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 Pollutants (NESHAP) for Polyvinyl 

Chloride and Copolymers (PVC) Production, 40 CFR part 63, subpart HHHHHHH, referred to 

as the PVC NESHAP. In 2002, the Environmental Protection Agency (EPA) promulgated 

national emission standards for hazardous air pollutants 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 Act (CAA) section 112. This information 

collection request (ICR) documents the associated recordkeeping and reporting for the proposed 

PVC NESHAP. 

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

following promulgation of the proposed PVC 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 proposed PVC 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 

NESHAP. Respondents are owners or operators of existing PVC production facilities. 

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

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 
2

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 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. 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 establish standards of 

performance for each category or subcategory of major sources and area sources of hazardous air 

pollutants (HAP). These standards are applicable to new or existing sources of HAP and require 

the maximum degree of emission reduction. In addition, CAA section 114(a) states that the 

Administrator may require any owner/operator subject to any requirement of this Act to: 

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require. 

In the Administrator's judgment, HAP emissions from PVC production facilities cause or 

contribute to air pollution that may reasonably be anticipated 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 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 
3

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 HHHHHHH.

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 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, 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 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 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. 
4

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 PVC production facilities. The PVC NESHAP 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). 
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 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, wastewater sampling, resin sampling, leak detection monitoring, heat 

exchanger 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 HAP, HCl, 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. Annual performance tests are also required 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 testing is also required. Monthly 

monitoring is also required for heat exchangers 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 
6

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; resin 

stripper and wastewater testing 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 exchangers. 

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. 
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 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 HAP, HCl, 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. 

Every year a 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
8

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 3,200 hours. The 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 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 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 this 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 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. 

EPA considered whether there might be any burden associated with the notification, 

recordkeeping and reporting requirements associated with the assertion of the affirmative 

defense. While recognizing that any such burdens are only incurred 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 requirement 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 measures to prevent the discharge.” 

The owners or operators must, within 10 days of any release from a pressure relief valve or a 

reactor manual vent valve, submit a report to the Administrator. The report must include the 

“nature and cause of discharge, the date and time of the discharge, the approximate total vinyl 

chloride loss during the discharge, the method used for determining the vinyl chloride loss, the 

action that was taken to prevent the discharge, and measures 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 additional costs for sources that choose to take 

advantage of the affirmative defense for malfunctions since it is already required for compliance 

with the rule. However, there may be additional malfunctions 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 magnitude 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 administrative adjustment to this ICR 

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

assertion of the affirmative defense might entail. 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 EPA. 

EPA provides this illustrative estimate of this burden because these costs are only incurred if 
10

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 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 

$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 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, 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 will 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 to average 63 hours per response. 

The total annual capital/startup and O&M costs to the regulated 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 treats these burden estimates as new 

burdens and the burden is not compared to previous burden estimates made for the vacated rule. 

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), 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. 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 63 hours per response. Burden means total time, effort, or financial resources 
12

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, 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. 
13

PART B OF THE SUPPORTING STATEMENT 

This section is not applicable because statistical methods 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 comply 

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 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 
Attachment 2 

(A) (B) (C) (D) (E) (F) (G)

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 B) (CXD) (E x 0.05) (E x 0.1)

1. Applications N/A2. Surveys and Studies N/A3. Reporting Requirements

A. Read and Understand Rule Requirements 25 $100 1 25 17 425 21 43 $46,229 $1,700 0 a,bB. Required Activities

1) 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 monitoring

a) Initial capital costs (Fabric Filters) 0 $17,100 1 0 5 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 Electronic Monitor) 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,e

C. Create Information Incl. in 3.BD. Gather Information Incl. in 3.EE. Report Preparation

1) Initial Notification 5 $0 1 5 17 85 4 9 $9,246 $0 172) Batch precompliance report 5 $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 status 20 $0 1 20 17 340 17 34 $36,983 $0 17 b5) Compliance report 25 $0 1 25 0 0 0 0 $0 $0 06) Notice of inspection 5 $0 1 5 17 85 4 9 $9,246 $0 177) Affirmative defense 18 $0 1 18 0 18 12 0 $0 $0 0 g

ReportingSubtotal 2,718 136 272 $295,647 $2,444,820 854. Recordkeeping Requirements

A. Read Instructions Incl. in 3.A B. Implement Activities N/AC. Develop Record System N/AD. Record Information

1) 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 0 0 $0 $0 04) Records of equipment leak requirements 25 $0 1 25 0 0 0 0 $0 $0 05) Records of heat exchanger requirements 10 $0 1 10 0 0 0 0 $0 $0 0

E. Personnel Training Incl. in 3.B 

F. Time for Audits N/A

Recordkeeping Subtotal 0 0 0 $0 $0 0

TOTAL: 2,718 136 272 $295,647 $2,444,820 85

Total Hours Labor Non-Labor Total

Summary of Respondent Burden 3,126 $295,647 $2,444,820 $2,740,467Initial Capital and Startup $3,298,721

 $2,444,820

FOOTNOTES

a 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 until the 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 Includes 11 months testing for wastewater and resin to 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 estimate

Annualized Capital/Start-up and O & M

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

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

Footnotes
Attachment 2 

(A) (B) (C) (D) (E) (F) (G)

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 B) (CXD) (E x 0.05) (E x 0.1)

1. Applications N/A2. Surveys and Studies N/A3. Reporting Requirements

A. Read and Understand Rule Requirements 25 $100 1 25 0 0 0 0 $0 $0 0 a,bB. Required Activities

1) 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 monitoring

a) 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 Electronic Monitor) 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 0 0 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,e

C. Create Information Incl. in 3.BD. Gather Information Incl. in 3.EE. Report Preparation

1) Initial Notification 5 $0 1 5 0 0 0 0 $0 $0 02) Batch precompliance report 5 $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 status 20 $0 1 20 0 0 0 0 $0 $0 0 b5) Compliance report 25 $0 1 25 17 425 21 43 $46,229 $0 176) Notice of inspection 5 $0 1 5 17 85 4 9 $9,246 $0 177) Affirmative defense 18 $0 1 18 0 18 12 0 $0 $0 0 f

ReportingSubtotal 1,613 81 161 $175,452 $2,469,800 344. Recordkeeping Requirements

A. Read Instructions Incl. in 3.A B. Implement Activities N/AC. Develop Record System N/AD. Record Information

1) Records of process vent requirements 10 $0 1 10 17 170 9 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 0

E. Personnel Training Incl. in 3.B 

F. Time for Audits N/A

Recordkeeping Subtotal 1190 59.5 119 $129,441 $0 0

TOTAL: 2,803 140 280 $304,893 $2,469,800 34

Total Hours Labor Non-Labor Total

Summary of Respondent Burden 3,223 $304,893 $2,469,800 $2,774,693

Initial Capital and Startup $0

 $2,469,800

FOOTNOTES

a 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 until the 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 estimate

Annualized Capital/Start-up and O & M

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

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

Footnotes
Attachment 2 

(A) (B) (C) (D) (E) (F) (G)

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 B) (CXD) (E x 0.05) (E x 0.1)

1. Applications N/A2. Surveys and Studies N/A3. Reporting Requirements

A. Read and Understand Rule Requirements 25 $100 1 25 0 0 0 0 $0 $0 0 a,bB. Required Activities

1) 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 monitoring

a) 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 Electronic Monitor) 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 0 0 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,e

C. Create Information Incl. in 3.BD. Gather Information Incl. in 3.EE. Report Preparation

1) Initial Notification 5 $0 1 5 0 0 0 0 $0 $0 02) Batch precompliance report 5 $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 status 20 $0 1 20 0 0 0 0 $0 $0 0 b5) Compliance report 25 $0 1 25 17 425 21 43 $46,229 $0 176) Notice of inspection 5 $0 1 5 17 85 4 9 $9,246 $0 177) Affirmative defense 18 $0 1 18 0 18 12 0 $0 $0 0 f

ReportingSubtotal 1,613 81 161 $175,452 $2,469,800 344. Recordkeeping Requirements

A. Read Instructions Incl. in 3.A B. Implement Activities N/AC. Develop Record System N/AD. Record Information

1) Records of process vent requirements 10 $0 1 10 17 170 9 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 0

E. Personnel Training Incl. in 3.B 

F. Time for Audits N/A

Recordkeeping Subtotal 1190 59.5 119 $129,441 $0 0

TOTAL: 2,803 140 280 $304,893 $2,469,800 34

Total Hours Labor Non-Labor Total

Summary of Respondent Burden 3,223 $304,893 $2,469,800 $2,774,693Initial Capital and Startup $0

 $2,469,800

FOOTNOTES

a 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 until the 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 estimate

Annualized Capital/Start-up and O & M

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

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

Footnotes
Attachment 2 

Year

Technical 

Hours

Management 

Hours Clerical Hours Total Hours Labor Costs

Non-Labor 

(Annualized 

Capital/Startup and 

O&M) Costs Total 

1 2,718 136 272 3,126 $295,647 $2,444,820 $2,742 2,803 140 280 3,223 $304,893 $2,469,800 $2,773 2,803 140 280 3,223 $304,893 $2,469,800 $2,77

Total 8,324 416 832 9,573 $905,432 $7,384,420 $8,28

Average 2,775 139 277 3,191 $301,811 $2,461,473 $2,76

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

of the MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Unit
21

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 
Attachment 3

(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. 3 b 48 163 8 16 B. Excess emissions -- Enforcement Activities 2 d 24 41 2 4 

C. Create InformationD. Gather InformationE. Report Reviews

1) Review initial notification 17 3 51 3 5 2) Review batch precompliance report 17 5 85 4 9 3) Review notification of performance test 17 10 170 9 17 4) Review notification of compliance status 17 40 680 34 68 5) Review compliance report 0 20 0 0 0 6) Review notice of inspection 17 3 51 3 5 7) Review affirmative defense 0 10 0 0 0 

F. Prepare annual summary report 1 c 200 200 10 20 

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

TOTAL 1601 80 160 

FOOTNOTES

a 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 summary report.

d Assume 10% have emission exceedances.

Observe initial performance tests

not applicablenot applicable

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

the MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - 

(A)

not applicable

Number of 

Occurrences Per 

Burden Item Year
Attachment 3

(B) (C) (D) (E) 

EPA Hours Per 

Occurrence

Tech Hours Per 

Year (C=AxB)

Management 

Hours Per Year 

(D=Cx0.05)

Clerical Hour

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 2 d 24 41 2 4 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 17 20 340 17 34 6) Review notice of inspection 17 3 51 3 5 7) Review affirmative defense 0 10 0 0 0 

F. Prepare annual summary report 1 c 200 200 10 20 

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 632 32 63 

FOOTNOTES

a 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 summary report.

d Assume 10% have emission exceedances.

Observe initial performance tests

not applicablenot applicable

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

the MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - 

(A)

not applicable

Number of 

Occurrences Per 

Burden Item Year
Attachment 3

(B) (C) (D) (E) 

EPA Hours 

Per 

Occurrence

Tech Hours Per 

Year (C=AxB)

Management 

Hours Per Year 

(D=Cx0.05)

Clerical Hours 

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 2 d 24 41 2 4 C. Create InformationD. Gather InformationE. Report Reviews

1) Review initial notification 0 3 0 0 0 2) Review batch precompliance report 53) 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 17 20 340 17 34 6) Review notice of inspection 17 3 51 3 5 7) Review affirmative defense 0 10 0 0 0 

F. Prepare annual summary report 1 c 200 200 10 20 

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 632 32 63 

FOOTNOTES

a 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 summary report.

d Assume 10% have emission exceedances.

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

MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Ye

(A)

not applicable

Number of 

Occurrences Per 

Burden Item Year

Observe initial performance tests

not applicablenot applicable
Attachment 3

Year

Technical 

Hours

Management 

Hours Clerical Hours Total Hours Labor Costs

Non-Labor 

Costs 

1 1,601 80 160 1,841 $85,964 $0 2 632 32 63 727 $32,741 $0 3 632 32 63 727 $32,741 $0 

Total 2,865 143 286 3,294 $151,447 $0 

Average 955 48 95 1,098 $50,482 $0 

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

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

Manufacturing Units