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 D DDDDD)

1(b) Short Characterization/Abstract

This supporting statement addresses information collection activities that will be imposed by the National Emission Standards for Hazardous Air Pol lutants (NESHAP) for Polyvinyl Chloride and Copolymers (PVC) Production Area Sources, 40 C FR part 63, subpart DDDDDD, referred to as the PVC NESHAP for area sources. In 2007, t he 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 requi red area sources to meet the requirements imposed by the NESHAP for PVC Produc tion, 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 prop osal 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 are a source PVC production facilities. The final 40 CFR part 63 subpart HHHHHHH will r egulate 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 collectio n 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 c omments.

The ICR prepared for the May 20, 2011 proposed 40 CFR part 63 subpar t 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 so urce 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 c onducted in the first three years following promulgation of the proposed PVC Area Source NE SHAP. These activities include reading the rule, resin sampling, performance testing, e stablishing operating parameters, andmonitoring, recordkeeping, and reporting requirements. We rea lize 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 S ource NESHAP.

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

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

The requirements described below are the minimum requir ements established by the PVC Area Source NESHAP. Although the Designated Administrat or may choose to impose more stringent requirements, it is assumed for this burden esti mate 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 At tachment 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 N ESHAP 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 a t least 30 HAP which, as the result of emissions from area sources, pose the greate st 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). Specifica lly, 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) requi res EPA to list sufficient categories or subcategories of area sources to ensure t hat 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 promulgat e standards or requirements for area sources "which provide for the use o f generally available controltechnologies or management practices (“GACT”) by such so urces to reduce emissions of

hazardous air pollutants." Additional information on GAC T 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 commerc ially available and appropriate for application by the sources in the categor y considering economic impacts and the technical capabilities of the firms to oper ate and maintain the emissions control systems.

Consistent with the legislative history, we can cons ider 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 ma y reasonably be anticipated to endanger public health or welfare. Therefore, the NESHAP was prom ulgated for this source category in 2007 at 40 CFR part 63, subpart DDDDDD and is being revised for the current rulemaki ng.

2(b) Practical Utility/Users of the Data

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

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

3. Nonduplication, Consultations, and Other Collection Criter ia

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 info rmation is sent directly to the appropriate EPA regional office. Otherwise, the inform ation 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 sta te or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplicationexists.

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

A public notice of this collection was provided in the Fede ral 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 o n 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 complianc e requirements in the final subpart DDDDDD in response to these comments and to min imize the burden on affected entities. Significant items that have reduced the burden on affected entities include removal of the continuous parametric monitoring requirements for res in strippers and wastewater strippers, reduced sampling and analysis frequency for process wastewater streams that do not require treatment, and consolidation of some reporting requireme nts. 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 no tification, initial and periodic testing, continuous operating parameter monitoring, a notific ation of compliance status, and compliance reports. The frequency of these activities w as chosen by EPA as the period that will provide an adequate margin of assurance that affected facil ities will not operate for extended periods in violation of the standards.

During the initial performance tests for vinyl chloride, tota l 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 par ameter. Thereafter, the owner or operator must continuously monitor the operating parameters . In addition, monthly wastewater and resin sampling must also be performed. Owners and opera tors must also conduct a leak detection and repair program and must operate a vinyl chloride m onitoring system.

Although continuous monitoring of operating parameters cannot provide a direct measurement of emissions, it is less expensive than con tinuous emissions monitoring systems (CEMS), and the information provided can be used to ensure t hat the air pollution control devices are operating properly. This information assures 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 inf ormation and data parameters so that any potential problems can be identified in a tim ely fashion.

3(e) General GuidelinesWith the exception of requiring records to be maintained for more than three years, none

of the guidelines in 5 CFR 1320.5 are being exceeded. This rule requires all records to be maintained at the source for a period of five years. In 40 CFR part 63, subpart A, "General Provisions for National Emission Standards for Hazardous Air Pollutants for Source Categories," owners or operators of facilities are required to keep an d maintain records for a period of five years. These records must be kept on file for use, if needed, by the regulating authority to ensure that the plant personnel are operating and maintai ning control equipment properly. The title V permit programs also require records to be retaine d for five years. These records must be kept on file for use, if needed, by the regulating authorit y to ensure that the plant personnel are operating and maintaining control equipment properly.

3(f) Confidentiality

All information submitted to the Agency for which a clai m of confidentiality is made will be safeguarded according to the Agency policies set forth i n 40 CFR 2, subpart B -- Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976, amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive questions.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS Codes

The respondents to the recordkeeping and reporting requirements are owners or operators of new or existing area source PVC production facilities. The PVC NESHAP for area sources affects any industry using a polyvinyl chloride and copolymer s production process unit as defined in the regulation. This includes, but is not limit ed to, North American Industry Classification System (NAICS) Code 325211 (Facilities tha t 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 repor ting requirements of this regulation.(ii) Respondent Activities

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

(iii) Summary of Requirements

The information collection activities in this ICR include the following: reading the rule, performance tests, process wastewater sampling, resin s ampling, leak detection monitoring, heat exchange system monitoring, pressure relief device (PRD) mo nitoring, operating parameter monitoring, preparation of a site-specific monitoring plan , one-time and periodic reports, and the maintenance of records. Some information collection a ctivities included in the PVC NESHAP may occur within the first three years, and are present ed in this burden estimate, but may not occur until four or five years following promulgation of t he proposed standards for some affected sources. To be conservative in our estimate, the burden for these items is included in this ICR.

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

A notification of performance test must be submitted, an d a site-specific test plan written for the performance test along with a monitoring plan. The regulation requires an initial performance test for the following pollutants, vinyl chloride , total 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 o wner or operator must continuously monitor the operating parameters. Performance tests are also re quired for vinyl chloride, total hydrocarbons or total organic HAP, and CDD/CDF every five y ears.

For stripped resin and process wastewater streams, testi ng 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 proces s wastewater streams that require treatment, monthly sampling is required for both vinyl chlor ide 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 oper ator must submit a notification of compliance status that documents the performance tes ts, values for the operating parameters, resin stripper tests, and wastewater tests. This report a lso includes the following additional items: identification of storage vessels, information for equi pment 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 leakdefinition. Other reporting requirements include submittal of a batch pre-compliance report and

notice of inspection.

Owners or operators of PVC production facilities are re quired to keep records of certain parameters and information for a period of five years. Th ese records include the initial performance test and operating parameter values consiste nt 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 st orage 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 Adminis trator. The information will be used to determine that all sources subject to the PVC NES HAP are achieving the requirements.

As an administrative addition to this ICR, EPA is als o including an illustrative estimate of the burden associated with performing a Root Cause Analys is (RCA) associated with affirmative defense of malfunctions if the source elect s to avail themselves to this defense in court. EPA is providing this as an illustrative example of the potential additional administrative burden a source may incur to assert in an affirmative defe nse in response to an action to enforce the standards set forth in the applicable subpart. If a source is in compliance and does not encounter malfunctions that cause a violation of the st andard, EPA does not expect this activity to be routinely performed by a source. Our decision to incl ude this recordkeeping and reporting in the ICR burden is not to assert that EPA assumes l ess than full compliance. EPA cannot estimate whether an affirmative defense would be neces sary for any source or class of sources. It is not an enforceable requirement of compliance.

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

5(a) Agency Activities

A list of Agency activities is provided in section 6(c) a nd in Tables 5 through 8 of Attachment 3.

5(b) Collection Methodology and Management

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

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

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

5(c) Small Entity Flexibility

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

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

5(d) Collection Schedule

In the first three years following promulgation of the PVC NESHAP owners or operators would read the rule and are required to submit an initial noti fication. As discussed earlier, we also anticipate many of the one-time activities, includ ing: initial performance tests (vinyl chloride, total hydrocarbons or total organic HAP, and CDD/C DF), initial resin stripper and wastewater testing, and the notification of complianc e status (including performance tests results and operating parameter values) to occur for many faciliti es 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 o f individual burdens and non-labor costs for the recordkeeping and reporting requireme nts applicable to the industry for each year for the subpart included in this ICR. The indiv idual 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 no t required to respond to, a collection of information unless it displays a currentl y 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 o f which are shown in Tables 1 through 4 of Attachment 2.6(b) Estimating Respondent Costs

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

(i) Estimating Labor Costs

This ICR uses the following labor rates:

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

These rates are from the United States Department of L abor, Bureau of Labor Statistics, September 2010, “Table 2. Civilian Workers, by occupational and i ndustry group.” The rates are from column 1, Total compensation. The rates have been i ncreased by 110 percent to account for the benefit packages available to those employed by privat e industry.

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

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

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

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

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

(A) Unit Type (B)

Number of Respondents (facilities) (C)

Total Capital/Startup Costs (D)

Total Annualized Capital/Start-up and O&M over 3
years (E)

Average Annual Capital/Startup and O&M Costs

PVC Facilities Total 2 $130,000 $850,000 $280,000

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

The total annualized capital/startup and O&M costs for thi s ICR are $850 thousand, or an average of $280 thousand per year; columns D and E. These ar e recordkeeping costs.

(iv) Potential Burden under Affirmative DefenseWhen 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 malfu nctions is available to a source if it can demonstrate that certain criteria and requirements are satisfied. The criteria ensure that the affirmative defense is available only where the event that causes an exceedance of the emission limit meets the narrow definition of malfunction in 40 C .F.R. 63.2 (sudden, infrequent, not reasonable preventable and not caused by poor maintenance an d or careless operation) and where the source took necessary actions to minimize emission s. In addition, the source must meet certain notification and reporting requirements. For ex ample, the source must prepare a written root cause analysis and submit a written report to the Adm inistrator documenting that it has met the conditions and requirements for assertion of the af firmative defense.

To provide the public with an estimate of the relative mag nitude of the burden associated with an assertion of the affirmative defense position adopted by a source, the EPA provides an administrative adjustment to this ICR that shows the notification, recordkeeping and reporting requirements associated with the assertion of the aff irmative defense might entail. The EPA’s estimate for the required notification, reports and recor ds, 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 surroun ding a malfunction that has caused an exceedance of an emission limit. The estimate al so includes time to produce and retain the record and reports for submission to the EPA. The EPA pro vides this illustrative estimate of this burden because these costs are only incurred if there has be en 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 enforce ment 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 collec ted information.

The average annual agency cost during the three years of th e 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 Manageme nt (OPM), 2010 General Schedule, which excludes locality rates of pay. The rates have bee n increased by 60 percent to account for overhead and fringe benefit costs. Details on the line item estimates used to calculate these burdens are presented in Tables 5 through 8 of Attachment 3.

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

The total number of respondents is also referred to as th e respondent universe. Based on research, 2 existing facilities will be subject to the standard. No new respondents will become subject. Industry burden is calculated based on the number o f facilities in each subcategory and the anticipated controls and monitoring that each unit wil l most likely utilize to comply with the proposed emissions guidelines.

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 the se estimates may be found in Tables 1 through 4 of Attachment 2. Furthermore, the annual pu blic reporting and recordkeeping burden for this collection of information is estimated t o average 71 hours per response.

The total annual capital/startup and O&M costs to the regul ated 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 Ad ministrator burden hours and costs are presented in Tables 5 through 8 of Attachment 3.

6(f) Reasons for change in burdenAn ICR was not prepared at the proposal stage of this ru lemaking because the burden for

area sources was contained in a separate ICR, which out lined 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 (IC R 0186.12). However, this final rule action requires additional testing, monitoring, reporting, and recordkeeping requirements that are not considered under ICR 0186.12. Theref ore, a new ICR was created to account these additional burden items. This ICR treats t hese burden estimates as new burdens and the burden is not compared to any previous burden estima tes. 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 subpar t 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 mag nitude 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 ad justment to this ICR. The adjustment shows the notification, recordkeeping and repo rting 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 th e burden because these costs are only incurred if the source believes that there has been a vi olation, and chooses to take advantage of the affirmative defense.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this c ollection of information is estimated to be 71 hours per response. Burden means total t ime, effort, or financial resources expended by persons to generate, maintain, retain, or disc lose or provide information to or for a Federal agency. This includes the time needed to review instruc tions; develop, acquire, install, and utilize technology and systems for the purposes of c ollecting, validating, and verifying information, processing and maintaining information, and d isclosing and providing information; adjust the existing ways to comply with any previously app licable instructions and requirements; train personnel to be able to respond to a collection of inf ormation; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentl y valid OMB control number. The OMB Control Numbers for EPA regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

To comment on the agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing res pondent burden, including the use of automated collection techniques, the EPA has establis hed a public docket for this ICR under Docket ID Number EPA-HQ-OAR-2002-0037. An electronic version of the public docketis available at http://www.regulations.gov/ which may be us ed to obtain a copy of the draft

collection of information, submit or view public comments , access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Do cket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is ( 202) 566-1744, and the telephone number for the docket center is (202) 566-1927. Also, you can sen d 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. Plea se 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 meth ods 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 63.11975ATTACHMENT 2

TABLES 1, 2, 3, and 4

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

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

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

Reporting Requirements of the MACT Floor for Existing So urces: Polyvinyl Chloride and Copolymer Manufacturing 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 Ho urs Labor Costs Non-Labor Responses Occurrence Per Per Respondent Per Year Per Year Per Year P er 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 pl an
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 numb er 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 res ins

f Estimated 1 uncontrolled stream and 1 wastewater s tripper per facility. 1 wastewater stripper outlet is expected to require monthly testing; 1 uncontro lled stream will require annual testing (per facili ty).
g All heat exchnager testing and monitoring costs as sumed to be incurred annually. 4 heat exchangers a t 2 area sources.
h

i process vent testing is an annual occurrence, ther efore no additional costs are expected in additiona l to the initial testing requirement.
j Hours for affirmative defense are shown only for i llustration and are not included in the total burde n 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 C opolymer Manufacturing Units - Year 1 Table 1 - Annual Respondent Burden and Cost of Reco rdkeeping and Reporting RequirementsFootnotes

Non-Labor costs technically include labor to perfor m 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 Ho urs Labor Costs Non-Labor Responses Occurrence Per Per Respondent Per Year Per Year Per Year P er 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 pl an
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 numb er 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 res ins

f Estimated 1 uncontrolled stream and 1 wastewater s tripper per facility. 1 wastewater stripper outlet is expected to require monthly testing; 1 uncontro lled stream will require annual testing (per facili ty).
g All heat exchnager testing and monitoring costs as sumed to be incurred annually. 4 heat exchangers a t 2 area sources.
h

i process vent testing is an annual occurrence, ther efore no additional costs are expected in additiona l to the initial testing requirement.
j Hours for affirmative defense are shown only for i llustration and are not included in the total burde n 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 Reco rdkeeping and Reporting Requirements for Existing Area Sources: Polyvinyl Chloride and C opolymer Manufacturing Units - Year 2Footnotes

Annualized Capital/Start-up and O & M

Non-Labor costs technically include labor to perfor m 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 Ho urs Labor Costs Non-Labor Responses Occurrence Per Per Respondent Per Year Per Year Per Year P er 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 pl an
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 numb er 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 res ins

f Estimated 1 uncontrolled stream and 1 wastewater s tripper per facility. 1 wastewater stripper outlet is expected to require monthly testing; 1 uncontro lled stream will require annual testing (per facili ty).
g All heat exchnager testing and monitoring costs as sumed to be incurred annually. 4 heat exchangers a t 2 area sources.
h

i process vent testing is an annual occurrence, ther efore no additional costs are expected in additiona l to the initial testing requirement.
j Hours for affirmative defense are shown only for i llustration and are not included in the total burde n 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 Reco rdkeeping and Reporting Requirements for Existing Area Sources: Polyvinyl Chloride and C opolymer Manufacturing Units - Year 3Footnotes

Annualized Capital/Start-up and O & M

Non-Labor costs technically include labor to perfor m LDAR testing in addition to monitoring equipment and maintenance materials. Respondent hours are an estimation of the additional reporting required by the final rule.YearTechnical HoursManagementHours Clerical Hours Total Hours Labor CostsNon-Labor(AnnualizedCapital/Startup andO&M) Costs Total Costs1 343 17 34 394 $37,309 $566,652 $603,9622 385 19 38 443 $41,856 $140,210 $182,0663 385 19 38 443 $41,856 $140,210 $182,066Total 1,113 56 111 1,279 $121,022 $847,073 $968,094Average 371 19 37 426 $40,341 $282,358 $322,698Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements forExisting Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units18 ATTACHMENT 3

TABLES 5, 6, 7, and 8

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

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

Table 8: Summary of Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting Requirements of the MACT Floor for Existing Sources: Polyvinyl Chloride and Copolymer Manufacturing Uni ts(B) (C) (D) (E) (F)EPA HoursPerOccurrenceTech Hours PerYear (C=AxB)ManagementHours Per Year(D=Cx0.05)Clerical HoursPer Year(E=Cx0.1)EPA Cost PerYear (a,b)1. Applications2. Read and Understand Rule Requirements 10 16 160 8 16 $8,2923. Required ActivitiesA.0 b 48 19 1 2 $995B. Excess emissions -- Enforcement Activities 0 d 24 0 0 0$0C. Create InformationD. Gather InformationE. Report Reviews1) Review initial notification 2 3 6 0 1 $3112) Review batch precompliance report 2 5 10 1 1 $5183) Review notification of performance test 2 10 20 1 2 $1,0364) Review notification of compliance status 2 40 80 4 8 $4,1465) Review compliance report 0 20 0 0 0 $06) Review notice of inspection 2 3 6 0 1 $3117) Review affirmative defense 0 10 0 0 0 $0F. Prepare annual summary report 1 c 8 8 0 1 $4154. Travel expenses: (1 person * 30 hours per year/ 8 hours per day * $75 per diem) + ($600 per roundtrip) = $881 per trip $353TOTAL309 15 31 $16,376FOOTNOTESa 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 summaryreport.d Assume no emissions exceedancesObserve initial performance testsnot applicablenot applicableTable 5 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting RequirementsforExisting Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 1(A)not applicableNumber ofOccurrences PerYearBurden Item(B) (C) (D) (E) (F)EPA HoursPerOccurrenceTech Hours PerYear (C=AxB)ManagementHours Per Year(D=Cx0.05)Clerical HoursPer Year(E=Cx0.1)EPA Cost PerYear (a,b)1. Applications2. Read and Understand Rule Requirements 0 16 0 0 0 $03. Required ActivitiesA.0 b 48 0 0 0 $0B. Excess emissions -- Enforcement Activities 0 d 24 0 0 0$0C. Create InformationD. Gather InformationE. Report Reviews1) Review initial notification 0 3 0 0 0 $02) Review batch precompliance report 0 5 0 0 0 $03) Review notification of performance test 0 10 0 0 0 $04) Review notification of compliance status 0 40 0 0 0 $05) Review compliance report 2 20 40 2 4 $2,0736) Review notice of inspection 2 3 6 0 1 $3117) Review affirmative defense 0 10 0 0 0 $0F. Prepare annual summary report 1 c 8 8 0 1 $4154. Travel expenses: (1 person * 30 hours per year/ 8 hours per day * $75 per diem) + ($600 per roundtrip) = n/a per trip $0TOTAL54 3 5 $2,798FOOTNOTESa 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 summaryreport.d Assume no emissions exceedancesnot applicablenot applicableTable 6 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting RequirementsforExisting Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 2(A)Burden ItemNumber ofOccurrences PerYearnot applicableObserve initial performance tests(B) (C) (D) (E) (F)EPA HoursPerOccurrenceTech Hours PerYear (C=AxB)ManagementHours Per Year(D=Cx0.05)Clerical HoursPer Year(E=Cx0.1)EPA Cost PerYear (a,b)1. Applications2. Read and Understand Rule Requirements 0 16 0 0 0 $03. Required ActivitiesA.0 b 48 0 0 0 $0B. Excess emissions -- Enforcement Activities 0 d 24 0 0 0$0C. Create InformationD. Gather InformationE. Report Reviews1) Review initial notification 0 3 0 0 0 $02) Review batch precompliance report 0 5 0 0 0 $03) Review notification of performance test 0 10 0 0 0 $04) Review notification of compliance status 0 40 0 0 0 $05) Review compliance report 2 20 40 2 4 $2,0736) Review notice of inspection 2 3 6 0 1 $3117) Review affirmative defense 0 10 0 0 0 $0F. Prepare annual summary report 1 c 8 8 0 1 $4154. Travel expenses: (1 person * 30 hours per year/ 8 hours per day * $75 per diem) + ($600 per roundtrip) = n/a per trip $0TOTAL54 3 5 $2,798FOOTNOTESa 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 summaryreport.d Assume no emissions exceedancesnot applicablenot applicableTable 7 - Annual Designated Administrator Burden and Cost of Recordkeeping and Reporting RequirementsforExisting Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units - Year 3(A)Burden ItemNumber ofOccurrences PerYearnot applicableObserve initial performance testsYearTechnical HoursManagementHours Clerical Hours Total Hours Labor CostsNon-LaborCosts Total Costs1 309 15 31 356 $16,376 $0 $16,3762 54 3 5 62 $2,798 $0 $2,7983 54 3 5 62 $2,798 $0 $2,798Total 417 21 42 480 $21,973 $0 $21,973Average 139 7 14 160 $7,324 $0 $7,324Table 8 - Summary of Annual Designated Administrator Burden and Cost of Recordkeeping and ReportingRequirements for Existing Area Sources: Polyvinyl Chloride and Copolymer Manufacturing Units