**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Vinyl Chloride**  **(40 CFR Pa**  **rt 61**  **, Subpart F**  **) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Vin ylChloride (40 CFR Part 61, Subpart F) (Renewal), EPA I CR Number 0186.13 , OMB Control Number 2060

- 0071

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Vin yl 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 appl y to : exhaust gases and ox ychlorination vents at ethylene dichloride (EDC) p lants; exhaust gases at vinyl chloride monomer (VCM) plants; and exhaust gases, reactor opening losses, manual vent valves, and stripping residuals at poly vinyl chloride (PVC) plants. The standards also appl y to relief valves and fugitive emission sources at all three ty pes 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 report s, performance tests, and periodic reports b y 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 an y 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 ye ars 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Over the next three ye ars, an average of 18 respondents per ye ar will be subject to the standard , and no additional respondents per year will become subject to the se standard s
. 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 th e s e s tandard 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 currentl y active I CR without any

“Terms of Clearance.”2

The respondents are EDC, PVC, and VCM plants in the United States, which are owned and operated b y the vin yl 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 Res pondent 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 F ederal emplo yees or government contractors and may be found below in Table 2: Av erage 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 inte rvals, 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 reasonabl y require. In the Administrator's judgment, eth yl ene dichloride, vinyl chloride, and poly merized 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 standard s
. Continuous e mission monitors are used to3

ensure compliance with the standard s 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 the se standard s 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 properl y installed and operated , leaks are being detected and repaired , and the standard s are being met. The performance test may also be observed. The required quarterl y reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/mai ntenance 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 directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 cop y 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) Pub lic 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 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 b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of all complianc e 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 standard s4

have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this I CR, we contacted : 1) the Vinyl Institute , at (571) 970

- 3283 ; and 2) the American Chemistry Council , at (202) 249

- 6706

. The Vin ylInstitute 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 rene wal 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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**
T he 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 ( SI C ) code for the respondents affected b y the standards is SI C 2821 , which corresponds to the North American Industry Classification System (NAI CS ) code 325211 for Pl astics Material and Resin Manufacturing

. **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y NESHAP for Vinyl Chloride (40 CFR Part 61, Subpart F)

. A source must make the following reports:
**Notification s**  **/ 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 ph ys ical 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 Quarterl y 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 sy stem 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 dail y 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 recordke eping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated th at approximately 10 percent of the respon dents 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining info rmation. 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.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 s ys tem. 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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **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 p roperl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comp ly with the emission standard, and note the operating conditions under wh ich 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 mainten ance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data fo r approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authoriti es can edit, store, retrieve and analyze the data.8

The records required b y this regulation must be retained by the owner/operator for three ye ars. **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 ty pes 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 Respond ent 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 I CR. 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 an d 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 requirement s is estimated to be 7,60 3 ( Total Labor Hours from Table 1 below). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previousl y approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Cost**  **s** This I CR uses the following labor rates:9
Managerial $ 123.04 ($5 8

. 59 + 110%) Technical $ 10 1

. 2 2 ($4 8

. 2 0 + 110%) Clerical $ 51

. 18 ($2 4

. 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 b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Es timating Capital/Startup and Operation and Maintenance Costs**  The ty pe 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 photocop ying 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 I CR are $ 0 . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR 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 IC R is estimated to be $ 810 ,000

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. E PA's overall compliance and enforcement program i ncludes activities such as the examination of records maint ained 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 hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Cleri cal $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 3 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 I CR, approximately 26 existing sources are currentl y subject to the standard. After April 17, 2015 (year 2 of this I CR 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. Itis estimated that no additional respondents per year will become subject. The overall av erage number of respondents, as shown in the table below, is 18 per ye ar. The number of respondents is calculated using the following table that addresses the three ye ars covered b y 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 su bject to th e s e standard s beginning in Year 2 of this ICR is (26

– 12) = 14. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 18

. The total number of annual responses per ye ar 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 Table s**  The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 7,60 3 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 Vin ylChloride (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, 201 5 , 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 u pdated the number of existing sources from 28 in the previous I CR 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 av erage 60 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instruction s; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 IC R under Docket ID Number EPA

- HQ

- OECA

- 201 3

- 0328

. An electronic version of the public docket is13

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 sy stem , 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include th e EPA Docket ID Number EPA

- HQ

- OECA

- 201 3

- 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.14

**Table 1: Annual Respondent Burden and Cost**

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

**Reporting/Recordkeeping Requirements (A)**  **Person**
  ** hours per** **occurrence (**  **B )** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent per year**  **(AxB) (D)** 

**Respondents per year (a)**  **(E)**

**Technical person**  **** **hours per year**  **(CxD) (F)** 

**Managem ent**  **person**   ** hours per** **year (Ex0.05)**  **(G)**

**Clerical person**  **** **hours per**  **y ear**  **(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 c 60 1 60 0 0 0 0 $0 Repeat performance tests d 60 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 e 2 1 2 0 0 0 0 $0 Application for waiver of testing f 8 1 8 0 0 0 0 $0 Application of equivalency g 40 1 40 0 0 0 0 $0 Initial report 24 1 24 0 0 0 0 $0 Quarterly report h 50 4 200 18 3,600 180 360 $404,964.0015

**Reporting/Recordkeeping Requirements (A)**  **Person**
  ** hours per** **occurrence (**  **B )** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent per year**  **(AxB) (D)** 

**Respondents per year (a)**  **(E)**

**Technical person**  **** **hours per year**  **(CxD) (F)** 

**Managem ent**  **person**   ** hours per** **year (Ex0.05)**  **(G)**

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

**Cost,$ (b)**

MVV/RVD report i 8 3 24 18 432 21.6 43.2 $48,595.68 **Subtotal for Reporting Requirements**  **4,63 6.8**  **$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 j 0.25 365 91.25 18 1,643 82.13 164.25 $184,764.83 Records of leaks detected k 1 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)**  **7,60 3**  **$743,615**
**Assu mptions:** 
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. Th erefore, the average number of sources over the 3

- year period is 18. We have further assumed that there will be no ne w 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 l abor. These rates are from the U.S. Department of Labor, Bureau of Labor Statistics, Mar ch 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 d ischarge (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 person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**  **** **hours per**  **plant per year**  **(AxB) (D)** 

**Plants per**  **year (E)**  **Technical person**  **** **hours per year**  **(CxD) (E)** 

**Managem ent**  **person**   ** hours per** **year (Ex0.05)**  **(F)**

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost b**  **($)**

1. Initial performance test c 24 1 24 0 0 0 0 $0 2. Repeat performance test d 24 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 b 0.5 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 f 24 1 24 0 0 0 0 $0 Application for waiver of testing g 24 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 h 4 4 16 18 288 14.4 28.8 $14,925.46 MVV/RVD report i 24 3 72 18 1,296 64.8 129.6 $67,164.55 **TOTAL ANNUAL BURDEN (rounded)**  **1,822 $82,090** 
**Assu mptions:**  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 ne w growth in the industry over the next three years. b Th is cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government ove rhead 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 are18

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 W e have assumed that 20 percent of initial performance test s 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

- fo ur hours to revie w 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.