**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Polyvinyl Chloride and Copolymers Production**  **(40 CFR Part 63, Subpart HHHHHHH** **) (Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NESHAP for Poly

vinyl Chloride and Copoly mers Production (40 CFR Part 63, Subpart HHHHHHH) (Renewal), EPA ICR Number 2432.03 , OMB Control Number 2060

- 0666

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous A ir Pollutants (NESHAP) for Poly vinyl Chloride (PVC) and Copoly mers Production were proposed on May 20, 2011, and promulgated on April 17, 2012. These regulations appl y to both new and existing major source PVC production facilities. Area source PVC facilities are subject to 40 CFR Part 63, Subpart DDDDDD and not covered in this I CR. 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 63, Subpart HHHHHHH. In general, all NESHAP standards require initial report notifications, 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 any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are req

uired 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 five years following the date of such measurements, maintenance reports, and records. All reports are sent to the deleg ated 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 1 7 respondents per ye ar will be subject to the standard, and no additional respondents per year will become subject to the standard. This estimate is based on consultation with industry trade association during the renewal of this I CR. The Office of Management and Budget (OMB) approved the currentl y active ICR without any

“Terms of Clearance.” All of the subject major source PVC facilities are owned b y the private sector. The “burden” to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Poly vinyl Chloride and Copoly mers Production (40 CFR Part 63, Subpart HHHHHHH) (Renewal). The Federal Government “burden” is attributed entirel y to2

work performed b y either F ederal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Poly vinyl Chloride and Copoly

mers Production (40 CFR Part 63, Subpart HHHHHHH) (Renewal). **2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charg ed under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction

. Inaddition, 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 reasonabl y require

. In the Administrator's judgment, hazardous air pollutant (HAP) emissions from major source PVC production facilities cause or contribute to air pol lution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category

at 40 CFR Part 63, Subpart HHHHHHH

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which w ere promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Perfo rmance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard s . Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance test a reco rd 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 delegated3

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 are being met. The performance test may also be observed. The required semiannual 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 63 , Subpart HHHHHHH

. **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 ICR was published in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency

has consulted industry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is Enforcement and Compliance History Online (ECHO), which is operated and maintained by EPA's Office of Compliance. ECHO 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 as sociated with the standard as it was being developed. In developing this ICR, we contacted the Vinyl Institute , at (202) 765

- 2200 , and Formosa Plastics , at (973) 992

- 2090

. The VinylInstitute provided substantial comments on the respondent universe and specific burden hours and costs associated with the reporting and recordkeeping requirements. We have updated this ICR to incorporate the comments received.4

**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 b y 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** These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR Part 1320, Section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

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

- ye ar statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant viol ators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 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 major source PVC production facilities . The United States Standard Industrial Classification ( SIC ) code for the respondents affected b y the standards is SIC 2821 which corresponds to the North American Industry Classification System (NAICS ) 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 b y the NESHAP for Poly vinyl Chloride and Copoly mers Production (40 CFR Part 63, Subpart HHHHHHH)

. A source must make the following reports:
**Notification s**  Initial notification 63.9(b) Batch pre

- compliance report 63.11985(c)(2) and 63.11985(c)( 3) and 63.11985(c)( 8) Notification of performance test with test plan 63.9(e) Notification of compliance status 63.11985(a) Compliance report 63.10(e)(3), 63.11985(b) Notice of Inspection 63.11985(c)(1) A source must keep the following records: **Recordkeeping** A cop y of each notification and report submitted to comply with this subpart 6 3

. 11990 (a)
Records of storage vessels 6 3

. 11990 (b ) Records of equipment leaks 6 3

. 11990 ( c ) Records of heat exchanger s ys tems 6 3

. 11990 ( d) Records of process vents 6 3

. 11990(e) and 6 3

. 11990 ( f

) Records of closed vent systems 63.11930(g) and 6 3

. 11990 ( g )6 **Recordkeeping** Records of resin strippers 6 3

. 11990(e) and 6 3

. 11990(h) Records of process wastewater 6 3

. 11990(e) and 6 3

. 11990(i) Keep records for five ye ars 6 3

. 11995(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. **(ii) Respondent Activities Respondent Activities**  Familization with the regulatory requirements

. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for control devices. Perform initial performance test, Reference Method 301, 303, 303A, 304B, 305 , 306, 306A, 308, 312C, 315, 316, 319, 320, 321 test s , 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. Transmit, or otherwise disclose the information. **5. The Information Collected: Agency Activities, Collection Methodology, and** 7

**Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information below: **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 Integrated Compliance Information System (I CI S) and ECHO. **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 properl 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 which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in complianc e and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations

. In formation contained in the reports is reported b y state and local governments in the IC IS Air database which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** There are no small entities (i.e., small businesses) affected b y this regulation. **5(d) Collection Schedule**8

The specific frequency

for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Poly vinyl Chloride and Copoly

mers Production (40 CFR Part 63, Subpart HHHHHHH) (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 record

keeping and reporting requirement s is estimated to be 37 8 , 00 0 ( Total Labor Hours below from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency kno wledge 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: Managerial $ 129

. 93 ($ 61.87 + 110%) Technical $ 103

. 97 ($ 49.51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 66 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 , “ 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) Estimating 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 costs are one - time cos ts when a facility beco mes subject to the regulation, such as monitoring s ys tem installation , initial performance9

testing, resin stripper testing, and wastewater testing

. The annual operation and maintenance costs are the ongoing costs to maintain the monitors, perform subsequent testing, 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)

**Continuous Parameter Monitoring** PRD Electronic Monitor 8 $375,000 0 $0 $26,897 17 $457,249 VC Ambient mo nitoring 9 NA 0 $0 $164,250 17 $2,792,250 Gas holders $5,000 0 $0 NA 17 $0 **Periodic Testing** Process Vent Testing $51,198 0 $0 $48,030 17 $816,510 Resin Sampling and Monitoring 1 $1,803 0 $0 $7,212 17 $122,604 Stripped resin: Non

VC TOHAP testing 2 $1,950 0 $0 $23,400 17 $397,800 Wastewater Testing 3 $491 0 $0 $5,892 17 $100,164 Wastewater: Non

- VC TOHAP testing4 $650 0 $0 $7,800 17 $132,600 Uncontrolled Wastewater testing 5 $0 0 $0 $491 85 $41,735 Uncontrolled wa stewater: Non

- VC TOHAP testing 6 $3,250 0 $0 $3,250 17 $55,250 Equipment Leak Testing 7 $77,798 0 $0 $18,205 13 $236,665 **Total** $0 $5,152,827

1 Monthly testing ($601 x 12 months = $7,212 per year) 2 Per VI's comments, the costs of Non

-VC TOHAP testing is $650 per sample, and 3 resin samples per facility. 3 Monthly testing ($491 x 12 months = $5,892 per year) 4 Per VI's comments, the costs of Non

-VC TOHAP testing is $650 per sample, and one sample per facility. 5 Per VI's comments, there are 5 uncontrolled wastewater streams per source sampled annually. 6 Per VI's comments, the costs of Non

-VC TOHAP testing is $650 per sample, and five samples per facility. 7 13 facilities are expected to be required to increase stringency of their LDAR programs to 40 CFR Part 63, Subpart UU.10

8 Per VI's comments, the capital cost of the PRD monitor is $15,000 per device, and it is assumed that 25 devices per facility require indicators. 9 Per VI's comments, there are 73 GC monitors in the industry (3 area source and 17 major source) with an annual O&M cost of $45,000 per monitor. The total capital/startup costs for this ICR are $ 0 . The total operation and maintenance ( O&M) costs for this ICR are $ 5,150,000

. 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 $ 5,150,000

. **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. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic in spection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 42,0 00

. This cost is based on the average hourl y labor rate as follow s: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 5 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 Cos t

– NESHAP for Poly vinyl Chloride and Copoly

mers Production (40 CFR Part 63, Subpart HHHHHHH) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this ICR, on average over the next three ye ars, approximately 1 7 existing respondents will be subject to the se standard s . It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is 1 7 per year. This estimate is base d on data provided by the VinylInstitute during the renewal of this ICR. 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 Do11 **Number of Respondents** Respondents That Submit Reports Not Submit Any Reports

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 17 0 0 17
2 0 17 0 0 17 3 0 17 0 0 17 Average 17 1 New respondents include sources with constructed, reconstructed and modified affected facilities. 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 1 7

. The total number of annual responses per ye ar is calculated using the following table below :

**Total Annual Responses** 

(A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

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

Initial notification 0 1 0 0 Batch pre

- compliance report 0 1 0 0 Notification of performance test with test plan 0 1 0 0 Notification of compliance status 0 1 0 0 Compliance report 17 2 0 34 Notice of Inspection 17 1 0 1 7 Total 51 The number of Total Annual Responses is 51

.12

The total annual labor costs are $ 3 8 , 0 00,000

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Poly vinyl Chloride and Copoly

mers Production (40 C FR Part 63, Subpart HHHHHHH) (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, respectivel y, and summarized below. **(i) Respondent Tally**  The total annual labor hours are 37 8 , 00 0

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Poly vinyl Chloride and Copoly mers Production (40 CFR Part 63, Subpart HHHHHHH) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 7,4 00 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $ 5,15 0,000

. 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 92 5 labor hours at a cost of $ 42, 000 . See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Poly

vinyl Chloride and Copoly mers Production (40 CFR Part 63, Subpart HHHHHHH) (Renewal). **6(f) Reasons for Change in Burden** There is an adjustment increase in the estimated burden as currentl y identified in the OMB Inventory

of Approved Burdens . In consulting with the Vinyl Institute during the renewal of this ICR, EPA received comprehensive comments on the burden associated with specific reporting and recordkeeping requirements , including, but not limited to, performance test, monitor installation, resin and wastewater sampling, equipment leak and process vent monitoring. We have updated the burden items to more accurately reflect the costs incurred by the industry . The update results in a substantial increase in the respondent labor hours, labor costs, and capital/O&M costs. There is also an increase in the number of responses as we have updated the number of subject major sources from 15 to 17 based on data provided by the V inyl Institute. **6(g) Burden Statement**13

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 7,4 00 hours per response. “ Burden” means the total time, effort, or financial resources expended by p ersons 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 c ollection 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

- 201 4

- 0101. An electronic version of the public docket i s 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), 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 l egal holidays. 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 the EPA Docket ID Number EPA

- HQ

- OECA

- 2014

- 0101 and OMB Control Number 2060

- 0666 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 Polyvinyl Chlor** **ide and Copolymers Production (40 CFR Part 63, Subpart HHHHHHH) (Renewal)** 

Burden I tem (A) (B) (C) (D) (E) (F) (G) (H) Respondent Number of Hours Number of Technical Management Clerical Total Hours per Occurrences Per Respondents Hours Hours Hours Labor Costs Occurrence Per Respondent Per Year Per Year Per Year Per Year Per Year (Technical Respondent Per Year hours) Per Year (C=A x B) (D x E) (F x 0.05) (F x 0.1) 1. Applications N/A 2. Surveys and Studies N/A 3. Reporting Requirements A. Read and Understand Rule Requirements a,b,l 320 1 320 0 0 0 0 $0 B. Required Activities 1) I nitial performance test, sampling, and report a) Process Vents a,d 120 1 120 0 0 0 0 $0 b) Resins a,e 36 1 36 0 0 0 0 $0 c) wastewater a,f 8 1 8 0 0 0 0 $0 d) uncontrolled wastewater a,f 40 1 40 0 0 0 0 $0 e) heat exchangers a,g 8 1 8 0 0 0 0 $0 f) equipment leaks a,h 850 1 850 0 0 0 0 $0 2) Periodic performance test, sampling, and report a) Process Vents i 17.1 350 5985 15 89,775 4,489 8,978 $10,382,074.76 b) Resins e 36 350 12600 17 214,200 10,710 21,420 $24,771,266.10 c) wastewater f 8 12 96 16 1,536 77 154 $177,631.49 d) uncontrolled wastewater f 40 1 40 17 680 34 68 $78,638.94 e) heat exchangers g 8 12 96 16 1,536 77 154 $177,631.49 f) equipment leaks h 43 12 510 17 8,670 434 867 $1,002,646.49 3) Establish operating parameters and monitoring plan15

Burden I tem (A) (B) (C) (D) (E) (F) (G) (H) Respondent Number of Hours Number of Technical Management Clerical Total Hours per Occurrences Per Respondents Hours Hours Hours Labor Costs Occurrence Per Respondent Per Year Per Year Per Year Per Year Per Year (Technical Respondent Per Year hours) Per Year (C=A x B) (D x E) (F x 0.05) (F x 0.1) a) Process Vents a,b,c 8 1 8 0 0 0 0 $0 4) Continuous parameter monitoring a) I nitial capital costs (PRD Electronic Monitor) a,i 524 1 524 0 0 0 0 $0 b) Annualized capital and O&M costs (PRD Electronic Monitor) i 24 1 24 5 110.16 5.51 11.02 $12,739.51 5) Ot her requirements a) equipment openings, initial measurement a,m 1.5 1 1.5 0 0 0 0 $0 b) equipment openings, daily measurement m 1.5 350 525 17 8,925 446.25 892.5 $1,032,136.09 c) gasholders a,n 24 1 24 0 0 0 0 $0 d) storage vessels a,o 40 1 40 0 0 0 0 $0 e) bypasses, initial requirement a,p 40 1 40 0 0 0 0 $0 f) bypasses, ongoing inspection p 1 12 12 17 204 10.2 20.4 $23,591.68 C. Create I

nformation Incl. in 3.B D. Gather I

nformation Incl. in 3.E E. Report Preparation 1) I nitial Notification a,b 5 1 5 0 0 0 0 $0 2) Batch precompliance report a,b 5 1 5 0 0 0 0 $0 3) Notification of performance test with test plan a,b 10 1 10 0 0 0 0 $0 4) Notification of compliance status a,b 20 1 20 0 0 0 0 $0 5) Compliance report b,j 40 2 80 17 1,360 68 136 $157,277.88 6) Notice of inspection b 5 1 5 17 85 4 9 $9,829.87 **Reporting Subtotal**  **k 376,143**  **$37,825,464.29** 4. Recordkeeping Requirements A. Read I

nstructions Incl. in 3.A16

Burden I tem (A) (B) (C) (D) (E) (F) (G) (H) Respondent Number of Hours Number of Technical Management Clerical Total Hours per Occurrences Per Respondents Hours Hours Hours Labor Costs Occurrence Per Respondent Per Year Per Year Per Year Per Year Per Year (Technical Respondent Per Year hours) Per Year (C=A x B) (D x E) (F x 0.05) (F x 0.1) B. I mplement Activities N/A C. Develop Record System N/A D. Record I

nformation 1) Records of process vent requirements b 10 1 10 17 170 9 17 $19,659.74 2) Records of resin stripper requirements b 15 1 15 17 255 13 26 $29,489.60 3) Records wastewater requirements b 15 1 15 17 255 13 26 $29,489.60 4) Records of storage vessel requirements b 10 1 10 17 170 9 17 $19,659.74 5) Records of equipment leak requirements b 25 1 25 17 425 21 43 $49,149.34 6) Records of heat exchanger requirements b 10 1 10 17 170 9 17 $19,659.74 7) Records of other emission sources requirements b 10 1 10 17 170 9 17 $19,659.74 E. Personnel Training Incl. in 3.B F. Time for Audits N/A **Record keeping Subtotal**  **1,857 $186,767.50**  **TOTAL ANNUAL BURDEN AND COSTS (rounded)**  **378,001 $38,012,232**  **Capital and O&M Cost (see Section 6(b)(iii)): $5,152,827**  **TOTAL COST: $43,165,059** 

FOOTNOTES

a One

- time only costs. b Cost incurred by a facility regardless of the number of affected units at the plant.

c 17 major sources in affected source category17

d 15 major sources are expected to perform testing for process vents. OxyVinyls Pedricktown does not operate a process vent control, but rather sends process vent gas streams to Mexichem Pedricktown for control. Likewise, the Wacker Calvert City facility does not operate a process vent control device, but rather sends process ent gas streams to the Westlake Calvert City facility for control. Per VI , it is assumed that performance testing for process vents will take 120 hours per occurrence initially. The initial compliance and operating procedure development for continuous compliance and will take 8 hours. The daily monitoring of parameters will take 5 min per record with 112 records a day acros s 33 devices in the industry. There are 3 area source and 15 major source subject to this requirement. Therefore, the continuous/daily monitoring will take on average 17.1 hr per facility per day over 350 day/yr.

e Per VI, it is assumed that performance testing for process vents will take 4 hours per sample for 9 samples per facility, initially and daily (350 days per year). See continuous monthly sampling & testing of Non

- VC TOHAP in O&M section.
f Per VI, wastewater testing is estimated to take 4 hours per sample for 2 samples per facility. There are 16 wastewater streams for 17 major sources, yields 16/17 wastewater streams per major source that are sampled monthly. There are 5 uncontrolled wastewater streams per source that are sampled annually. See Capital/O&M costs for non

- VC TOHAP samples.

g Per V I, it is assumed that performance testing on heat exchangers will take 4 hours per sample for 2 samples per facility, initially and monthly, for 16 of the 17 major sources. One of the sources relied on another facility to cool the water. h For Equipment leaks, VI estimates approx 10,000 components per facility and 5 minutes per component, plus additional time calibration of analytical device for a total of 850 hr per facility. For continuous monitoring, VI assumes 1 hr is required per component for leak repair, if detected. I t was assumed that overall continuous compliance of leak monitoring will take 5% of the time with initial monitoring per month.

i Per VI, the initial performance testing for pressure relief devices (PRD), would take 524 hours per facility. Periodically, corrective action for discharge from a PRD would take 24 hours. I t is estimated that 27% of the respondents would experience discharge from a PRD each year. j Per VI, Estimated that semiannual compliance report s would take 40 technical hours twice per year. k Reporting subtotal does not include capital costs for PRD monitoring system. l It will take 8 employees 40 hours per person to read and understand the rule requirements. m For Equipment openings, Per VI , 1.5 hr to obtain measurement, initially, daily. n Per VI, it will require 24 hr to evaluate compliance options, order materials, monitor installation, and developing O&M procedures. Note: there are only 15 gas holders in t he industry among major & area sources. o Per VI, 40 hr per facility to develop initial and ongoing compliance, inspection, and maintenance plans and procedures. p Per VI, 40 hr per facility for training, development, and implementation; and it will take 1 hr per month to inspect car seal s per facility. q Total have been rounded to 3 significant values. Figures may not add exactly due to rounding.18

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for Polyvinyl Chloride and Copolymers Production (40 CFR Part**  **63, Subpart HHHHHHH) (Renewal)**

**Burden Item (A)**  **EPA person**
  ** hours per** **occurrence (B)** 

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

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

**Plants Per**  **Year (E)** 

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

**Management person**  **- hours**  **per year (Ex0.05)**  **(G)**

**Clerical person**  **** **hours per year**  **(Ex0.10) (H)** 

**EPA Cost Per**  **Year a,b** 
1. Applications not applicable 2. Read and Understand Rule Requirements 16 1 16 0 0 0 0 $0 3. Required Activities A. Observe initial performance tests b 48 1 48 0 0 0 0 $0 B. Excess emissions

-- Enforcement Activities d 24 1 24 1.7 41 2 4 $2,135 C. Create Information not applicable D. Gather Information not applicable E. Report Reviews 1) Review initial notification 3 1 3 0 0 0 0 $0 2) Review batch pre

- compliance report 5 1 5 0 0 0 0 $0 3) Review notification of performance test 10 1 10 0 0 0 0 $0 4) Review notification of compliance status 40 1 40 0 0 0 0 $0 5) Review compliance report 20 2 40 17 680 34 68 $35,591 6) Review notice of inspection 3 1 3 17 51 3 5 $2,669 F. Prepare annual summary report c 4 1 4 8 32 2 3 $1,675 4. Travel expenses: (1 person *30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = n/a per trip $0 TOTAL 924 $42,07119

FOOTNOTES

a Figures may not add exactly due to rounding.
b Assumes EPA personnel attend 20 percent of the initial process vent stack tests.

c Using four hours per state (8 states) to write annual summary report.
d Assume 10% of major source facilities (17) have emission exceedances. e Totals have been rounded to 3 significant values. F igures may not add exactly due to rounding.