1

SUPPORTING STATEMENT 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS 

EMISSIONS: GROUP I POLYMERS AND RESINS 

PART A

1.0 Identification of the Information Collection

(a) Title and Number of the Information Collection. 

This information collection request (ICR) is entitled "Reporting and Recordkeeping 

Requirements for National Emission Standards for Hazardous Air Pollutant Emissions: Group I 

Polymers and Resins." The EPA tracking number is 2410.02, and the Office of Management and 

Budget (OMB) number is 2060-0356. 

 (b) Short Characterization. 

 This ICR covers information collection requirements in the final rulemaking that amend 

title 40, chapter I, part 63 of the Code of Federal Regulations (CFR) Subpart U National 

Emission Standards for Hazardous Air Pollutants: Group I Polymers and Resins, hereafter, this 

subpart is referred to as the "Polymers & Resins I NESHAP". Respondents are owners or 

operators subject to the new requirements of the NESHAP, which include an estimated 5 existing 

facilities that produce butyl rubber, epichlorohydrin elastomers, ethylene-propylene rubber, 

neoprene rubber, and nitrile butadiene rubber. Respondents also include owners or operators of 

all 19 existing facilities regulated by the Polymers and Resins I NESHAP who may wish to make 

use of the new affirmative defense provisions in the amendments to the rule. 

 The final standards add emissions limits for the back-end process operations for the butyl 

rubber production, epichlorohydrin elastomers production, neoprene rubber production, and 

nitrile butadiene rubber production categories. The owner or operator is required to calculate 

and record the organic HAP emissions from all back end process operations as well as the mass 

of elastomer product produced. The final rule also revises the MACT standards for front-end 

process vents for the butyl rubber and ethylene propylene rubber source categories adding limits 

for HCl emissions resulting from the combustion of chlorinated organic compounds. The owner 

or operator is required to calculate and record the HCl emissions from the front-end process 
2

vents as well as the mass of elastomer product produced. Information related to these new 

requirements is required to be submitted in the semi-annual reports already required by the 

existing rule. The final rule also adds provisions for facility owners or operators to use if they 

wish to claim an affirmative defense against civil penalties for exceedances of emission 

standards caused by malfunctions. If these provisions are used, the owner or operator is required 

to meet certain criteria during the malfunction, notify the Administrator of malfunctions that may 

cause an exceedance of the emissions standards, and submit a report for the malfunction to the 

Administrator, to include a root cause analysis of the malfunction, within certain timeframes. 

 Existing major sources subject to the new front-end process vent and back-end operations 

requirements are required to comply with these requirements within one year of the effective 

date (promulgation date) of the standards. All existing major sources may use the affirmative 

defense provisions upon the effective date of the standards. All new or reconstructed affected 

sources must be in compliance with the existing and new requirements of the Polymers & Resins 

I NESHAP on the date of startup or the effective date, whichever is later. 

 The new information collection requirements for existing and new Polymers & Resins I 

manufacturing sources are listed in Attachment 1. 

2. Need For and Use of the Collection 

(a) Need/Authority for the Collection. 

 Section 112 of the Clean Air Act (CAA) requires EPA to establish NESHAP for both 

major and area sources of HAP that are listed for regulation under CAA section 112(c). A major 

source is a stationary source that has the potential to emit more than 10 tons per year [tpy] of any 

single HAP and more than 25 tpy of any combination of HAP. The Polymers & Resins I source 

category contains major sources of HAP emissions and is included on EPA’s list of categories 

for regulation. The Polymers & Resins I NESHAP are based on maximum achievable control 

technology (MACT). 

 Certain records and reports are necessary for the Administrator to confirm the 

compliance status of major sources, identify any new or reconstructed sources subject to the 

standards, and confirm that the standards are being achieved on a continuous basis. These 

recordkeeping and reporting requirements are specifically authorized by section 114 of the Clean 

Air Act (42 U.S.C. 7414) and set out in the part 63 NESHAP General Provisions. The 
3

recordkeeping and reporting requirements for title V permits are contained in 40 CFR 70.6 and 

40 CFR 71.6. Under parts 63 and 70 or 71, the owner or operator must keep each record for 5 

years following the date of each occurrence, measurement, maintenance, corrective action, 

report, or record. 

 (b) Use/Users of the Data.

 The information will be used by the delegated authority (state agency, or Regional 

Administrator if there is no delegated state agency) to ensure that the standards and other 

requirements are being achieved. Based on review of the recorded information at the site and the 

reported information, the delegated permitting authority can identify facilities that may not be in 

compliance and decide which facilities, records, or processes may need inspection. 

3. Nonduplication, Consultations, and Other Collection Criteria

(a) Nonduplication.

A computer search of our existing standards and ongoing ICRs revealed no duplication of 

information gathering efforts. However, certain reports required by State or local agencies may 

duplicate information required by the standards. In such cases, a copy of the report submitted to 

the State or local agency can be provided to the Administrator in lieu of the required report. 

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

This is a rule-related ICR and comments were solicited on the proposal package and the 

proposed ICR. This ICR contains revisions from the proposed ICR to include burden associated 

with the provisions for affirmative defense, the notification of facilities’ back-end process 

operations emission limits, and the notification of facilities’ front-end process vent HCl 

emissions limits. The revisions also include the removal of burden associated with performance 

tests and monitors for the front-end process vents. 

(c) Consultations. The original rule was developed in consultation with several 

representatives of the elastomers and synthetic resins industry, environmental organizations, and 

state/local air pollution control agencies. The key non-EPA persons consulted on the 

information collection activities during the original rule development are identified in Table 1. 

No consultations have occurred in the subsequent time periods.
4

TABLE 1. PERSONS CONSULTED ON THE INFORMATION COLLECTION ACTIVITIES 

Contact Title Company 

C.J. Jankowski Managing Director International Institute of 

Synthetic Rubber Producers, Inc. 

Alan Rautio Director Styrene Butadiene Latex 

Manufacturers Council 

R.D. Hembree Staff Engineer Exxon Chemical 

George M. Ladzun Corporate director of 

Engineering and Operations 

Support 

Zeon Chemicals USA, Inc. 

Thomas D. 

Gentner 

Manager, Environmental 

Affairs 

Morton International, Inc. 

Jonathon D. Miller Air Emissions Specialist DuPont Elastomers 

Dave Berkebile Principal Engineer, Corporate 

Engineering 

The Goodyear Tire and Rubber 

Co. 

David Gustafson Environmental Air Issues 

Manager 

Dow Chemical 

Lloyd J. Tabary Environmental Manager DSM Copolymer 

(d) Effects of Less Frequent Collection.

 If the relevant information were collected less frequently, the delegated permitting 

authority (State or EPA) will not be reasonably assured that a facility is in compliance with the 

standards. In addition, the EPA's authority to take administrative action would be significantly 

reduced; section l13(d) of the CAA limits the assessment of administrative penalties to violations 

which occur no more than 12 months before initiation of the administrative proceeding. Since 

administrative proceedings are less costly and require use of fewer resources than judicial 

proceedings, both the EPA and the regulated community benefit from preservation of the EPA's 

administrative powers. 
5

 (e) General Guidelines. 

 The Polymers & Resins I NESHAP requires that facility owners or operators retain 

records for a period of 5 years, which exceeds the 3-year retention period contained in the 

guidelines in 5 CFR 1320.6. The 5-year retention period is consistent with the subpart A 

General Provisions of 40 CFR part 63 and the retention requirement in the operating permit 

program under Title V of the CAA. All subsequent general guidelines have been followed and 

do not violate any of the Paperwork Reduction Act guidelines contained in 5 CFR 1320.6. 

(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 Title 40, Chapter 1, Part 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).

(g) Sensitive Questions. 

 This section is not applicable because this ICR does not involve matters of a sensitive 

nature. 

4. The Respondents and the Information Requested

(a) Respondents/NAICS Codes. 

Potential respondents under Subpart U are owners or operators of any existing or new 

Polymers & Resins I manufacturing facility that is a major source of HAP emissions. The source 

category and affected sources regulated by the Polymers & Resins I NESHAP are classified 

under the Standard Industrial Classification (SIC) code 2822, for synthetic rubber 

manufacturing. The corresponding North American Industrial Classification System (NAICS) 

code is 325212, for synthetic rubber manufacturing. 

 According to information included in recent Federal Register notices related to Residual 

Risk analyses1

, the Polymers & Resins I source category is estimated to consist of 19 existing 

facilities nationwide, all of which are major sources and would be subject to the major source 

provisions specified under the Polymers & Resins I NESHAP. We estimate the 5 facilities will 

 

1 72 FR 70543, December 12, 2007; and 73 FR 60432, October 10, 2008.
6

be subject to the new requirements of the NESHAP. All 19 existing facilities could make use of 

the new affirmative defense provisions added to the rule. No new major sources are projected 

during the 3-year period of this ICR. 

(b) Information Requested.

(i) Data Items, Including Recordkeeping Requirements. Attachment 1, Information 

Requirements, summarizes the data items, including recordkeeping and reporting requirements, 

for the Polymers & Resins I source category. 

 (ii) Respondent Activities. The respondent activities that are required by the 

Polymers & Resins I NESHAP are identified in Table 2 (located at the end of this supporting 

statement) and are introduced in section 6(a). 

(iii) Summary of Requirements. Facilities subject to the new requirements for front-end 

process vents are required to provide a notification of their front-end process vent HCl emissions 

limit and perform and record monthly calculations of HCl emissions and the mass of elastomer 

product produced. Facilities subject to the new requirements for back-end process operations are 

required to provide a notification of their back-end limit and perform and record monthly 

calculations of HAP emissions and the mass of elastomer product produced. Information related 

to these new requirements is required to be submitted in the semi-annual reports already required 

by the existing rule. 

EPA is including in Table 3 (located at the end of this supporting statement) an estimate 

of the burden associated with performing an affirmative defense. 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. 

This illustrative estimate is not considered a duplicate estimate of cost under the General 

Duty to Minimize Emissions clause under 63.6(e)(1)(i), which states: “At all times, the owner 

and operator must operate and maintain any affected source, including associated air pollution 

control equipment and monitoring equipment, in a manner consistent with safety and good air 

pollution control practices for minimizing emissions. Determining whether such operation and 

maintenance procedures are being used will be based on information available to the 

Administrator which may include, but is not limited to, monitoring results, review of operation 
7

and maintenance procedures, review of operation and maintenance records, and inspection of the 

source.” 

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, EPA provides an 

administrative adjustment to this ICR that estimates the costs of the notification, recordkeeping 

and reporting requirements associated with the assertion of the affirmative defense. EPA’s 

estimate for the required notification, reports and records, including the root cause analysis, 

associated with a single incident totals approximately $1,113 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 records and reports for submission to EPA. EPA 

provides this illustrative estimate of this burden because these costs are only incurred if there has 

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

Of the number of excess emission events reported by source operators, only a small 

number would be expected to result from a malfunction, and only a subset of excess emissions 

caused by malfunctions would result in the source choosing to assert the affirmative defense. 

Thus we believe the number of instances in which source operators might be expected to avail 

themselves of the affirmative defense will be extremely small. For this reason, we estimate no 

more than 2 or 3 such occurrences for all sources within a given category over the 3-year period 

covered by this ICR. For the purpose of this estimate, we are adding two (2) instances of 

affirmative defense. We expect to gather information on such events in the future and will revise 

this estimate as better information becomes available. 

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

Information Management

(a) Agency Activities.

 The Agency activities associated with the Polymers & Resins I NESHAP are provided in 

Table 4 (located at the end of this supporting statement) and are introduced in section 6(c). 

(b) Collection Methodology and Management. 
8

 Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs of the delegated permitting authority. The performance 

test notifications and reports required under the final rule are used for problem identification, as 

a check on source operation and maintenance, and for compliance determinations. EPA is the 

permitting authority until the state agency is delegated authority to implement the rule. 

Therefore, information contained in the reports submitted to the Regional Administrator will be 

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. 

(c) Small Entity Flexibility. 

The Small Business Administration defines a small entity as one that meets the Small 

Business Administration size standards for small businesses found at 13 CFR 121.201 (less than 

1000 employees for NAICS 325212). We estimate that none of the facilities affected by the new 

requirements are small entities. Accordingly, the rule does not impose significant economic 

impact on a substantial number of small businesses, and small business considerations do not 

apply. 

(d) Collection Schedule. 

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

shown in Table 2 for the Polymers & Resins I source category. 

6. Estimating the Burden and Cost of the Collection

(a) Estimating Respondent Burden.

 The annual burden estimates for the Polymers & Resins I NESHAP are shown in Table 2. 

These numbers were derived from estimates based on EPA’s experience with this and other 

standards. No burden estimates are provided for new sources because no new facilities are 

expected to become affected sources during the 3-year period of this ICR. 

(b) Estimating Respondent Costs.
9

 The information collection activities for the Polymers & Resins I NESHAP are presented 

in Table 2. Because the facilities are already in compliance with the existing rule, and no new 

sources are expected within the next 3 years, no respondent development costs are associated 

with the information collection activities. 

 Information collection requirements for one-time-only reports are included in the burden 

calculations because five facilities are required to submit one-time-only notifications of their 

back-end process limit and three facilities are required to submit one-time-only notifications of 

the front-end process vents HCl emissions limit. The estimates of total technical-hours per year 

per source and the number of activities per respondent per year listed in Table 2 are based upon 

experience with similar information collection requirements in the HON and on the number of 

emission points in each source. 

(i) Estimating Labor Costs. Labor rates and associated costs are based on Bureau of 

Labor Statistics (BLS) data. Technical, management, and clerical average hourly rates for 

private industry workers were taken from United States Department of Labor, Bureau of Labor 

Statistics for NAICS 325200, May 2009 information, available at 

http://www.bls.gov/oes/current/naics4_325200.htm. Wages for technical labor are based on 

"Production occupations: Chemical Equipment Operators & Tenders" with a total compensation 

of $23.38/hour. Wages for management labor are taken from "Production occupations: Firstline supervisors/managers of production and operating workers" with a total compensation of 

$31.20/hour. Wages for clerical labor are based on "Office and administrative support 

occupations: Office clerks general" with a total compensation of $14.22/hour. These rates 

represent salaries plus fringe benefits and do not include the cost of overhead. An overhead rate 

of 110 percent is used to account for these costs. The fully-burdened hourly wage rates used to 

represent respondent labor costs are: technical at $49.10, management at $65.52, and clerical at 

$29.86. 

 

 (ii) Estimating Capital and Operations and Maintenance (O&M) Costs. The final 

standards do not include any capital or operations and maintenance costs because no monitoring 

or other equipment is required by the amendments to the rule. 
10

(iii) Annualizing Capital Costs. Annualized costs are calculated by multiplying the 

capital recovery factor by the capital cost. The capital recovery factor is 0.1098 based on an 

interest rate of 7 percent and an assumed equipment life of 15 years. The total annualized capital 

cost is $795. 

(iv) Affirmative Defense, Root Cause Analysis, and Malfunction Costs. EPA’s estimate 

for a affirmative defense and root cause analysis is based on general experience to calculate the 

time and effort required of a source to review relevant data, interview plant employees, and 

reconstruct the events prior to a malfunction in order to determine primary and contributing 

causes. The level of effort also includes time to produce and retain the report in document form 

so that the source will have it available should EPA or state enforcement agencies ever request to 

review it. 

(c) Estimating Agency Burden and Cost. 

 Because the information collection requirements were developed as an incidental part of 

standards development, no costs can be attributed to the development of the information 

collection requirements. Because reporting and recordkeeping requirements on the part of the 

respondents are required under the operating permits rules in 40 CFR part 70 or part 71 and the 

part 63 NESHAP General Provisions, no operational costs will be incurred by the Federal 

Government. Publication and distribution of the information are part of the Compliance Data 

System, with the result that no Federal costs can be directly attributed to the ICR. Examination 

of records to be maintained by the respondents will occur incidentally as part of the periodic 

inspection of sources that is part of EPA’s overall compliance and enforcement program, and, 

therefore, is not attributable to the ICR. The only costs that the Federal government will incur 

are user costs associated with the analysis of the reported information, as presented in Table 4. 

 The Agency labor rates are from the Office of Personnel Management (OPM) 2009 

General Schedule which excludes locality rates of pay. These rates can be obtained from Salary 

Table 2009-GS available on the OPM website,

http://www.opm.gov/flsa/oca/09tables/html/gs_h.asp. The government employee labor rates are 

$15.40/hour for clerical (GS-6, Step 3), $28.45 for technical (GS-12, Step 1), and $38.35/hr for 

management (GS-13, Step 5). These rates were increased by 60 percent to include fringe 
11

benefits and overhead. The fully-burdened wage rates used to represent Agency labor costs are: 

clerical at $24.64; technical at $45.52, and management at $61.36. 

(d) Estimating the Respondent Universe and Total Burden and Costs. 

 There are an estimated 5 existing facilities that will be subject to the new provisions of 

the Polymers & Resins I NESHAP. No new sources are expected during the next 3 years. While 

all 19 existing facilities could make use of the new affirmative defense provisions added to the 

rule, EPA estimates only two total instances of the use of these provisions from all 19 facilities 

over the three year ICR period. Consequently, the average annual number of Polymers & Resins 

I manufacturing facility respondents during the 3-year period of this ICR is 5. 

For the Polymers & Resins I NESHAP, the components of the total annual responses 

attributable to this ICR are one-time notifications of performance tests and performance test 

reports for two respondents. For five respondents, a notification of the back-end process limit, 

recordkeeping, and a small amount of additional information will be required to be added to the 

semiannual reports already required for these respondents. As these reports are already required 

by the existing rule, they are not included in this ICR. The number of total annual responses for 

subpart U is estimated as: 3. 

(e) Bottom Line Burden Hours and Cost Tables.

(i) Respondent tally. The bottom line respondent burden hours and costs, presented in 

Table 2 are calculated by adding person-hours per year down each column for technical, 

managerial, and clerical staff, and by adding down the cost column. The annual burden for the 

recordkeeping and reporting requirements for the 5 existing facilities subject to the new backend operations and front-end process vent requirements and the 19 existing facilities subject to 

the new affirmative defense provisions of the Polymers & Resins I Manufacturing NESHAP is 

251 person-hours, with an annual labor cost of $12,222 and annualized capital costs of $0. 

(ii) The Agency tally. The average annual Federal Government cost is $408 for 9 hours 

for the new requirements of subpart U. The bottom line Agency burden hours and costs 

presented in Table 4 (located at the end of this supporting statement) are calculated by adding 

person-hours per year down each column for technical, managerial, and clerical staff, and by 

adding down the cost column. 
12

(iii) Variations in the annual bottom line. This section does not apply since no 

significant variation is anticipated. 

(f) Reasons for Change in Burden.

We are requesting an increase in burden of 251 hours due to implementation of the new 

provisions of this regulation. EPA provides an adjustment to this ICR that estimates the costs of 

the notification, recordkeeping and reporting requirements associated with the assertion of the 

affirmative defense. EPA’s estimate for the required notification, reports and records, including 

the root cause analysis, associated with a single incident totals approximately $1,670 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 records and 

reports for submission to EPA. For the purpose of estimating the annual burden, EPA is 

attributing a total of 2 instances of affirmative defense over a three year period across all sources 

in the category. EPA is using this frequency of 2 events in three years because, of the number of 

excess emission events reported by source operators, only a small number would be expected to 

result from a malfunction, and only a subset of excess emissions caused by malfunctions would 

result in the source choosing to assert the affirmative defense. Thus, we believe the number of 

instances in which source operators might be expected to avail themselves of the affirmative 

defense will be extremely small. 

 (g) Burden Statement 

 The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 75 hours per response. The average annual respondent burden for the 

new Polymers & Resins I Manufacturing NESHAP requirements is estimated at 50 hours. 

Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This 

includes the time needed to review instructions; develop, acquire, install, and utilize technology 

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able 
13

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’s regulations in 40 CFR part 63 are listed in 40 CFR part 9. 

 To comment on the Agency’s need for this information the accuracy of the provided 

burden estimates, and any suggestions for minimizing respondent burden, including through the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID No. EPA-HQ-OAR-2010-0600, which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation 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 

Air Docket is (202) 566-1742. An electronic version of the public docket is available at 

http://www.regulations.gov. This site can be used to submit or view public comments, access 

the index listing of the contents of the public docket, and to access those documents in the public 

docket that are available electronically. When in the system, select “search,” then key in one of 

the Docket ID Numbers identified above. 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 relevant Docket ID 

Number (EPA-HQ-OAR-2010-0600) in any correspondence. 

PART B

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

associated with the rule. 
14 

TABLE 2. ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS OF THE FINAL STANDARD

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

Person- No. of Person-hours Sources Technical Management 

hours per occurrences per source per year person-hours person-hours p

occurrence per source per year per year per year 

(a) per year (b) (C=AxB) (E=CxD) (Ex0.05) 

1. Applications N/A2. Survey and Studies N/A3. Acquisition, Installation, & Utilization of Tech. & Systems See 5F 4. Reporting RequirementsA. Read instructions (d) 3.20 20.0 64.0 0.0 0.0 0.0 

B. Required activitiesC. Create information See 4BD. Gather existing information See 4BE. Write report See 4B Semi-annual compliance reports 40.00 2.0 80.0 0.0 0.0 0.0  Leak detection and repair reports 24.00 2.0 48.0 0.0 0.0 0.0  Front-end limit notification 4.00 1.0 4.0 1.0 4.0 0.2  Back-end limit notification 4.00 1.0 4.0 1.7 6.7 0.3  Performance test notification (e) 2.00 1.0 2.0 0.0 0.0 0.0  Performance test report (e) 8.00 1.0 8.0 0.0 0.0 0.0  Affirmative defense (f) 30.00 1.0 30.0 0.7 12.0 8.0  Other reports ( e.g., quarterly periodic reports where a respondent did not qualify for semiannual reporting) 8.00 1.0 8.0 0.0 0.0 0.0 

22.7 8.5 

5. Recordkeeping RequirementsA. Read instructions See 4AB. Plan activities See 5EC. Implement activities See 5ED. Develop record system See 5EE. Time to enter information Plan Activities (d) 2.00 20.0 40.0 0.0 0.0 0.0  Create, Test, Research, Develop (d) 18.00 80.0 1440.0 0.0 0.0 0.0  Gather information, Monitor, Inspect 1.00 12.0 12.0 5.0 60.0 3.0  Process, Compile, Review 1.00 12.0 12.0 5.0 60.0 3.0 F. Time to train personnel (d) 3.00 10.0 30.0 0.0 0.0 0.0 G. Time to adjust existing ways to comply w/ prev. appl. req. N/AH. Time to Record and disclose information 1.00 2.0 2.0 5.0 10.0 0.5  Store, file and maintain records 1.00 12.0 12.0 5.0 60.0 3.0 I. Time for audits N/A

190.0 9.5 

TOTAL ANNUAL BURDEN AND COST (SALARY) 212.7 18.0 

TOTAL ANNUAL NUMBER OF RESPONSES CAPITAL AND O&M COSTS: Total annual capital 0.00 

ANNUALIZED CAPITAL COSTS:  Total annualized capital 0.00 

ANNUAL O&M COSTS 0.00 

TOTAL ANNUALIZED COSTS (Annualized capital + O&M costs) 

N/A = Not Applicable.(a) Estimate of burden for each activity(b) Estimate based on average facilities, as per original P&R I ICR(c) Costs are based on the following hourly rates: technical at $49.10, management at $65.52, and clerical at $29.86(d) One-time occurrence, assumed to have already occurred for existing sources. No new sources are expected during the 3-yr ICR period.(e) 3 new tests required by proposed rule(f) Assumes 2 affirmative defense reports for entire industry during the 3-yr ICR period. Formulas are not followed for person-hours per year. For affirmative defense, hours technical, 12 hours management, 0 clerical for each instance of affirmative defense.
15

TABLE 3. SINGLE AFFIRMATIVE DEFENSE BURDEN ESTIMATE 

Personnel 

Number of 

Personnel 

Time 

Requirement 

(hours) 

Total 

Hours 

Hourly Rate 

($/hr) Total 

Technical Personnel 3 6 18 49.10 $ 884Managerial Personnel 2 6 12 65.52 $ 786

Total 5 30 $1,670

TABLE 4. ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT OF THE FINAL STANDARDS

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

EPA person- No. of EPA person- Plants Technical Management 

hours per occurrences hours per per person-hours person-hours 

occurrence per plant plant per year per year per year 

per year year (E=CxD) (Ex0.05) 

Activity (C=AxB) Performance Tests: Initial 40 1 40.0 0 0.0 0Performance Tests: Repeat 40 1 40.0 0 0.0 0Litigation (c) 2080 0 0.0 0 0.0 0Reports Review:Compliance status (b) 40.0 0 0.0 0 0.0 0Review equipment leak monitoring (c) 7.0 2 14.0 0 0.0 0Notification of front-end operations limit (b) 3.0 1 3.0 1 3.0 0Notification of back-end operations limit (b) 3.0 1 3.0 2 5.0 0Notification of construction/reconstruction (b) 6.0 0 0.0 0 0.0 0Notification of anticipated startup (b) 6.0 0 0.0 0 0.0 0Notification of actual startup (b) 6.0 0 0.0 0 0.0 0Notification of performance test (b) 6.0 1 6.0 0 0.0 0Review of test results (b) 24.0 1 24.0 0 0.0 0Review periodic reports 3.0 2 6.0 0 0.0 0Review other reports (d) 6.0 1 6.0 0 0.0 0TOTAL BURDEN AND COST (SALARY) 8.0 0(a) Costs are based on the following hourly rates: technical at $45.52, management at $61.36, and clerical at $24.64.  Management person-hours and clerical person-hours are assumed to be 5 percent and 10 percent of technical person-hours, respectively.(c) Represents the cost of litigating an average of 1 case per year. It is assumed that there wil be no more litigation.(d) Examples of these reports include quarterly periodic reports where a respondent did not qualify for semiannual reporting(b) One-time occurrence, only applies to sources subject to newly proposed standards. There are 5 notifications of back-end limits expected. There are 3 notifications of fro
16

ATTACHMENT 1. INFORMATION REQUIREMENTS--NESHAP FOR POLYMERS AND RESINS I MANUFACTURING 

Requirement Citation for existing sources Citation for new sources General Provisions 

Notifications 

Notification of front-end process vent HCl limit §63.485(q) §63.485(q) N/A Notification of back-end limit §63.499(f)(1) §63.499(f)(1) N/A 

Records 

Records of notifications §63.506(e) §63.506(e) 40 CFR 63.10 Records that demonstrate continuous compliance §63.498(a)(4), §63.498(e), §63.506(d) §63.498(a)(4), §63.498(e), 

§63.506(d) 

40 CFR 63.10 

Reports 

Back-end process vents records in periodic reports §63.499(f), §63.506(e)(6) §63.499(f), §63.506(e)(6) N/A Front-end process vents records in periodic reports §63.506(d), §63.506(e)(6) §63.506(d), §63.506(e)(6) N/A Reports of malfunctions that result in an exceedances of the standard for the purpose of affirmative defense 

§63.480(j)(4) §63.480(j)(4) N/A