**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Semiconductor Manufacturing**  **(40 CFR P**  **art 63, S**  **ubpart BBBBB**  **) (Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection**
NESHAP for Semiconductor Manufacturing (40 CFR Part 63, S ubpart BBBBB ) (Renewal) , EPA I CR Number 2042. 05 , OMB Control Number 2060

- 0519 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP), for semiconductor manufacturing were proposed on May 8, 2002, (67 FR 30848), promulgated on May 22, 2003 (68 FR 27925) , and amended on July 22, 2008, (73 FR 42529). These regulations apply to each new, reconstructed, or existing affected major source that emits or has the potential to em it, considering controls, in the aggregate, any single hazardous air pollutants (HAP) at a rate of 10 tons per ye ar (tpy) or more or any combination of HAP at a rate of 25 tpy or more. Semiconductor manufacturing process units are used to manu facture p

- ty pe and n

- ty

pe semiconductors and active solid

- state devices from a water substrate, including research and development activities integrated into a semiconductor manufacturing process unit. A semiconductor manufa cturing process unit includes the equipment assembled and connected by ductwork or hard

- piping including furnaces and associated unit operations; associated wet and dry work benches; associated recovery devices; feed, intermediate, and product storage tanks; product transfer racks and connected ducts and piping; pumps, compressors, agitators, pressure - relief devices, sampling connecting sy stems, open

- ended valves or lines, valves, connectors, and instrumentation sy stems; and control devices. This information is being collected to assure compliance with 40 CFR part 63, Subpart BBBBB. In general, all NESHAP standards require initial notifications, 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 es sential 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 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. Based on our consultations with industry r epresentatives, there are 127 facilities ; however, only one of which is considered a major source. The other 126 non

- major sources onl y read the2

rule for the first year. Over the next three ye ars, an average of one respondent per year will be subject to the standard, and no additional respondents will become subject to the standard. The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.” The semiconductor facilities in the United States are owned and operated by the semi conductor manufacturing industry (the “Affected Public”). These facilities in the United States are not owned b y any state, local, tribal entities or by the Federal government. These facilities are privatel y- owned , for

- profit businesses. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Semiconductor Manufacturing (40 CFR Part 6 3 , Subpart BBBBB ) (Renewal) . The burden to the “ Federal Government” is attributed entirely to work performed b y either F ederal employees or government contractors. The burden to the “Federal Government” may be found below in Table 2: Average Annual EPA Burden and Cost

- NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB ) (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 sourc es of hazardou s air pollutants . These standards are applicable to 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 or operato r 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 w ith 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 m onitoring 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, HAP emissions from sem iconductor manufacturing facilities cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP standards were promulgated for this source category at 40 CFR part 6 3 , subpart BBBBB

.3

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

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, 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 standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properl y installed and operated, that leaks are being detected and repaired, and that the standards 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 6 3 , subpart BBBBB

. **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 directl y to the delegated state or local agency
. If a state or local agency h a s adopted their 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 b y the Federal standards. Therefore, no duplication exist s. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this IC R was published in the Federal Register ( 76 FR 26900 ) on May 9 , 2011 . No comments were received on the burden published in the Federal Register

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

industry experts have been consulted, and the Agency internal data sources and projections of industry growth over the next three ye ars have been considered. The primary source of information as repo rted by industry, in compliance with the recordkeeping and reporting4

provisions in the standard, is the Online Tracking Information Sy stem (OTIS) which is operated and maintained b y the EPA Office of Compliance. OTIS is the EPA database for the collection , maintenance, and retrieval of all compliance data. The growth rate for the industry i s based on our consultations with the Agency 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. In developing this ICR, w e contacted : 1) the Semiconductor Industry Association (SIA) , at ( 202 ) 446

- 1700 ; 2) the Fab Owners Association ( FOA) , at (408) 725

- 7127 ; and 3) Semiconductor Equipment and Materials International (SEMI) , at (202) 289

- 0440. It is our polic y t o respond after a thorough review of comments received since the last ICR renewal as well as to those submitted in response to the f irst Federal Register n otice. **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 det ecting violations would be less likely

. **3(e) General Guidelines**
These reporting or recordkeeping requirements do not violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. E PA believes that the five

- ye ar records retention requirement is consistent with the part 70 permit p rogram 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 violators have violations extending beyond the five years. 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 i s 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 b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).5

**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**  The respondents to the recordkeeping and reporting requirements are owners or operators of semiconductor manufacturing facilities

. The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standard is SI C 3674 , which correspond to the North American Industry Classification System (NAI CS) code 334413 for semiconductor manufacturing. **4(b) Information Requested (i) Data Items**  In this ICR, all the data that is recorded or reported is required b y NE S HAP for Semiconductor Manufacturing (40 CFR Part 6 3 , Subpart BBBBB ). A source must make the following reports:
**Notification Report**  **s** Initial n otification 6 3. 9 (b) (2 )

- (3) , 63. 7 1 8 9(b)

- (c) Notification of performance test 6 3. 7 (b )

- (c) , 63.9(e), 63. 7 1 8 9( d) Notification of compliance status 6 3

. 9(h), 63.10(d)(2), 63.7189(e) Performance evaluation reports 63.8(e)(5), 63.7191(a)(e) Startup, shutdown, malfunction 63.6(e)(3), 63.7190(a)(2) Semiannual summary

report 6 3

. 71 90 A source must keep the following records: **Recordkeeping** Initial notification or notification of compliance status 6 3 .1 0 (b) ( 2)(xiv), 63.7191(a)(1 ) Record of startup, shutdown, malfunctions 63.6(e)(3), 63.7191(a)(2) Records of performance tests and performance evaluations 63.10(b)(2)(viii), 63.7191(a)(3) Records are required to be retained for five years 6 3 .1 0 (b ) (2) Electronic Reporting Some of the respondents are using monitoring equipm ent that automatically records6

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 sy stems to transmit data electronically . However, electronic reporting s ys tems are not widel y used. At this time, it is estimated that none of the respondents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Perform initial performance test, Reference Methods 320, 26, 26A test, and repeat performance test is 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 information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously

applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently , sources are using monitoring equipment that provides 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 ty pe 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, analy sis, storage, and distribution of the required inf ormation. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

.7 **Agency Activities** Review notifications and reports, including performance test reports, excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the 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 properl y installed and operated

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

with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In form ation contained in the reports is entered into OTI S which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and gover nment

- owned facilities. E PA uses OTIS for tracking air pollution compliance and enforcement by l ocal and state regulatory

agencies, EPA regional offices, and EPA headquarters. EPA

- delegated a uthorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner or operator for five ye ars. **5(c) Sm**  **all 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 p rocess 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

f or each information collect ion activity w ithin this request is shown below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB ) ( Renewal ). **6. Estimating the Burden and Cost of the Collection** Table 1 documents the c omputation of individual burdens for the recordkeeping and8

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. Wherever 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 37 (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 previousl y approved ICR, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 121.42 ($ 57.82 + 110%) Technical $ 99.14 ($ 47.21 + 110%) Clerical $ 49.81 ($ 23.72 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September , 20 11 , “ Table 2. Civilian Workers, by O ccupational 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 labor costs which are addressed elsewhere in this I CR, and the costs associated with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs, s uch as photocopying and postage.9 **(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)
N/A N/A N/A N/A $5 0. 1 $5 0. Total $5 0. The total capital/startup costs for this I CR are zero. This is the total of column D in the above table. The total operation and maintenance (O&M) costs for this ICR are $ 50. 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 ye ars of the I CR is estimated to be $ 5 0

. These are recordkeeping costs. **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. The EPA compliance and enforcement program includes activities such as: the examination of records maintained by the respondents; periodic inspection of sources of emissions; and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 1, 555

. This cost is based on the average hourl y labor rate as follows:

Manag erial $ 62.27 (GS

- 13, Step 5, $ 38.92 x 1.6) Technical $ 46.21 (GS

- 12, Step 1, $ 28.88 x 1.6) Clerical $ 25.01 (GS

- 6, Step 3, $ 15.63 x 1.6) These rates are from the Office of Personnel Management (OPM) “ 2011 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 emplo ye es
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cos t

- NESHAP for Semiconductor Manufacturing (40 CFR Part 6 3 , Subpart BBBBB ) ( Renewal )

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately one existing respondent will be subject to the standard. It is estimated that n o additional respondent will become subject to the standard. The overall average number of respondents,10

as shown in the table below, is one per ye ar. The number of respo ndents is calculated using the following table which addresses the three ye ars covered b y this I CR. **Number of Respondents**

Year (A)

Number of New Respondents (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 1 0 0 1 2 0 1 0 0 1 3 0 1 0 0 1 Average 0 1 0 0 1
Column 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 one
. 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 Initial notification 0 1 0 0 Notification of performance evaluation 0 1 0 0 Notification of compliance status 0 1 0 0 Performance evaluation reports 0 1 0 0 Startup, shutdown, malfunction report 0 4 0 0 Semiannual summary report 1 2 0 2 Total 2 The number of Total Annual Responses is 2. The total annual labor costs are $ 3, 526

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

- NESHAP for Semiconductor Manufacturing (40 CFR Part 6 3 , Subpart BBBBB ) ( Renewal )

. **6(e) Bottom Line Burden Hours 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.11 **(i) Respondent Tally** The total annual labor hours are 3 7 , at a cost of $3,526 . Details regarding these estimates may be found below in Table 1 : Annual Respondent Burden and Cost

- NESHAP for Semiconductor Manufacturing (40 CFR Part 6 3 , Subpart BBBBB ) (Renewal )

. Furthermore, the annual public reporting and recordkeeping burden for this collecti on of information is estimated to average 19 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $ 5 0. 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 35 labor hours , at a cost of $ 1, 555 . See below Table 2 : Average Annual EPA Burden and Cost

- NESHAP for Semiconductor Manufacturing (40 C FR Part 6 3 , Subpart BBBBB ) (Renewal)

. **6(f) Reasons for Change in Burden** There is no change in labor hours in this IC R compared to the previous ICR. This is due to two considerations : 1) the regulation s have not changed over the past three years and they are not anticipat ed to change over the next three years ; and 2) the growth rate for the industry is very low, negative or nonexistent, so there is no significant change in the overall burden. There is an increase in respondent and Agency costs resulting from labo r rate increases since the last renewal . This ICR uses updated labor rates from the most recently available data for each of the three labor categories

. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 19 hours per response. “ Burden ” means the total time, effort, or financial resources expended by

persons to generate, maintain, retain, 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providi ng information; adjust the existing way s 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 ’ s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.12

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any s uggested methods for minimizing respondent burden, including the use of automated collection t echniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 20 11

- 0262

. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a cop y of the draft collection of information, submit or view public comments, access the index listing of the content of the docket, and to access those documents in the public docket that are available electronically . When in the sy stem, se lect “search” than 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 33 34, 1301 Constitution Avenue, N.W., Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is (202) 566

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

- 1752

. Also, yo u can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street , N.W., Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2011

- 0262 and OMB Control Number 2060

- 0 5 19 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because n o statistical methods were used in collecting this information.13

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

**– NESHAP for**  **Semiconductor Manufacturing**  **(40 CFR Part 6 3**  **, Subpart BBBBB**  **) (Renewal)** 

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

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

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

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

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

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

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

**Total Cost Per year**  **b**

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions c 4 1 4 0 0 0 0 $0 B. Process/review information d 4 2 8 1 8 0.40 0.80 $881.54 C. Write Report Initial notification c 2 1 2 0 0 0 0 $0 Notification of performance evaluation c 2 1 2 0 0 0 0 $0 Notification of compliance status c 2 1 2 0 0 0 0 $0 Performance evaluation reports c 2 1 2 0 0 0 0 $0 Startup, shutdown, malfunction (SSM) report e 1 4 4 0 0 0 0 $0 Semiannual summary report f 4 2 8 1 8 0.40 0.80 $881.54 **Subtotal for Reporting Requirements 18**  **.4** 4. Recordkeeping requirements A. Read instructions 4 1 4 0 0 0 0 $0 B. Plan activities 8 1 8 1 8 0.40 0.80 $881.54 C. Implement activities Control devices Design analysis 15 1 15 0 0 0 0 $0 Performance evaluation 40 1 40 0 0 0 0 $0 Equipment inspection 1 52 52 0 0 0 0 $0 Monitoring activities 1 52 52 0 0 0 0 $0 Maintenance 2 52 104 0 0 0 0 $0 D. Develop record system Develop SSM plan 8 1 8 0 0 0 0 $0 Control equipment/maintenance plan 12 1 12 0 0 0 0 $014

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

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

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

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

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

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

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

**Total Cost Per year**  **b**

E. Time to enter information Control equipment testing 1 1 1 0 0 0 0 $0 Control equipment inspection 0.5 52 26 0 0 0 0 $0 Control equipment monitoring 0.5 52 26 0 0 0 0 $0 F. Time to train personnel Control equipment inspection and Monitoring 40 1 26 0 0 0 0 $0 G. Store, file and maintain records g 2 2 4 1 4 0.20 0.40 $440.77 H. Retrieve records/reports h 2 2 4 1 4 0.20 0.40 $440.77 **Subtotal for Recordkeeping Requirements**  **18 .4**  **TOTAL LABOR BURDEN AND COST (rounded)**  **37 $3,526** 

**Assu mptions:**  a We hav e assumed that there is approximately one existing source currently subject to this rule . There will be no additional new source that will become subject to the rule over the three

- year period of this ICR. b This ICR uses the following labor rates: $ 121.42 per hour for Managerial labor; $ 99.14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. T hese rates are from the United States Department of Labor, Bureau of Labor Statistics, September , 20 11 “ Table 2. Civilian Workers, by O ccupational and I ndustry group. ” The rates are from column 1, “ Total C om pensation. ” The rates have been increase d by 110 percent to account for the benefit packages available to those employed by private industry. c This is a one

- time only activity. d We have assumed that it will take the respondent 4 hours twice a year to process and review information. e We hav e assumed that it will take each respondent 1 hour four times a year to w rite SSM report. f We have assumed that it will take the respondent 4 hours two time s a year to complete the semiannual report. g We have assumed that the respondent will take 2 hours two times per year to store, file and maintain records. h We have assumed that the respondent will take 2 hour s two times per year to retrieve records/reports.15

**Table 2: Average Annual EPA Burden and Cost** 
**- NESHAP**  **for Semiconductor Manufacturin**  **g (40 CFR Part 63, Subpart**  **BBBBB) (Renewal)** 

**Activity (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 a**  **(E)**

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

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

**Clerical person**  **- ho**  **urs per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

Revie w initial notification reports 8 1 8 0 0 0 0 $0 Revie w notification of compliance status 10 1 10 0 0 0 0 $0 Revie w semiannual summary reports c 15 2 30 1 30 1.5 3 $1,554.74 Revie w notification of performance test d 4 1 4 0 0 0 0 $0 Attend initial performance tests 120 1 120 0 0 0 0 $0 Revie w test results e 10 1 10 0 0 0 0 $0 **TOTAL ANNUAL BURDEN AND COST (rounded)**  **3 5**  **$1,555 Assu**  **mptions:** a We have assumed that there is approximately one ex isting sources currently subject to this rule. There will be no additional new source that will become subject to the rule each year over the three

- year period of this ICR. b This cost is based on the followin g labor rates w hich incorporate 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 from the Office of Personnel Management (OPM) “20 11 General Schedule” which excludes locality rates of pay. c We have assumed that the respondent will take 15 h ours two times a year to review the semiannual summary reports. d We have assumed that it will take each respondent 4 hours one time a year to review notification of performance tests. e We have assumed that it will take each respondent 10 hours one time a year to review test results.