SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Polyvinyl Chloride and Copolymers Production Area Sources (40 CFR Part 

63, Subpart DDDDDD) (Renewal) 

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Polyvinyl Chloride and Copolymers Production Area Sources (40 CFR Part 63, 

Subpart DDDDDD) (Renewal), EPA ICR Number 2454.02, OMB Control Number 2060-0684.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Polyvinyl 

Chloride (PVC) and Copolymers Production Area Sources were originally promulgated on 

January 23, 2007. The original rule was based on GACT and required area sources to meet the 

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

referred to as the part 61 NESHAP. The part 61 NESHAP requirements address only vinyl 

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

Source NESHAP in accordance with the Clean Air Act (CAA) section 112. The updated Subpart 

DDDDDD is promulgated on April 17, 2012, and applies to new and existing PVC and 

copolymer production facilities that are an area source of hazardous air pollutants (HAP). 

This ICR includes burden estimates for area sources only. Major sources are regulated 

under NESHAP Subpart HHHHHHH and their burdens are included in a separate ICR (EPA ICR 

Number 2432.02). New facilities include those that commenced construction or reconstruction 

after the date of proposal. This information is being collected to assure compliance with 40 CFR 

Part 63, Subpart DDDDDD.

In general, all NESHAP standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the 

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. In 

the event that there is no such delegated authority, the reports are sent directly to the United 

States Environmental Protection Agency (EPA) regional office.

All of the PVC and copolymer area source facilities are owned by the private sector. The 

burden to the “Affected Public” may be found in Table 1: Annual Respondent Burden and Cost –

NESHAP for Polyvinyl Chloride and Copolymers Production Area Sources (40 CFR Part 63, 
2

Subpart DDDDDD) (Renewal). The “Federal Government” burden is attributed entirely to work 

performed by federal employees or government contractors and may be found in Table 2: 

Average Annual EPA Burden and Cost – NESHAP for Polyvinyl Chloride and Copolymers 

Production Area Sources (40 CFR Part 63, Subpart DDDDDD) (Renewal).

Over the next three years, approximately 3 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. 

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.” 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

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

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

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

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

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

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

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

public health or welfare. Therefore, the NESHAP were promulgated for this source category at 

40 CFR Part 63, Subpart DDDDDD.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the

applicable regulations which were promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.
3

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard is being met. The 

performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart

DDDDDD.

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no 

duplication exists.

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

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

of information as reported by industry, in compliance with the recordkeeping and reporting 

provisions in the standard, is Enforcement and Compliance History Online (ECHO), which is 

operated and maintained by EPA's Office of Compliance. ECHO is EPA’s database for the 
4

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed. In developing 

this ICR, we contacted both the Vinyl Institute (VI) at (202) 765-2200 and the Occidental 

Chemical Corporation (OxyVinyls Deer Park, TX PVC facility) at (972) 404-3800. The Vinyl

Institute provided substantial comments on the respondent universe and specific burden hours 

and costs associated with the reporting and recordkeeping requirements. We have updated this 

ICR to incorporate the comments received. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the standards. Requirements for information gathering and 

recordkeeping are useful techniques to ensure that good operation and maintenance practices are 

applied and emission limitations are met. If the information required by these standards was 

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five year records retention requirement is consistent with 

the Part 70 permit program and the five year statute of limitations on which the permit program 

is based. The retention of records for five years allows EPA to establish the compliance history 

of a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any 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 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions
5

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

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are PVC production 

area source facilities. The United States Standard Industrial Classification (SIC) code for the 

respondents affected by the standards is SIC 2821 which corresponds to the North American 

Industry Classification System (NAICS) code 325211 for Plastics Material and Resin 

Manufacturing.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Polyvinyl Chloride and Copolymers Production Area Sources (40 CFR Part 63, Subpart 

DDDDDD). 

A source must make the following reports:

Notifications / Reports

Submit an initial notification 63.9(b)

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

Submit a notification of performance test 63.9(e)

Submit a compliance report 63.11142(f)(18)

Submit a notification of inspection 63.11142(f)(18)

Submit a batch pre-compliance report 63.11142(f)(18)

A source must keep the following records:

Recordkeeping

A copy of each notification and report submitted to comply with this 

subpart 63.11142(f)(19)

Records of storage vessels 63.11142(f)(19)

Records of equipment leaks 63.11142(f)(19)

Records of heat exchanger systems 63.11142(f)(19)
6

Recordkeeping

Records of process vents 63.11142(f)(19)

Records of closed vent systems

63.11142(f)(9) and

63.11142(f)(19)

Records of resin strippers 63.11142(f)(19)

Records of process wastewater 63.11142(f)(19)

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

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device.

Perform initial performance test, Reference Method 1 or 1A; 2, 2A, 2C, 2D, 2F, or 2G; 3, 3A, 

or 3B; 4 or 320; 25A or 18; 308; 316; 204 and 204A – 204F tests, and repeat performance tests 

if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Train personnel to be able to respond to a collection of information.
7

Respondent Activities

Transmit, or otherwise disclose the information.

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

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) and 

ECHO. 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply

with the emission standard and note the operating conditions under which compliance was 

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

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 

determinations.

Information contained in the reports is reported by state and local governments in the 

ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

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

years.
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5(c) Small Entity Flexibility

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

The PVC NESHAP does not contain any provisions reserved exclusively for the benefit 

of small entities; however, there are provisions that reduce the impact on all regulated entities, 

which would include any small entities. Reporting is annual and operating parameter monitoring 

is required instead of CEMS.

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Polyvinyl 

Chloride and Copolymers Production Area Sources (40 CFR Part 63, Subpart DDDDDD) 

(Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 69,200 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)
9

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the 

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation, which includes monitoring system installation, 

performance testing, resin stripper testing, and wastewater testing. The annual operation and 

maintenance costs are the ongoing costs to maintain the monitors and other costs such as 

photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
10

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

(A)

Continuous Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

Continuous Parameter Monitoring

PRD Electronic Monitor 1

$375,000 0 $0 $31,772 3 $95,316

VC Ambient Monitoring 2

NA 0 $0 $164,250 3 $492,750

Gasholder 3

$5,000 0 $0 NA 3 $0

Periodic Testing

Process Vent Testing $43,198 0 $0 $8,640 3 $25,920

Resin Sampling and 

Monitoring4 $1,803 0 $0 $7,212 3 $21,636

Resin: Non-VC TOHAP 

testing5 $1,950 0 $0 $23,400 3 $70,200

Wastewater Testing6$491 0 $0 $5,892 3 $17,676

Wastewater Testing: NonVC TOHAP testing $650 0 $0 $7,800 3 $23,400

Uncontrolled Wastewater 

testing $0 0 $0 $491 3 $1,473

Uncontrolled Wastewater 

testing: Non-VC TOHAP 

testing 7

$3,250 0 $0 $3,250 3 $9,750

Equipment Leak Testing $177,360 0 $0 $16,105 3 $48,315

Total (rounded) $0 $806,000

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 

1

Per VI's comments, the capital cost of the PRD monitor is $15,000 per device, and it is assumed that 25 devices per facility 

require indicators.

2

Per VI's comments, there are 73 GC monitors in the industry with an annual cost of $45,000 per monitor for vinyl chloride (for 

3 area and 17 major source facilities). The average cost per facility is therefore $164,250. 

3

Per VI's comments, estimated installation cost for gasholder is $5,000. Note there are only 15 gasholders in the industry across 

both major and area source facilities. 

4 Monthly testing ($601 x 12 months = $7,212 per year)

5

Per VI's comments, the costs of Non-VC TOHAP testing is $650 per sample, and three samples per facility.

6 Monthly testing ($491 x 12 months = $5,892 per year)

7

Per VI's comments, the costs of Non-VC TOHAP testing is $650 per sample, and five samples per facility.

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $806,000. This is the 

total of column G. 
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The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $806,000. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$7,170. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2015 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Polyvinyl 

Chloride and Copolymers Production Area Sources (40 CFR Part 63, Subpart DDDDDD) 

(Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

three existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is three per year. 

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 
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Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 3 0 0 3

2 0 3 0 0 3

3 0 3 0 0 3

Average 0 3 0 0 3

1

New respondents include sources with constructed, reconstructed and modified affected facilities. 

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is three. 

The total number of annual responses per year is calculated using the following table: 

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

1) Initial Notification 0 1 0 0

2) Batch pre-compliance report 0 1 0 0

3) Notification of performance 

test with test plan 0 1 0 0

4) Notification of compliance 

status 0 1 0 0

5) Compliance report 3 2 0 6

6) Notice of inspection 3 1 0 3

Total 9

The number of Total Annual Responses is 9.

The total annual labor costs are $6,960,000. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Polyvinyl Chloride 
13

and Copolymers Production Area Sources (40 CFR Part 63, Subpart DDDDDD) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 69,200. Details regarding these estimates may be found 

in Table 1: Annual Respondent Burden and Cost – NESHAP for Polyvinyl Chloride and 

Copolymers Production Area Sources (40 CFR Part 63, Subpart DDDDDD) (Renewal). 

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records. 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 7,689 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $806,000. The 

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

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 158

labor hours at a cost of $7,170. See Table 2: Average Annual EPA Burden and Cost – NESHAP 

for Polyvinyl Chloride and Copolymers Production Area Sources (40 CFR Part 63, Subpart 

DDDDDD) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records. 

6(f) Reasons for Change in Burden

There is an adjustment increase in the estimated burden as currently identified in the

OMB Inventory of Approved Burdens. In consulting with the Vinyl Institute during the renewal 

of this ICR, EPA received comprehensive comments on the burden associated with specific 

reporting and recordkeeping requirements, including, but not limited to, performance test, 

monitor installation, resin and wastewater sampling, equipment leak and process vent 

monitoring. We have updated the burden items to more accurately reflect the costs incurred by
14

the industry. The update results in a substantial increase in the respondent labor hours, labor 

costs, and capital/O&M costs. There is also a small increase in the number of responses as we 

have updated the number of subject area sources from two to three based on data provided by the 

Vinyl Institute. 

6(g) Burden Statement

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

is estimated to average 7,689 hours per response. 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 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 valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

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

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

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

Docket ID Number EPA-HQ-OECA-2014-0104. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

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

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2014-0104 and OMB Control Number 2060-0684 in any

correspondence. 

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for Polyvinyl Chloride and Copolymers Production Area Sources 

(40 CFR Part 63, Subpart DDDDDD) (Renewal)

Burden Item

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

Respondent Number of Hours Number of Technical Management Clerical Total

Hours per Occurrences Per Respondents Hours Hours Hours Labor Costs

Occurrence Per Respondent Per Year Per Year Per Year

Per 

Year Per Year

Respondent Per Year

Per Year (C=A x B) (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. Familiarization with the Rule Requirements

 New sources a,b,c,j 320 1 320 0 0 0 0 $0 

 Existing sources ,j 8 1 8 3 24 1.2 2.4 $2,775.49 

B. Required Activities

1) Initial performance test, sampling, and report

a) Process Vents a,d 120 1 120 0 0 0 0 $0 

b) Resins a,e 36 1 36 0 0 0 0 $0 

c) wastewater a,f 8 1 8 0 0 0 0 $0 

d) uncontrolled wastewater f40 1 40 0 0 0 0 $0 

e) heat exchangers g8 1 8 0 0 0 0 $0 

f) equipment leaks h850 1 850 0 0 0 0 $0 

2) Periodic performance test, sampling, and report

a) Process Vents d17.1 350 5,985 3 17,955 897.75 1,795.50 $2,076,414.95 

b) Resins e36 350 12,600 3 37,800 1,890 3,780 $4,371,399.90 

c) wastewater f8 12 96 3 288 14.4 28.8 $33,305.90 

d) uncontrolled wastewater f40 1 40 3 120 6 12 $13,877.46 

e) heat exchangers g8 12 96 3 288 14.4 28.8 $33,305.90 

f) equipment leaks h43 12 510 3 1,530 76.5 153 $176,937.62 

3) Establish operating parameters and monitoring plan
16

a) Process Vents a,b,d 8 1 8 0 0 0 0 $0 

4) Continuous parameter monitoring

a) Initial capital costs (PRD Electronic Monitor)a,i 524 1 524 0 0 0 0 $0 

b) Annualized capital and O&M costs (PRD Electronic Monitor)

i

24 1 24 0.81 19.44 0.97 1.94 $2,248.15 

5) Other requirements

a) equipment openings, initial measurement 

k

1.5 1 1.5 0 0 0 0 $0 

b) equipment openings, daily measurement 

k

1.5 350 525 3 1,575 78.75 157.5 $182,141.66 

c) gasholders 

k

24 1 24 0 0 0 0 $0 

d) storage vessels 

k

40 1 40 0 0 0 0 $0 

e) bypasses, initial requirement 

k

40 1 40 0 0 0 0 $0 

f) bypasses, ongoing inspection 

k

1 12 12 3 36 1.8 4 $4,163.24 

C. Create Information Incl. in 3.B

D. Gather Information Incl. in 3.E

E. Report Preparation

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

2) Batch pre-compliance report a,b 5 1 5 0 0 0 0 $0 

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

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

5) Compliance report

b

40 2 80 3 240 12 24 $27,754.92 

6) Notice of inspection

b

5 1 5 3 15 0.75 1.5 $1,734.68 

Reporting Subtotal 68,874 $6,926,059.88

4. Recordkeeping Requirements

A. Familiarize with Rule Requirements Incl. in 3.A

B. Implement Activities N/A

C. Develop Record System N/A

D. Record Information

1) Records of process vent requirements

b

10 1 10 3 30 1.53 $3,469.37 

2) Records of resin stripper requirements

b

15 1 15 3 45 2.25 4.5 $5,204.05 

3) Records wastewater requirements

b

15 1 15 3 45 2.25 4.5 $5,204.05 

4) Records of storage vessel requirements

b

10 1 10 3 30 1.53 $3,469.37 

5) Records of equipment leak requirements

b

25 1 25 3 75 3.75 7.5 $8,673.41 

6) Records of heat exchanger requirements

b

10 1 10 3 30 1.53 $3,469.37 

7) Records of other emission sources requirements 10 1 10 3 30 1.53 $3,469.37 

E. Personnel Training Incl. in 3.B

F. Time for Audits N/A

Recordkeeping Subtotal 328 $32,958.97 

TOTAL ANNUAL BURDEN AND COSTS 69,201.8 $6,95

9,018.85
17

(rounded) 69,200 $6,960,000

Capital and O&M Cost (see Section 6(b)(iii)): $806,000

TOTAL COST: $7,770,000

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 

FOOTNOTES

a One-time only costs.

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

c

3 area sources in affected source category

d

Per the Vinyl Institute (VI), it is assumed that performance testing for process vents will take 120 hours per occurrence initially. The initial compliance and operating procedure development for continuous 

compliance and will take 8 hours. The daily monitoring of parameters wil take 5 min per record with 112 records a day across 33 devices in the industry. There are 3 area source and 15 major source subject 

to this requirement. Therefore, the continous/daily monitoring wil take on avg 17.1 hr per facility per day over 350 day/yr.

e

Per VI, it is assumed that performance testing for process vents will take 4 hours per sample for 9 samples per facility, initially and daily (350 days per year). See continuous monthly sampling & testing of 

Non-VC TOHAP in O&M section.

f Estimated 1 uncontrolled stream and 1 wastewater stripper per facility. 1 wastewater stripper outlet is expected to require monthly testing; 5 uncontrolled stream will require annual testing (per facility). Per 

VI, it will take 4 hours per sample for 2 samples per stream.

g

Per VI, it is assumed that performance testing on heat exchangers will take 4 hours per sample for 2 samples per facility, initially and monthly. 

h For Equipment leaks, VI estimates approx 10,000 components per facility and 5 minutes per component, plus additional time calibration of analytical device for a total of 850 hr per facility. For continuous 

monitoring, VI assumes 1 hr is required per component for leak repair, if detected. It was assumed that overall continuous compliace of leak monitoring will take 5% of the time with initial monitoring per 

month. 

i

Per VI, the initial performance testing for pressure relieft devices (PRD), would take 524 hours per facility. Periodically, corrective action for discharge from a PRD would take 24 hours. It is estimated that 

27% of the respondents would experience discharge from a PRD each year.

j It will take 8 employees 40 hours per person to read and understand the rule requirements for new sources. For existing sources, we assume it will take 8 employees 1 hour per person. 

k We have included this burden item per comment from VI. 
18

Table 2: Average Annual EPA Burden and Cost – NESHAP for Polyvinyl Chloride and Copolymers Production Area Sources 

(40 CFR Part 63, Subpart DDDDDD) (Renewal)

Burden Item

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

personhours per 

plant per 

year 

(C=AxB)

(D)

Plants Per 

Year 

(E) 

Technical 

person-hours 

per year 

(E=CxD)

(F) 

Management 

person-hours 

per year 

(Ex0.05)

(G) 

Clerical 

personhours per 

year 

(Ex0.10)

(H) 

EPA Cost Per 

Year a,b

1. Applications not applicable

2. Familiarize with Rule Requirements 16 0 0 0 0 0 0 $0 

3. Required Activities

A. Observe initial performance tests b48 0 0 0 0 0 0 $0 

B. Excess emissions -- Enforcement Activities d24 0 0 0 0 0 0 $0 

C. Create Information not applicable

D. Gather Information not applicable

E. Report Reviews

1) Review initial notification 3 0 0 0 0 0 0 $0 

2) Review batch pre-compliance report 5 0 0 0 0 0 0 $0 

3) Review notification of performance test 10 0 0 0 0 0 0 $0 

4) Review notification of compliance status 40 0 0 0 0 0 0 $0 

5) Review compliance report 20 2 40 3 120 6 12 $6,281 

6) Review notice of inspection 3 1 3 3 9 0.45 0.9 $471 

F. Prepare annual summary report c8 1 8 1 8 0.4 0.8 $419 

TOTAL (rounded) 158 $7,170

Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 

FOOTNOTES

a

Figures may not add exactly due to rounding.

b Assumes EPA personnel attend 20 percent of the initial process vent stack tests.
19

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

d Assume no emissions exceedances.