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. Th is information collection request (I CR) is entitled "Reporting and Recordkeeping Requirements for National Emission Standards for Hazardous Air Pollutant Emissions : Group I Poly mers and Resins ." T he EPA tracking number i s 2410.0 2 , and the Office of Manage ment and Budget (OMB) number is 2060

- 0356

. (b) Short Characterization. This I CR covers information collection requirements in the final rulemaking that amen d title 40, chapter I , part 63 of the Code of Federal Regulations (CFR) Subpart U National Emiss ion Standards for Hazardous Air Pollutants : Group IPoly mers and Resins , hereafter, this subpart is referred to as the " Poly mers & Resins I NESHAP". Respondents are owners or operators s ubject 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 Poly mer s and Resins INESHAP who may wish to make use of the new affirmative defense provisions in the amen dments to the rule. The final standards add emissions limits f or the back

- end process operations for the butyl rubber production, epichlorohydrin elastomer s 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 revise s 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 owner2

or operator is required to calculate and record the HCl emissions from the front

- end process vents as well as the mass of elastomer product produced. In formation related to these new requirements is required to be submitted in the semi

- annual repo rts 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 . I f 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 A dministrator, to include a root cause analysis of the malfunction, within certain timeframes. E xisting 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 exist ing and new requirements of the Poly mers & Resins I NESHAP on the date of startup or the effective date, whichever is later. The new information collection requirements for existing and new Poly mers & 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 C lean Air Act (C AA ) require s 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 ha s the potential to emit more than 10 tons per year [ t py] of any single HAP and more than 25 t py of any combination of HAP. The Poly mers & Resins I source category contains major sources of HAP emissions and is in cluded on EPA’s list of categories for regulation. T he Poly

mers & Resins I NESHAP are based on maximum achievable control technology (MACT). Certain records and reports are nec essary for the Administrator to confir m the compliance status of major sources , identify any new or reconstructed s ources subject to the standards, and confirm that the standards are being achieved on a continuous basis. These recordkeeping and3

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 recordkeeping and reporting requirements for t itle 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 ( s tate agency , or Regional Administrator if there is no delegated s tate 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

n ot be in compliance and decide which facilitie s, records, or processes may need inspection

. 3. Nonduplication, Consultations, and Other Collection Criteria (a) Nonduplication. A computer search of our existing standards and ongoing I CRs revealed no d uplication of information gathering efforts

. However, certain reports required by State or local agencies may duplicate information required by the standards. Insuch 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 I CR and comments were solicited on the proposal package and the proposed IC R. This I CR contains revisions from the prop osed I CR to include burden associated with the provisions for affirmative defense , the notification of facilities’ back

- end process operations emission limit s , 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 w as developed in consultation with several representatives of the elastomers and sy nthetic resins indus try , 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 Sy nthetic Rubber Producers, Inc. Alan Rautio Director Sty rene 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. Jonath on D. Miller Air Emissions Specialist DuPont Elastomers Dave Berkebile Principal Engineer, Corporate

Engineering The Goodyear Tire and Rubber Co. David Gustafson Environmental Air I ssues

Manager Dow Chemical
Ll oyd J. Tabary Environmental Manager DSM Cop oly mer (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. Inadditio n, the EPA's authority to take administrative action would be significantly reduced; s ection 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 procee ding. 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

. T he Po ly mers & Resins I NESHAP requires that facility owners or operators retain records for a period of 5 years, which exceeds the 3

- ye ar retention period contained in the guidelines in 5 CFR 1320.6. The 5

- ye ar 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 c ontained i n 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 In formation (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 I CR does not involve matters of a sensitive nature. 4. The Respondents and the Information Requested (a) Respondents/NAIC S Codes

. Potential respondents under Subpart U are owners or operators of any existing or new Poly mers & Resins I manufacturing facility that is a maj or source of HAP emissions. The source category and affected sources regulated by the Poly mers & Resins I NESHAP are classified under the Standard In dustrial Classification (SI C) code 2822 , for sy nthetic rubber manufacturing. The corresponding North American Industrial Classification System (NAI CS) code is 325212 , for sy nthetic rubber manufacturing

. According to information included in recent Federal Register notices related to Residual Risk analyses 1 , the Poly

mers & Resins I source category is estimat ed 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 Poly mers & 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. N o new major sources are projected during the 3

- ye ar period of this I CR. (b) Information Requested. (i) Data Items, Including Recordkee ping Requirements. Attachment 1, Information Requirements, summarizes the data items, including recordkeeping and reporting requirements, for the Poly

mers & Resins I s ource c ategory

. (ii) Respondent Activities. The respondent activities that are requi red by the Poly mers & Resins I NESHAP are identified in Table 2 (located at the end of this supporting statement) an d 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 H Cl emissions and the mass of elastomer product produced

. Facilities subject to the new requirements for back

- end proc ess 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. In formation related to these new requirements is required to be submitte d 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 the7

Admi nistrator which may include, but is not limited to, monitoring results, review of operation 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 I CR that estimates the costs of the notification, recordkeeping and reporting requirements associat ed 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 requi red 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 sub mission 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 reporte d 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 in stances 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

- ye ar period
co vered by

this I CR. 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 Inf

ormation Collected

–Agency Activities, Collection Methodology, and Information Management (a) Agency Activities. The Agency

activities associated with the Poly mers & Resins I NESHAP are provided in Table 4 (located at the end of this supporting statement) and are introduced in section 6(c).8

(b) Collection Methodology and Management

. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs of the delegated permitting authority . The performanc e 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 s tate agency

is delegated auth ority

to implement the rule. Therefore, i nformation 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 reg ional offices and EPA headquarters. EPA and its delegated a uthorities can edit, store, retrieve and analy

ze 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 NAI CS 325212 ). We estimate that none of the facilities affected by the new requirements are small entities. Accordingly , the rule does not impose significant e conomic impact on a substantial number of small businesses , and small business considerations d o not apply

. (d) Collection Schedule

. The specific frequency

for each information collection activity within this request is shown in Table 2 for the Poly mers & Resins I s ource c atego ry
. 6. Estimating the Burden and Cost of the Collection (a) Estimating Respondent Burden. The annual burden estimates for the Poly mers & Resins I NESHAP are shown in Table 2

. These numbers were derived from estimates based o n 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

- ye ar period of this I CR.9

(b) Estimating Respondent Costs. The information collection activities for the Poly mers & 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 associ ated with the information collection activities. In formation 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 lim it 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 T able 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 NAI CS 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: First

line 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 gene ral " with a total compensation of $1 4

. 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

.10

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

. The final standards do not include any capital or operations and maintenanc e costs because no monitoring or other equipment is required by the amendments to the rule. (i ii ) Annualizing Capital Costs

. Annualized costs are calculated by multiplying the capital recovery

factor by the capital cost. The capital recovery factor i s 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 th e 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 w ill be incurred by the Federal Government. Publication and distribution of the information are par t of the Compliance Data System, with the result that no Federal costs can be directly attributed to the I CR. 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 I CR. The only costs that the Federal government w ill 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) 200 9 General Schedule which excludes locality rates of pay . These rates can be obtained from Salary Table 200 9

- GS available on the OPM website,11

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 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 Poly mers & Resins I N ESHAP

. No new sources are expected during the next 3 years. While

all 19 existing facilities could make use of th e 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 I CR period. Consequently , the average annual number of Poly mers & Resins I manufacturi ng facility respondents during the 3

- ye ar period of this I CR is 5

. For the Poly

mers & Resins I NESHAP , the components of the total annual responses attributable to this I CR 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 rep orts are already required by the existing rule, they

are not included in this I CR. T he 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 back

- end operations and front

- end process vent requirements and the 19 existing facilities subject to the new affirmative defense provisions of the Poly mers & Resins I Manufacturing NESHAP is 25 1 person - hours , with an annual labor cost of $ 12, 222 and annualized capital costs of $ 0

. (ii) The Agency tally. The average annual Federal Go vernment cost is $ 408 for 9 hours for the new requirements of subpart U

. The bottom line Agency burden hours and costs12

pres ented 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. (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 25 1 hours due to implementation of the new provisions of this regulation. EPA provides an adjustm ent to this I CR 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 an alysis, 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 exceedan ce 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 on ly

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 defen se 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 Poly mers & Resin s I Manufacturing NESHAP requirements is estimated at 5 0 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 technology13

and systems for the purposes of collecting, validating, and verify ing information, processing and maintaining information, and disclosing and providing information; adju st 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 other wise 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 p art 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 I CR under Docket ID No

. EPA

- HQ

- OAR

- 20 10

- 0 600 , which is available for online viewing at http://www.regulations.gov , or in person viewing at the Air and Radiation Docket and In formation 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 te lephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the Air Docket is (202) 566

- 1 742

. An e lectronic version of the public do cket 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 Number s identified above. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17 th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include the rel evant Docket ID Number ( EPA

- HQ

- OAR

- 2010

- 0 600 ) in any c orrespondence. 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) (G) (H) Person- No. of Person-hours Sources Technical Management Clerical Cost,$ (c) hours per occurrences per source per year person-hours person-hours person-hours occurrence per source per year per year per year per year (a) per year (b) (C=AxB) (E=CxD) (Ex0.05) (Ex0.1) 1. Applications N/A 2. Survey

and Studies N/A 3. Acquisition, Installation, & Utilization of Tech. & Sy stems See 5F 4. Reporting Requirements A. Read instructions (d) 3.20 20.0 64.0 0.0 0.0 0.0 0.0

- $ B. Required activities C. Create information See 4B D. Gather existing information See 4B E. W rite report See 4B Semi-annual compliance reports 40.00 2.0 80.0 0.0 0.0 0.0 0.0

- $ Leak detection and repair reports 24.00 2.0 48.0 0.0 0.0 0.0 0.0

- $ Front-end limit notification 4.00 1.0 4.0 1.0 4.0 0.2 0.4 221 $ Back-end limit notification 4.00 1.0 4.0 1.7 6.7 0.3 0.7 369 $ Performance test notification (e) 2.00 1.0 2.0 0.0 0.0 0.0 0.0

- $ Performance test report (e) 8.00 1.0 8.0 0.0 0.0 0.0 0.0

- $ Affirmative defense (f) 30.00 1.0 30.0 0.7 12.0 8.0 0.0 1,113 $ 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 0.0

- $ 22.7 8.5 1.1 5. Recordkeeping Requirements A. Read instructions See 4A B. Plan activities See 5E C. Implement activities See 5E D. Develop record system See 5E E. Time to enter information Plan Activities (d) 2.00 20.0 40.0 0.0 0.0 0.0 0.0

- $ Create, Test, Research, Develop (d) 18.00 80.0 1440.0 0.0 0.0 0.0 0.0

- $ Gather information, Monitor, Inspect 1.00 12.0 12.0 5.0 60.0 3.0 6.0 3,322 $ Process, Compile, Review 1.00 12.0 12.0 5.0 60.0 3.0 6.0 3,322 $ F. Time to train personnel (d) 3.00 10.0 30.0 0.0 0.0 0.0 0.0

- $ G. Time to adjust existing ways to comply w/ prev. appl. req. N/A H. Time to Record and disclose information 1.00 2.0 2.0 5.0 10.0 0.5 1.0 554 $ Store, file and maintain records 1.00 12.0 12.0 5.0 60.0 3.0 6.0 3,322 $ I. Time for audits N/A 190.0 9.5 19.0 TOTAL ANNUAL BURDEN AND COST (SALARY) 212.7 18.0 20.1 12,222 $ TOTAL ANNUAL NUMBER OF RESPONSES 3 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 required assumes 18 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

Requirem ent (hours) Total

Hours Hourly Rate

($/hr) Total Techni cal Personnel 3 6 18 49.10 $ 884 Managerial Personnel 2 6 12 65.52 $ 786 Total 5 30 $1,670

TA BLE 4. ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT OF THE FINAL STANDARDS (A) (B) (C) (D) (E) (F) (G) (H) EPA person- No. of EPA person- Plants Te chnical Management Clerical Cost,$ (a) hours per occurrences hours per per person-hours person-hours personoccurrence per plant plant per year per year per year hours per

per year year (E=CxD) (Ex0.05) ye ar Activity (C=AxB) (Ex0.1) Performance Tests: Initial 40 1 40.0 0 0.0 0.0 0.0 $0 Performance Tests: Repeat 40 1 40.0 0 0.0 0.0 0.0 $0 Litigation (c) 2080 0 0.0 0 0.0 0.0 0.0 $0 Reports Review: Compliance status (b) 40.0 0 0.0 0 0.0 0.0 0.0 $0 Review equipment leak monitoring (c) 7.0 2 14.0 0 0.0 0.0 0.0 $0 Notification of front-end operations limit (b) 3.0 1 3.0 1 3.0 0.2 0.3 $153 Notification of back-end operations limit (b) 3.0 1 3.0 2 5.0 0.3 0.5 $255 Notification of construction/reconstruction (b) 6.0 0 0.0 0 0.0 0.0 0.0 $0 Notification of anticipated startup (b) 6.0 0 0.0 0 0.0 0.0 0.0 $0 Notification of actual startup (b) 6.0 0 0.0 0 0.0 0.0 0.0 $0 Notification of performance test (b) 6.0 1 6.0 0 0.0 0.0 0.0 $0 Review of test results (b) 24.0 1 24.0 0 0.0 0.0 0.0 $0 Review periodic reports 3.0 2 6.0 0 0.0 0.0 0.0 $0 Review other reports (d) 6.0 1 6.0 0 0.0 0.0 0.0 $0 TOTAL BURDEN AND COST (SALARY) 8.0 0.4 0.8 $408 (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 front-end limits expected.16 ATTACHMENT 1. INFORMATION REQUIREMENTS
-- NESHAP FOR POLYMERS AND RESINS I MANUFACTURING

Requirem ent Citation for existing sources Citation for new sources General Provisions citation Notifications Notification of front

- end proc ess 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 §6 3. 499(f), §63.506(e ) (6) §6 3. 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