### 1 SUPPORTING STATEMENT

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS

EMISSIONS: GROUP IV POLYMERS AND RESINS

PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection.

This information collection request (ICR) is entitled “Amendments to Requirements for

Sources regulated by the National Emission Standards for Hazardous Air Pollutant Emissions:

Group IV Polymers and Resins.” The EPA tracking number is 2457.02. The Office of

Management and Budget (OMB) number is 2060

- 0351.

(b) Short Characterization.

This ICR covers information collection requirements in the final rulemaking that amend

title 40, chapter I, part 63 of the Code of Federal Regulations (CFR) Subpart JJJ Nati onal

Emission Standards for Hazardous Air Pollutants: Group IV Polymers and Resins, hereafter, this

subpart is referred to as the “Polymers and Resins IV NESHAP”. Respondents are owners or

operators who will be subject to the new requirements of the Polyme rs & Resins IV NESHAP,

which include an estimated 31 existing facilities that produce thermoplastic resin in the

following source categories: Acrylonitirile Butadiene Styrene (ABS), Methyl Methacrylate

Butadiene Styrene (MBS), Polyethylene Terephthalate (P ET), Polystyrene (PS), and Styrene

Acrylonitrile (SAN). Respondents also include any of the 31 facilities who may wish to make

use of the new affirmative defense provisions in the amendments to the rule.

The final amendments require that that there be n o discharge to the atmosphere from any

pressure relief device (PRD) on any equipment in organic HAP service within the process units

for the Polymers and Resins IV source category. To ensure compliance with this requirement,

facility owners or operators ar e required to monitor each PRD in a way that would be able to

identify and record the time and duration of each pressure release and notify operators that a

pressure release is occurring.

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In addition to requirements for PRD, the amendments also provide r equirements for

equipment leaks and process contact cooling towers (PCCT) for one facility in the PET

continuous TPA high viscosity multiple end finisher subcategory. Under the new requirements,

this facility must report certain information when a leak is detected for equipment components in

gas/vapor or light liquid service. The facility must also report all cases when the ethylene glycol

concentration in the PCCT exceeds the standard. Information related to these new provisions is

required to be submitted in the semi

- annual reports that are already required by the existing

Polymers and Resins IV NESHAP.

The final amendments also add provisions for facility owners or operators to use if they

wish to assert an affirmative defense to avoid civil penalties fo r exceedances of the applicable

standards that are caused by a malfunction. If these provisions are used, the owner or operator is

required to meet certain criteria during the malfunction, notify the Administrator of malfunctions

that may cause an exceedan ce of the emissions standards, and submit a report of the malfunction

to the Administrator, to include a root cause analysis of the malfunction, within certain

timeframes.

Existing major sources subject to the new PRD requirements will be required to comp ly

with these requirements within three years of the effective date of the standards. Existing major

sources may use the affirmative defense provisions upon the effective date of the standards. All

new or reconstructed affected sources must be in complianc e with the existing and new

requirements of the Polymers and Resins IV NESHAP on the date of startup or the effective

date, whichever is later.

The new information collection requirements for existing and new Polymers and Resins

IV manufacturing sources are listed in Attachment 1.

2. Need For and Use of the Collection

(a) Need/Authority for the Collection

.

Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP for both

major and area sources of HAP that are listed for regulation under CAA section 112(c). A major

source is a stationary source that has the potential to emit more than 10 tons per year [tpy] of any

single HAP and more than 25 tpy of any combination of HAP. The Polymers and Resins IV

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source category contains major sources o f HAP emissions and is included on EPA’s list of

categories for regulation. The Polymers and Resins IV NESHAP are based on maximum

achievable control technology (MACT).

Certain records and reports are necessary for the Administrator to confirm the complian ce

status of major sources, identify any new or reconstructed sources subject to the standards, and

confirm that the standards are being achieved on a continuous basis. These recordkeeping and

reporting requirements are specifically authorized by section 1 14 of the Clean Air Act (42 U.S.C.

7414) and set out in the part 63 NESHAP General Provisions. The recordkeeping and reporting

requirements for title V permits are contained in 40 CFR 70.6 and 40 CFR 71.6. Under parts 63

and 70 or 71, the owner or operator must keep each record for 5 years following the date of each

occurrence, measurement, maintenance, corrective action, report, or record.

(b) Use/Users of the Data.

The information will be used by the delegated authority (state agency, or Regional

Administrator if there is no delegated state agency) to ensure that the standards in the

amendments are being achieved. Based on review of the recorded information at the si te and the

reported information, the delegated permitting authority can identify facilities that may be in

violation of the emission standards due to the emissions of HAP from pressure release events,

equipment leaks, and/or exceedances of the ethylene gly col concentration limit in a PCCT. The

information will also be used by the delegated authority to determine if a source meets the

criteria for affirmative defense. If a source meets the affirmative defense criteria, they may be

excused from civil penaltie s for exceedances of an emission limit.

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.

A computer search of our existing standards and ongoing ICRs revealed no duplication of

information gathering efforts. However, c ertain reports required by State or local agencies may

duplicate information required by the standards. In such cases, a copy of the report submitted to

the State or local agency can be provided to the Administrator in lieu of the required report.

### 4

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

This ICR is related to amendments to the Polymers and Resins IV NESHAP. Comments

were solicited on the proposal package and the proposed ICR. No comments were received on

the proposed ICR.

(c) Consulta tions.

Upon review of the standard, information available and the data, the Agency has

determined the recordkeeping and reporting requirements in the “Active” ICR is fully supported

and necessary to fulfill the requirements of the Clean Air Act (CAA). It has been determined that

no further consultations with industry are necessary to calculate the burden associated with the

amendments to the Polymers and Resins IV NESHAP.

(d) Effects of Less Frequent Collection.

If the relevant information were collected less frequently, the delegated permitting

authority (State or EPA) will not be reasonably assured that a facility is in compliance with the

standards. In addition, the EPA's authority to take administrative action would be significantly

reduced; section l1 3(d) of the CAA limits the assessment of administrative penalties to violations

which occur no more than 12 months before initiation of the administrative proceeding. Since

administrative proceedings are less costly and require use of fewer resources than judicial

proceedings, both the EPA and the regulated community benefit from preservation of the EPA's

administrative powers.

(e) General Guidelines

.

The Polymers & Resins IV NESHAP requires that facility owners or operators retain

records for a period of 5 years, which exceeds the 3

- year retention period contained in the

guidelines in 5 CFR 1320.6. The 5

- year retention period is consistent with the subpart A General

Provisions of 40 CFR part 63 and the retention requirement in the operating permit progr am

under Title V of the CAA. All subsequent general guidelines have been followed and do not

violate any of the Paperwork Reduction Act guidelines contained in 5 CFR 1320.6.

(f) Confidentiality.

All information submitted to the Agency for which a claim of confidentiality is made will

be safeguarded according to the Agency policies set forth in Title 40, Chapter 1, Part 2, Subpart

B

-- Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976;

### 5

amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR

17674, March 23, 1979).

(g) Sensitive Questions.

This section is not applicable because this ICR does not involve matters of a sensitive

nature.

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes

.

Potential respondents under Subpart JJJ are owners or operators of any existing or new

Polymers & Resins IV manufacturing facility that is a major source of HAP emissions, including

any facilities who may wish to make use of the new affirmative defense provisions to avoid civil

penalties resulting from the exceedance of an emission limit. The source category and affected

sources regulated by the Polymers & Resins IV NESHAP are classified under the North

American Industrial Classification System (NAICS) code is 325211, for plastic material and

resin manufacturing.

The Polymers & Resins IV source category is estimated to consist of 31 existing facilities

na tionwide, all of which are major sources and would be subject to the major source provisions

specified under the Polymers & Resins IV NESHAP. All 31 existing facilities could make use of

the new affirmative defense provisions added to the rule. N o new majo r sources are projected

during the 3

- year period of this ICR.

(b) Information Requested.

(i) Data Items, Including Recordkeeping Requirements. Attachment 1, Information

Requirements, summarizes the data items, including recordkeeping and reporting requ irements,

for the Polymers and Resins IV source category.

(ii) Respondent Activities. The respondent activities that are required by the new

provisions of the Polymers and Resins IV NESHAP are identified in Table 1 (located at the end

of this supporting statement) and are introduced in section 6(a).

(iii) Summary of Requirements. The amendments to the Polymers and Resins IV

NESHAP require that facilities report any pressure device releases, equipment leaks from

equipment in gas/vapor or light liquid ser vice, or exceedances of the ethylene glycol

### 6

concentration limit in a PCCT. The above information is required to be submitted with the next

periodic report required by the existing Polymers and Resins IV NESHAP. Facility owners or

operators are required to monitor each PRD in organic HAP service that releases to the

atmosphere to identify and record the time and duration of each pressure release. For affirmative

defense, the primary data item required is a written report which proves that all the criteria fo r

asserting an affirmative defense have been met. The owner or operator may submit this report

(which is to include a root cause analysis of the reported violation) in the first periodic

compliance report, deviation report or excess emissions report otherw ise required after the initial

occurrence of the exceedance of the relevant standard. However, if such report is due less than

45 days after the exceedance, the affirmative defense report may be included in the next such

required report.

The EPA is includi ng in Table 2 (located at the end of this supporting statement) an

estimate of the burden associated with performing an affirmative defense. The EPA is providing

this as an illustrative example of the potential additional administrative burden a source may

incur to assert in an Affirmative Defense in response to an action to enforce the standards set

forth in the applicable subpart.

This illustrative estimate is not considered a duplicate estimate of cost under the General

Duty to Minimize Emissions clause under 63.6(e)(1)(i), which states: “At all times, the owner

and operator must operate and maintain any affected source, including associated air pollution

control equipment and monitoring equipment, in a manner consistent with safety and good air

pollutio n control practices for minimizing emissions. Determining whether such operation and

maintenance procedures are being used will be based on information available to the

Administrator which may include, but is not limited to, monitoring results, review of o peration

and maintenance procedures, review of operation and maintenance records, and inspection of the

source.”

To provide the public with an estimate of the relative magnitude of the burden associated

with an assertion of the affirmative defense positi on adopted by a source, the EPA provides an

administrative adjustment to this ICR that estimates the costs of the notification, recordkeeping

and reporting requirements associated with the assertion of the affirmative defense. The EPA’s

estimate for the re quired notification, reports and records, including the root cause analysis,

### 7

associated with a single incident totals approximately $2,375 and is based on the time and effort

required of a source to review relevant data, interview plant employees, and docu ment the events

surrounding a malfunction that has caused an exceedance of an emission limit. The estimate also

includes time to produce and retain the records and reports for submission to the EPA. The EPA

provides this illustrative estimate of this burde n because these costs are only incurred if there has

been a violation and a source chooses to take advantage of the affirmative defense.

Of the number of excess emission events reported by source operators, only a small

number would be expected to result from a malfunction, and only a subset of excess emissions

caused by malfunctions would result in the source choosing to assert the affirmative defense.

Thus we believe the number of instances in which source operators might be expected to avail

themselves of the affirmative defense will be extremely small. For this reason, we estimate no

more than 2 or 3 such occurrences for all sources within a given category over the 3

- year period

covered by this ICR. For the purpose of this estimate, we are adding two (2 ) instances of

affirmative defense. We expect to gather information on such events in the future and will revise

this estimate as better information becomes available.

5. The Information Collected

– Agency Activities, Collection Methodology, and

Informatio n Management

(a) Agency Activities.

The Agency activities associated with this ICR are provided in Table 3 (located at the end

of this supporting statement) and are introduced in section 6(c).

(b) Collection Methodology and Management

.

Data and records m aintained by the respondents are tabulated and published for use in

compliance and enforcement programs of the delegated permitting authority. The semiannual

reports are used for problem identification, as a check on source operation and maintenance, and

f or compliance determinations. The required report for facilities who wish to avail themselves of

the affirmative defense will be used by the delegated authority to determine if a source meets the

criteria for affirmative defense. If a source meets the crit eria for affirmative defense, they may be

excused from civil penalties for exceedances of an emission limit. The EPA is the permitting

authority until the state agency is delegated authority to implement the rule. Therefore,

### 8

information contained in the re ports submitted to the Regional Administrator will be entered into

the Air Facility System (AFS), which is operated and maintained by the EPA’s Office of

Compliance. The AFS is the EPA’s database for the collection, maintenance, and retrieval of

compliance data for approximately 125,000 industrial and government

- owned facilities. The

EPA uses the AFS for tracking air pollution compliance and enforcement by local and state

regulatory agencies, EPA regional offices and EPA headquarters. The EPA and its delega ted

authorities can edit, store, retrieve and analyze the data.

(c) Small Entity Flexibility.

A majority of the affected facilities are large entities (e.g., large businesses). However,

the impact on the one small entity (i.e., small business) in this s ource category was taken into

consideration during development of the final amendments. Due to the type of monitoring

equipment to be used, the recordkeeping and reporting requirements are the same for both small

and large entities. The Agency considers th ese requirements the minimum needed to ensure

compliance and, therefore, cannot reduce them further for small entities.

(d) Collection Schedule

.

The specific frequency for each information collection activity within this request is

shown in Table 1 for the Polymers & Resins IV source category.

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

The annual burden estimates for the final amendments to the Polymers and Resins IV

NESHAP are shown in Table 1. These numbers were derived from estimates based on the EPA’s

experience with this and other standards. No burden estimates are provided for new sources

because no new facilities are expected to become affected sources during the 3-year period of

this ICR.

(b) Estimating Respondent Costs.

The estimates of total technical

- hours per year per source and the number of activities per

respondent per year for the new PRD, equipment leaks, and PCCT requirements are listed in

Table 1. Information used to estimate the bur den resulting from the new requirements is based

### 9

upon experience with similar information collection requirements in the Polyvinyl Chloride and

Copolymers Production NESHAP (Subpart HHHHHHH).

The EPA’s estimate for an affirmative defense and root cause ana lysis is based on the

time and effort required of a source to review relevant data, interview plant employees, and

reconstruct the events prior to a malfunction in order to determine primary and contributing

causes. The level of effort also includes time t o produce and retain the report in document form

so that the source will have it available should the EPA or state enforcement agencies ever

request to review it. The estimates of total technical

- hours per year per source for asserting an

affirmative defen se are listed in Table 2 and are based upon experience with similar information

collection requirements in the Sewage Sludge Incineration Units NESHAP (Subpart MMMM).

(i) Estimating Labor Costs . Labor rates and associated costs are based on data from the

United States Department of Labor, Bureau of Labor Statistics (BLS) from May 2012. The data

provides technical, management, and clerical average hourly rates for private industry workers.

Wages for technical labor are from the category “chemical plant and system operators” with a

mean hourly wage of $26.03/hour. Wages for management labor are from the category “general

and operations managers” with a mean hourly wage of $55.22/hour. Wages for clerical labor are

from the category “secretaries and administra tive assistants” with a mean hourly wage of

$18.16/hour. These rates represent salaries plus fringe benefits and do not include the cost of

overhead. The wages provided above were increased by a rate of 110 percent to account for

overhead. The fully

- burden ed hourly wage rates used to represent respondent labor costs are:

technical at $54.66, management at $115.96, and clerical at $38.14.

(ii) Estimating Capital and Operations and Maintenance (O&M) Costs . As part of the

amendments to the Polymers and R esins IV NESHAP, facility owners or operators are required

to monitor each PRD to identify and record the time and duration of each pressure release. For

purposes of estimating the costs of this requirement, we assumed that operators would install

electron ic indicators on each PRD in organic HAP service that vents to the atmosphere to

identify and record the time and duration of each pressure release. The cost of each such

monitoring system is expected to be $112,180 and the total cost for these capital exp enditures for

all facilities in the Polymers and Resins IV source category is estimated to be $3,814,120. The

### 10

operation and maintenance (O&M) costs expected from operating the electronic indicators have

not been estimated.

(iii) Annualizing Capital Costs . Annualized costs are calculated by multiplying the

capital recovery factor by the capital cost. The capital recovery factor is 0.142 based on an

interest rate of 7 percent and an assumed equipment life of 10 years. The total annualized capital

cost is $5 41,620.

(c) Estimating Agency Burden and Cost

.

Because the information collection requirements were developed as an incidental part of

standards development, no costs can be attributed to the development of the information

collection requirements. Beca use reporting and recordkeeping requirements on the part of the

respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the

part 63 NESHAP General Provisions, no operational costs will be incurred by the Federal

Governme nt. Publication and distribution of the information are part of the Compliance Data

System, with the result that no Federal costs can be directly attributed to the ICR. Examination of

records to be maintained by the respondents will occur incidentally as p art of the periodic

inspection of sources that is part of EPA’s overall compliance and enforcement program, and,

therefore, is not attributable to the ICR. The only costs that the Federal government will incur are

user costs associated with the analysis of the reported information, as presented in Table 4.

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

.

For the final amendments related to PRD, respondents include owners or operators of

all 31 existing facilities regulated by the Pol ymers and Resins IV NESHAP. For the amendments

related to equipment leaks from components in gas/vapor service or light liquid service and for

PCCT, there is only one respondent

- the facility in the PET continuous TPA high viscosity

multiple end finisher subcategory. Each facility will be required to submit information in the

periodic report required by the existing Polymers and Resins IV NESHAP. Periodic reports are

required to be submitted two times per year, but the extent of the required information in each

submittal is dependent upon the occurrence of an emission discharge from a PRD, an equipment

leak, or an emission exceedance from a PCCT.

While a ll 31 of the existing facilities could make use of the new affirmative defense

provisions added to the r ule, the EPA estimates only two total instances of the use of these

### 11

provisions over the three year ICR period. Consequently, the average annual number of Pesticide

Active Ingredient manufacturing facility respondents during the 3

- year period of this ICR is 2.

The average annual burden and cost over the next three years is shown in Table 1 . The

EPA’s estimate for the total burden and cost for a single incident of an affirmative defense is

shown in Table 2.

(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent tally. The bottom line respondent burden hours and costs, presented in

Table 1, are calculated by adding person

- hours per year down each column for technical,

managerial, and clerical staff, and by adding down the cost column. The annual burden for the

recordkeeping and reporting requirements for the 31 existing facilities subject to the amendments

to the Polymers and Resins NESHAP is 459 person

- hours, with an annual labor cost of $26,137.

(ii) The Agency tally. There is no significant burden or cost expected to the agency as a

result of the amendments; see Table 3.

(iii) Variations in the annual bottom line. This section does not apply since no significant

variation is anticipated.

(f) Reasons for Change in Burden.

We are requesting an incr ease in burden of 459 hours per year due to implementation of

the new provisions of this regulation. The EPA provides an adjustment to this ICR that estimates

the costs of the notification, recordkeeping and reporting requirements associated with the

asser tion of the affirmative defense. The EPA’s estimate for the required notification, reports and

records, including the root cause analysis, associated with a single incident totals approximately

$2,375 and is based on the time and effort required of a sourc e to review relevant data, interview

plant employees, and document the events surrounding a malfunction that has caused an

exceedance of an emission limit. The estimate also includes time to produce and retain the

records and reports for submission to the EPA. For the purpose of estimating the annual burden,

the EPA is attributing a total of 2 instances of affirmative defense over a three year period across

all sources in the category. The EPA is using this frequency of 2 events in three years because, of

t he number of excess emission events reported by source operators, only a small number would

be expected to result from a malfunction, and only a subset of excess emissions caused by

malfunctions would result in the source choosing to assert the affirmative defense. Thus, we

### 12

believe the number of instances in which source operators might be expected to avail themselves

of the affirmative defense will be extremely small.

(g) Burden Statement

The average annual respondent burden is estimated to average 459 hours. 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

app licable 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 cond uct or sponsor, and a person is not required to respond to a

collection of information unless it displays a currently valid OMB control number. The OMB

control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9.

To comment on the Agency’s need for this information the accuracy of the provided

burden estimates, and any suggestions for minimizing respondent burden, including through the

use of automated collection techniques, the EPA has established a public docket for this ICR

under Docket ID No. EPA

- HQ

- OAR

- 2011

- 0435

, which is available for online viewing at

http://www.regulations.gov , or in person viewing at the Air and Radiation 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 Air Docket

is (202) 566

- 1742. An electronic version of the public docket is available at

http://www.regulations.gov. This site can be used 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. Wh en in the system, select “search,” then key in one of

the Docket ID Numbers identified above. Also, you can send comments to the Office of

Information and Regulatory Affairs, Office of Management and Budget, 725 17 th 

### Street, NW,

### 13

Washington, DC 20503, Atten tion Desk Officer for EPA. Please include the relevant Docket ID

Number (EPA

- HQ

- OAR

- 201

- 0435 ) in any correspondence.

PART B

This section is not applicable because statistical methods are not used in data collection

associated with the rule.

### 14

TABLE 1. ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS OF THE FINAL STANDARD

Burden Item (A) (B) (C) (D) (E) (F) (G) (H)

Person

- No. of Person

- hours Sources Technical Management Clerical Cost,$ (c)

hours per occurrences per source per year person

- hours person

- hours person

- hours

occurrence per source per year per year per year per year

(a) per year (b) (C= AxB) (E=CxD) (Ex0.05) (Ex0.1)

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, Installation, & Utilization of Tech. & Systems N/A

4. Reporting Requirements

A. Read instructions N/A

B. Required activities N/A

C. Create information N/A

D. Gather existing information N/A

E. Write report

Semi

- annual periodic reports (PRD monitoring)(d) 5.50 2.0 11.0 34.0 374.0 18.7 37.4 $24,038

Semi

- annual periodic reports (Equip. leaks) 3.00 2.0 6.0 1.0 6.0 0.3 0.6 $386

Semi

- annual periodic reports (PCCT) 1.00 2.0 2.0 1.0 2.0 0.1 0.2 $129

Leak detection and repair reports N/A

Performance test notification N/A

Performance test report N/A

Affirmative defense (e) 30

- - 0.67 12 8 0.0 $1,584

Other reports ( e.g., quarterly periodic reports where a

respondent did not qualify for semiannual reporting) N/A

REPORTING SUBTOTAL 39.50 6.00 19.0 36.7 394.0 27.1 38.2 $26,137

5. Recordkeeping Requirements

A. Read instructions N/A

B. Plan activities

C. Implement activities

D. Develop record system

E. Time to enter information

Plan Activities

Create, Test, Research, Develop

Gather information, Monitor, Inspect

Process, Compile, Review

F. Time to train personnel

G. Time to adjust existing ways to comply w/ prev. appl. req.

H. Time to Record and disclose information

### 15 Burden Item (A) (B) (C) (D) (E) (F) (G) (H)

Person

- No. of Person

- hours Sources Technical Management Clerical Cost,$ (c)

hours per occurrences per source per year person

- hours person

- hours person

- hours

occurrence per source per year per year per year per year

(a) per year (b) (C= AxB) (E=CxD) (Ex0.05) (Ex0.1)

Store, file and maintain records

I. Time for audits

TOTAL ANNUAL NUMBER OF RESPONSES (f) 62.7

TOTAL ANNUAL BURDEN HOURS 394.0 27.1 38.2 459.3

TOTAL ANNUAL COST (SALARY) $26,137

INITIAL CAPITAL COSTS: $3,814,120

ANNUALIZED CAPITAL COSTS: $541,620

N/A = Not Applicable.

(a) Estimate of burden for each activity, technical hours only

(b) Estimate based on average facilities

(c) Costs are based on the following hourly rates: technical at $54.66, management at $115.96, and clerical at $38.14

(d) There are 31 facilities, but several facilities have operations of more than one P&R IV source category at the site. The PRD costs for each facility and P&R IV source category

present were considered separately for a total of 34 sources per year.

(e) Assumes 2 affirmative defense reports for entire industry during the 3

- yr ICR period. For affirmative defense, hours required assumes 18 hours technical, 12 hours management,

0 clerical for each instance of affirmative defense. Formulas not followed for person hours per year.

(f) Total responses calculated by adding semiannual reports (31 sources * 2 responses) and affirmative defense (0.67 response s (2 responses in 3 years))

Table 2. Cost Estimate for Affirmative Defense/Root Cause Analysis



### RCFA Personnel Number of Personnel Time Requirement (hours) Total Hours Hourly Rate ($/hr) Total

Technical Personnel 3 6 18 $54.66 $983.93

Managerial Personnel 2 6 12 $115.96 $1,391.54

Total 5 30 $2,375.48

May 2012 National Occupational Employment and Wage Estimates United States

- Production Occupations http://www.bls.gov/oes/current/oes_nat.htm#51

-

0000.

### 16 TABLE 3. ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT OF THE FINAL STANDARDS

Burden Item (A) (B) (C) (D) (E) (F) (G) (H)

EPA person

- No. of EPA person

- Plants Technical Management Clerical Cost,$ (a)

hours per occurrences hours per per person

- hours person

- hours person

occurrence per plant plant per year per year per year hours per

per year year (E=CxD) (Ex0.05) year

Activity (C=AxB) (Ex0.1)

Performance Tests: Initial 0 0 0.0 0 0.0 0.0 0.0 $0

Performance Tests: Repeat 0 0 0.0 0 0.0 0.0 0.0 $0

Litigation 0 0 0.0 0 0.0 0.0 0.0 $0

Reports Review:

Compliance status 0.0 0 0.0 0 0.0 0.0 0.0 $0

Review equipment leak monitoring 0.0 0 0.0 0 0.0 0.0 0.0 $0

Notification of front

- end operations limit 0.0 0 0.0 0 0.0 0.0 0.0 $0

Notification of back

- end operations limit 0.0 0 0.0 0 0.0 0.0 0.0 $0

Notification of construction/reconstruction 0.0 0 0.0 0 0.0 0.0 0.0 $0

Notification of anticipated startup 0.0 0 0.0 0 0.0 0.0 0.0 $0

Notification of actual startup 0.0 0 0.0 0 0.0 0.0 0.0 $0

Notification of performance test 0.0 0 0.0 0 0.0 0.0 0.0 $0

Review of test results 0.0 0 0.0 0 0.0 0.0 0.0 $0

Review periodic reports 0.0 0 0.0 0 0.0 0.0 0.0 $0

Review other reports 0.0 0 0.0 0 0.0 0.0 0.0 $0

TOTAL BURDEN AND COST (SALARY) 0.0 0.0 0.0 $0

### 17 ATTACHMENT 1. INFORMATION REQUIREMENTS

-- NESHAP FOR POLYMERS AND RESINS IV MANUFACTURING

Requirement Citation for existing sources Citation for new sources General Provisions citation

Reports

PRD requirements in Periodic reports §63.1335(e)(9) §63.1335(e)(9)

Equipment leak requirements in Periodic reports for

“multiple

- end

- finisher” subcategory §63.1331(c)(4) §63.1331(c)(4)

PCCT requirements in Periodic reports for

“multiple

- end

- finisher” subcategory §63.1329(c) §63.1329(c)

Reports of malfunctions that result in an

exceedances of the standard for the purpose of

affirmative defense §63. 1310(k) §63. 1360(k)