1 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and

Copolymers Production (Subpart HHHHHHH)

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production (40 CFR part 63, subpart HHHHHHH)

1(b) Short Characterization/Abstract

This supporting statement addresses information collection activities that will be imposed by the National Emission Standards for Hazardous Air Pol lutants (NESHAP) for Polyvinyl Chloride and Copolymers (PVC) Production, 40 CFR part 63, subpa rt HHHHHHH, referred to

as the PVC NESHAP. In 2002, the Environmental Protection Agency (EPA) promulgated national emission standards for hazardous air pollutant s for new and existing PVC and copolymers production facilities under 40 CFR part 63, subpart J (67 FR 45886, July 10, 2002). In 2004 the court vacated and remanded the subpart J NESHAP, and the proposed standard is in response to the remand in accordance with Clean Air Ac t (CAA) section 112. This information collection request (ICR) documents the associated recor dkeeping and reporting for the proposed

PVC NESHAP.

This ICR includes the burden for activities that will be c onducted in the first three years following promulgation of the proposed PVC NESHAP. Thes e activities include reading the rule, resin sampling, performance testing, establishing oper ating parameters, and monitoring, recordkeeping, and reporting requirements. We realize that some facilities may not incur these costs within the first three years, and may incur them dur ing the fourth or fifth year instead. Therefore, this ICR presents a conservatively high burde n estimate for the initial three years following promulgation of the proposed PVC NESHAP.

The use of the term "Designated Administrator" throughou t this document refers to the U.S. EPA Administrator or a delegated authority such a s a state agency. The term

"Administrator" alone refers to the U.S. EPA Adminis trator.

This ICR presents the burden to respondents and the Designa ted Administrator (State or Federal Government) that will be imposed by the plans deve loped to implement the PVC NESHAP. Respondents are owners or operators of existing PVC production facilities.

The requirements described below are the minimum requir ements established by the PVC NESHAP. Although the Designated Administrator may choo se to impose more stringent requirements, it is assumed for this burden estimate tha t the implemented plans mirror the PVC2

NESHAP.

Over the next three years, 17 PVC production facilities will be subject to this standard,

and the cost of this ICR will be $8.3 million. The burden to the “Affected Public” for each PVC facility may be found in Tables 1 through 4 in Attachment 2. This rule affects respondents in only the private sector. The burden to the “Designated Adm inistrator” is attributed entirely to work performed by federal employees or government contra ctors; this burden may be found in Tables 5 through 8 of Attachment 3.

2. AUTHORITY/NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

The EPA is charged under CAA Section 112, as amended, to es tablish standards of performance for each category or subcategory of major s ources and area sources of hazardous air pollutants (HAP). These standards are applicable to new o r existing sources of HAP and require the maximum degree of emission reduction. In addition, C AA 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 repo rts; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissio ns (in accordance with such procedures or methods, at such locati ons, at such intervals, during such periods, and in such manner as th e Administrator shall prescribe); (E) keep records on contr ol equipment parameters, production variables or other indir ect 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 Administrat or may reasonably require.

In the Administrator's judgment, HAP emissions from PVC production facilities cause or contribute to air pollution that may reasonably be antic ipated to endanger public health or welfare. Therefore, the NESHAP are proposed for this source category at 40 CFR part 63, subpart HHHHHHH.

2(b) Practical Utility/Users of the Data

The information will be used by Designated Administrators ' enforcement personnel to ensure that the requirements are being implemented and ar e complied with on a continuous basis. Specifically, the information will be used by the Design ated Administrator to: (1) identify sources subject to the standards; (2) ensure that the PVC NESHAP is being properly applied; (3) ensure that the PVC NESHAP is being complied with; an d (4) ensure, on a continuous basis, that the operating parameters established during performance tests are not exceeded.

In addition, records and reports are necessary to enable the Designated Administrator to3

identify PVC production facilities that may not be in c ompliance with the standards. Based on reported information, the Designated Administrator can dec ide which facilities should be inspected and what records or processes should be inspected . The records that facilities maintain would indicate to the Designated Administrator whether the personnel are operating and maintaining control equipment properly and whether they ha ve met the qualification requirements.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTI ON

CRITERIA

The requested recordkeeping and reporting will be required under 40 CFR part 63, subpart HHHHHHH.

3(a) Nonduplication

If the subject standards have not been delegated, the info rmation is sent directly to the appropriate EPA regional office. Otherwise, the infor mation is sent directly to the delegated state or local agency. If a state or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report subm itted to the state or local agency can be sent to the Administrator in lieu of the report requi red by the Federal standards. Therefore, no duplication exists.

3(b) Public notice prior to ICR submission to OMB

A public notice of this collection is being provided in the Federal Register notice of proposed rulemaking published for the PVC NESHAP.

3(c) Consultations

The public has the opportunity to review and comment on the proposed PVC NESHAP and ICR during the public comment period.

3(d) Effects of Less Frequent Data Collection

The PVC NESHAP requires an initial notification, initi al and periodic testing, continuous operating parameter monitoring, a notification of complia nce status, and compliance reports. The frequency of these activities was chosen by EPA as the period that will provide an adequate margin of assurance that affected facilities will not operate for extended periods in violation of

the standards.

During the initial performance tests for vinyl chloride, tota l HAP, hydrogen chloride (HCl), and chlorinated dibenzo-dioxins and furans (CDD/CDF), the owner or operator must establish maximum or minimum values for each operating par ameter. Thereafter, the owner or operator must continuously monitor the operating parameters . In addition, monthly wastewater and resin sampling must also be performed. Owners and oper ators must also conduct a leak detection and repair program and must operate a vinyl chloride m onitoring system.4

Although continuous monitoring of operating parameters cannot provide a direct measurement of emissions, it is less expensive than con tinuous emissions monitoring systems (CEMS), and the information provided can be used to ensure t hat the air pollution control devices are operating properly. This information assures EP A and the public that the reductions envisioned by the regulations are being achieved. Less frequent monitoring would not ensure continuous compliance.

The compliance reports allow the submittal of required inf ormation and data parameters so that any potential problems can be identified in a tim ely fashion.

3(e) General Guidelines

With the exception of requiring records to be maintained for more than three years, none of the guidelines in 5 CFR 1320.5 are being exceeded. This rule requires all records to be maintained at the source for a period of five years. In 40 CFR part 63, subpart A, "General

Provisions for National Emission Standards for Hazardous Air Pollutants for Source Categories," owners or operators of facilities are required to keep an d maintain records for a period of five years. These records must be kept on file for use, if needed, by the regulating authority to ensure that the plant personnel are operating and maintai ning control equipment properly. The title V permit programs also require records to be retaine d for five years. These records must be kept on file for use, if needed, by the regulating authorit y to ensure that the plant personnel are operating and maintaining control equipment properly.

3(f) Confidentiality

All information submitted to the Agency for which a clai m of confidentiality is made will be safeguarded according to the Agency policies set forth i n 40 CFR 2, subpart B -- Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976, amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 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/NAICS Codes

The respondents to the recordkeeping and reporting requirements are owners or operators of new or existing PVC production facilities. The PVC N ESHAP affects any industry using a polyvinyl chloride and copolymers production process unit as def ined in the regulation. This includes, but is not limited to, North American Industry Classification System (NAICS) Code 325211 (Facilities that polymerize vinyl chloride monomer to pr oduce PVC and/or copolymers products).5

Based on the distribution of facilities with affected PVC production facilities, there are 17 existing facilities which will be affected. Of these, 100 percent are located in the private sector.

4(b) Information Requested

(i) Data Items

Attachment 1, Source Data and Information Requirements, and Tables 1 through 4 of Attachment 2 present a summary of the recordkeeping and repor ting requirements of this regulation.

(ii) Respondent Activities

The respondent activities required by the standards are provi ded under the first column of Tables 1 through 4 of Attachment 2, introduced in section 6(a) . All burden items are included in

these tables.

(iii) Summary of Requirements

The information collection activities in this ICR include the following: reading the rule, performance tests, wastewater sampling, resin sampling, leak detection monitoring, heat exchanger monitoring, pressure relief device (PRD) monitorin g, operating parameter monitoring, preparation of a site-specific monitoring plan, one-time and periodic reports, and the

maintenance of records. Some information collection activities included in the PVC NESHAP may occur within the first three years, and are present ed in this burden estimate, but may not occur until four or five years following promulgation of t he proposed standards for some affected

sources. To be conservative in our estimate, the burden for these items is included in this ICR.

An initial notification is required to notify the Design ated Administrator of the applicability of this subpart and to identify storage vess els, process vents, equipment leaks, and other equipment and emission points subject to this subpart.

A notification of performance test must be submitted, an d a site-specific test plan written for the performance test along with a monitoring plan. The regulation requires an initial performance test for the following pollutants, vinyl chloride , total HAP, HCl, and CDD/CDF. During the initial performance test the owner or operato r must establish limits for each operating parameter. Thereafter, the owner or operator must con tinuously monitor the operating parameters. Annual performance tests are also require d for total HAP and CDD/CDF.

For resin strippers and wastewater streams, testing is required for vinyl chloride and total HAP. An initial test must be performed and subsequent monthly te sting is also required. Monthly monitoring is also required for heat exchangers and equipmen t leaks.

Following the initial performance test, the owner or oper ator must submit a notification of compliance status that documents the performance tes ts, values for the operating parameters, resin stripper tests, and wastewater tests. This report also includes the following additional items: identification of storage vessels, information for equipment leaks, and identification of6

heat exchange systems.

A compliance report submitted annually documents the values for the operating parameters and deviations, storage vessel inspection records , leak and monitoring information for equipment leaks, and leak and monitoring data for heat exchangers if greater than leak definition. Other reporting requirements include submitt al of a batch pre-compliance report and notice of inspection.

Owners or operators of PVC production facilities are re quired to keep records of certain parameters and information for a period of five years. T hese records include the initial performance test and operating parameter values consiste nt with the monitoring plan; resin stripper and wastewater testing results; the date and tim e for each deviation; copies of the current version of the monitoring plan and the equipment leak det ection and repair plan; monitoring schedule and inspection records for valves, pumps, conne ctors, agitators, pressure relief devices, and compressors; inspection records for storage vessels; defects and leaks for vessels; and monitoring events along with leak and repair dates for hea t exchangers.

All reports are to be submitted to the Designated Adminis trator. The information will be used to determine that all sources subject to the PVC NES HAP are achieving the requirements.

As an administrative addition to this ICR, EPA is als o including an illustrative estimate of the burden associated with performing a Root Cause Analys is (RCA) associated with

affirmative defense of malfunctions if the source elect s to avail themselves to this defense in court. EPA is providing this as an illustrative example of the potential additional administrative burden a source may incur to assert in an affirmative defe nse in response to an action to enforce the standards set forth in the applicable subpart. If a source is in compliance and does not

encounter malfunctions that cause a violation of the st andard, EPA does not expect this activity to be routinely performed by a source. Our decision to inc lude this recordkeeping and reporting

in the ICR burden is not to assert that EPA assumes l ess than full compliance. EPA cannot

estimate whether an affirmative defense would be neces sary for any source or class of sources. It is not an enforceable requirement of compliance.

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, C OLLECTION, METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

A list of Agency activities is provided in section 6(c) a nd in Tables 5 through 8 of

Attachment 3.

5(b) Collection Methodology and Management

Data obtained during periodic visits by EPA personnel, from records maintained by the respondents, and from information provided in reports will be tabulated and published for internal EPA use in compliance and enforcement programs. The PVC NESHAP allows records to be retained in hardcopy or electronic format to allo w flexibility and minimize burden.7

Information contained in the reports is entered into the Air Facility System (AFS) which is operated and maintained by EPA's Office of Compliance . AFS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses the AFS for t racking air pollution compliance and enforcement by local and state regulatory agencies, EPA r egional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retri eve and analyze the data.

The records required by this regulation must be retained by t he owner/operator for five

years.

5(c) Small Entity Flexibility

There are no small entities (i.e., small businesses) affected by this regulation.

The PVC NESHAP does not contain any provisions reserved ex clusively for the benefit of small entities; however, there are provisions tha t reduce the impact on all regulated entities, which would include any small entities. Reporting is annual and operating parameter monitoring is required instead of CEMS.

5(d) Collection Schedule

In the first three years following promulgation of the PVC NESHAP owners or operators would read the rule and are required to submit an initial noti fication. As discussed earlier, we also anticipate many of the one-time activities, includ ing: initial performance tests (vinyl chloride, total HAP, HCl, and CDD/CDF), initial resin st ripper and wastewater testing, and the notification of compliance status (including performance tests results and operating parameter values) to occur for many facilities within the first th ree years, but they may occur in years four

or five.

Every year a compliance report that includes data on th e operating parameters and deviations, and information from inspections and monitoring is required.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Tables 1 through 4 of Attachment 2 document the computation o f individual burdens and non-labor costs for the recordkeeping and reporting requireme nts applicable to the industry for each year for the subpart included in this ICR. The indi vidual 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 . Tables 5 through 8 of Attachment 3 present a summary of the agency burden.

The Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentl y valid OMB Control Number.

6(a) Estimating Respondent Burden8

The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 3,200 hours. T he average annual recordkeeping hours are 900 and the reporting requirement hours are 2,300, both of which are shown in Tables 1 through 4 of Attachment 2.

6(b) Estimating Respondent Costs

The information collection activities for sources subje ct to these requirements are presented in Tables 1 through 4 of Attachment 2. The total c ost for each respondent activity includes labor costs, capital/startup costs, and operating and maintenance (O&M) costs.

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $114.49 ($54.52 + 110%) Technical $98.20 ($46.76 + 110%) Clerical $48.53 ($23.11 + 110%)

These rates are from the United States Department of L abor, Bureau of Labor Statistics, September 2010, “Table 2. Civilian Workers, by occupational and i ndustry 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 pri vate industry.

(ii) Estimating Capital/Start-up and Operation and Mainte nance Costs

The capital costs associated with the proposed PVC NES HAP include monitoring system initial costs, performance testing, resin stripper test ing, wastewater testing; one time costs when a facility becomes subject to the regulation. The annual o peration and maintenance costs are the ongoing costs to maintain the monitors, perform subsequent testing, and other costs such as photocopying and postage.

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

Below are the estimated capital and startup costs and O& M costs for the affected units for the first three years after promulgation.

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

(A) Unit Type (B)

Number of Respondents (facilities) (C)

Total Capital/Startup

Costs (D)

Total Annualized Capital/Start-up

and O&M over 3

years (E)

Average Annual Capital/Startup and

O&M Costs

PVC Facilities Total 17 $3,300,000 $7,400,00 $2,500,000

The total capital/startup costs for this ICR are $3,300,000 ; column C.9

The total annualized capital/startup and O&M costs for thi s ICR are $7.4, million, or an average of $2.5 million per year; columns D and E. These are recordkeeping costs.

(iv) Burden under Affirmative Defense

When a malfunction occurs, sources must report them according to the applicable reporting requirements of this Subpart HHHHHHH. An affirm ative defense to civil penalties for exceedances of emission limits that are caused by malfu nctions is available to a source if it can demonstrate that certain criteria and requirements are satisfied. The criteria ensure that the affirmative defense is available only where the event that causes an exceedance of the emission

limit meets the narrow definition of malfunction in 40 C .F.R. 63.2 (sudden, infrequent, not reasonable preventable and not caused by poor maintenance an d or careless operation) and where the source took necessary actions to minimize emission s. In addition, the source must meet certain notification and reporting requirements. For ex ample, the source must prepare a written root cause analysis and submit a written report to the Adm inistrator documenting that it has met the conditions and requirements for assertion of the af firmative defense.

EPA considered whether there might be any burden associ ated with the notification, recordkeeping and reporting requirements associated with the assertion of the affirmative defense. While recognizing that any such burdens are only incur red if there has been a violation and a source chooses to take advantage of the affirmative defense. The PVC industry is currently required to comply with the part 61 NESHAP requi rement for releases from pressure

relief valves and reactor manual vent valves, which does not allow a discharge into the atmosphere from these valves, except during an emergency. An emergency discharge means a “discharge which could not have been avoided by taking mea sures to prevent the discharge.” The owners or operators must, within 10 days of any releas e from a pressure relief valve or a reactor manual vent valve, submit a report to the Adminis trator. The report must include the “nature and cause of discharge, the date and time of the d ischarge, the approximate total vinyl chloride loss during the discharge, the method used for deter mining the vinyl chloride loss, the action that was taken to prevent the discharge, and measur es adopted to prevent future discharges.” The costs for these reports are already accounted for in the ICR burden estimate.

Therefore, EPA estimates that there would be no additi onal costs for sources that choose to take advantage of the affirmative defense for malfunctions s ince it is already required for compliance with the rule. However, there may be additional malfu nctions that are not currently regulated under the part 61 NESHAP that might require an affirmative defense.

To provide the public with an estimate of the relative mag nitude of the burden associated with an assertion of the affirmative defense position adopted by a source (for those not already regulated under the part 61 NESHAP), EPA provides an adminis trative adjustment to this ICR that shows the notification, recordkeeping and reporting re quirements associated with the assertion of the affirmative defense might entail. E PA’s estimate for the required notification, reports and records, including the root cause analysis, totals $3,141 and is based on the time and effort required of a source to review relevant data, inte rview plant employees, and document the events surrounding a malfunction that has caused an exce edance of an emission limit. The estimate also includes time to produce and retain the rec ord and reports for submission to EPA. EPA provides this illustrative estimate of this burden be cause these costs are only incurred if10

there has been a violation and a source chooses to take advantage of the affirmative defense.

Burden under Affirmative Defense

(A)

Personnel (B)

Number of

Personnel (C)

Time Requirement (hours) (D)

Total Hours (E)

Hourly Rate ($/hr) (F)

Total

Technical Personnel 3 6 18 98.20 $1,768

Managerial Personnel 2 6 12 114.49 $1,374

Total 5 30 $3,141

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. EPA's overall compliance and enforcemen t program includes activities such as the examination of records maintained by the respondents, period ic inspection of sources of emissions, and the publication and distribution of collec ted information.

The average annual Agency cost during the three years of th e ICR is estimated to be $50,000.

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

Managerial $62.27 (GS-13, Step 5, $38.92+ 60%) Technical $46.21 (GS-12, Step 1, $28.88+ 60%) Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Manageme nt (OPM), 2010 General Schedule, which excludes locality rates of pay. The rates have b een increased by 60 percent to account for overhead and fringe benefit costs. Details on the line item estimates used to calculate these burdens are presented in Tables 5 through 8 of Attachment 3.

6(d) Estimating the Respondent Universe and Total Burden C osts

The total number of respondents is also referred to as th e respondent universe. Based on research, 17 existing facilities will be subject to the standard. No new respondents will become subject. Industry burden is calculated based on the number of facilities in each subcategory and the anticipated controls and monitoring that each unit wil l most likely utilize to comply with the proposed emissions guidelines.11 Total Annual Responses

(A) Unit Type (B)

Number of Respondents (facilities) (C)

Total Number Responses for 3- year Period (D)

Average Annual

Number of Responses

PVC Facilities Total 17 153 51

The number of average annual responses is 51.

6(e) Bottom Line Burden Hours and Cost Tables

(i) The Respondent Tally

The total annual labor hours are 3,200. Details regarding these estimates may be found in Tables 1 through 4 of Attachment 2. Furthermore, the annual public reporting and recordkeeping

burden for this collection of information is estimated t o average 63 hours per response.

The total annual capital/startup and O&M costs to the regul ated entity are $7.4 million.

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

Maintenance Costs.

(ii) The Designated Administrator Tally

The average annual burden over the first three years for the Designated Administrator would be 1,100 hours at a cost of $50,000 per year. The Designated Administrator burden hours and costs are presented in Tables 5 through 8 of Attachment 3.

6(f) Reasons for change in burden

Since this rule was vacated by the courts, this ICR trea ts these burden estimates as new burdens and the burden is not compared to previous burden esti mates made for the vacated rule.

To provide the public with an estimate of the relative mag nitude of the burden associated with a source asserting an affirmative defense position (for those not already regulated under the part 61 NESHAP), EPA is providing an administrative adjustm ent to this ICR. The adjustment shows the notification, recordkeeping and reporting requiremen ts associated with the assertion of the affirmative defense. This illustrative example does not result in an increase in the burden for this rule. EPA provides this estimate of the burden beca use these costs are only incurred if the

source believes that there has been a violation, and chooses to take advantage of the affirmative

defense.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this c ollection of information is estimated to be 63 hours per response. Burden means total time, effort, or financial resources12

expended by persons to generate, maintain, retain, or disc lose or provide information to or for a Federal agency. This includes the time needed to review instr uctions; develop, acquire, install, and utilize technology and systems for the purposes of c ollecting, validating, and verifying information, processing and maintaining information, and d isclosing and providing information; adjust the existing ways to comply with any previously app licable instructions and requirements; train personnel to be able to respond to a collection of inf ormation; 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 currentl y valid OMB control number. The OMB Control Numbers for EPA regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, th e accuracy of the provided burden estimates, and any suggested methods for minimizing res pondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OAR-2002-0037. 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

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 Do cket 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 legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1927. Also, you can se nd comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Ple ase include the EPA Docket ID Number EPA-HQ-OAR-2002-0037 in any correspondence.13 PART B OF THE SUPPORTING STATEMENT

This section is not applicable because statistical meth ods are not used in data collection associated with this regulation.14 ATTACHMENT 1

SOURCE DATA AND INFORMATION REQUIREMENTS

Requirement 40 CFR 63 Subpart

HHHHHHH

RECORDKEEPING

A copy of each notification and report submitted to compl y with this subpart 63.11990(a)

Records of storage vessels 63.11990(b)

Records of equipment leaks 63.11990(c)

Records of heat exchanger systems 63.11990(d)

Records of process vents 63.11990(e) and 63.11990(f) Records of closed vent systems 63.11990(g)

Records of resin strippers 63.11990(e) and 63.11990(h) Records of process wastewater 63.11990(e) and 63.11990(i)

Keep records for five years 63.11995(a)

REPORTING

Submit an initial notification 63.9(b)

Submit a notification of compliance status 63.11985(a)

Submit a notification of performance test 63.9(e)

Submit a compliance report 63.11985(b)

Submit a notification of inspection 63.11985(c)(1)

Submit a batch precompliance report 63.11985(c)(2)

Submit an affirmative defense report 63.11985(c)(4)15 ATTACHMENT 1 (cont.)

SOURCE DATA AND INFORMATION REQUIREMENTS

Requirement 40 CFR 63 Subpart

HHHHHHH

MONITORING

General Monitoring Requirements 63.11890(c) and 63.11935(a) and 63.11935(b) and 63.11935(c) and 63.11935(d) Storage Vessel Monitoring 63.11910(a) and 63.11910(c) Pressure Relief Device Monitoring 63.11915(c)

Heat Exchanger Monitoring 63.11920(a)

Process Vent Control Device Monitoring 63.11925(c) and 63.11925(d) and 63.11925(e) and 63.11925(f) and

63.11940 and 63.11945(a) Closed Vent System Monitoring 63.11930(c) and 63.11930(d) and 63.11930 (f) and 63.11930 (h) Ambient Vinyl Chloride Monitoring 63.11956

Resin Stripper Monitoring 63.11960(b) and 63.11960(c)

Wastewater Monitoring 63.11965(a) and 63.11975(a) and 63.11975(d) and 63.11975(e)16 ATTACHMENT 2

TABLES 1, 2, 3, and 4

Tables 1 - 3: Annual Respondent Burden and Cost of Recordkeepin g and Reporting

Requirements of the MACT Floor for Existing Sources: P olyvinyl Chloride and Copolymer Manufacturing Units – Years 1-3

Table 4: Summary of Annual Respondent Burden and Cost of Rec ordkeeping and

Reporting Requirements of the MACT Floor for Existing So urces: Polyvinyl Chloride and Copolymer Manufacturing UnitsAttachment 2(A) (B) (C) (D) (E) (F) (G)Respondent Non-Labor Number of Hours Number of TechnicalManagement Clerical Total Total TotalHours per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor ResponsesOccurrence Per Per Respondent Per Year Per Year Per Year Per Year Per Year Costs Per Year(Technical Occurrence Respondent Per YearPer YearBurden Itemhours) Per Year (C=A x B) (CXD) (E x 0.05) (E x 0.1)1. ApplicationsN/A2. Surveys and StudiesN/A3. Reporting RequirementsA. Read and Understand Rule Requirements 25 $100 1 25 17 425 21 43 $46,229 $1,700 0 a,bB. Required Activities1) Initial performance test, sampling, and report 40$53,139 1 40 17 680 34 68 $73,966 $903,355 0 a2) Periodic performance test, sampling, and report 15 $54,042 1 15 17 255 13 26 $27,737 $918,716 0 f3) Establish operating parameters and monitoring plan 20 $0 1 20 17 340 17 34 $36,983 $0 0 a4) Continuous parameter monitoringa) Initial capital costs (Fabric Filters) 0 $17,100 1 05 0 0 0 $0 $85,500 0 a,db) Annualized capital and O&M costs (Fabric Filters& ACI) 11 $31,700 1 11 5 55 3 6 $5,983 $158,500 0 c,ec) Initial capital costs (PRD Electronic Monitor) 0 $188,913 1 0 17 0 0 0 $0 $3,211,521 0 a,dd) Annualized capital and O&M costs (PRD ElectronicMonitor) 11 $26,897 1 11 17 187 9 19 $20,341 $457,249 0 c,ee) Initial capital costs (PB Scrubber Monitor) 0 $23,000 1 0 1 0 0 0 $0 $23,000 0 a,df) Annualized capital and O&M costs (PB Scrubber Monitor 11 $5,300 1 11 1 11 1 1 $1,197 $5,300 0 c,eC. Create InformationIncl. in 3.BD. Gather InformationIncl. in 3.EE. Report Preparation1) Initial Notification5 $0 1 5 17 85 4 9 $9,246 $0 172) Batch precompliance report5 $0 1 5 17 85 4 9 $9,246 $0 173) Notification of performance test with test plan 10 $0 1 10 17 170 9 17 $18,492 $0 174) Notification of compliance status20 $0 1 20 17 340 17 34 $36,983 $0 17 b5) Compliance report25 $0 1 25 0 0 0 0 $0 $0 06) Notice of inspection5 $0 1 5 17 85 4 9 $9,246 $0 177) Affirmative defense18 $0 1 18 0 18 12 0 $0 $0 0 gReportingSubtotal2,718 136 272 $295,647 $2,444,820 854. Recordkeeping RequirementsA. Read InstructionsIncl. in 3.AB. Implement ActivitiesN/AC. Develop Record SystemN/AD. Record Information1) Records of process vent requirements 10 $0 1 10 0 0 0 0 $0 $0 02) Records of resin stripper and wastewater requirements 15 $0 1 15 0 0 0 0 $0 $0 03) Records of storage vessel requirements 10 $0 1 10 0 0 00 $0 $0 04) Records of equipment leak requirements 25 $0 1 25 0 0 00 $0 $0 05) Records of heat exchanger requirements 10 $0 1 10 0 0 00 $0 $0 0E. Personnel TrainingIncl. in 3.BF. Time for AuditsN/ARecordkeeping Subtotal0 0 0$0$0 0TOTAL:2,718 136 272 $295,647 $2,444,820 85Total Hours Labor Non-Labor TotalSummary of Respondent Burden 3,126 $295,647 $2,444,820$2,740,467Initial Capital and Startup $3,298,721$2,444,820FOOTNOTESa One-time only costs.b Cost incurred by a facility regardless of the number of affected units at the plant.c Annual cost. Annual costs are not incurred untilthe second year of operation.d Based on the sum of the total capital costs for each monitoring system required for PVC facilities.e Based on the sum of the annualized capital costs for each monitoring system required for PVC facilities.fIncludes 11 months testing for wastewater and resinto cover rest of the year after the initial test.g Hours for affirmative defense are shown only for illustration and are not included in the total burden estimateAnnualized Capital/Start-up and O & Mfor Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 1Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor FootnotesAttachment 2(A) (B) (C) (D) (E) (F) (G)Respondent Non-Labor Number of Hours Number of TechnicalManagement Clerical Total Total TotalHours per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor ResponsesOccurrence Per Per Respondent Per Year Per Year Per Year Per Year Per Year Costs Per Year(Technical Occurrence Respondent Per YearPer YearBurden Itemhours) Per Year (C=A x B) (CXD) (E x 0.05) (E x 0.1)1. ApplicationsN/A2. Surveys and StudiesN/A3. Reporting RequirementsA. Read and Understand Rule Requirements 25 $100 1 25 0 0 00 $0 $0 0 a,bB. Required Activities1) Initial performance test, sampling, and report 40$53,139 1 40 0 0 0 0 $0 $0 0 a2) Periodic performance test, sampling, and report 50 $108,750 1 50 17 850 43 85 $92,458 $1,848,751 03) Establish operating parameters and monitoring plan 20 $0 1 20 0 0 0 0 $0 $0 0 a4) Continuous parameter monitoringa) Initial capital costs (Fabric Filters) 0 $0 1 0 0 0 0 0 $0 $0 0 a,db) Annualized capital and O&M costs (Fabric Filters& ACI) 11 $31,700 1 11 5 55 3 6 $5,983 $158,500 0 c,ec) Initial capital costs (PRD Electronic Monitor) 0 $0 1 0 0 0 0 0 $0 $0 0 a,dd) Annualized capital and O&M costs (PRD ElectronicMonitor) 11 $26,897 1 11 17 187 9 19 $20,341 $457,249 0 c,ee) Initial capital costs (PB Scrubber Monitor) 0 $0 1 00 0 0 0 $0 $0 0 a,df) Annualized capital and O&M costs (PB Scrubber Monitor 11 $5,300 1 11 1 11 1 1 $1,197 $5,300 0 c,eC. Create InformationIncl. in 3.BD. Gather InformationIncl. in 3.EE. Report Preparation1) Initial Notification5 $0 1 5 0 0 0 0 $0 $0 02) Batch precompliance report5 $0 1 5 0 0 0 0 $0 $0 03) Notification of performance test with test plan 10 $0 1 10 0 0 0 0 $0 $0 04) Notification of compliance status20 $0 1 20 0 0 0 0 $0 $0 0 b5) Compliance report25 $0 1 25 17 425 21 43 $46,229 $0 176) Notice of inspection5 $0 1 5 17 85 4 9 $9,246 $0 177) Affirmative defense18 $0 1 18 0 18 12 0 $0 $0 0 fReportingSubtotal1,613 81 161 $175,452 $2,469,800 344. Recordkeeping RequirementsA. Read InstructionsIncl. in 3.AB. Implement ActivitiesN/AC. Develop Record SystemN/AD. Record Information1) Records of process vent requirements 10 $0 1 10 17 1709 17 $18,492 $0 02) Records of resin stripper and wastewater requirements 15 $0 1 15 17 255 13 26 $27,737 $0 03) Records of storage vessel requirements 10 $0 1 10 17 170 9 17 $18,492 $0 04) Records of equipment leak requirements 25 $0 1 25 17 425 21 43 $46,229 $0 05) Records of heat exchanger requirements 10 $0 1 10 17 170 9 17 $18,492 $0 0E. Personnel TrainingIncl. in 3.BF. Time for AuditsN/ARecordkeeping Subtotal1190 59.5 119$129,441$0 0TOTAL:2,803 140 280 $304,893 $2,469,800 34Total Hours Labor Non-Labor TotalSummary of Respondent Burden 3,223 $304,893 $2,469,800$2,774,693Initial Capital and Startup $0$2,469,800FOOTNOTESa One-time only costs.b Cost incurred by a facility regardless of the number of affected units at the plant.c Annual cost. Annual costs are not incurred untilthe second year of operation.d Based on the sum of the total capital costs for each monitoring system required for PVC facilities.e Based on the sum of the annualized capital costs for each monitoring system required for PVC facilities.f Hours for affirmative defense are shown only for illustration and are not included in the total burden estimateAnnualized Capital/Start-up and O & Mfor Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 2Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor FootnotesAttachment 2(A) (B) (C) (D) (E) (F) (G)Respondent Non-Labor Number of Hours Number of TechnicalManagement Clerical Total Total TotalHours per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor ResponsesOccurrence Per Per Respondent Per Year Per Year Per Year Per Year Per Year Costs Per Year(Technical Occurrence Respondent Per YearPer YearBurden Itemhours) Per Year (C=A x B) (CXD) (E x 0.05) (E x 0.1)1. ApplicationsN/A2. Surveys and StudiesN/A3. Reporting RequirementsA. Read and Understand Rule Requirements 25 $100 1 25 0 0 00 $0 $0 0 a,bB. Required Activities1) Initial performance test, sampling, and report 40$53,139 1 40 0 0 0 0 $0 $0 0 a2) Periodic performance test, sampling, and report 50 $108,750 1 50 17 850 43 85 $92,458 $1,848,751 03) Establish operating parameters and monitoring plan 20 $0 1 20 0 0 0 0 $0 $0 0 a4) Continuous parameter monitoringa) Initial capital costs (Fabric Filters) 0 $0 1 0 0 0 0 0 $0 $0 0 a,db) Annualized capital and O&M costs (Fabric Filters& ACI) 11 $31,700 1 11 5 55 3 6 $5,983 $158,500 0 c,ec) Initial capital costs (PRD Electronic Monitor) 0 $0 1 0 0 0 0 0 $0 $0 0 a,dd) Annualized capital and O&M costs (PRD ElectronicMonitor) 11 $26,897 1 11 17 187 9 19 $20,341 $457,249 0 c,ee) Initial capital costs (PB Scrubber Monitor) 0 $0 1 00 0 0 0 $0 $0 0 a,df) Annualized capital and O&M costs (PB Scrubber Monitor 11 $5,300 1 11 1 11 1 1 $1,197 $5,300 0 c,eC. Create InformationIncl. in 3.BD. Gather InformationIncl. in 3.EE. Report Preparation1) Initial Notification5 $0 1 5 0 0 0 0 $0 $0 02) Batch precompliance report5 $0 1 5 0 0 0 0 $0 $0 03) Notification of performance test with test plan 10 $0 1 10 0 0 0 0 $0 $0 04) Notification of compliance status20 $0 1 20 0 0 0 0 $0 $0 0 b5) Compliance report25 $0 1 25 17 425 21 43 $46,229 $0 176) Notice of inspection5 $0 1 5 17 85 4 9 $9,246 $0 177) Affirmative defense18 $0 1 18 0 18 12 0 $0 $0 0 fReportingSubtotal1,613 81 161 $175,452 $2,469,800 344. Recordkeeping RequirementsA. Read InstructionsIncl. in 3.AB. Implement ActivitiesN/AC. Develop Record SystemN/AD. Record Information1) Records of process vent requirements 10 $0 1 10 17 1709 17 $18,492 $0 02) Records of resin stripper and wastewater requirements 15 $0 1 15 17 255 13 26 $27,737 $0 03) Records of storage vessel requirements 10 $0 1 10 17 170 9 17 $18,492 $0 04) Records of equipment leak requirements 25 $0 1 25 17 425 21 43 $46,229 $0 05) Records of heat exchanger requirements 10 $0 1 10 17 170 9 17 $18,492 $0 0E. Personnel TrainingIncl. in 3.BF. Time for AuditsN/ARecordkeeping Subtotal1190 59.5 119$129,441$0 0TOTAL:2,803 140 280 $304,893 $2,469,800 34Total Hours Labor Non-Labor TotalSummary of Respondent Burden 3,223 $304,893 $2,469,800$2,774,693Initial Capital and Startup $0$2,469,800FOOTNOTESa One-time only costs.b Cost incurred by a facility regardless of the number of affected units at the plant.c Annual cost. Annual costs are not incurred untilthe second year of operation.d Based on the sum of the total capital costs for each monitoring system required for PVC facilities.e Based on the sum of the annualized capital costs for each monitoring system required for PVC facilities.f Hours for affirmative defense are shown only for illustration and are not included in the total burden estimateAnnualized Capital/Start-up and O & Mfor Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 3Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor FootnotesAttachment 2YearTechnicalHoursManagementHours Clerical Hours Total Hours Labor CostsNon-Labor(AnnualizedCapital/Startup andO&M) Costs Total Costs1 2,718 136 272 3,126 $295,647 $2,444,820 $2,740,4672 2,803 140 280 3,223 $304,893 $2,469,800 $2,774,6933 2,803 140 280 3,223 $304,893 $2,469,800 $2,774,693Total 8,324 416 832 9,573 $905,432 $7,384,420 $8,289,852Average 2,775 139 277 3,191 $301,811 $2,461,473 $2,763,284Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirementsof the MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units21

ATTACHMENT 3

TABLES 5, 6, 7, and 8

Tables 5 - 7: Annual Designated Administrator Burden and Cos t of Recordkeeping and

Reporting Requirements of the MACT Floor for Existing So urces: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 1-3

Table 8: Summary of Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Uni tsAttachment 3(B) (C) (D) (E) (F)EPA HoursPerOccurrenceTech Hours PerYear (C=AxB)ManagementHours Per Year(D=Cx0.05)Clerical HoursPer Year(E=Cx0.1)EPA Cost PerYear (a,b)1. Applications2. Read and Understand Rule Requirements 10 16 160 8 16 $8,2923. Required ActivitiesA.3 b 48 163 8 16 $8,457B. Excess emissions -- Enforcement Activities 2 d 24 41 24 $2,114C. Create InformationD. Gather InformationE. Report Reviews1) Review initial notification 17 3 51 3 5 $2,6432) Review batch precompliance report 17 5 85 4 9 $4,4053) Review notification of performance test 17 10 170 9 17$8,8104) Review notification of compliance status 17 40 680 3468 $35,2395) Review compliance report 0 20 0 0 0 $06) Review notice of inspection 17 3 51 3 5 $2,6437) Review affirmative defense 0 10 0 0 0 $0F. Prepare annual summary report 1 c 200 200 10 20 $10,3644. Travel expenses: (1 person * 30 hours per year/ 8 hours per day * $75 per diem) + ($600 per roundtrip) = $881 per trip $2,996TOTAL1601 80 160 $85,964FOOTNOTESa Figures may not add exactly due to rounding.b Assumes EPA personnel attend 20 percent of the initial stack tests.c Using four hours per state to write annual summaryreport.d Assume 10% have emission exceedances.Observe initial performance testsnot applicablenot applicableTable 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirementsofthe MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 1(A)not applicableNumber ofOccurrences PerYearBurden ItemAttachment 3(B) (C) (D) (E) (F)EPA Hours PerOccurrenceTech Hours PerYear (C=AxB)ManagementHours Per Year(D=Cx0.05)Clerical HoursPer Year(E=Cx0.1)EPA Cost PerYear (a,b)1. Applications2. Read and Understand Rule Requirements 0 16 0 0 0 $03. Required ActivitiesA.0 b 48 0 0 0 $0B. Excess emissions -- Enforcement Activities 2 d 24 41 24 $2,114C. Create InformationD. Gather InformationE. Report Reviews1) Review initial notification 0 3 0 0 0 $02) Review batch precompliance report 0 5 0 0 0 $03) Review notification of performance test 0 10 0 0 0 $04) Review notification of compliance status 0 40 0 0 0 $05) Review compliance report 17 20 340 17 34 $17,6206) Review notice of inspection 17 3 51 3 5 $2,6437) Review affirmative defense 0 10 0 0 0 $0F. Prepare annual summary report 1 c 200 200 10 20 $10,3644. Travel expenses: (1 person * 30 hours per year/ 8 hours per day * $75 per diem) + ($600 per roundtrip) = n/a per trip $0TOTAL632 32 63 $32,741FOOTNOTESa Figures may not add exactly due to rounding.b Assumes EPA personnel attend 20 percent of the initial stack tests.c Using four hours per state to write annual summaryreport.d Assume 10% have emission exceedances.Observe initial performance testsnot applicablenot applicableTable 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirementsofthe MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 2(A)not applicableNumber ofOccurrences PerYearBurden ItemAttachment 3(B) (C) (D) (E) (F)EPA HoursPerOccurrenceTech Hours PerYear (C=AxB)ManagementHours Per Year(D=Cx0.05)Clerical HoursPer Year(E=Cx0.1)EPA Cost PerYear (a,b)1. Applications2. Read and Understand Rule Requirements 0 16 0 0 0 $03. Required ActivitiesA.0 b 48 0 0 0 $0B. Excess emissions -- Enforcement Activities 2 d 24 41 2 4 $2,114C. Create InformationD. Gather InformationE. Report Reviews1) Review initial notification 0 3 0 0 0 $02) Review batch precompliance report53) Review notification of performance test 0 10 0 0 0 $04) Review notification of compliance status 0 40 0 0 0 $05) Review compliance report 17 20 340 17 34 $17,6206) Review notice of inspection 17 3 51 3 5 $2,6437) Review affirmative defense 0 10 0 0 0 $0F. Prepare annual summary report 1 c 200 200 10 20 $10,3644. Travel expenses: (1 person * 30 hours per year / 8hours per day * $75 per diem) + ($600 per round trip) = n/a per trip $0TOTAL632 32 63 $32,741FOOTNOTESa Figures may not add exactly due to rounding.b Assumes EPA personnel attend 20 percent of the initialstack tests.c Using four hours per state to write annual summary report.d Assume 10% have emission exceedances.Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirementsof theMACT Floor for Existing Sources: Polyvinyl Chlorideand Copolymer Manufacturing Units - Year 3(A)not applicableNumber ofOccurrences PerYearBurden ItemObserve initial performance testsnot applicablenot applicableAttachment 3YearTechnicalHoursManagementHours Clerical Hours Total Hours Labor CostsNon-LaborCosts Total Costs1 1,601 80 160 1,841 $85,964 $0 $85,9642 632 32 63 727 $32,741 $0 $32,7413 632 32 63 727 $32,741 $0 $32,741Total 2,865 143 286 3,294 $151,447 $0 $151,447Average 955 48 95 1,098 $50,482 $0 $50,482Table 8 - Summary of Annual Designated Administrator Burden and Cost of Recordkeeping andReporting Requirements of the MACT Floor for Existing Sources: Polyvinyl Chloride and CopolymerManufacturing Units