SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY 

National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and 

Copolymers Production Area Sources (Subpart DDDDDD) 

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 Area Sources (40 CFR part 63, subpart DDDDDD) 

1(b) Short Characterization/Abstract 

This supporting statement addresses information collection activities that will be imposed 

by the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Polyvinyl 

Chloride and Copolymers (PVC) Production Area Sources, 40 CFR part 63, subpart DDDDDD, 

referred to as the PVC NESHAP for area sources. In 2007, the Environmental Protection Agency 

(EPA) promulgated national emission standards for hazardous air pollutants for new and existing 

PVC and copolymers production area sources under 40 CFR part 63, subpart DDDDDD (72 FR 

2930, January 23, 2007). Subpart DDDDDD was based on GACT and required area sources to 

meet the requirements imposed by the NESHAP for PVC Production, in 40 CFR, part 61, 

subpart F, referred to as the part 61 NESHAP. The part 61 NESHAP requirements address only 

vinyl chloride emissions. On May 20, 2011, the EPA issued a proposal to update the PVC Area 

Source NESHAP in accordance with the Clean Air Act (CAA) section 112 and proposed a new 

40 CFR part 63 subpart HHHHHHH to regulate both major and area source PVC production 

facilities. The final 40 CFR part 63 subpart HHHHHHH will regulate major source PVC 

production facilities only, and the final 40 CFR part 63 subpart DDDDDD will regulate area 

source PVC production facilities. By updating the 2007 standards, the EPA is fulfilling their 

obligation under the CAA section 112(d)(6) to review and revise, as necessary, the PVC 

production area source standards. This information collection request documents the 

recordkeeping and reporting requirements associated with the EPA’s final rule as well as 

adjustments made since the proposal in response to public comments. 

The ICR prepared for the May 20, 2011 proposed 40 CFR part 63 subpart HHHHHH 

(2454.01) included estimates of burden for both major and area sources combined. The final 40 

CFR part 63, subpart DDDDDD applies to new and existing area source PVC and copolymer 

production facilities and this ICR includes burden estimates for area sources only. A separate 

ICR (2432.01) has been prepared to estimate the burden to area source PVC and copolymer 

productions facilities following promulgation of 40 CFR part 63, subpart DDDDDD. 

This ICR includes the burden for activities that will be conducted in the first three years 

following promulgation of the proposed PVC Area Source NESHAP. These activities include 

reading the rule, resin sampling, performance testing, establishing operating 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 during the fourth or fifth year 

instead. Therefore, this ICR presents a conservatively high burden estimate for the initial three 

years following promulgation of the promulgated PVC Area Source NESHAP. 

The use of the term "Designated Administrator" throughout this document refers to the 

U.S. EPA Administrator or a delegated authority such as a state agency. The term 

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

This ICR presents the burden to respondents and the Designated Administrator (State or 

Federal Government) that will be imposed by the plans developed to implement the PVC Area 

Source NESHAP. Respondents are owners or operators of existing PVC production area source 

facilities. 

The requirements described below are the minimum requirements established by the PVC 

Area Source NESHAP. Although the Designated Administrator may choose to impose more 

stringent requirements, it is assumed for this burden estimate that the implemented plans mirror 

the PVC Area Source NESHAP. 

Over the next three years, 2 PVC production area source facilities will be subject to this 

standard, and the cost of this ICR will be $970 thousand. 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 Administrator” is 

attributed entirely to work performed by federal employees or government contractors; this 

burden may be found in Tables 5 through 8 of Attachment 3. 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection 

 Section 112(d) of the CAA requires the EPA to establish NESHAP for both major and 

area sources of hazardous air pollutants (HAP) that are listed for regulation under CAA section 

112(c). A major source emits or has the potential to emit 10 tons per year (tpy) or more of any 

single HAP or 25 tpy or more of any combination of HAP. An area source is a HAP-emitting 

stationary source that is not a major source. 

 CAA section 112(k)(3)(B) calls for the EPA to identify at least 30 HAP which, as the 

result of emissions from area sources, pose the greatest threat to public health in the largest 

number of urban areas. The EPA implemented this provision in 1999 in the Integrated Urban Air 

Toxics Strategy (Strategy), (64 FR 38715, July 19, 1999). Specifically, in the Strategy, the EPA 

identified 30 HAP that pose the greatest potential health threat in urban areas, and these HAP are 

referred to as the “30 urban HAP.” CAA section 112(c)(3) requires EPA to list sufficient 

categories or subcategories of area sources to ensure that area sources representing 90 percent of 

the emissions of the 30 urban HAP are subject to regulation. 

 

 Under CAA section 112(d)(5), the EPA may elect to promulgate standards or 

requirements for area sources "which provide for the use of generally available control 
technologies or management practices (“GACT”) by such sources to reduce emissions of 

hazardous air pollutants." Additional information on GACT is found in the Senate report on the 

legislation (Senate Report Number 101-228, December 20, 1989), which describes GACT as: 

. . . methods, practices and techniques which are commercially available and 

appropriate for application by the sources in the category considering economic 

impacts and the technical capabilities of the firms to operate and maintain the 

emissions control systems. 

 Consistent with the legislative history, we can consider costs and economic impacts in 

determining GACT. 

In the Administrator's judgment, HAP emissions from PVC production area source 

facilities cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health or welfare. Therefore, the NESHAP was promulgated for this source category in 

2007 at 40 CFR part 63, subpart DDDDDD and is being revised for the current rulemaking. 

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 are complied with on a continuous basis. 

Specifically, the information will be used by the Designated 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; and (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 to 

identify PVC production facilities that may not be in compliance with the standards. Based on 

reported information, the Designated Administrator can decide 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 have met the qualification 

requirements. 

3. Nonduplication, Consultations, and Other Collection Criteria

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

subpart DDDDDD.

3(a) Nonduplication

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 its 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 prior to ICR submission to OMB

A public notice of this collection was provided in the Federal Register notice of final 

rulemaking published for the PVC NESHAP on May 20, 2011 at 76 FR 29528. 

3(c) Consultations

The public was provided the opportunity to review and comment on the burden estimated 

in the Information Collection Request during the comment period for the proposed 40 CFR part 

63 subpart HHHHHHH. We have reviewed the public comments on the proposed subpart 

HHHHHHH and have adopted several changes to the compliance requirements in the final 

subpart DDDDDD in response to these comments and to minimize the burden on affected 

entities. Significant items that have reduced the burden on affected entities include removal of 

the continuous parametric monitoring requirements for resin strippers and wastewater strippers, 

reduced sampling and analysis frequency for process wastewater streams that do not require 

treatment, and consolidation of some reporting requirements. The preamble and final rule discuss 

the significant changes made since proposal. In response to specific comments received on the 

estimated burden we have updated the burden estimates. 

3(d) Effects of Less Frequent Data Collection

The PVC NESHAP for area sources requires an initial notification, initial and periodic 

testing, continuous operating parameter monitoring, a notification of compliance 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, total hydrocarbons or total organic 

HAP, and chlorinated dibenzo-dioxins and furans (CDD/CDF), the owner or operator must 

establish maximum or minimum values for each operating parameter. Thereafter, the owner or 

operator must continuously monitor the operating parameters. In addition, monthly wastewater 

and resin sampling must also be performed. Owners and operators must also conduct a leak 

detection and repair program and must operate a vinyl chloride monitoring system. 

Although continuous monitoring of operating parameters cannot provide a direct 

measurement of emissions, it is less expensive than continuous emissions monitoring systems 

(CEMS), and the information provided can be used to ensure that the air pollution control 

devices are operating properly. This information assures EPA 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 information and data parameters 

so that any potential problems can be identified in a timely 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 and 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 maintaining control equipment properly. The 

title V permit programs also require records to be retained for 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 maintaining control equipment properly. 

3(f) Confidentiality

All information submitted to the Agency for which a claim of confidentiality is made will 

be safeguarded according to the Agency policies set forth in 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 area source PVC production facilities. The PVC NESHAP for area sources 

affects any industry using a polyvinyl chloride and copolymers production process unit as 

defined 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 produce PVC and/or copolymers products). 

Based on the distribution of facilities with affected PVC production facilities, there are 2 

existing area source 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 reporting requirements of this 

regulation. 
(ii) Respondent Activities

The respondent activities required by the standards are provided 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, process wastewater sampling, resin sampling, leak detection monitoring, heat 

exchange system monitoring, pressure relief device (PRD) monitoring, 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 presented in this burden estimate, but may not 

occur until four or five years following promulgation of the 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 Designated Administrator of the 

applicability of this subpart and to identify storage vessels, process vents, equipment leaks, and 

other equipment and emission points subject to this subpart.

A notification of performance test must be submitted, and 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 hydrocarbons or total organic 

HAP, and CDD/CDF. During the initial performance test the owner or operator must establish 

limits for each operating parameter. Thereafter, the owner or operator must continuously monitor 

the operating parameters. Performance tests are also required for vinyl chloride, total 

hydrocarbons or total organic HAP, and CDD/CDF every five years. 

For stripped resin and process wastewater streams, testing is required for both vinyl 

chloride and total non-vinyl chloride organic HAP. An initial test must be performed. For 

stripped resins, subsequent daily sampling is required for vinyl chloride and monthly sampling is 

required for total non-vinyl chloride organic HAP. For process wastewater streams that require 

treatment, monthly sampling is required for both vinyl chloride and total non-vinyl chloride 

organic HAP. Monthly monitoring is also required for heat exchange systems and equipment 

leaks. 

Following the initial performance test, the owner or operator must submit a notification 

of compliance status that documents the performance tests, 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 of 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 submittal of a batch pre-compliance report and 

notice of inspection. 

Owners or operators of PVC production facilities are required to keep records of certain 

parameters and information for a period of five years. These records include the initial 

performance test and operating parameter values consistent with the monitoring plan; stripped 

resin and process wastewater sampling results; the date and time for each deviation; copies of the 

current version of the monitoring plan and the equipment leak detection and repair plan; 

monitoring schedule and inspection records for valves, pumps, connectors, 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 heat exchange systems. 

All reports are to be submitted to the Designated Administrator. The information will be 

used to determine that all sources subject to the PVC NESHAP are achieving the requirements. 

As an administrative addition to this ICR, EPA is also including an illustrative estimate 

of the burden associated with performing a Root Cause Analysis (RCA) associated with 

affirmative defense of malfunctions if the source elects 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 defense 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 standard, EPA does not expect this activity 

to be routinely performed by a source. Our decision to include this recordkeeping and reporting 

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

estimate whether an affirmative defense would be necessary for any source or class of sources. It 

is not an enforceable requirement of compliance. 

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION, 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

A list of Agency activities is provided in section 6(c) and 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 allow flexibility and minimize burden. 

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 tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 
EPA and its delegated Authorities can edit, store, retrieve and analyze the data. 

 The records required by this regulation must be retained by the 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 exclusively for the benefit 

of small entities; however, there are provisions that 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 notification. As discussed earlier, we 

also anticipate many of the one-time activities, including: initial performance tests (vinyl 

chloride, total hydrocarbons or total organic HAP, and CDD/CDF), initial resin stripper 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 three years, but they 

may occur in years four or five. 

A semi-annual compliance report that includes data on the 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 of individual burdens and 

non-labor costs for the recordkeeping and reporting requirements applicable to the industry for 

each year for the subpart included in this ICR. The individual burdens are expressed under 

standardized headings believed to be consistent with the concept of burden under the Paperwork 

Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. 

Responses to this information collection are mandatory. 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 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 426 hours. The average annual recordkeeping 

hours are 146 and the reporting requirement hours are 281, both of which are shown in Tables 1 

through 4 of Attachment 2. 
6(b) Estimating Respondent Costs

The information collection activities for sources subject to these requirements are 

presented in Tables 1 through 4 of Attachment 2. The total cost 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 Labor, Bureau of Labor Statistics, 

September 2010, “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/Start-up and Operation and Maintenance Costs 

The capital costs associated with the proposed PVC NESHAP include monitoring system 

initial costs, performance testing, resin stripper testing, wastewater testing; one time costs when a 

facility becomes subject to the regulation. The annual operation 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) Costs 

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 2 $130,000 $850,000 $280,000 

The total capital/startup costs for this ICR are $130,000; column C. 

The total annualized capital/startup and O&M costs for this ICR are $850 thousand, or an 

average of $280 thousand per year; columns D and E. These are recordkeeping costs. 

(iv) Potential Burden under Affirmative Defense 
When a malfunction occurs, sources must report them according to the applicable 

reporting requirements of subpart DDDDDD. An affirmative defense to civil penalties for 

exceedances of emission limits that are caused by malfunctions 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 and or careless operation) and where 

the source took necessary actions to minimize emissions. In addition, the source must meet 

certain notification and reporting requirements. For example, the source must prepare a written 

root cause analysis and submit a written report to the Administrator documenting that it has met 

the conditions and requirements for assertion of the affirmative defense. 

To provide the public with an estimate of the relative magnitude of the burden associated 

with an assertion of the affirmative defense position adopted by a source, the EPA provides an 

administrative adjustment to this ICR that shows the notification, recordkeeping and reporting 

requirements associated with the assertion of the affirmative defense might entail. The EPA’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, 

interview plant employees, and document the events surrounding a malfunction that has caused 

an exceedance of an emission limit. The estimate also includes time to produce and retain the 

record and reports for submission to the EPA. The EPA provides this illustrative estimate of this 

burden because these costs are only incurred if 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. The EPA's overall 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 

$7,000. 

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 Management (OPM), 2010 General Schedule, 

which excludes locality rates of pay. The rates have been 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 Costs 

The total number of respondents is also referred to as the respondent universe. Based on 

research, 2 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 will most likely utilize to comply with the 

proposed emissions guidelines. 

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 2 18 6 

 The number of average annual responses is 6. 

6(e) Bottom Line Burden Hours and Cost Tables 

(i) The Respondent Tally 

The total annual labor hours are 426. 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 to average 71 hours per response. 

The total annual capital/startup and O&M costs to the regulated entity are $850 thousand. 

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 160 hours at a cost of $7,000 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 
An ICR was not prepared at the proposal stage of this rulemaking because the burden for 

area sources was contained in a separate ICR, which outlined the combined burden for both area 

and major source PVC and copolymer production facilities (ICR 2432.01). Further, the area 

source rule has never had an unique ICR assigned to it. The 2007 revisions to 40 CFR part 63 

subpart DDDDDD noted that the rule did not impose any new burden since all sources subject to 

the area source rule were also required to comply with the same testing, monitoring, reporting, 

and recordkeeping requirements under 40 CFR part 61 subpart F (ICR 0186.12). However, this 

final rule action requires additional testing, monitoring, reporting, and recordkeeping 

requirements that are not considered under ICR 0186.12. Therefore, a new ICR was created to 

account these additional burden items. This ICR treats these burden estimates as new burdens 

and the burden is not compared to any previous burden estimates. 

For sources that were subject to 40 CFR part 63 subpart F, the requirements—and 

associated burden— of that subpart are shifting to this ICR, beginning on the compliance date of 

this rule for existing sources. This initial ICR covers incremental burden estimates, above the 

burden currently required to comply with 40 CFR part 61 subpart F since both ICR will be 

relevant collection instruments during this three year time period. Subsequent renewals of this 

ICR should consider combining the burden estimates for ICR 0186 and ICR 2454, after sources 

shift their compliance from 40 CFR part 61 subpart F to 40 CFR part 63 subpart DDDDDD. 

To provide the public with an estimate of the relative magnitude of the burden associated 

with a source asserting an affirmative defense position (for those not already regulated under the 

part 61 NESHAP), the EPA is providing an administrative adjustment to this ICR. The 

adjustment shows the notification, recordkeeping and reporting requirements associated with the 

assertion of the affirmative defense. This illustrative example does not result in an increase in the 

burden for this rule. The EPA provides this estimate of the burden because 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 collection of information 

is estimated to be 71 hours per response. Burden means total time, effort, or financial resources 

expended by persons to generate, maintain, retain, or disclose or provide information to or for a 

Federal agency. This includes the time needed to review instructions; develop, acquire, install, 

and utilize technology and systems for the purposes of collecting, validating, and verifying 

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

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

train personnel to be able to respond to a 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 currently 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, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, the 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 Docket Center (EPA/DC), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding 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 send 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. Please include the EPA Docket ID 

Number EPA-HQ-OAR-2002-0037 in any correspondence. 
PART B OF THE SUPPORTING STATEMENT 

This section is not applicable because statistical methods are not used in data collection 

associated with this regulation. 
ATTACHMENT 1 

SOURCE DATA AND INFORMATION REQUIREMENTS 

Requirement 40 CFR part 63 

subpart DDDDDD 

Cross-Reference to 40 

CFR part 63 subpart 

HHHHHHH 

Recordkeeping 

A copy of each notification and report 

submitted to comply with this subpart 63.11142(f)(19) 63.11990(a) 

Records of storage vessels 63.11142(f)(19) 63.11990(b) 

Records of equipment leaks 63.11142(f)(19) 63.11990(c) 

Records of heat exchanger systems 63.11142(f)(19) 63.11990(d) 

Records of process vents 63.11142(f)(19) 63.11990(e) and 

63.11990(f) 

Records of closed vent systems 63.11142(f)(9) and 

63.11142(f)(19) 

63.11930(g) and 

63.11990(g) 

Records of resin strippers 63.11142(f)(19) 63.11990(e) and 

63.11990(h) 

Records of process wastewater 63.11142(f)(19) 63.11990(e) and 

63.11990(i) 

Keep records for five years 63.11142(f)(19) 63.11995(a) 

Reporting

Submit an initial notification 63.9(b) 63.9(b) 

Submit a notification of compliance status 63.11142(f)(18) 63.11985(a) 

Submit a notification of performance test 63.9(e) 63.9(e) 

Submit a compliance report 63.11142(f)(18) 63.11985(b) 

Submit a notification of inspection 63.11142(f)(18) 63.11985(c)(1) 

Submit a batch precompliance report 63.11142(f)(18) 

63.11985(c)(2) and 

63.11985(c)(3) and 

63.11985(c)(8) 
ATTACHMENT 1 (cont.) 

SOURCE DATA AND INFORMATION REQUIREMENTS 

Requirement 40 CFR part 63 

subpart DDDDDD 

Cross-Reference to 40 

CFR part 63 subpart 

HHHHHHH 

Monitoring 

General Monitoring Requirements 63.11142(f)(2) and 

63.11142(f)(10) 

63.11890(c) and 

63.11935(a) and 

63.11935(b) and 

63.11935(c) and 

63.11935(d) 

Storage Vessel Monitoring 63.11142(f)(5) 63.11910(a) and 

63.11910(c) 

Pressure Relief Device Monitoring 63.11142(f)(6) 63.11915(c) 

Heat Exchange System Monitoring 63.11142(f)(7) 63.11920(a) 

Process Vent Control Device Monitoring 

63.11142(f)(8) and 

63.11142(f)(11) and 

63.11142(f)(12) 

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 63.11142(f)(9) 

63.11930(c) and 

63.11930(d) and 

63.11930 (f) and 

63.11930 (h) 

Ambient Vinyl Chloride Monitoring 63.11142(f)(15) 63.11956 

Resin Stripper Sampling and Testing 63.11142(f)(16) 63.11960(c) and 

63.11960(d) 

Process Wastewater Sampling and Analysis 63.11142(f)(17) 

63.11965(b) and 

63.11965(c) and 

63.11965(d) and 

63.11970 and 

63.11975 
ATTACHMENT 2 

 TABLES 1, 2, 3, and 4 

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

Requirements of the MACT Floor for Existing Sources: Polyvinyl Chloride and 

Copolymer Manufacturing Units – Years 1-3 

Table 4: Summary of Annual Respondent Burden and Cost of Recordkeeping and 

Reporting Requirements of the MACT Floor for Existing Sources: Polyvinyl 

Chloride and Copolymer Manufacturing Units 
(A) (B) (C) (D) (E) (F) (G) (H)

Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Total 

Hours per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor Responses

Occurrence Per Per Respondent Per Year Per Year Per Year Per Year Per Year Costs Per Year

(Technical Occurrence Respondent Per Year Per Year

Burden Item hours) Per Year (C=A x C (D x E) (F x 0.05) (F x 0.1)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read and Understand Rule Requirements 25 $100 1 25 2 50 3 5 $5,439 $200 0 a,b,c

B. Required Activities

1) Initial performance test, sampling, and report

a) Process Vents 32 $43,198 1 32 2 64 3 6 $6,962 $86,395 0 a,d

b) Resins 2 $1,803 1 2 2 4 0 0 $435 $3,606 0 a,e

c) wastewater 2 $491 1 2 4 8 0 1 $870 $1,964 0 a,f

d) heat exchangers $0 0 0 4 0 0 0 $0 $0 0 g -

e) equipment leaks 2 $177,360 1 2 2 4 0 0 $435 $354,720 0 h

2) Periodic performance test, sampling, and report

a) Process Vents 32 $43,198 1 32 0 0 0 0 $0 $0 0 i

b) Resins 1 $601 11 11 2 22 1 2 $2,393 $13,222 0 e

c) wastewater 1 $491 11 11 2 22 1 2 $2,393 $10,791 0 f

d) uncontrolled wastewater 1 $491 1 1 0 0 0 0 $0 $0 0 f

e) heat exchangers 1 $0 12 12 4 48 2 5 $5,221 $0 0 g

f) equipment leaks 1 $16,105 1 1 2 2 0 0 $218 $32,210 0 h

3) Establish operating parameters and monitoring plan

a) Process Vents 3.5 $0 1 3.5 2 7 0 1 $761 $0 0 a,b,c

4) Continuous parameter monitoring

a) Initial capital costs (PRD Electronic Monitor) 0 $64,244 1 0 2 0 0 0 $0 $128,488 0 a,b

b) Annualized capital and O&M costs (PRD Electronic Monitor) 11 $31,772 1 11 2 22 1 2 $2,393 $63,544 0 b

C. Create Information Incl. in 3.B

D. Gather Information Incl. in 3.E

E. Report Preparation

1) Initial Notification 5 $0 1 5 2 10 1 1 $1,088 $0 2 a,b

2) Batch precompliance report 5 $0 1 5 2 10 1 1 $1,088 $0 2 a,b

3) Notification of performance test with test plan 10 $0 1 10 2 20 1 2 $2,175 $0 2 a,b

4) Notification of compliance status 20 $0 1 20 2 40 2 4 $4,351 $0 2 a,b

5) Compliance report 25 $0 1 25 0 0 0 0 $0 $0 0 b,k

6) Notice of inspection 5 $0 1 5 2 10 1 1 $1,088 $0 2 b,k

7) Affirmative defense 18 $0 1 18 0 18 12 0 $0 $0 0 j

ReportingSubtotal 343 17 34 $37,309 $566,652 10 l

4. Recordkeeping Requirements 

A. Read Instructions Incl. in 3.A 

B. Implement Activities N/A

C. Develop Record System N/A

D. Record Information

1) Records of process vent requirements 10 $0 1 10 0 0 0 0 $0 $0 0 b,k

2) Records of resin stripper requirements 15 $0 1 15 0 0 0 0 $0 $0 0 b,k

3) Records wastewater requirements 15 $0 1 15 0 0 0 0 $0 $0 0 b,k

4) Records of storage vessel requirements 10 $0 1 10 0 0 0 0 $0 $0 0 b,k

5) Records of equipment leak requirements 25 $0 1 25 0 0 0 0 $0 $0 0 b,k

6) Records of heat exchanger requirements 10 $0 1 10 0 0 0 0 $0 $0 0 b,k

7) Records of other emission sources requirements 10 $0 1 10 0 0 0 0 $0 $0 0 b,k

E. Personnel Training Incl. in 3.B 

F. Time for Audits N/A

Recordkeeping Subtotal 0 0 0 $0 $0 0

TOTAL: 343 17 34 $37,309 $566,652 10

Total Hours Labor Non-Labor Total

Summary of Respondent Burden 394 $37,309 $566,652 $603,962

Initial Capital and Startup $128,688

 $566,652

FOOTNOTES

a One-time only costs.

b Cost incurred by a facility regardless of the number of affected units at the plant.

c 2 area sources in affected source category

d 2 area sources are expected to perform testing for process vents. 

e 2 area sources expected to perform testing for resins

f Estimated 1 uncontrolled stream and 1 wastewater stripper per facility. 1 wastewater stripper outlet is expected to require monthly testing; 1 uncontrolled stream will require annual testing (per facility).

g All heat exchnager testing and monitoring costs assumed to be incurred annually. 4 heat exchangers at 2 area sources. 

h

i process vent testing is an annual occurrence, therefore no additional costs are expected in additional to the initial testing requirement. 

j Hours for affirmative defense are shown only for illustration and are not included in the total burden estimate

k Annual cost. Annual costs are not incurred until the second year of operation.

l Reporting subtotal does not include capital costs for PRD monitoring system. 

Annualized Capital/Start-up and O & M

for Existing Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 1

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements 

Footnotes

Non-Labor costs technically include labor to perform LDAR testing in addition to monitoring equipment and maintenance materials. Respondent hours are an estimation of the additional reporting required by the final rule. 
(A) (B) (C) (D) (E) (F) (G) (H)

Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Total 

Hours per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor Responses

Occurrence Per Per Respondent Per Year Per Year Per Year Per Year Per Year Costs Per Year

(Technical Occurrence Respondent Per Year Per Year

Burden Item hours) Per Year (C=A x C (D x E) (F x 0.05) (F x 0.1)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read and Understand Rule Requirements 25 $100 1 25 0 0 0 0 $0 $0 0 a,b,c

B. Required Activities

1) Initial performance test, sampling, and report

a) Process Vents 32 $43,198 1 32 0 0 0 0 $0 $0 0 a,d

b) Resins 2 $1,803 1 2 0 0 0 0 $0 $0 0 a,e

c) wastewater 2 $491 1 2 0 0 0 0 $0 $0 0 a,f

d) heat exchangers $0 0 0 0 0 0 0 $0 $0 0 g -

e) equipment leaks 2 $177,360 1 2 0 0 0 0 $0 $0 0 h

2) Periodic performance test, sampling, and report

a) Process Vents 6.4 $8,640 1 6.4 2 13 1 1 $1,392 $17,279 0 i

b) Resins 1 $601 12 12 2 24 1 2 $2,611 $14,424 0 e

c) wastewater 1 $491 12 12 2 24 1 2 $2,611 $11,772 0 f

d) uncontrolled wastewater 1 $491 1 1 2 2 0 0 $218 $981 0 f

e) heat exchangers 1 $0 12 12 4 48 2 5 $5,221 $0 0 g

f) equipment leaks 1 $16,105 1 1 2 2 0 0 $218 $32,210 0 h

3) Establish operating parameters and monitoring plan

a) Process Vents 3.5 $0 1 3.5 0 0 0 0 $0 $0 0 a,b,c

4) Continuous parameter monitoring

a) Initial capital costs (PRD Electronic Monitor) 0 $64,244 1 0 0 0 0 0 $0 $0 0 a,b

b) Annualized capital and O&M costs (PRD Electronic Monitor) 11 $31,772 1 11 2 22 1 2 $2,393 $63,544 0 b

C. Create Information Incl. in 3.B

D. Gather Information Incl. in 3.E

E. Report Preparation

1) Initial Notification 5 $0 1 5 0 0 0 0 $0 $0 0 a,b

2) Batch precompliance report 5 $0 1 5 0 0 0 0 $0 $0 0 a,b

3) Notification of performance test with test plan 10 $0 1 10 0 0 0 0 $0 $0 0 a,b

4) Notification of compliance status 20 $0 1 20 0 0 0 0 $0 $0 0 a,b

5) Compliance report 25 $0 1 25 2 50 3 5 $5,439 $0 2 b,k

6) Notice of inspection 5 $0 1 5 2 10 1 1 $1,088 $0 2 b,k

7) Affirmative defense 18 $0 1 18 0 18 12 0 $0 $0 0 j

ReportingSubtotal 195 10 19 $21,189 $140,210 4 l

4. Recordkeeping Requirements 

A. Read Instructions Incl. in 3.A 

B. Implement Activities N/A

C. Develop Record System N/A

D. Record Information

1) Records of process vent requirements 10 $0 1 10 2 20 1 2 $2,175 $0 0 b,k

2) Records of resin stripper requirements 15 $0 1 15 2 30 2 3 $3,263 $0 0 b,k

3) Records wastewater requirements 15 $0 1 15 2 30 2 3 $3,263 $0 0 b,k

4) Records of storage vessel requirements 10 $0 1 10 2 20 1 2 $2,175 $0 0 b,k

5) Records of equipment leak requirements 25 $0 1 25 2 50 3 5 $5,439 $0 0 b,k

6) Records of heat exchanger requirements 10 $0 1 10 2 20 1 2 $2,175 $0 0 b,k

7) Records of other emission sources requirements 10 $0 1 10 2 20 1 2 $2,175 $0 0 b,k

E. Personnel Training Incl. in 3.B 

F. Time for Audits N/A

Recordkeeping Subtotal 190 9.5 19 $20,667 $0 0

TOTAL: 385 19 38 $41,856 $140,210 4

Total Hours Labor Non-Labor Total

Summary of Respondent Burden 443 $41,856 $140,210 $182,066

Initial Capital and Startup $0

 $140,210

FOOTNOTES

a One-time only costs.

b Cost incurred by a facility regardless of the number of affected units at the plant.

c 2 area sources in affected source category

d 2 area sources are expected to perform testing for process vents. 

e 2 area sources expected to perform testing for resins

f Estimated 1 uncontrolled stream and 1 wastewater stripper per facility. 1 wastewater stripper outlet is expected to require monthly testing; 1 uncontrolled stream will require annual testing (per facility).

g All heat exchnager testing and monitoring costs assumed to be incurred annually. 4 heat exchangers at 2 area sources. 

h

i process vent testing is an annual occurrence, therefore no additional costs are expected in additional to the initial testing requirement. 

j Hours for affirmative defense are shown only for illustration and are not included in the total burden estimate

k Annual cost. Annual costs are not incurred until the second year of operation.

l Reporting subtotal does not include capital costs for PRD monitoring system. 

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

for Existing Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 2

Footnotes

Annualized Capital/Start-up and O & M

Non-Labor costs technically include labor to perform LDAR testing in addition to monitoring equipment and maintenance materials. Respondent hours are an estimation of the additional reporting required by the final rule. 
(A) (B) (C) (D) (E) (F) (G) (H)

Respondent Non-Labor Number of Hours Number of Technical Management Clerical Total Total Total 

Hours per Costs Occurrences Per Respondents Hours Hours Hours Labor Costs Non-Labor Responses

Occurrence Per Per Respondent Per Year Per Year Per Year Per Year Per Year Costs Per Year

(Technical Occurrence Respondent Per Year Per Year

Burden Item hours) Per Year (C=A x C (D x E) (F x 0.05) (F x 0.1)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read and Understand Rule Requirements 25 $100 1 25 0 0 0 0 $0 $0 0 a,b,c

B. Required Activities

1) Initial performance test, sampling, and report

a) Process Vents 32 $43,198 1 32 0 0 0 0 $0 $0 0 a,d

b) Resins 2 $1,803 1 2 0 0 0 0 $0 $0 0 a,e

c) wastewater 2 $491 1 2 0 0 0 0 $0 $0 0 a,f

d) heat exchangers $0 0 0 0 0 0 0 $0 $0 0 g -

e) equipment leaks 2 $177,360 1 2 0 0 0 0 $0 $0 0 h

2) Periodic performance test, sampling, and report

a) Process Vents 6.4 $8,640 1 6.4 2 13 1 1 $1,392 $17,279 0 i

b) Resins 1 $601 12 12 2 24 1 2 $2,611 $14,424 0 e

c) wastewater 1 $491 12 12 2 24 1 2 $2,611 $11,772 0 f

d) uncontrolled wastewater 1 $491 1 1 2 2 0 0 $218 $981 0 f

e) heat exchangers 1 $0 12 12 4 48 2 5 $5,221 $0 0 g

f) equipment leaks 1 $16,105 1 1 2 2 0 0 $218 $32,210 0 h

3) Establish operating parameters and monitoring plan

a) Process Vents 3.5 $0 1 3.5 0 0 0 0 $0 $0 0 a,b,c

4) Continuous parameter monitoring

a) Initial capital costs (PRD Electronic Monitor) 0 $64,244 1 0 0 0 0 0 $0 $0 0 a,b

b) Annualized capital and O&M costs (PRD Electronic Monitor) 11 $31,772 1 11 2 22 1 2 $2,393 $63,544 0 b

C. Create Information Incl. in 3.B

D. Gather Information Incl. in 3.E

E. Report Preparation

1) Initial Notification 5 $0 1 5 0 0 0 0 $0 $0 0 a,b

2) Batch precompliance report 5 $0 1 5 0 0 0 0 $0 $0 0 a,b

3) Notification of performance test with test plan 10 $0 1 10 0 0 0 0 $0 $0 0 a,b

4) Notification of compliance status 20 $0 1 20 0 0 0 0 $0 $0 0 a,b

5) Compliance report 25 $0 1 25 2 50 3 5 $5,439 $0 2 b,k

6) Notice of inspection 5 $0 1 5 2 10 1 1 $1,088 $0 2 b,k

7) Affirmative defense 18 $0 1 18 0 18 12 0 $0 $0 0 j

ReportingSubtotal 195 10 19 $21,189 $140,210 4 l

4. Recordkeeping Requirements 

A. Read Instructions Incl. in 3.A 

B. Implement Activities N/A

C. Develop Record System N/A

D. Record Information

1) Records of process vent requirements 10 $0 1 10 2 20 1 2 $2,175 $0 0 b,k

2) Records of resin stripper requirements 15 $0 1 15 2 30 2 3 $3,263 $0 0 b,k

3) Records wastewater requirements 15 $0 1 15 2 30 2 3 $3,263 $0 0 b,k

4) Records of storage vessel requirements 10 $0 1 10 2 20 1 2 $2,175 $0 0 b,k

5) Records of equipment leak requirements 25 $0 1 25 2 50 3 5 $5,439 $0 0 b,k

6) Records of heat exchanger requirements 10 $0 1 10 2 20 1 2 $2,175 $0 0 b,k

7) Records of other emission sources requirements 10 $0 1 10 2 20 1 2 $2,175 $0 0 b,k

E. Personnel Training Incl. in 3.B 

F. Time for Audits N/A

Recordkeeping Subtotal 190 9.5 19 $20,667 $0 0

TOTAL: 385 19 38 $41,856 $140,210 4

Total Hours Labor Non-Labor Total

Summary of Respondent Burden 443 $41,856 $140,210 $182,066

Initial Capital and Startup $0

 $140,210

FOOTNOTES

a One-time only costs.

b Cost incurred by a facility regardless of the number of affected units at the plant.

c 2 area sources in affected source category

d 2 area sources are expected to perform testing for process vents. 

e 2 area sources expected to perform testing for resins

f Estimated 1 uncontrolled stream and 1 wastewater stripper per facility. 1 wastewater stripper outlet is expected to require monthly testing; 1 uncontrolled stream will require annual testing (per facility).

g All heat exchnager testing and monitoring costs assumed to be incurred annually. 4 heat exchangers at 2 area sources. 

h

i process vent testing is an annual occurrence, therefore no additional costs are expected in additional to the initial testing requirement. 

j Hours for affirmative defense are shown only for illustration and are not included in the total burden estimate

k Annual cost. Annual costs are not incurred until the second year of operation.

l Reporting subtotal does not include capital costs for PRD monitoring system. 

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements

for Existing Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 3

Footnotes

Annualized Capital/Start-up and O & M

Non-Labor costs technically include labor to perform LDAR testing in addition to monitoring equipment and maintenance materials. Respondent hours are an estimation of the additional reporting required by the final rule. 
Year Technical Hours

Management 

Hours Clerical Hours Total Hours Labor Costs

Non-Labor 

(Annualized 

Capital/Startup and 

O&M) Costs Tota

1 343 17 34 394 $37,309 $566,652 $602 385 19 38 443 $41,856 $140,210 $183 385 19 38 443 $41,856 $140,210 $18

Total 1,113 56 111 1,279 $121,022 $847,073 $96

Average 371 19 37 426 $40,341 $282,358 $32

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requireme

Existing Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units
18

ATTACHMENT 3 

 TABLES 5, 6, 7, and 8 

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

Reporting Requirements of the MACT Floor for Existing Sources: 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 Units 
(B) (C) (D) (E) 

EPA Hours 

Per 

Occurrence

Tech Hours Per 

Year (C=AxB)

Management 

Hours Per Year 

(D=Cx0.05)

Clerical Hou

Per Year 

(E=Cx0.1)

1. Applications2. Read and Understand Rule Requirements 10 16 160 8 16 3. Required Activities

A. 0 b 48 19 1 2 B. Excess emissions -- Enforcement Activities 0 d 24 0 0 0 C. Create InformationD. Gather InformationE. Report Reviews

1) Review initial notification 2 3 6 0 1 2) Review batch precompliance report 2 5 10 1 1 3) Review notification of performance test 2 10 20 1 2 4) Review notification of compliance status 2 40 80 4 8 5) Review compliance report 0 20 0 0 0 6) Review notice of inspection 2 3 6 0 1 7) Review affirmative defense 0 10 0 0 0 

F. Prepare annual summary report 1 c 8 8 0 1 

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = $881 per trip 

TOTAL 309 15 31 

FOOTNOTES

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

c Using four hours per state to write annual summary report.

d Assume no emissions exceedances

Observe initial performance tests

not applicablenot applicable

Table 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requ

Existing Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 1 

(A)

not applicable

Number of 

Occurrences Per 

Burden Item Year
(B) (C) (D) (E) 

EPA Hours 

Per 

Occurrence

Tech Hours Per 

Year (C=AxB)

Management 

Hours Per Year 

(D=Cx0.05)

Clerical Hou

Per Year 

(E=Cx0.1)

1. Applications2. Read and Understand Rule Requirements 0 16 0 0 0 3. Required Activities

A. 0 b 48 0 0 0 B. Excess emissions -- Enforcement Activities 0 d 24 0 0 0 C. Create InformationD. Gather InformationE. Report Reviews

1) Review initial notification 0 3 0 0 0 2) Review batch precompliance report 0 5 0 0 0 3) Review notification of performance test 0 10 0 0 0 4) Review notification of compliance status 0 40 0 0 0 5) Review compliance report 2 20 40 2 4 6) Review notice of inspection 2 3 6 0 1 7) Review affirmative defense 0 10 0 0 0 

F. Prepare annual summary report 1 c 8 8 0 1 

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = n/a per trip 

TOTAL 54 3 5 

FOOTNOTES

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

c Using four hours per state to write annual summary report.

d Assume no emissions exceedances

not applicablenot applicable

Table 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requ

Existing Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 2 

(A)

Burden Item

Number of 

Occurrences Per 

Year

not applicable

Observe initial performance tests
(B) (C) (D) (E) 

EPA Hours 

Per 

Occurrence

Tech Hours Per 

Year (C=AxB)

Management 

Hours Per Year 

(D=Cx0.05)

Clerical Hou

Per Year 

(E=Cx0.1)

1. Applications2. Read and Understand Rule Requirements 0 16 0 0 0 3. Required Activities

A. 0 b 48 0 0 0 B. Excess emissions -- Enforcement Activities 0 d 24 0 0 0 C. Create InformationD. Gather InformationE. Report Reviews

1) Review initial notification 0 3 0 0 0 2) Review batch precompliance report 0 5 0 0 0 3) Review notification of performance test 0 10 0 0 0 4) Review notification of compliance status 0 40 0 0 0 5) Review compliance report 2 20 40 2 4 6) Review notice of inspection 2 3 6 0 1 7) Review affirmative defense 0 10 0 0 0 

F. Prepare annual summary report 1 c 8 8 0 1 

4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) = n/a per trip 

TOTAL 54 3 5 

FOOTNOTES

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

c Using four hours per state to write annual summary report.

d Assume no emissions exceedances

not applicablenot applicable

Table 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requ

Existing Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 3 

(A)

Burden Item

Number of 

Occurrences Per 

Year

not applicable

Observe initial performance tests
Year Technical Hours

Management 

Hours Clerical Hours Total Hours Labor Costs

Non-Lab

Costs 

1 309 15 31 356 $16,376 $0 2 54 3 5 62 $2,798 $0 3 54 3 5 62 $2,798 $0 

Total 417 21 42 480 $21,973 $0 

Average 139 7 14 160 $7,324 $0 

Table 8 - Summary of Annual Designated Administrator Burden and Cost of Recordkeeping 

Requirements for Existing Area Sources: Polyvinyl Chloride and Copolymer Manufactu