SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal), 

EPA ICR 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 emit, considering controls, in the aggregate, any single hazardous air pollutants (HAP) at 

a rate of 10 tons per year (tpy) or more or any combination of HAP at a rate of 25 tpy or more. 

Semiconductor manufacturing process units are used to manufacture p-type and n-type 

semiconductors and active solid-state devices from a water substrate, including research 

and development activities integrated into a semiconductor manufacturing process unit. 

A semiconductor manufacturing 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 systems, open-ended valves or lines, valves, 

connectors, and instrumentation systems; 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 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 five years following the date of such measurements, 

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

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

Environmental Protection Agency (EPA) regional office.

Based on our consultations with industry representatives, there are 127 facilities; however,

only one of which is considered a major source. The other 126 non-major sources only read the 
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rule for the first year. 

Over the next three years, 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 

semiconductor manufacturing industry (the “Affected Public”). These facilities in the United 

States are not owned by any state, local, tribal entities or by the Federal government. These 

facilities are privately-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 63, Subpart BBBBB) (Renewal). The burden to the “Federal 

Government” is attributed entirely to work performed by either Federal 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 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. In addition, section 

114(a) states that the Administrator may require any owner or operator subject to any requirement 

of this Act to:

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

In the Administrator's judgment, HAP emissions from semiconductor 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 63, subpart BBBBB.
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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. In addition, 

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 initial 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 properly 

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 63, 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 directly to the delegated state 

or local agency. If a state or local agency has adopted their own similar standards to implement the 

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

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 

exists.

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

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

the Federal Register (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 years have been considered. The primary

source of information as reported by industry, in compliance with the recordkeeping and reporting 
4

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

and maintained by 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 is 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, we 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 policy to respond after a thorough review of comments received since the last ICR 

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

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities 

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

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

emission limitations are met. If the information required by these standards was collected less 

frequently, the proper operation and maintenance of control equipment and the possibility of 

detecting violations would be less likely.

3(e) General Guidelines

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

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. EPA believes that the five-year records retention requirement is consistent with the part 

70 permit program and the five-year 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 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).
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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 

(SIC) code for the respondents affected by the standard is SIC 3674, which correspond to the 

North American Industry Classification System (NAICS) 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 by NESHAP for 

Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB).

A source must make the following reports:

Notification Reports

Initial notification 63.9(b)(2)-(3), 63.7189(b)-(c)

Notification of performance test 63.7(b)-(c), 63.9(e), 63.7189(d)

Notification of compliance status 63.9(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 63.7190

A source must keep the following records:

Recordkeeping

Initial notification or notification of compliance status 63.10(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 63.10(b)(2)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 
6

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

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

a plant site.

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

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

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 

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.

Adjust the existing ways to comply with any previously applicable instructions and 

requirements.

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

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 system). Although personnel at the source 

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

burden associated with monitoring and recordkeeping.

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

Management

5(a) Agency Activities

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

and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.
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Agency Activities

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

required to be submitted by industry.

Audit facility records.

Input, analyze, 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 properly installed and operated. Performance 

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

emission standard. Data and records maintained by the respondents are tabulated and published for 

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

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

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

by 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 government-owned 

facilities. EPA uses OTIS for tracking air pollution compliance and enforcement by local and state 

regulatory agencies, EPA regional offices, and EPA headquarters. EPA-delegated authorities can 

edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner or operator for five

years.

5(c) Small Entity Flexibility

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

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

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

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

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

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

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

the overall burden will be reduced.

5(d) Collection Schedule

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

below in Table 1: Annual Respondent Burden and Cost - NESHAP for Semiconductor 

Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 
8

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. 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 previously 

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR 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, 2011, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are 

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

for the benefit packages available to those employed by private industry.

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

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

subject standard are 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 and other costs, such 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 $50. 1 $50.

Total $50.

The total capital/startup costs for this ICR 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 years of the ICR is estimated to be $50. These are recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis 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 hourly labor rate as follows:

Managerial $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 employees. Details upon which this estimate is based 

appear below in Table 2: Average Annual EPA Burden and Cost - NESHAP for Semiconductor 

Manufacturing (40 CFR Part 63, Subpart BBBBB) (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 years, approximately

one existing respondent will be subject to the standard. It is estimated that no additional 

respondent will become subject to the standard. The overall average number of respondents, 
10

as shown in the table below, is one per year.

The number of respondents is calculated using the following table which addresses the 

three years covered by this ICR.

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-year period of this ICR is one.

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total 

Annual 

Responses

E=(BxC)+D

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 63, 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, respectively, and summarized below. 
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(i) Respondent Tally

The total annual labor hours are 37, 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 63, Subpart BBBBB) (Renewal). 

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

information is estimated to average 19 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $50. 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 CFR Part 63, Subpart BBBBB) (Renewal). 

6(f) Reasons for Change in Burden

There is no change in labor hours in this ICR compared to the previous ICR. This is due to 

two considerations: 1) the regulations have not changed over the past three years and they are not 

anticipated 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 labor 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 systems for the purposes of collecting, validating, and verifying 

information, processing and maintaining information, and disclosing and providing information; 

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

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

and review the collection of information; and transmit or otherwise disclose the information.

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

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

Numbers for EPA’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 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-2011-0262. An electronic version of the public docket is 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 content of the docket, 

and to access those documents in the public docket that are available electronically. When in 

the system, select “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 3334, 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 holidays. 

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, 

you 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 2060-0519 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Semiconductor Manufacturing (40 CFR Part 63, 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 

personhours per

year

(E=CxD)

(F)

Management 

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 c4 1 4 0 0 0 0 $0

 B. Process/review information d4 2 8 1 8 0.40 0.80 $881.54

 C. Write Report

 Initial notification c2 1 2 0 0 0 0 $0

 Notification of performance 

evaluation c 2 1 2 0 0 0 0

$0

 Notification of compliance status c2 1 2 0 0 0 0 $0

 Performance evaluation reports c2 1 2 0 0 0 0 $0

 Startup, shutdown, malfunction 

(SSM) report e 1 4 4 0 0 0 0

$0

 Semiannual summary report f4 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

$0
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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 

personhours per

year

(E=CxD)

(F)

Management 

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 g2 2 4 1 4 0.20 0.40 $440.77

 H. Retrieve records/reports h2 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 

Assumptions:

a

 We have 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. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September, 2011 “Table 2. Civilian Workers, by Occupational and

Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed 

by private industry.

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 have assumed that it will take each respondent 1 hour four times a year to write SSM report.

f

 We have assumed that it will take the respondent 4 hours two times 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 hours two times per year to retrieve records/reports.
15

Table 2: Average Annual EPA Burden and Cost - NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart 

BBBBB) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours 

per plant 

per year

(C=AxB)

(D)

Plants 

per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

person-ho

urs per 

year

(Ex0.1)

(H)

Cost, $ b

Review initial notification reports 8 1 8 0 0 0 0 $0 

Review notification of compliance status 10 1 10 0 0 0 0 $0 

Review semiannual summary reports c15 2 30 1 30 1.5 3 $1,554.74 

Review notification of performance test d4 1 4 0 0 0 0 $0 

Attend initial performance tests 120 1 120 0 0 0 0 $0 

Review test results e10 1 10 0 0 0 0 $0 

TOTAL ANNUAL BURDEN AND COST 

(rounded) 35 $1,555 

Assumptions:

a

 We have assumed that there is approximately one existing 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 following labor rates which 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) “2011 General Schedule” which excludes locality rates of pay.

c

 We have assumed that the respondent will take 15 hours 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.