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 1737.01. 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 National 

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 Polymers & Resins IV NESHAP, 

which include an estimated 30 existing facilities that produce thermoplastic resin in the following 

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

Styrene (MBS), Polyethylene Terephthalate (PET), Polystyrene (PS), and Styrene Acrylonitrile 

(SAN). Respondents also include any of the 30 facilities who may wish to make use of the new 

affirmative defense provisions in the amendments to the rule.

The proposed amendments require that that there be no discharge to the atmosphere from 

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

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

facility owners or operators are required to install electronic indicators on each PRD that would 

be able to identify and record the time and duration of each pressure release and notify operators 

that a pressure release has occurred. 
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In addition to requirements for PRD, the amendments also provide requirements 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 proposed amendments also add provisions for facility owners or operators to use if 

they wish to assert an affirmative defense to avoid civil penalties for 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 exceedance 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 comply

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 compliance with the existing and new 

requirements of the Polyether Polyols 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
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single HAP and more than 25 tpy of any combination of HAP. The Polymers and Resins IV 

source category contains major sources of 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 compliance 

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 114 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 proposed 

amendments are being achieved. Based on review of the recorded information at the site 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 glycol 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 penalties 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, certain 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. 
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(b) Public Notice Required Prior to ICR Submission to OMB.

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

Comments will be solicited on the proposal package and the proposed ICR. 

(c) Consultations. 

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 l13(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 program 

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; 
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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 30 existing facilities 

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

specified under the Polymers & Resins IV NESHAP. All 30 existing facilities could make use 

of the new affirmative defense provisions added to the rule. No new major 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 requirements, 

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 proposed amendments to the Polymers and Resins 

IV NESHAP require that facilities report any pressure device releases, equipment leaks from 
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equipment in gas/vapor or light liquid service, or exceedances of the ethylene glycol 

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 install electronic indicators on each PRD 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 for asserting an affirmative defense have been 

met. The report also must include a root cause analysis of the malfunction and must be 

submitted within 45 days of the initial occurrence of the emissions exceedance. The owner or 

operator must notify the administrator within 2 days of the initial occurrence of the malfunction 

if it wishes to avail itself of an affirmative defense.

EPA is including in Table 3 (located at the end of this supporting statement) an estimate 

of the burden associated with performing an affirmative defense. 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 

pollution 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 operation 

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 position adopted by a source, 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. EPA’s 

estimate for the required notification, reports and records, including the root cause analysis, 
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associated with a single incident totals approximately $2,188 and is based on the time and effort 

required of a source 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 EPA. EPA 

provides this illustrative estimate of this burden 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 

Information 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 maintained 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 

for 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 criteria for affirmative defense, they may be 

excused from civil penalties for exceedances of an emission limit.
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EPA is the permitting authority until the state agency is delegated authority to implement the 

rule. Therefore, information contained in the reports submitted to the Regional Administrator 

will be entered into the Air Facility System (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.

(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 source category was taken into 

consideration during development of the proposed amendments. Due to the proposed type of 

monitoring equipment to be used, 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. 

(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 proposed amendments to the Polymers and Resins IV 

NESHAP are shown in Table 1. These numbers were derived from estimates based on 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 
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Table 1. Information used to estimate the burden resulting from the new requirements is based 

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

Copolymers Production NESHAP (Subpart HHHHHHH).

EPA’s estimate for an affirmative defense and root cause analysis 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 to produce and retain the report in document form 

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

review it. The estimates of total technical-hours per year per source for asserting an affirmative 

defense are listed in Table 1 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 July 2010. 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 $24.58/hour. Wages for management labor are from the category "general 

and operations managers" with a mean hourly wage of $49.96/hour. Wages for clerical labor are 

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

$19.84/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-burdened hourly wage rates used to represent respondent labor costs are: 

technical at $51.62, management at $104.92, and clerical at $41.66. 

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

proposed amendments to the Polymers and Resins IV NESHAP, facility owners or operators are 

required to install electronic indicators on each PRD to identify and record the time and duration 

of each pressure release. The cost of each monitoring system is expected to be $188,913, and the 

total cost for these capital expenditures for all facilities in the Polymers and Resins IV source 

category is estimated to be $5,667,390. The operation and maintenance (O&M) costs expected 

from operating the electronic indicators have not been estimated. 
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(iii) Annualizing Capital Costs. Annualized costs are calculated by multiplying the 

capital recovery factor by the capital cost. The capital recovery factor is 0.1424 based on an 

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

cost is $806,910.

(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. Because 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 

Government. 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 part 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 proposed amendments related to PRD, respondents include owners or operators 

of all 30 existing facilities regulated by the Polymers and Resins IV NESHAP. For the proposed 

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 all 30 of the existing facilities could make use of the new affirmative defense 

provisions added to the rule, EPA estimates only two total instances of the use of these 
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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. 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 30 existing facilities subject to the proposed 

amendments to the Polymers and Resins NESHAP is 409 person-hours, with an annual labor cost 

of $22,087.

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

result of the proposed 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 increase in burden of 409 hours per year due to implementation of 

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

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

of the affirmative defense. EPA’s estimate for the required notification, reports and records, 

including the root cause analysis, associated with a single incident totals approximately $2,188 

and is based on the time and effort required of a source 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 EPA. For the purpose of estimating the annual burden, EPA is attributing a 

total of 2 instances of affirmative defense over a three year period across all sources in the 

category. EPA is using this frequency of 2 events in three years because, of the number of excess 

emission events reported by source operators, only a small number would be expected to result 
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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. 

(g) Burden Statement

The average annual respondent burden is estimated to average 409 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

applicable instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and transmit 

or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to a 

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

control numbers for EPA’s regulations 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, 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 
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docket that are available electronically. When 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 17th Street, NW, 

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

Number (EPA-HQ-OAR-2011-0435) in any correspondence.

PART B

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

associated with the rule.
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TABLE 1. ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS OF THE FINAL STANDARD

(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 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

2. Survey and Studies 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

3. Acquisition, Installation, & Utilization of Tech. & Systems 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

4. Reporting Requirements 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

A. Read instructions 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

B. Required activities

C. Create information 0.00 0.0 0.0 0.0 0.0 0.0 0.0

D. Gather existing information 0.00 0.0 0.0 0.0 0.0 0.0 0.0

E. Write report 0.00 0.0 0.0 0.0 0.0 0.0 0.0

 Semi-annual periodic reports (PRD monitoring) 5.50 2.0 11.0 30.0 330.0 16.5 33.0 $ 20,140

 Semi-annual periodic reports (Equip. leaks) 3.00 2.0 6.0 1.0 6.0 0.3 0.6 $ 366

 Semi-annual periodic reports (PCCT) 1.00 2.0 2.0 1.0 2.0 0.1 0.2 $ 122

 Leak detection and repair reports 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

 Performance test notification 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

 Performance test report 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

 Affirmative defense (d) 18.00 - - - 12.00 8.00 0.0 $1,459

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

respondent did not qualify for semiannual reporting) 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

REPORTING SUBTOTAL 27.50 6.00 19.0 32.0 350.0 24.9 33.8 $ 22,087

5. Recordkeeping Requirements

A. Read instructions 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

B. Plan activities 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

C. Implement activities 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

D. Develop record system 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

E. Time to enter information

 Plan Activities 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

 Create, Test, Research, Develop 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

 Gather information, Monitor, Inspect 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

 Process, Compile, Review 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

F. Time to train personnel 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

G. Time to adjust existing ways to comply w/ prev. appl. req. 0.00 0.0 0.0 0.0 0.0 0.0 0.0

H. Time to Record and disclose information 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

 Store, file and maintain records 0.00 0.0 0.0 0.0 0.0 0.0 0.0 $ -

I. Time for audits 0.00 0.0 0.0 0.0 0.0 0.0 0.0

0.0 0.0 0.0

TOTAL ANNUAL NUMBER OF RESPONSES (e) 60.7

TOTAL ANNUAL BURDEN HOURS 350.0 24.9 33.8 408.7

TOTAL ANNUAL COST (SALARY) $ 22,087

INITIAL CAPITAL COSTS: $ 5,667,390

ANNUALIZED CAPITAL COSTS: $ 806,910

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 $51.62, management at $104.92, and clerical at $41.66

(d) 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

(e) Total responses calculated by adding semiannual reports (30 sources * 2 responses) and affirmative defense (0.67 responses (2 responses in 3 years))
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RCFA Personnel Number of Personnel Time Requirement (hours) Total Hours Hourly Rate ($/hr) Total

Technical Personnel 3 6 18 51.62 929.16

Managerial Personnel 2 6 12 104.92 1,259.04

Total 5 30 2,188.20

*Ref. 1: Bureau of Labor Statistics Occupational earnings tables: United States, December 2009 - January 2011 (average reference date July 2010) 

Table 4. Full-time private industry workers: Mean and median hourly, weekly, and annual earnings and mean weekly and annual hours. Available at

http://www.bls.gov/ncs/ocs/sp/nctb1478.pdf

TABLE 2. COST ESTIMATE FOR AFFIRMATIVE DEFENSE/ROOT CAUSE ANALYSIS

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

(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 personoccurrence 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
16

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)