-----+-----------+--------+--------------+------------+------------+
| 3   | 3         | 88     | 0            | 1          | 90         |
+-----+-----------+--------+--------------+------------+------------+
| A   | 3         | 86     | 0            | 1          | 88         |
| ver |           |        |              |            |            |
| age |           |        |              |            |            |
+-----+-----------+--------+--------------+------------+------------+

^1^ New respondents include sources that have reconstructed.

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 88. 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**              |        |       |              |         |
+==========================+========+=======+==============+=========+
| \(A\)                    | \(B\)  | \(C\) | \(D\)        | \(E\)   |
|                          |        |       |              |         |
| Information Collection   | Number | N     | Number of    | Total   |
| Activity                 | of     | umber | Existing     | Annual  |
|                          | Respo  | of    | Respondents  | Re      |
|                          | ndents | Resp  | That Keep    | sponses |
|                          |        | onses | Records But  |         |
|                          |        |       | Do Not       | E=      |
|                          |        |       | Submit       | (BxC)+D |
|                          |        |       | Reports      |         |
+--------------------------+--------+-------+--------------+---------+
| Notification of          | 3      | 1     | N/A          | 3       |
| con                      |        |       |              |         |
| struction/reconstruction |        |       |              |         |
+--------------------------+--------+-------+--------------+---------+
| Notification of process  | 9      | 1     | N/A          | 9       |
| changes                  |        |       |              |         |
+--------------------------+--------+-------+--------------+---------+
| Notification of          | 3      | 1     | N/A          | 3       |
| anticipated startup      |        |       |              |         |
+--------------------------+--------+-------+--------------+---------+
| Notification of actual   | 3      | 1     | N/A          | 3       |
| startup                  |        |       |              |         |
+--------------------------+--------+-------+--------------+---------+
| Notification of initial  | 3      | 1     | N/A          | 3       |
| performance test         |        |       |              |         |
+--------------------------+--------+-------+--------------+---------+
| Notification of initial  | 3      | 1     | N/A          | 3       |
| CMS performance          |        |       |              |         |
| evaluation               |        |       |              |         |
+--------------------------+--------+-------+--------------+---------+
| Quarterly reporting      | 9      | 4     | N/A          | 36      |
+--------------------------+--------+-------+--------------+---------+
| Semiannual reporting     | 79     | 2     | N/A          | 158     |
+--------------------------+--------+-------+--------------+---------+
| Leak detention and       | 88     | 2     | N/A          | 176     |
| repair (LDAR) report     |        |       |              |         |
+--------------------------+--------+-------+--------------+---------+
| Emissions averaging plan | 8      | 1     | N/A          | 8       |
+--------------------------+--------+-------+--------------+---------+
|                          |        |       | Total        | 402     |
+--------------------------+--------+-------+--------------+---------+

The number of Total Annual Responses is 402. This number is shown on the
OMB 83-I form in block 13(b), Total annual responses.

The Total Hours Requested is shown on the OMB 83-I form in block 13(c).
The total annual labor costs are \$1,542,049. 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 - Pesticide
Active Ingredient Production (40 CFR part 63, subpart MMM).

The total annual capital/startup and O&M costs to the regulated entities
are \$353,000. 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.

**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 are shown on the OMB 83-I form in block 13(c).
The total annual labor costs are \$1,542,049. 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 - Pesticide
Active Ingredient Production (40 CFR part 63, subpart MMM) attached.
Furthermore, the annual public reporting and recordkeeping burden for
this collection of information are estimated to average 60 (rounded)
hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are \$353,000. 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 next three years are
estimated to be 1,265 labor hours at a cost of \$50,637. See Table 2.
Annual Agency Burden and Cost, NESHAP - Pesticide Active Ingredient
Production (40 CFR Part 63, Subpart MMM) attached.

**6(f) Reasons for Change in Burden**

The decrease in burden hours from the most recently approved ICR is due
to an adjustment. Change in the burden for the existing facilities is
due primarily to an assumption that they are in compliance with the
initial requirements of the rule since the previous ICR covers the first
three years prior to the compliance date of the rule. To achieve
compliance the respondents incurred initial expenses they no longer
have.

In addition, this assumption resulted in a significant reduction in
capital/startup cost since CMS monitors are assumed to be purchased
during the period of the active ICR which is a one time cost. The
Operation and Maintenance (O&M) Costs increased slightly due to an
increase in the number of sources.

**6(g) Burden Statement**

The annual public reporting and recordkeeping burden for this collection
of information are estimated to average 60 (rounded) 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-2004-0007, 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 Asearch,@ 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 Officer for
EPA. Please include EPA Docket ID Number OECA-2004-0007 and OMB Control
Number 2060-0370 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 Pesticide
Active Ingredient Production (40 CFR part 63,**

**subpart MMM)**

+--------------+------+-----+-----+-----+-----+------+----+-------+
| **Burden     | **(  | *   | *   | *   | *   | **(  | *  | **    |
| item**       | A)** | *(B | *(C | *(D | *(E | F)** | *( | (H)** |
|              |      | )** | )** | )** | )** |      | G) |       |
|              | **P  |     |     |     |     | **   | ** | **    |
|              | erso | **  | **  | **R | *   | Mana |    | Total |
|              | n-** | No. | Per | esp | *Te | geme | ** | C     |
|              |      | o   | son | ond | chn | nt** | Cl | ost** |
|              | **h  | f** | -** | ent | ica |      | er |       |
|              | ours |     |     | s** | l** | **   | ic | **Per |
|              | p    | **o | *   |     |     | pers | al | Year  |
|              | er** | ccu | *ho | **  | **  | on-h | ** | ^a^** |
|              |      | rre | urs | per | per | ours |    |       |
|              | **   | nce | pe  | yea | son | p    | *  |       |
|              | occu | s** | r** | r** | -** | er** | *p |       |
|              | rren |     |     |     |     |      | er |       |
|              | ce** | **  | **  |     | *   | **ye | so |       |
|              |      | per | res |     | *ho | ar** | n- |       |
|              |      | res | pon |     | urs |      | ** |       |
|              |      | pon | den |     | pe  | **(E |    |       |
|              |      | den | t** |     | r** | x0.0 | *  |       |
|              |      | t** |     |     |     | 5)** | *h |       |
|              |      |     | **  |     | **  |      | ou |       |
|              |      | **  | per |     | yea |      | rs |       |
|              |      | per | yea |     | r** |      | p  |       |
|              |      | yea | r** |     |     |      | er |       |
|              |      | r** |     |     | **  |      | ye |       |
|              |      |     | **  |     | (E= |      | ar |       |
|              |      |     | (C= |     | CxD |      | ** |       |
|              |      |     | AxB |     | )** |      |    |       |
|              |      |     | )** |     |     |      | *  |       |
|              |      |     |     |     |     |      | *( |       |
|              |      |     |     |     |     |      | Ex |       |
|              |      |     |     |     |     |      | 0. |       |
|              |      |     |     |     |     |      | 1) |       |
|              |      |     |     |     |     |      | ** |       |
+==============+======+=====+=====+=====+=====+======+====+=======+
| 1\.          | N/A  |     |     |     |     |      |    |       |
| Applications |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| 2\. Survey   | N/A  |     |     |     |     |      |    |       |
| and Studies  |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| 3\.          |      |     |     |     |     |      |    |       |
| Reporting    |      |     |     |     |     |      |    |       |
| Requirements |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| A. Read      | 2    | 1   | 2   | 2   | 4   | 0.2  | 0  | \$2   |
| instructions |      |     |     | ^b^ |     |      | .4 | 93.50 |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| B. Required  |      |     |     |     |     |      |    |       |
| Activities   |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| Performance  | 13   | 6   | 78  | 2   | 156 | 7.8  | 15 | \     |
| evaluation   |      |     |     | ^c^ |     |      | .6 | $11,4 |
| test         |      |     |     |     |     |      |    | 46.50 |
|              |      |     |     |     |     |      |    |       |
| (c           |      |     |     |     |     |      |    |       |
| ertification |      |     |     |     |     |      |    |       |
| of CMS)      |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| C. Create    | Incl |     |     |     |     |      |    |       |
| information  | uded |     |     |     |     |      |    |       |
|              | in   |     |     |     |     |      |    |       |
|              | 3E   |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| D. Gather    | Incl |     |     |     |     |      |    |       |
| existing     | uded |     |     |     |     |      |    |       |
| information  | in   |     |     |     |     |      |    |       |
|              | 3E   |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| E. Write     |      |     |     |     |     |      |    |       |
| Report       |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| Notification | 2    | 1   | 2   | 3^b | 6   | 0.3  | 0  | \$4   |
| of           |      |     |     | ,d^ |     |      | .6 | 40.25 |
| con          |      |     |     |     |     |      |    |       |
| struction/re |      |     |     |     |     |      |    |       |
| construction |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| Notification | 8    | 1   | 8   | 9   | 72  | 3.6  | 7  | \$5,2 |
| of process   |      |     |     | ^e^ |     |      | .2 | 83.00 |
| changes      |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| Notification | 2    | 1   | 2   | 3^b | 6   | 0.3  | 0  | \$4   |
| of           |      |     |     | ,d^ |     |      | .6 | 40.25 |
| anticipated  |      |     |     |     |     |      |    |       |
| startup      |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| Notification | 2    | 1   | 2   | 3^b | 6   | 0.3  | 0  | \$4   |
| of actual    |      |     |     | ,d^ |     |      | .6 | 40.25 |
| startup      |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| Notification | 2    | 1   | 2   | 0   | 0   | 0    | 0  | \$0   |
| of           |      |     |     | ^f^ |     |      |    |       |
| a            | 2    | 1   | 2   |     | 6   | 0.3  | 0  | \$4   |
| pplicability |      |     |     | 3^b |     |      | .6 | 40.25 |
| of the       |      |     |     | ,d^ |     |      |    |       |
| standard     |      |     |     |     |     |      |    |       |
|              |      |     |     |     |     |      |    |       |
| \- Existing  |      |     |     |     |     |      |    |       |
| source       |      |     |     |     |     |      |    |       |
|              |      |     |     |     |     |      |    |       |
| \- New       |      |     |     |     |     |      |    |       |
| source       |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| P            | 40   | 1   | 40  | 2   | 80  | 4    | 8  | \$5,8 |
| recompliance |      |     |     | ^g^ |     |      |    | 70.00 |
| plan         |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| Notification | 2    | 1   | 2   | 3   | 6   | 0.3  | 0  | \$4   |
| of initial   |      |     |     | ^h^ |     |      | .6 | 40.25 |
| performance  |      |     |     |     |     |      |    |       |
| test         |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| Notification | 2    | 1   | 2   | 3^b | 6   | 0.3  | 0  | \$4   |
| of initial   |      |     |     | ,d^ |     |      | .6 | 40.25 |
| CMS          |      |     |     |     |     |      |    |       |
| performance  |      |     |     |     |     |      |    |       |
| evaluation   |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| Notification | 80   | 1   | 80  | 3   | 240 | 12   | 24 | \     |
| of           |      |     |     | ^i^ |     |      |    | $17,6 |
| compliance   | 120  | 1   | 120 |     | 0   | 0    | 0  | 10.00 |
| status       |      |     |     | 0   |     |      |    |       |
|              |      |     |     | ^j^ |     |      |    | \$0   |
| \- With      |      |     |     |     |     |      |    |       |
| performance  |      |     |     |     |     |      |    |       |
| test         |      |     |     |     |     |      |    |       |
|              |      |     |     |     |     |      |    |       |
| \- Without   |      |     |     |     |     |      |    |       |
| performance  |      |     |     |     |     |      |    |       |
| test         |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| F. Write     | 24   | 4   | 96  | 9   | 864 | 43.2 | 86 | \     |
| periodic     |      |     |     | ^k^ |     |      | .4 | $63,3 |
| report -     | 8    | 2   | 16  |     | 1,  | 63.2 |    | 96.00 |
| Quarterly    |      |     |     | 79  | 264 |      | 1  |       |
| reporting    | 94   | 2   | 188 | ^l^ |     | 8    | 26 | \     |
|              |      |     |     |     | 16, | 27.2 | .4 | $92,7 |
| \-           | 40   | 1   | 40  | 88  | 544 |      |    | 46.00 |
| Semiannual   |      |     |     | ^m^ |     | 18   | 1  |       |
| reporting    |      |     |     |     | 360 |      | ,6 | \$1,  |
|              |      |     |     | 9   |     |      | 54 | 213,9 |
| \- LDAR      |      |     |     | ^n^ |     |      | .4 | 16.00 |
| reporting    |      |     |     |     |     |      |    |       |
|              |      |     |     |     |     |      | 36 | \     |
| \- Emissions |      |     |     |     |     |      |    | $26,4 |
| averaging    |      |     |     |     |     |      |    | 15.00 |
| plan         |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| 4\.          |      |     |     |     |     |      |    |       |
| R            |      |     |     |     |     |      |    |       |
| ecordkeeping |      |     |     |     |     |      |    |       |
| Requirements |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| A. Read      | Incl |     |     |     |     |      |    |       |
| instructions | uded |     |     |     |     |      |    |       |
|              | in   |     |     |     |     |      |    |       |
|              | 3A   |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| B. Plan      | N/A  |     |     |     |     |      |    |       |
| activities   |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| C. Implement | N/A  |     |     |     |     |      |    |       |
| activities   |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| D. Develop   | 40   | 1   | 40  | 2   | 80  | 4    | 8  | \$5,8 |
| record       |      |     |     | ^o^ |     |      |    | 70.00 |
| system       |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| E. Develop   | 100  | 1   | 100 | 2   | 200 | 10   | 20 | \     |
| startup,     |      |     |     | ^p^ |     |      |    | $14,6 |
| shutdown,    |      |     |     |     |     |      |    | 75.00 |
| and          |      |     |     |     |     |      |    |       |
| malfunction  |      |     |     |     |     |      |    |       |
| plans        |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| F. Develop   | 40   | 1   | 40  | 2   | 80  | 4    | 8  | \$5,8 |
| QA/QC plan   |      |     |     | ^q^ |     |      |    | 70.00 |
| for CMS      |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| G. Time to   |      |     |     |     |     |      |    |       |
| enter        |      |     |     |     |     |      |    |       |
| information  |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| \- Records   | 1.5  | 52  | 78  | 2   | 156 | 7.8  | 15 | \     |
| of startup,  |      |     |     | ^r^ |     |      | .6 | $11,4 |
| shutdown,    | 1    | 320 | 320 |     | 640 | 32   |    | 46.50 |
| and          |      |     |     | 2   |     |      | 64 |       |
| malfunction  | 16   | 2   | 32  | ^s^ | 64  | 3.2  |    | \     |
|              |      |     |     |     |     |      | 6  | $46,9 |
| Records of   |      |     |     | 2   |     |      | .4 | 60.00 |
| CMS data     |      |     |     | ^t^ |     |      |    |       |
|              |      |     |     |     |     |      |    | \$4,6 |
| \- Record    |      |     |     |     |     |      |    | 96.00 |
| continuously |      |     |     |     |     |      |    |       |
| monitored    |      |     |     |     |     |      |    |       |
| parameters   |      |     |     |     |     |      |    |       |
|              |      |     |     |     |     |      |    |       |
| \-           |      |     |     |     |     |      |    |       |
| Enter/verify |      |     |     |     |     |      |    |       |
| information  |      |     |     |     |     |      |    |       |
|              |      |     |     |     |     |      |    |       |
| for          |      |     |     |     |     |      |    |       |
| semiannual   |      |     |     |     |     |      |    |       |
| reports      |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| F.           | 48   | 1   | 48  | 2   | 96  | 4.8  | 9  | \$7,0 |
| Calibration  |      |     |     | ^u^ |     |      | .6 | 44.00 |
| of CMS       |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| G. Time to   | 40   | 1   | 40  | 2   | 80  | 4    | 8  | \$5,8 |
| train        |      |     |     |     |     |      |    | 70.00 |
| personnel    |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| H. Time for  | N/A  |     |     |     |     |      |    |       |
| audits       |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| Subtotal     |      |     |     |     | 21, | 1,0  | 2, | \$1,  |
| Labor Burden |      |     |     |     | 016 | 50.8 | 09 | 542,0 |
|              |      |     |     |     |     |      | 7. | 49.00 |
|              |      |     |     |     |     |      | 61 |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+
| **TOTAL      |      |     |     |     | 24, |      |    | \     |
| LABOR BURDEN |      |     |     |     | 164 |      |    | $1,54 |
| AND COST     |      |     |     |     |     |      |    | 2,049 |
| (rounded)**  |      |     |     |     |     |      |    |       |
+--------------+------+-----+-----+-----+-----+------+----+-------+

Assumptions:

^a^ 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, ATable 10. Private industry, by occupational
and industry group.@

^b^ Assume that there will be 2 percent growth per year, which will
equate to two new facilities that will be built per year over the three
year period of this ICR.

^c^ Assume that all new sources are required to report the performance
evaluation test (continuous monitoring system certification).

^d^ Assume that one existing facility will be reconstructed each year.

^e^ Assume that 10 percent of existing facilities will implement process
changes.

^f^ Assume that rule only applies to new sources and reconstructed
facilities.

^g^ Assume 50 percent of new or reconstructed facilities will submit a
precompliance report with their notification of
construction/reconstruction.

^h^ Assume that 90 percent of new and reconstructed facilities will
conduct a performance test.

^i^ Assume that 90 percent of facilities will conduct a performance
test. The notification of compliance status includes the report of the
performance test and the CMS performance evaluation.

^j^ Assume that 10 percent of facilities will comply by submitting
engineering calculations, design calculations and report of CMS
performance evaluation.

^k^ Assume 10 percent of facilities will have exceedances and periods of
noncompliance.

^l^ Assume 90 percent of facilities will have no exceedances.

^m^ Assume that it will take ninety-four hours to write a leak detention
and repair (LDAR) report.

^n^ Assume that 10 percent of existing facilities will comply with
emissions averaging requirements. New sources are not allowed to use
emissions averaging.

^o^ Assume it will take forty hours to develop a record system for
recording parameter monitoring information.

^p^ Assume one person would require 80 hours to draft the startup,
shutdown, and malfunction plan and another twenty hours to
review/revisions for a total

of 100 hours.

^r^ Assume it will take 1.5 hours to record startup, shutdown, and
malfunction information.

^s^ Assume it will take one hour to record continuously monitored
parameters.

^t^ Assume it will take sixteen hours to enter/verify information for
semiannual report.

^u^ Assume that it will take 48 hours for the calibration of the
continuous monitoring system (CMS) to be completed.

**Table 2: Average Annual EPA Burden - NESHAP for Pesticide Active
Ingredient Production (40 CFR part 63, subpart MMM)**

+--------------+-----+------+-----+-----+-----+-------+-----+------+
| **Burden     | *   | **(  | *   | *   | *   | **    | *   | **(  |
| Item**       | *(A | B)** | *(C | *(D | *(E | (F)** | *(G | H)** |
|              | )** |      | )** | )** | )** |       | )** |      |
|              |     | **Nu |     |     |     | **    |     | **T  |
|              | *   | mber | **  | **  | **  | Manag | **C | otal |
|              | *Pe | of** | Per | Pla | Tec | ement | ler | ^    |
|              | rso |      | son | nts | hni | Hours | ica | a^** |
|              | n** | **O  | Ho  | Per | cal | Per   | l** |      |
|              |     | ccur | urs | Yea | H   | Y     |     | **   |
|              | *   | renc | Per | r** | our | ear** | *   | Cost |
|              | *Ho | es** | Pl  |     | s** |       | *Ho | s,** |
|              | urs |      | ant |     |     | **(F  | urs |      |
|              | Pe  | *    | Pe  |     | **  | =0.05 | Pe  | *    |
|              | r** | *Per | r** |     | Per | xE)** | r** | *Per |
|              |     | Pla  |     |     | Yea |       |     | Ye   |
|              | **  | nt** | **  |     | r** |       | **  | ar** |
|              | Occ |      | Yea |     |     |       | Yea |      |
|              | urr | *    | r** |     | **  |       | r** |      |
|              | enc | *Per |     |     | (E= |       |     |      |
|              | e** | Ye   | **  |     | CxD |       | *   |      |
|              |     | ar** | (C= |     | )** |       | *(G |      |
|              |     |      | AxB |     |     |       | =0. |      |
|              |     |      | )** |     |     |       | 1xE |      |
|              |     |      |     |     |     |       | )** |      |
+==============+=====+======+=====+=====+=====+=======+=====+======+
| Initial      | 40  | 1    | 40  | 2   | 80  | 4     | 8   | \$   |
| Performance  |     |      |     | ^b^ |     |       |     | 3,63 |
| Test         |     |      |     |     |     |       |     | 9.04 |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Repeat       | 40  | 1    | 40  | 0   | 0   | 0     | 0   | \$0  |
| performance  |     |      |     | ^c^ |     |       |     |      |
| test         |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Performance  | 2   | 1    | 2   | 1   | 2   | 0.1   | 0.2 | \$9  |
| evaluation   |     |      |     | ^d^ |     |       |     | 0.98 |
| test         |     |      |     |     |     |       |     |      |
| (c           |     |      |     |     |     |       |     |      |
| ertification |     |      |     |     |     |       |     |      |
| of CMS)      |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Report       |     |      |     |     |     |       |     |      |
| Review       |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Notification | 2   | 2    | 4   | 2   | 8   | 0.4   | 0.8 | \$36 |
| of           |     |      |     | ^b^ |     |       |     | 3.90 |
| a            |     |      |     |     |     |       |     |      |
| pplicability |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Notification | 2   | 1    | 2   | 3^b | 6   | 0.3   | 0.6 | \$27 |
| of           |     |      |     | ,e^ |     |       |     | 2.93 |
| construction |     |      |     |     |     |       |     |      |
| and          |     |      |     |     |     |       |     |      |
| re           |     |      |     |     |     |       |     |      |
| construction |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Notification | 2   | 1    | 2   | 3^b | 6   | 0.3   | 0.6 | \$27 |
| of           |     |      |     | ,e^ |     |       |     | 2.93 |
| anticipated  |     |      |     |     |     |       |     |      |
| startup      |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Notification | 2   | 1    | 2   | 3^b | 6   | 0.3   | 0.6 | \$27 |
| of actual    |     |      |     | ,e^ |     |       |     | 2.93 |
| startup      |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Notification | 8   | 1    | 8   | 9   | 72  | 3.6   | 7.2 | \$   |
| of process   |     |      |     | ^f^ |     |       |     | 3,27 |
| changes      |     |      |     |     |     |       |     | 5.14 |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Review of    | 4   | 1    | 4   | 1   | 4   | 0.2   | 0.4 | \$18 |
| p            |     |      |     | ^g^ |     |       |     | 1.95 |
| recompliance |     |      |     |     |     |       |     |      |
| report       |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Notification | 2   | 1    | 2   | 3^b | 6   | 0.3   | 0.6 | \$27 |
| of           |     |      |     | ,e^ |     |       |     | 2.93 |
| performance  |     |      |     |     |     |       |     |      |
| test         |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Notification | 2   | 1    | 2   | 3^b | 6   | 0.3   | 0.6 | \$27 |
| of CMS       |     |      |     | ,e^ |     |       |     | 2.93 |
| performance  |     |      |     |     |     |       |     |      |
| evaluation   |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Review of    | 40  | 1    | 40  | 3^  | 120 | 6     | 12  | \$   |
| notification |     |      |     | b,e |     |       |     | 5,45 |
| of           | 40  | 0    | 0   | ,h^ | 0   | 0     | 0   | 8.56 |
| compliance   |     |      |     |     |     |       |     |      |
| status       |     |      |     | 0   |     |       |     | \$0  |
|              |     |      |     | ^i^ |     |       |     |      |
| \- With      |     |      |     |     |     |       |     |      |
| performance  |     |      |     |     |     |       |     |      |
| test         |     |      |     |     |     |       |     |      |
|              |     |      |     |     |     |       |     |      |
| \- Without   |     |      |     |     |     |       |     |      |
| performance  |     |      |     |     |     |       |     |      |
| test         |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Review of    | 20  | 1    | 20  | 9   | 180 | 9     | 18  | \$   |
| emission     |     |      |     | ^f^ |     |       |     | 8,18 |
| averaging    |     |      |     |     |     |       |     | 7.84 |
| plan         |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Review of    | 2   | 2    | 4   | 79  | 316 | 15.8  | 3   | \$1  |
| semiannual   |     |      |     | ^j^ |     |       | 1.6 | 4,37 |
|              |     |      |     |     |     |       |     | 4.21 |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Review of    | 8   | 4    | 32  | 9   | 288 | 14.4  | 2   | \$1  |
| quarterly    |     |      |     | ^f^ |     |       | 8.8 | 3,10 |
| reports      |     |      |     |     |     |       |     | 0.54 |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Review of    | N/A |      |     |     |     |       |     |      |
| NESHAP       |     |      |     |     |     |       |     |      |
| waiver       |     |      |     |     |     |       |     |      |
| application  |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Subtotal     |     |      |     |     | 1,  | 55    | 110 | \$5  |
|              |     |      |     |     | 100 |       |     | 0,03 |
|              |     |      |     |     |     |       |     | 6.81 |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| Travel       | (1  |      |     |     |     |       |     |      |
| Expenses     | per |      |     |     |     |       |     |      |
|              | son |      |     |     |     |       |     |      |
|              | x 2 |      |     |     |     |       |     |      |
|              | pl  |      |     |     |     |       |     |      |
|              | ant |      |     |     |     |       |     |      |
|              | /yr |      |     |     |     |       |     |      |
|              | x 2 |      |     |     |     |       |     |      |
|              | day |      |     |     |     |       |     |      |
|              | /pl |      |     |     |     |       |     |      |
|              | ant |      |     |     |     |       |     |      |
|              | x   |      |     |     |     |       |     |      |
|              | \   |      |     |     |     |       |     |      |
|              | $50 |      |     |     |     |       |     |      |
|              | per |      |     |     |     |       |     |      |
|              | d   |      |     |     |     |       |     |      |
|              | iem |      |     |     |     |       |     |      |
|              | ) + |      |     |     |     |       |     |      |
|              | (\$ |      |     |     |     |       |     |      |
|              | 400 |      |     |     |     |       |     |      |
|              | /ro |      |     |     |     |       |     |      |
|              | und |      |     |     |     |       |     |      |
|              | t   |      |     |     |     |       |     |      |
|              | rip |      |     |     |     |       |     |      |
|              | x 1 |      |     |     |     |       |     |      |
|              | ro  |      |     |     |     |       |     |      |
|              | und |      |     |     |     |       |     |      |
|              | tr  |      |     |     |     |       |     |      |
|              | ip/ |      |     |     |     |       |     |      |
|              | yr) |      |     |     |     |       |     |      |
|              | =   |      |     |     |     |       |     |      |
|              | \$  |      |     |     |     |       |     |      |
|              | 600 |      |     |     |     |       |     |      |
|              | .00 |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+
| **TOTAL      |     |      |     |     | 1,  |       |     | \$50 |
| LABOR BURDEN |     |      |     |     | 265 |       |     | ,637 |
| and COST     |     |      |     |     |     |       |     |      |
| (rounded)**  |     |      |     |     |     |       |     |      |
+--------------+-----+------+-----+-----+-----+-------+-----+------+

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: \$54.66 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) A2004 General Schedule@ which excludes locality rates
of pay.

^b^ Assume that there will be 2 percent growth per year, which will
equate to two new facilities that will be built per year over the three
year period of this ICR.

^c^ Assume that 5 percent of new facilities will repeat performance
test.

^d^ Assume EPA personnel will attend 10 percent of these performance
evaluation tests.

^e^ Assume that one existing facility will be reconstructed each year.

^f^ Assume 10 percent of existing facilities will require process
changes over the three year period of this ICR.

^g^ Assume 50 percent of new facilities will submit a precompliance
report.

^h^ Assume 90 percent of all new sources will conduct a performance test
that covers the reviewing of compliance status report.

^i^ Assume 10 percent of facilities will comply by submitting
engineering calculations, design calculations and report of CMS
performance evaluation.

^j^ Assume 90 percent of facilities will have no exceedances.