## SUPPORTING STATEMENT **ENVIRONMENTAL PROTECTION AGENCY NESHAP for Source Categories: Generic Maximum Achievable Control Technology**  **Standards (40 CFR P**  **art 63, S**  **ubpart YY) (Renewal)**
**1. Identification of the Information Collection 1(a) Title**  **of the Information Collection** NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR part 63, subpart YY) (Renewal) , EPA I CR Number 1871.05, OMB Control Number 2060

- 0420 **1(b) Short Characterization/Abstract**
The N ational Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories: Generic Maximum Achievable Control Technology (hereafter, this subpart is referred to as the "Generic MACT ” ) were proposed on October 14, 1998 ( 63 FR 55178 ) and promulg ated on June 29, 1999 ( 64 FR 34854 )

. These regulations apply to hazardous air pollutant (HAP) emission sources in four categories including: Poly carbonates (PC) Production, Acry lic and Modacry lic Fibers (AMF) Production, Acetal Resins (AR) Production and Hy drogen Fluoride (HF) Production. This I nformation Collection Request (I CR) addresses these four source categories. On November 2, 2001, the Agency promulgated wastewater provisions amendments to the Generic MACT applicable to wastewater streams for the PC, AMF, and AR production source categories. The HF production source category does not have wastewater streams. On June 7, 2002, the Agency made additional amendments as a direct ruling to the Generic MACT to clarify definitions and the recordkeeping provisions related to how readily accessible records should be maintained. This information is being collected to assure compliance with the provisions of 40 CFR part 63, subpart YY.

In general, all NESHAP standards require initial notifications, perform ance tests, and periodic reports. Owners or operators are also required to maintain records of the occurrence and duration of any

startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem is inoperative. The specific monitoring and recordkeeping requirements vary for each source category

depending on the ty

pes of emissions control equipment and monitoring equipment used to comply with the Generic MACT standards for their category . These n otifications, reports, and records are essential in determining compliance, and are required of all sources subject to NESHAP. Any owner or operator subject to the provisions of this subpart will maintain a file of these measurements, and retain the file for at least five y ears following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority . I n the event that there is no such delegated authority , the reports are sent directly to th e United States Environmental Protection Agency (EPA) regional office.

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Based on our consultations with industry representatives, there is an average of one affected facility

at each plant site and that each plant site has only one respondent (i.e., the
own er/operator of the plant site). There are, approximately , 10 respondents in four categories that are currently subject to the regulation and they

are: 1) Poly carbonates (PC) Production

- four sources; 2) Acry lic and Modacry lic Fibers (AMF) Production

- th ree sources; 3) Acetal Resins (AR) Production

- two sources; and 4) Hy drogen Fluoride (HF) Production

- one source. I t is estimated that no additional respondents per y ear will become subject to the regulation in the next three y ears.
**2. Need for and Us e 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 reduction. I n addition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

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

require.

In the Administrator's judgment, hazardous air pollutant (HAP) emissi ons from PC, AMF, AR and HF source categories cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category

at 40 CFR part 63, subpart YY. **2(b ) Practical Utility/Users of the Data**  The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulation s which were promulgated in accordance with the Clean Air Act. The

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collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capa bility to comply with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded a nd used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properly installed and operated, that leaks are being detected and repaired, and that the standard is being met. The performance test may be observed as well. The required semiannual reports are used to determine periods of excess emissions, to identify problems at the facility , to verify operation/maintenance procedures, and for compliance determinations.

**3. Non**

**- duplication, Consultations, and Other Collection Crite**  **ria** The requested recordkeeping and reporting are required under 40 CFR part 63, subpart YY. **3(a) Non**

**- duplication**  If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency . I f a state or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Admin istrator 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 I CR was published in the F ederal Register ( 73 FR 31088 ) on May 30, 2008 . No comments were received on the burden published in the Federal Register. **3(c) Consultations** For this information collection, we referenced the most recent I CR, consulted with the preparer of the active I CR, and used other resources to obtain the most recent data available. We

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reviewed information available from the United States Census Bureau, the Air Facility Sy stem (AFS), and websites covering PC, AMF, AR and HF source categories. We also con sulted with the EPA ’ s Office of Air Quality Planning and Standards, I nformation Transfer, the Program In tegration Division, and one EPA regional office. After reviewing our internal data sources and industry experts, we have determined that additional con sultations with industry are inappropriate for this I CR renewal. The standard was developed with the participation and/or consultation with industry representatives. The Agency has performed additional reviews to determine additional burden reduction opp ortunities. The Agency currently collects the minimum amount of information necessary to ensure compliance with the standard. **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. I f the information requi red by these standards was collected less frequently , the likelihood of detecting poor operation and maintenance of control equipment and noncompliance decreases. **3(e) General Guidelines** None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five y ears. This is consistent with the General Provisions as appl ied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the P art 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. Also, the retention of records for five y ears would allow EPA to establish the compliance history

of a source and any

pattern of compliance for the purpose of determining the appropriate level of enforcement action. Historically , EPA has found that the most flagrant violators frequently

have violati ons extending bey ond the five y ears. I f records were retained for less than five y ears, EPA would be prevented from pursuing the worst violators due to the destruction or nonexistence of records. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2,

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subpart B

- Confidentiality of Business I nformation (CBI ) (see 40 CFR 2; 41 FR 36902, September 1, 197 6; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** None of the reporting or recordkeeping requirements contain sensitive questions. **4. The Respondents and the Informati on Requested**  **4(a) Respondents NAICS and**  **SIC Codes** The respondents to the recordkeeping and reporting requirements are HAP emissions in four categories: Poly carbonates (PC) Production, Acry lic and Modacry lic Fibers (AMF) Production, Acetal Resins (AR) Pr oduction and Hy drogen Fluoride (HF) Production. The Standard I ndustrial Classification (SI C) codes for the respondents affected by the standards, which correspond to the North American I ndustry Classification Sy stem (NAI CS) codes, are listed below for sou rce category description.
**Standard (40 CFR part 61, subpart N) SIC Codes**  **NAICS Codes** Poly carbonates (PC) Production (Sy nthetic Rubber Manufacturing) 2822 325212

Acry lic and Modacry lic Fibers (AMF) Production (Manmade Organic Fibers, Except Cellulosic) 2824 325222

Acetal Resins (AR) Production (Plastic Materials, Sy nthetic and Resins, and Nonvulcanizable Elastomers) 2821 325211

Hy drogen Fluoride (HF) Production (I ndustrial I norganic Chemicals, Not Elsewhere Classified) 2819 325188

**4(b) Information Requested** None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. **(i) Data Items**
All data in this I CR that are recorded and/or reported are required by NESHAP for Source Categories: Generic Maximum Achievable Control Technology (40 CFR part 63, subpart YY) (Renewal).

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A source must make the following reports:
Notification Reports Standard Citation by Section Application for approval of construction/reconstruction 63.5(d), 63.1110(a) Notification of initial startup 63.1110(b) Notification of initial applicability 63.09(b), 63.1110(a), and 63.1110(c) Notification of compliance status 63.9(h), 63.1110(a), and 63.1110(d) Notification of performance test and performance evaluation results 63.7(b), 63.9(e), 63.10(d)(2), 63.1110(d), and 63.1110(a) Rescheduled initial performance test 63.7(b)(2) Demonstration of continuous monitoring sy stem 63.9(g) Phy sical or operational change 63.8(a) Opacity or visible emissions 63.10(d)(3) Develop startup, shutdown, malfunction plan and periodic reports 63.10(d)(5)(i), 63.1110(b), and 63.1111 Excess emissions and continuous parameter monitoring sy stems (CPMS) performance reports 63.1110(a)

Reports Periodic reports (Semiannual or according to the schedule for Title V) with information on excess emissions and on the implementation of leak detection and repair standard provisions 63.1110(e), 63.1108(a), and 63.1109

Startup, shutdown and malfunction reports 63.1110(a), and 63.1111(b)
A source must keep the following records:

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Recordkeeping Maintain records of startup, shutdown, malfunctions periods when excess emissions have occurred during the reporting period 63.10(b)(2) and 63.1109(a) Maintain records of performance test and performance evaluation results 63.1109(a)

Maintain records of all reports and notifications 63.10(b) and 63.1109(a) Maintain record of applicability 63.10(b) (3) and 63.1109(d) Maintain records of initial and compliance status notifications 63.9(h), 63.1109(d) Records of CPMS operation adjustments, calibration checks, and maintenance 63.10(b)(2)(vii) and 63.1109(a) Records of implementation of leak detection and repair (LDAR) standards provision 63.1107

Records are required to be retained for five y ears 63.10(b)(2)
Electronic Reporting Currently , respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must evaluate the data, this internal automation has significantly reduced the burden associated with monitoring and recordkeeping at the plant site. Also, regulatory

agencies in cooperation with the respondents, continu e to create reporting sy stems to transmit data electronically . However, electronic reporting sy stems are still not widely

used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.

**(ii) Respondent Act ivities** 

**Respondent Activities** Read instructions. Conduct control device performance tests. Conduct a performance evaluation of the CPMS.

## 8 **Respondent Activities**
In spect and monitor closed

- vent sy stem. Monitor control devices. 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 sy stems for the purpose of collecting, validating, and verify ing information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.
**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, analy sis, 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, analy

ze, and maintain data in the Air Facility Sy stem (AFS).
**5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority might inspect the source to

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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 capab ility to comply with the emission standard. 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 operat ion and maintenance, and for compliance determinations.

In formation 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 c ompliance 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 headquarters and EPA regional offices. EPA and its dele gated Authorities can edit, store, retrieve and analy ze the data. The records required by

this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** All of the respondents are large entities (i.e., large busine sses). 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 ty pes of control equipment employ ed, 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 la rger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. According to the Paperwork Reduction Act Submission for the NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards 1 

## , this IC R does not have a significant impact on small entities . The Agency assumes that zero percent of the 10 facilities affected by

this I CR, or zero facilities, are small entities. **5(d) Collection Schedule** The specific frequency

for each information collec tion activity within this request is shown in Table 1: Annual I ndustry Burden for NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR part 63, subpart YY) (Renewal) , attached

. **6. Estimating the Burden and Cost of the Collection** 

1 

### Paperw ork Reduction Act Submission for the NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards, U.S. EPA, June 1999.

## 10

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

. The Agency

may not conduct or spon sor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three y ears from these r ecordkeeping and reporting requirements is estimated to be 4,004 (Total L abor 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 pro gram, the previously approved I CR, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs** 
This I CR uses the following labor rates: Managerial $97.46 ($46.41 + 110%) Technical $83.71 ($39.86 + 110%) Clerical $42.55 ($20.26 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 19, 2005, “ Table 2 : Civilian Workers, by O ccupational and I ndustry group. ” The rates are from column 1, “ Total C ompensation. ” The rates have been increased by 110 percent to account for the benefit packages available to those employ ed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

cost associated with the information collection a ctivities in the subject standard are both labor costs which are addressed elsewhere in this I CR and the costs associated with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annu al operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

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

## 11 **Capital/Startup vs. Operation and Maintenance (O&M) Costs** (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/ Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent 1 

### (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)

PC (use of
non contractor) $0 0 $0 $144.55 2 $289.10

PC (use of contractor) 2 

### $0 0 $0 $53,128.85 2 $106,257.70

AMF $0 0 $0 $144.55 3 $433.65
AR $0 0 $0 $144.55 2 $289.10
HF $0 0 $0 $144.55 1 $144.55
Total $0 $107,414.10
Total rounded $107,414.00

1 We have assumed that each source will respond 5 times per year to comply with the rule at a total cost of $144.55 per source to cover O&M costs. This estimate is based on the assumption that it takes 0.5 hours to conduct these tasks at a clerical labor rate of $42.55 per hour for a total labor cost of $21.28 per response. First

- class postage is estimated at $7.63 per response. Thus, the total storage, filing, photocopying, and postage cost per response is $28.91.

2 Based on information we obtained, we have determined that two PC sources out of a total of four sources will use contractor support for CPMS O&M, at a total cost of approximately $53,000 per source. 

## The total capital/startup costs for this I CR are zero. The total operation and maintenance (O&M) costs for this I CR are $107,414. The average annual cost for capital/startup and operation and maintenance cost to industry over the next three y ears of the I CR is estimated to be $107,414. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with analy sis 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 y ears of the I CR is estimated to be

## 12

$2,797, for 69 hours.
This cost is based on the average hourly labor rate as follows: Managerial $56.02 (GS

- 13, Step 5, $35.01 x 1.6) Technical $41.57 (GS

- 12, Step 1, $25.98 x 1.6) Clerical $22.50 (GS

- 6, Step 3, $14.06 x 1.6)
These rates are from the Office of Personnel Management (OPM) A 2005 General Schedule @ which excludes locality

rates of pay . Details upon which this estimate is based appear in Table 2: Average Annual EPA Burden

- NESHAP for Source Categories: Generic Maximum Achievable Control Technology

Standards (40 CFR part 63, subpart YY) (Renewal) , attached

. **6(d) Estimating the Respondent Universe and Total Burden and Costs**
Based on our research for this I CR, on average over the next three y ears, approximately 10 existing respondents will be subject to the s tandard. I t is estimated that no additional respondents per y ear will become subject to the standard. The overall average number of respondents, as shown in the table below is 10 per y ear (see table below). The number of respondents is calculated using the following table which addresses the three y ears covered by

this I CR.
**Number of Respondents** Respondents That Submit Reports Respondents That Do Not Submit Any Reports



### Year (A) Number of New Respondents 1 

### (B)

Number of Existing Respondents (C)

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

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 10 0 0 10
2 0 10 0 0 10
3 0 10 0 0 10 Average 0 10 0 0 10



## . To avoid double

- counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three

- ye ar period of this I CR is 10. The total number of annual responses per y ear is calculated using the following table:

## 13 **Total Annual Responses** (A) Information Collection Activity (B)
Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D

Initial requirements for PC Production 0 1 N/A 0 Initial requirements for AMF Production 0 1 N/A 0 Initial requirements for AR Production 0 1 N/A 0 Initial requirements for HF Production 0 1 N/A 0 SSM reports for PC Production 4 1 N/A 4 SSM reports for AMF Production 3 1 N/A 3 SSM reports for AR Production 2 1 N/A 2 SSM reports for HF Production 1 1 N/A 1 Periodic reports for PC Production 4 2 N/A 8 Periodic reports for AMF Production 3 2 N/A 6 Periodic reports for AR Production 2 2 N/A 4 Periodic reports for HF Production 1 2 N/A 2 LDAR reports for PC Production 0 2 N/A 0 LDAR reports for AMF Production 0 2 N/A 0 LDAR reports for AR Production 0 2 N/A 0 LDAR reports for HF Production 0 2 N/A 0
Total 30 

## The number of Total Annual Responses is 30. The total annual labor costs are $331,146 for 4,004 hours

. Details regarding these estimates may

be found in Table 1 : Annual Respondent Burden and Cost, NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR part 63, subpart YY) (Renewal) , attached

. **6(e) Bottom Line Burden Hours and Cost Tables**
Details of the bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively , and summarized below.

## 14 **(i) Respondent Tally** The total annual labor costs are $331,146. Details regarding these estimates may be found in Tab le 1 : Annual Respondent Burden and Cost, NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR part 63, subpart YY) (Renewal) , attached . Furthermore, the annual public reporting and recordkeeping burden for this col lection of information are estimated to average 133 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $107,414. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Mainte nance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over the next three y ears is estimated to be 69 labor hours at a cost of $2,797. See Table 2 : Annual Agency Burden and Cost, NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR part 63, subpart YY) (Renewal) , attached

. **6(f) Reasons for Change in Burden**
The annual non - labor cost burden was increased by $4 14 due to an omission in the previous I CR renewal. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 133 hours per response. Burden means the total time, effort, or financial resources expended by

persons to generate, maintain, retain , or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; to develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verify ing information, processing and maintaining information, and disclosing and providing information; to adjust the existing way s to comply with any previously

applicable instructions and requirements; to train personnel to be able to respond to a collection of information; t o search data sources; complete and review the collection of information; and to 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 displa ys 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

## 15

burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket I D Number EPA

- HQ

- OECA

- 200 8

- 0 428

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in th e public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket I D number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and I nforma tion 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Enforcement and Compliance Docket and I nformation Center Docket is (202) 566

- 1514. Also, y ou can send comments to the Office of I nformation and Regulatory Affairs, Office of M anagement and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket I D Number EPA

- HQ

- OECA

- 200 8

- 0 428 and OMB Control Number 2060

- 0 420 in any correspondence.

**Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.

## 16 **Table 1: A nnual Respondent Burden and**  **Cost**

**- NESHAP for Source Categories: Generic Maximum Achievable Control**  **Technology Standards (40 CFR part 63, subpart YY)**  **(Renewal)**

**Burden item (A)**  **Technical Person**  **** **hours per occurrenc**  **e (B)** 

**No. of occurrence**  **s per**  **responden t**  **per y ear**  **(C)**

**Technical Person**  **** **hours per responde**  **nt per y**  **ear (C=AxB)**  **(D)**

**Responde nts**  **per y ear**  **a (E)** 

**Technical person**  **** **hours per ye**  **ar (E=CxD)**  **(F)**

**Managemen t**  **person**   ** hours per** **ye ar**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per y**  **ear (Ex0.1)**  **(H)**

**Total Cost per y**  **ear b** 

1. Applications N/A 2. Survey and Studies N/A 3. Reporting Requirements
A. Read Instructions c Polycarbonated (PC) Production 4 1 4 0 0 0 0 $0 Acrylic and Modacrylic Fibers (AMF) Production 4 1 4 0 0 0 0 $0 Acetal Resins (AR) Production 4 1 4 0 0 0 0 $0 Hydrogen Fluoride (HF) Production 4 1 4 0 0 0 0 $0 B. Required Activities for PC, AMF, AR, & HF c Included in 4C C. Create Information for PC, AMF, AR, & HF c Included in 4 C D. Gather existing information for PC, AMF, AR & HF c Included in 4C

E. W rite report i Initial requirements: notifications, initial compliance determination, performance tests c
PC Production 52 1 52 0 0 0 0 $0

AMF Production 52 1 52 0 0 0 0 $0

## 17

**Burden item (A)**  **Technical Person**  **** **hours per occurrenc**  **e (B)** 

**No. of occurrence**  **s per**  **responden t**  **per y ear**  **(C)**

**Technical Person**  **** **hours per responde**  **nt per y**  **ear (C=AxB)**  **(D)**

**Responde nts**  **per y ear**  **a (E)** 

**Technical person**  **** **hours per ye**  **ar (E=CxD)**  **(F)**

**Managemen t**  **person**   ** hours per** **ye ar**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per y**  **ear (Ex0.1)**  **(H)**

**Total Cost per y**  **ear b** 

AR Production 52 1 52 0 0 0 0 $0
HF Production 52 1 52 0 0 0 0 $0 ii Startup, Shutdown malfunction reports d
PC Production 2 1 2 4 8 0.4 0.8 $742.70
AMF Production 2 1 2 3 6 0.3 0.6 $557.03
AR Production 2 1 2 2 4 0.2 0.4 $371.35
HF Production 2 1 2 1 2 0.1 0.2 $185.68 iii Periodic reports e
PC Production 8 2 16 4 64 3.2 6.4 $5,941.63
AMF Production 8 2 16 3 48 2.4 4.8 $4,456.22
AR Production 8 2 16 2 32 1.6 3.2 $2,970.82
HF Production 8 2 16 1 16 0.8 1.6 $1,485.41 iv Leak detection and repair (LDAR) reports c, f
PC Production 8 2 16 0 0 0 0 $0
AMF Production 8 2 16 0 0 0 0 $0
AR Production 8 2 16 0 0 0 0 $0
HF Production 8 2 18 0 0 0 0 $0 4. Recordkeeping Requirements a
A. Read Instructions for c 4 1 4 0 0 0 0 $0

## 18

**Burden item (A)**  **Technical Person**  **** **hours per occurrenc**  **e (B)** 

**No. of occurrence**  **s per**  **responden t**  **per y ear**  **(C)**

**Technical Person**  **** **hours per responde**  **nt per y**  **ear (C=AxB)**  **(D)**

**Responde nts**  **per y ear**  **a (E)** 

**Technical person**  **** **hours per ye**  **ar (E=CxD)**  **(F)**

**Managemen t**  **person**   ** hours per** **ye ar**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per y**  **ear (Ex0.1)**  **(H)**

**Total Cost per y**  **ear b** 

PC Production 4 1 4 0 0 0 0 $0
AMF Production 4 1 4 0 0 0 0 $0
AR Production 4 1 4 0 0 0 0 $0
HF Production 4 1 4 0 0 0 0 $0
B. Plan Activities for c 40 1 40 0 0 0 0 $0
PC Production 40 1 40 0 0 0 0 $0
AMF Production 40 1 40 0 0 0 0 $0
AR Production 40 1 40 0 0 0 0 $0
HF Production 40 1 40 0 0 0 0 $0 C. Implement Activities a

i Material determinations c
PC Production N/A
AMF Production N/A
AR Production N/A
HF Production N/A ii Control equipment inspection
a. Tanks PC Production N/A
AMF Production 2 12 24 3 72 3.6 7.2 $6,684.34

## 19

**Burden item (A)**  **Technical Person**  **** **hours per occurrenc**  **e (B)** 

**No. of occurrence**  **s per**  **responden t**  **per y ear**  **(C)**

**Technical Person**  **** **hours per responde**  **nt per y**  **ear (C=AxB)**  **(D)**

**Responde nts**  **per y ear**  **a (E)** 

**Technical person**  **** **hours per ye**  **ar (E=CxD)**  **(F)**

**Managemen t**  **person**   ** hours per** **ye ar**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per y**  **ear (Ex0.1)**  **(H)**

**Total Cost per y**  **ear b** 

AR Production 2 12 24 2 48 2.4 4.8 $4,456.22
HF Production N/A b. Closed

- vent system PC Production 2 2 4 2 8 0.4 0.8 $742.70
AMF Production 2 2 4 3 12 0.6 1.2 $1,094.56
AR Production 2 2 4 2 8 0.4 0.8 $742.70
HF Production 2 2 4 1 4 0.2 0.4 $371.35 iii Control equipment leak monitoring a. Cover vented to control device PC Production 1 2 2 2 4 0.2 0.4 $371.35
AMF Production 1 2 2 3 6 0.3 0.6 $547.28
AR Production 1 2 2 2 4 0.2 0.4 $371.35
HF Production 1 2 2 1 2 0.1 0.2 $185.68
b. Closed

- vent system PC Production 1 2 2 2 4 0.2 0.4 $371.35
AMF Production 1 2 2 3 6 0.3 0.6 $547.28
AR Production 1 2 2 2 4 0.2 0.4 $371.35
HF Production 1 2 2 1 2 0.1 0.2 $185.68
iv. Control devices

## 20

**Burden item (A)**  **Technical Person**  **** **hours per occurrenc**  **e (B)** 

**No. of occurrence**  **s per**  **responden t**  **per y ear**  **(C)**

**Technical Person**  **** **hours per responde**  **nt per y**  **ear (C=AxB)**  **(D)**

**Responde nts**  **per y ear**  **a (E)** 

**Technical person**  **** **hours per ye**  **ar (E=CxD)**  **(F)**

**Managemen t**  **person**   ** hours per** **ye ar**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per y**  **ear (Ex0.1)**  **(H)**

**Total Cost per y**  **ear b** 

a. Initial requirements design analysis, performance c Test PC Production 80 1 80 0 0 0 0 $0
AMF Production 80 1 80 0 0 0 0 $0
AR Production 80 1 80 0 0 0 0 $0
HF Production 80 1 80 0 0 0 0 $0 b. Operate and maintain CMS PC Production 8 12 96 2 192 9.6 19.2 $17,824.90
AMF Production 8 12 96 3 288 14.4 28.8 $26,737.34
AR Production 8 12 96 2 192 9.6 19.2 $17,824.90
HF Production 8 12 96 1 96 4.8 9.6 $8,912.45 v. LDAR Program a. Initial requirement: Identify all effected streams c
PC Production 20 1 20 0 0 0 0 $0

AMF Production 20 1 20 0 0 0 0 $0
AR Production 20 1 20 0 0 0 0 $0
HF Production 20 1 20 0 0 0 0 $0 b. Perform monitoring/repairs PC Production

## 21

**Burden item (A)**  **Technical Person**  **** **hours per occurrenc**  **e (B)** 

**No. of occurrence**  **s per**  **responden t**  **per y ear**  **(C)**

**Technical Person**  **** **hours per responde**  **nt per y**  **ear (C=AxB)**  **(D)**

**Responde nts**  **per y ear**  **a (E)** 

**Technical person**  **** **hours per ye**  **ar (E=CxD)**  **(F)**

**Managemen t**  **person**   ** hours per** **ye ar**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per y**  **ear (Ex0.1)**  **(H)**

**Total Cost per y**  **ear b** 

1) In

- house g 0.1 1,092 192 2 384 19.2 38.4 $35,649.79 2) Use of contractor support h 2 $8,000.00
AMF Production 16 12 192 3 576 28.8 57.6 $53,474.69
AR Production 16 12 192 2 384 19.2 38.4 $35,649.79
HF Production g 0.1 1,092 192 1 192 9.6 19.2 $17,824.90 vi. Container vapor tightness certification PC Production N/A
AMF Production N/A
AR Production N/A
HF Production N/A D. Develop Record System i. Develop startup, shutdown, malfunction plan c
PC Production 20 1 20 0 0 0 0 $0
AMF Production 20 1 20 0 0 0 0 $0
AR Production 20 1 20 0 0 0 0 $0
HF Production 20 1 20 0 0 0 0 $0 ii. Control equipment c
PC Production 16 1 16 0 0 0 0 $0
AMF Production 16 1 16 0 0 0 0 $0

## 22

**Burden item (A)**  **Technical Person**  **** **hours per occurrenc**  **e (B)** 

**No. of occurrence**  **s per**  **responden t**  **per y ear**  **(C)**

**Technical Person**  **** **hours per responde**  **nt per y**  **ear (C=AxB)**  **(D)**

**Responde nts**  **per y ear**  **a (E)** 

**Technical person**  **** **hours per ye**  **ar (E=CxD)**  **(F)**

**Managemen t**  **person**   ** hours per** **ye ar**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per y**  **ear (Ex0.1)**  **(H)**

**Total Cost per y**  **ear b** 

AR Production 16 1 16 0 0 0 0 $0
HF Production 16 1 16 0 0 0 0 $0 iii. LDAR Program c
PC Production 40 1 40 0 0 0 0 $0
AMF Production 40 1 40 0 0 0 0 $0
AR Production 40 1 40 0 0 0 0 $0
HF Production 40 1 40 0 0 0 0 $0 E. Record Information (all information required by standard) i. Initial requirements: cover design, control device c design, and control equipment testing

PC Production 17 1 17 0 0 0 0 $0
AMF Production 17 1 17 0 0 0 0 $0
AR Production 17 1 17 0 0 0 0 $0
HF Production 17 1 17 0 0 0 0 $0 ii. Control equipment inspection PC Production 1 2 2 2 4 0.2 0.4 $371.35
AMF Production 1 2 2 3 6 0.3 0.6 $557.03
AR Production 1 2 2 2 4 0.2 0.4 $371.35
HF Production 1 2 2 1 2 0.1 0.2 $185.68

## 23

**Burden item (A)**  **Technical Person**  **** **hours per occurrenc**  **e (B)** 

**No. of occurrence**  **s per**  **responden t**  **per y ear**  **(C)**

**Technical Person**  **** **hours per responde**  **nt per y**  **ear (C=AxB)**  **(D)**

**Responde nts**  **per y ear**  **a (E)** 

**Technical person**  **** **hours per ye**  **ar (E=CxD)**  **(F)**

**Managemen t**  **person**   ** hours per** **ye ar**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per y**  **ear (Ex0.1)**  **(H)**

**Total Cost per y**  **ear b** 

iii. Control equipment monitoring i
PC Production 1 52 52 2 104 5.2 10.4 $9,655.15
AMF Production 1 52 52 3 156 7.8 15.6 $14,482.73
AR Production 1 52 52 2 104 5.2 10.4 $9,655.15
HF Production 1 52 52 1 52 2.6 5.2 $4,827.58
iv. Control device CMS PC Production 1 12 12 2 24 1.2 2.4 $2,228.11
AMF Production 1 12 12 3 36 1.8 3.6 $3,342.17
AR Production 1 12 12 2 24 1.2 2.4 $2,228.11
HF Production 1 12 12 1 12 0.6 1.2 $1,114.06 v. LDAR program
PC Production g 0.02 1,092 21.84 2 43.7 2.19 4.37 $4,057.51
AMF Production 2 12 24 3 72 3.6 7.2 $6,684.34
AR Production 2 12 24 2 48 2.4 4.8 $4,456.22
HF Production g 0.02 1,092 21.84 1 21.8 1.09 2.18 $2,023.87
F. Time to Train Personnel i. Material determination methods PC Production N/A
AMF Production N/A

## 24

**Burden item (A)**  **Technical Person**  **** **hours per occurrenc**  **e (B)** 

**No. of occurrence**  **s per**  **responden t**  **per y ear**  **(C)**

**Technical Person**  **** **hours per responde**  **nt per y**  **ear (C=AxB)**  **(D)**

**Responde nts**  **per y ear**  **a (E)** 

**Technical person**  **** **hours per ye**  **ar (E=CxD)**  **(F)**

**Managemen t**  **person**   ** hours per** **ye ar**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per y**  **ear (Ex0.1)**  **(H)**

**Total Cost per y**  **ear b** 

AR Production N/A
HF Production N/A ii. Control equipment inspection and monitoring j
PC Production 8 1 8 4 32 1.6 3.2 $2,939.98
AMF Prduction 8 1 8 3 24 1.2 2.4 $2,228.11
AR Production 8 1 8 2 16 0.8 1.6 $1,485.41
HF Production 8 1 8 1 8 0.4 0.8 $742.70 iii. LDAR program f

, j
PC Production 2 1 2 4 8 0.4 0.8 $742.70
AMF Production 2 1 2 3 6 0.3 0.6 $557.03
AR Production 2 1 2 2 4 0.2 0.4 $371.35
HF Production 2 1 2 1 2 0.1 0.2 $185.68 iv. Container leak tight method PC Production N/A
AMF Production N/A
AR Production N/A
HF Production N/A Subtotal Labor Burden 3481.5 174.08 348.15 $331,146.16

**TOTAL LABOR BURDEN AND COST (rounded)**  4,004 $331,146

## 25 **Assumptions:** a We have assumed that there are 10 existing sources, and that no additional new sources will become subject to the rule over the next three years. It is also assumed that affected facility owners and operators have already complied with the initial requireme nts including the instal l ation of any required equipment. In addition, we have assumed that two sources under this category will hire contractors to comply with the monitoring and recordkeeping requirements of th e rule while reports are developed by the s ource personnel. b This ICR uses the following labor rates: $97.46 per hour for Executive, Administrative, and Managerial labor; $83.71 per hou r for Technical labor, and $42.55 per hour for Clerical labor. These rates are from the United States Departme nt of Labor, Bureau of Labor Statistics, March 19, 2005, “ Table 2. Civilian W orkers, by occupational and industry group. ” The rates are from column 1, “ Total C ompensation. ” The rates have been increased by 110% to account for the benefit packages availab le to those employed by private industry. c We have assumed that there will be no new sources over the next three years of this ICR. W e have also assumed that all exist ing sources have already complied with this one - time activity. d All major sources must submit startup, shutdown, malfunction reports semiannually when actions are taken in the event of a st artup, shutdown, or malfunction that are consistent with the source ’ s SSM plans. Sources can submit this information with the pe riodic reports. e The rules requires that all sources submit periodic reports (semiannually or according to the schedule for Title V). f The standards for equipment leak requires the submittal of an initial report and semiannual reports of leak detectio n and repair (LDAR) and any changes to the processes, monitoring frequency and initiation of a quality improvement program. W e have assumed that sources are submitting the requir ed LDAR information with the periodic reports. g Visual inspections are requ ired once per shift with a total of three shifts per day, at seven days per week, for 52 weeks per year. (3x7x52) for a total of 1,092 inspections per year. h We have determined that, based on the industry representative in the PC category, the two source s ’ use of contractor support to complete the LDAR related monitoring will cost an estimated $8,000. i We have assumed that control equipment monitoring should be done on a weekly basis. j We have assumed that there will be some labor hours associated wi th rule analysis and training per year.



## Table 2: A

**verage A nnual A**  **gency Burden and Cost** 
**- NESHA**  **P for Source Categories: Generic Maximum Achievable Control**  **Technology Standards (40 CFR part 63, subpart YY) (Renew**  **al)**

**Burden item (A** **) Technical**  **Person Hours Per**  **Occurrenc e**  **(B)**

**Number of Occurrenc**  **es Per Year**  **(C)**

**Technical Person**  **Hours Per Plant Per**  **Year (C=A**  **xB) (D)** 

**Plants Per**  **Year a**  

### (E)

**Technica l Hours**  **Per Year (E=CxD)**  **(F)**

**Ma nagemen**  **t Hours Per Year**  **(F=0.05xE) (G)** 

**Clerical Hours**  **Per Year**  **(G=0.1xE )**  **(H)**

**Total Cost,**  **Per Year b** 



### Review Reports

## 26

**Burden item (A** **) Technical**  **Person Hours Per**  **Occurrenc e**  **(B)**

**Number of Occurrenc**  **es Per Year**  **(C)**

**Technical Person**  **Hours Per Plant Per**  **Year (C=A**  **xB) (D)** 

**Plants Per**  **Year a**  

### (E)

**Technica l Hours**  **Per Year (E=CxD)**  **(F)**

**Ma nagemen**  **t Hours Per Year**  **(F=0.05xE) (G)** 

**Clerical Hours**  **Per Year**  **(G=0.1xE )**  **(H)**

**Total Cost,**  **Per Year b** 



### 1. Initial requirements
a. Initial notification c 

### 2 1 2 0 0 0 0 $0

b. Performance test c, d 

### 2 1 2 0 0 0 0 $0 c. Compliance status c 

### 4 1 4 0 0 0 0 $0 d. Performance test reports c, d 

### 4 1 4 0 0 0 0 $0 2. Periodic requirements a. Startup, shutdown, malfunction reports e 

### 2 1 2 0 0 0 0 $0

b. Periodic reports e 

### 3 2 6 10 60 3 6 $2,797.26 c. Leak detection and repair (LDAR) reports f 

### 3 2 6 0 0 0 0 $0

Subtotals Labor Burden and Cost 60 3 6 $2,797.26
**TOTA L LA**  **BOR BURDEN A ND**  **COST (rounded**  ) 69 $2,797

**As sumptions:**  a 

### We have assumed that there are 10 existing sources, and that no additional new sources will become subject to the rule over t he next three y ears. b 

### This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government o verhead expenses: $56.02 for Managerial (GS

- 13, Step 5, $35.01 x 1.6), $41.57 for Technical (GS

- 12, Step 1, $25.98 x 1.6) and $22 .50 Clerical (GS

- 6, Step 3, $14.06 x 1.6). These rates are

## 27 from the Office of Personnel Management (OPM) “ 2005 General Schedule ” which excludes locality rates of pay

. c 

### We have assumed that there will be no new sources over the next three y ears of this ICR, W e have also assumed that all existing sources have already complied with this one

- tim e activity

. d 

### We have assumed that the Agency will not have additional bu rden from sources conducting performance tests due to a process change that may or may not result in the source meeting additional requirements. e 

### We have assumed that all sources have already developed a startup, shutdown and malfunction (SSM) plan. W e have further assumed that sources are submitting their information on SSM with the periodic report which is submitted on a semiannual basis. f 

### The equipment leak standards require the submittal of an initial report and semiannual report of leak detection and repair (LDAR) program experiencing any changes to the processes, monitoring frequency and initiation of a quality im provement program. W e have assumed that sources are submitting the required LDAR information with the periodic reports.