SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Vinyl Chloride (40 CFR Part 61, Subpart F) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Vinyl Chloride (40 CFR Part 61, Subpart F) (Renewal), EPA ICR Number 

0186.13, OMB Control Number 2060-0071.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Vinyl

Chloride were: 1) proposed on December 24, 1975; 2) promulgated on October 21, 1976; and 3) 

amended on June 7, 1977, September 30, 1986, September 23, 1988, December 23, 1992, and 

October 17, 2000. These standards apply to: exhaust gases and oxychlorination vents at ethylene 

dichloride (EDC) plants; exhaust gases at vinyl chloride monomer (VCM) plants; and exhaust 

gases, reactor opening losses, manual vent valves, and stripping residuals at polyvinyl chloride 

(PVC) plants. The standards also apply to relief valves and fugitive emission sources at all three 

types of plants. New facilities include those that commenced construction or reconstruction after 

the date of proposal. This information is being collected to assure compliance with 40 CFR part 

61, subpart F.

In general, all NESHAP standards require initial notification reports, performance tests, 

and periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least three years following the date of such 

measurements, maintenance reports, and records. All reports are sent to the delegated state or 

local authority. In the event that there is no such delegated authority, the reports are sent directly 

to the U. S. Environmental Protection Agency (EPA) regional office.

Over the next three years, an average of 18 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to these standards. This 

estimate accounts for the impact of the part 63 PVC NESHAP, which will become effective on 

April 17, 2015. Beginning on this date, a subset of existing sources subject to these standard will 

become subject to the part 63 rule, and will no longer need to comply with the part 61 NESHAP. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”
2

The respondents are EDC, PVC, and VCM plants in the United States, which are owned 

and operated by the vinyl chloride industry. None of the plants are owned by state, local, tribal, 

or the Federal government. The “burden” to the “Affected Public” may be found below in Table 

1: Annual Respondent Burden and Cost – NESHAP for Vinyl Chloride (40 CFR Part 61, Subpart 

F) (Renewal). The Federal Government “burden” is attributed entirely to work performed by

either Federal employees or government contractors and may be found below in Table 2: 

Average Annual EPA Burden and Cost – NESHAP for Vinyl Chloride (40 CFR Part 61, Subpart 

F) (Renewal). 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources 

of hazardous air pollutants. These standards are applicable to either new or existing sources of 

hazardous air pollutants and shall require the maximum degree of emission reduction. In 

addition, section 114(a) states that the Administrator may require any owner/operator subject to 

any requirement of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, ethylene dichloride, vinyl chloride, and polymerized 

vinyl chloride emissions from EDC, PVC, and VCM plants 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 61, subpart F.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which where promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standards. Continuous emission monitors are used to 
3

ensure compliance with the standards at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in these standards are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standards are being met. 

The performance test may also be observed.

The required quarterly reports are used to determine periods of excess emissions, identify

problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

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

The requested recordkeeping and reporting are required under 40 CFR part 61, subpart F.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.

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

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (78 FR 35023) on June 11, 2013. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts. 

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standards
4

have been reviewed previously to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted: 1) the Vinyl Institute, at (571) 970-3283; and 

2) the American Chemistry Council, at (202) 249-6706. The Vinyl Institute provided both 

editorial comments and technical corrections in response to the consultation. We have corrected 

the frequency of occurrence for submitting MVV/RVD reports in Table 1 to be consistent with 

the remaining supporting statement. In addition, we have revised the number of respondents to 

address the impact of the part 63 NESHAP rule on this standard. 

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

3(f) Confidentiality

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

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

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

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes
5

The respondents to the recordkeeping and reporting requirements are EDC, VCM, and PVC

manufacturing plants. The United States Standard Industrial Classification (SIC) code for the 

respondents affected by the standards is SIC 2821, which corresponds to the North American Industry

Classification System (NAICS) code 325211 for Plastics Material and Resin Manufacturing.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NESHAP for Vinyl 

Chloride (40 CFR Part 61, Subpart F). 

A source must make the following reports:

Notifications/ Reports

Notification and application of construction or modification 61.07

Notification of anticipated date of initial startup 61.09(a)(1)

Notification of actual startup 61.09(a)(2)

Notification of physical or operational change which may increase the 

emission rate 61.15

Notification of performance tests 61.13(f)

Notification of emissions testing 61.13(c)

Application for waiver of testing 61.13(i)(1), and 

61.13(i)(2)

Application for equivalent equipment and procedures 61.66

Initial report 61.69

Quarterly report 61.70(a)(1)

Manual vent valve (MVV) discharge report 61.64(a)(3)

Relief valve discharge (RVD) report 61.65(a)

A source must keep the following records:

Recordkeeping

Startup, shutdown, malfunction, periods where the continuous 

monitoring system is inoperative 61.14(f)

Emission test results and other data needed to determine emissions 61.13(g), 
6

Recordkeeping

61.71(1)(3)

Records of leak detected 61.71(a)(1), 

61.71(a)(2)

Performance test records, leaks detected, emissions records, and daily 

operating records are required to be retained on-site for three years

61.67(f), 61.71(a)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

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

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate vinyl chloride CMS. 

Perform initial performance test, Reference Method 106, 107, and or 601 test, and repeat 

performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.
7

Respondent Activities

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way e.g., continuous parameter monitoring system. Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly

reduced the burden associated with monitoring and recordkeeping. 

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply

with the emission standard, and note the operating conditions under which compliance was 

achieved. Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS 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 OTIS 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.
8

The records required by this regulation must be retained by the owner/operator for three 

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost – NESHAP for Vinyl Chloride 

(40 CFR Part 61, Subpart F) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 7,603 (Total Labor Hours from Table 1 below). 

These hours are based on Agency studies and background documents from the development of 

the regulation, Agency knowledge and experience with the NESHAP program, the previously 

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 
9

Managerial $123.04 ($58.59+ 110%) 

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2013, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

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

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

CEMS $150,000 0 $0 $45,000 18 $810,000

CEMS – Continuous emissions monitoring system. 

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $810,000. This is the 

total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $810,000. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 
10

The average annual Agency cost during the three years of the ICR is estimated to be 

$82,090. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2013 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Vinyl 

Chloride (40 CFR Part 61, Subpart F) (Renewal). 

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

Based on our research for this ICR, approximately 26 existing sources are currently

subject to the standard. After April 17, 2015 (year 2 of this ICR period), 12 of these sources will 

comply with the part 63 PVC NESHAP, and will no longer be subject to this standard. Of the 

remaining 14 sources, half will be subject only to this standard while half will be subject to both 

the part 61 and part 63 rules. It is estimated that no additional respondents per year will become 

subject. The overall average number of respondents, as shown in the table below, is 18 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR:

 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of 

New

Respondents 1

(B)

Number of 

Existing 

Respondents 2

(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)
11

Number of Respondents

1 0 26 0 0 26

2 0 14 0 0 14

3 0 14 0 0 14

Average 0 18 0 0 18

1

New respondents include sources with constructed, reconstructed and modified affected facilities. 

2 After the effective date of the part 63 PVC NESHAP (April 17, 2015), we estimate that 12 of the existing 26 

sources will become subject to the part 63 rule, and will no longer be subject to this standard. Therefore, the 

number of sources that will be subject to these standards beginning in Year 2 of this ICR is (26 – 12) = 14. 

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 18.

The total number of annual responses per year is calculated using the following table: 

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Quarterly Reports 18 4 N/A 72

Manual vent valve/relief valve 

discharge (MVV/RVD) Reports

18 3 N/A 54

Total 126

The number of Total Annual Responses is 126. 

The total annual labor costs are $743,615. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Vinyl Chloride (40 

CFR Part 61, Subpart F) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 7,603 hours at a cost of $743,615. Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost –
12

NESHAP for Vinyl Chloride (40 CFR Part 61, Subpart F) (Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 60 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $810,000. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

1,822 labor hours at a cost of $82,090. See below Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Vinyl Chloride (40 CFR Part 61, Subpart F) (Renewal). 

6(f) Reasons for Change in Burden

There is a decrease in the respondent and Agency burden as a result of the PVC NESHAP 

standard at 40 CFR part 63, subpart HHHHHHH. Beginning in April 17, 2015, 12 of the 

existing vinyl chloride plants will comply with the part 63 rule, and will no longer be subject to 

the part 61 NESHAP. Therefore, we expect a decrease in the number of respondents beginning 

in Year 2 of this ICR period. In addition, we have updated the number of existing sources from 

28 in the previous ICR to 26 based on latest Agency estimates for this industry. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 60 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, or disclose or provide information 

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

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

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

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

burden estimates, and any suggested methods for minimizing respondent burden, including the 

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

Docket ID Number EPA-HQ-OECA-2013-0328. An electronic version of the public docket is 
13

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

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

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

Number EPA-HQ-OECA-2013-0328 and OMB Control Number 2060-0071 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Vinyl Chloride (40 CFR Part 61, Subpart F) (Renewal)

Reporting/Recordkeeping Requirements

(A) 

Personhours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(AxB)

(D) 

Respondents 

per year (a)

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours 

per 

year 

(Ex0.1)

(H) 

Cost,$ (b)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions 1 1 1 0 0 0 0 $0

B. Required activities

Initial performance test c60 1 60 0 0 0 0 $0

Repeat performance tests d60 0.2 12 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3B

E. Write Report

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

Notification of anticipated startup 2 1 2 0 0 0 0 $0

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

Notification of emission testing 2 1 2 0 0 0 0 $0

Notification of test report 2 1 2 0 0 0 0 $0

Notification of physical or operational change e2 1 2 0 0 0 0 $0

Application for waiver of testing f8 1 8 0 0 0 0 $0

Application of equivalency g40 1 40 0 0 0 0 $0

Initial report 24 1 24 0 0 0 0 $0

Quarterly report h50 4 200 18 3,600 180 360 $404,964.00
15

Reporting/Recordkeeping Requirements

(A) 

Personhours per 

occurrence

(B) 

No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(AxB)

(D) 

Respondents 

per year (a)

(E) 

Technical 

personhours per 

year 

(CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours 

per 

year 

(Ex0.1)

(H) 

Cost,$ (b)

MVV/RVD report i8 3 24 18 432 21.6 43.2 $48,595.68 

Subtotal for Reporting Requirements 4,636.8 $453,560 

A. Read instructions See 3A

B. Plan activities See 3B

C. Implement Activities See 3D

D. Develop record system N/A

E. Time to enter information

Records of reactor parameters and emission j0.25 365 91.25 18 1,643 82.13 164.25 $184,764.83

Records of leaks detected k1 52 52 18 936 46.8 93.6 $105,290.64

F. Time to train personnel N/A

G. Time for audits N/A

Recordkeeping Subtotal 2,965.78 $290,055.47

TOTAL ANNUAL BURDEN AND LABOR COST (rounded) 7,603 $743,615 

Assumptions:

a

 We estimate there are currently 26 existing sources. Beginning in Year 2 of this ICR, only 14 sources will be subject to this part 61 standard. Therefore, the 

average number of sources over the 3-year period is 18. We have further assumed that there will be no new growth in the industry over the next three years.

b

 This ICR uses the following labor rates: $123.04 for managerial labor, $101.22 for technical labor, and $51.18 for clerical labor. These rates are from the U.S. 

Department of Labor, Bureau of Labor Statistics, March 2013. The rates have been increased by 110 percent to account for overhead.

c

 We have assumed that it will take 60 hours to complete the performance tests.

d

 We have assumed that 20 percent of initial performance tests must be repeated due to failure.

e

 Assumed that there will be no physical or operational changes over the next three years.

f Assume it will take eight hours to prepare application for waiver of testing.

g

 Assume it will take 40 hours to prepare application for equivalency.

h

 We have assumed that it will take 50 hours to prepare the quarterly report.

i

 We have estimated that there will be three discharges of manual vent valve/relief valve discharge (MVV/RVD) per year.
16

j

 Assume that affected facilities will operate 365 days per year as required of all facilities that are subject to the rule.

k

 It is estimated that it will occur 52 times per year to enter records of leak detection.
17

Table 2: Average Annual EPA Burden and Cost – NESHAP for Vinyl Chloride (40 CFR Part 61, Subpart F) (Renewal)

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

personhours 

per 

plant 

per year 

(AxB)

(D) 

Plants 

per 

year

(E) 

Technical 

personhours per 

year 

(CxD)

(E) 

Management 

personhours per 

year 

(Ex0.05)

(F) 

Clerical 

personhours 

per year 

(Ex0.1)

(H) 

Cost b($)

1. Initial performance test c24 1 24 0 0 0 0 $0

2. Repeat performance test d24 0.2 4.8 0 0 0 0 $0

3. Report review

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

Notification of anticipated startup 0.5 1 0.5 0 0 0 0 $0

Notification of actual startup b0.5 1 0.5 0 0 0 0 $0

Notification of emission testing 0.5 1 0.5 0 0 0 0 $0

Notification of physical or operational 

change e 0.5 1 0.5 0 0 0 0 $0

Emission test report f24 1 24 0 0 0 0 $0

Application for waiver of testing g24 1 24 0 0 0 0 $0

Application for equivalency 24 1 24 0 0 0 0 $0

Initial report 24 1 24 0 0 0 0 $0

Quarterly report h4 4 16 18 288 14.4 28.8 $14,925.46 

MVV/RVD report i24 3 72 18 1,296 64.8 129.6 $67,164.55 

TOTAL ANNUAL BURDEN (rounded) 1,822 $82,090 

Assumptions:

a

 We estimate there are currently 26 existing sources. Beginning in Year 2 of this ICR, only 14 sources will be subject to this part 61 standard. Therefore, the 

average number of sources over the 3-year period is 18. We have further assumed that there will be no new growth in the industry over the next three years.

b

 This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for 

Managerial (GS-13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6) and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are 
18

from the Office of Personnel Management (OPM) 2013 General Schedule which excludes locality rates of pay.

c

 We have assumed that it will take twenty-four hours to complete the performance tests.

d We have assumed that 20 percent of initial performance tests must be repeated due to failure.

e

 Assume that there will be no physical or operational changes over the next three years.

f It is assumed that it will take twenty-four hours to review an emissions test report.

g Assume that it will take twenty-four hours to review application for waiver of test.

h We have assumed that it will take four hours to review the quarterly report.

i We have assumed that there will be three discharges of manual vent valve/relief valve discharge (MVV/RVD) per year.