**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for**  **Synthetic Fiber Production Facilities (40 CFR**  **Part 60**  **, Subpart**  **HHH )**  **(Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NSPS for Sy

nthetic Fiber Production Facilities (40 CFR Part 6 0 , Subpart HHH ) (Renewal) , EPA I CR Number 1156.12 , OMB Control Number 2060

- 0059 **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) for Sy nthetic Fiber Production Facilities were proposed on November 23, 1982 , promulgated on April 5, 1984 , and amended on October 17, 2000 (65 FR 61768). These regulations apply to existing and new sy

nthetic fiber production plants with a solvent

- spun , sy nth etic fiber process that produce more than 500 megagrams (Mgs) of fiber per ye ar that commenced construction or reconstruction after the date of proposal . The provisions of this subpart do not apply to an y facility

that uses the reaction spinning process t o produce spandex fiber, or the viscose process to produce rayon fiber, or to facilities that commence modification , but not reconstruction , after November 23, 1982. This information is being collected to assure compliance with 40 CFR part 60, subpart HHH

. In general, all NSPS 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 an y startup, shutdown , or malfunction in the operation of an affected facility, or an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS

. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and records. All reports ar e sent to the delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, an aver age of 22 respondents per ye ar will be subject to the standard , and no additional respondents per year will become subject to the standard. The active (previous) IC R had the following Terms of Clearance (TOC): This request is approved. Prior to resubmission of this collection for2 extension, the Agency

should reassess estimates of burden taking into a ccount recent experience with the p rogram, including the number of reporting entities and estimates of burden for each respondent.
EPA has addressed each item of concern in the TOC by consulting with industry on the respondent universe

. All burden estimates have been thoroughly checked and updated. The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– N SPS for Sy nthetic Fiber Production Facilities (40 CFR Part 60 , Subpart HHH ) (Renewal). T he burden to the “Federal Government” is attributed entirely to work performed b y either F ederal employ ees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost

– N SPS for Sy nthetic Fiber Production Facilities (40 CFR Part 60 , Subpart HHH ) (Renewal)

. **2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or an y non - air quality health and environmental impact and energy requirements) the Administrator determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to thi s charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years. Inaddition, section 114(a) states that the Administrator may require an y 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 (i n 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);3 and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, volatile organic compound (VOC) emissions from sy nthetic fiber production plants either cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source cat egory

at 40 CFR part 60, subpart HHH

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard. Continuous emissio n 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 pollutio n control devices are properl y installed and operated, leaks are being detected and repaired , and the standard are 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. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 60, s ubpart HHH

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directl y to the de legated state or local agency

. If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y 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, dupl ication does not exist.4

**3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (77 FR 47631) on August 9, 2012. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** T he Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary

source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information Sy stem (OTIS) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agen cy ’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 I CR, we contacted : 1) the American Fiber Manufacturers Association (A FMA) , at ( 703 ) 875

- 0432 ; and 2) the Fiber Economics Burea u , at (703) 875

- 0676

. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notic e. In this case, no comments were 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. I f 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**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR part 1320, section 1320.5. **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 (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20,5

1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
T he 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 source category description. The United States Standard Industrial Classification (SI C ) code s for the respondents affected b y the standard and correspond ing North American Industry Classification Sy stem (NAICS ) codes are presented in the following table.
**Standard ( 40 CFR**  **P art 60,**  **S ubpart HHH**  **) SIC Codes**  **NAICS Codes** Manmade Organic Fibers, Except Cellulosic 2824 325222 Cellulosic Manmade Fibers 2823 3252211 **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y NSPS for Sy nthetic Fiber Production Facilities (40 CFR P art 6 0 , S ubpart HHH )

. A source must make the following reports:

**Notification s**  Notification of construction/reconstruction 60.7(a)(1) Notification of initial startup including compliance method 60.7(a)(3) Notification of initial performance test 60.8(d), 60.604(a) Performance test results 60.8(a), 60.604(a)(1) Demonstration of continuous monitoring sy stem 60.7(a)(5) Phy sical or operational change 60.7(a)(4) Quarterl y reports of exceedances or semiannual report of no exceedances 60.604(a)(2) Reports within 30 day s whenever extruded fiber for the preceding 60.604(b)6
**Notification s**  twelve calendar months exceeds 551 tons, if exempt from standard under Section 60.600 A source must keep the following records: **Recordkeeping** Record of startup, shutdown, and malfunctions 60.7(b) Records are required to be retained for two ye ars 60.7(f) Electronic Reporting Some of the r espondents 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. Also, regulatory

agencies in cooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respon dents use electronic reporting.

**(ii) Respon dent Activities** 

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for control device. Perform initial performance test 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and7 **Respondent Activities** providing information. Train personnel to be able to respond to a collection of information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring sy stem. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. **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, analy sis, 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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **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 p roperl y installed and operated. Performance test reports are used b y the Agency to discern a sourc e ’ s initial capability to compl y with the emission standard. 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 chec k on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, an d retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices , and EPA headquarters

. EPA and its delegated a

uthorities can edit, store, retrieve and anal yz e the data.8

The records required b y this regulation must be retained by the owner/operator for two ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations invol ving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

for each informat ion collection activity within this request is shown in below Table 1: Annual Respondent Burden and Cost

– N SPS for Sy nthetic Fiber Production Facilities (40 CFR Part 60 , Subpart HHH ) (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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where ver 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 display s 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 re quirement s is estimated to be 1,8 60 ( Total Labor Hours from Table 1 below ). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NSPS program, the previously app roved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates:9 Managerial $ 121.44 ($ 57.83 + 110%) Technical $ 100.23 ($ 47.73 + 110%) Clerical $ 50.51 ($ 24.05 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 p ercent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe 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. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs 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)
Flow indicator for solvent feed $3,300 0 0 $7,500 22 $165,000
The total capital/startup costs for this I CR are zero. This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR are $165,000. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the IC R is estimated to be $165,000

. These are recordkeeping costs. **6(c) Estimating Agency Burden and Cost**  The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents , periodic in spection of sources of10

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 $ 5,701

. This cost is based on the average hourl y l abor rate as follows:

Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 2012 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 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 Co st

– N SPS for Sy nthetic Fiber Production Facilities (40 CFR Part 60 , Subpart HHH ) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 22 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below is 22 per year. The number of respondents is cal culated using the following table that addresses the three ye ars covered b y this ICR.
**Number of Respondents**

Year (A) Number of Ne w 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 22 0 0 22
2 0 22 0 0 22
3 0 22 0 0 22 Average 0 22 0 0 22 1 New respondent include sources with constructed, reconstructed and modified affected facilities.

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 22

.11

The total number of annual responses per ye ar 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

Notification of construction/reconstruction 0 1 0 0 Notification of actual startup 0 1 0 0 Notification of initial performance test 0 1 0 0 Report of performance test 0 1 0 0 Report of repeat of performance test 0 0 .2 0 0 Quarterly report of VOCs emission exceedances 22 0.5 0 11 Semiannual report of no exceedances 22 2 0 44 Notification of noncompliance 22 0 0 0
Total 55 The number of Total Annual Responses is 55. The total annual labor costs are $180,0 60

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– N SPS for Sy nthetic Fiber Production Facilities (40 CFR Part 60 , Subpart HHH ) (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, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 1,8 60 at a cost of $180,058

. Details regarding these estimates may

be found below in Table 1: Annual Respondent Burden and Cost

– N SPS for Sy nthetic Fiber Production Facilities (40 CFR Part 60 , Subpart HHH ) (Renewal)

. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 34 hours per response

.12

The total annual capital/startup and O&M costs to the regulated entity are $165,00 0

. 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 y ears is estimated to be 127 labor hours at a cost of $5,701 . See below Table 2: Average Annual EPA Burden and Cost

– N SPS for Sy

nthetic Fiber Production Facilities (40 CFR Part 60 , Subpart HHH ) (Renewal)

. **6(f) Reasons for Change in Burden** There is no significant change in the respondent burden hours in this I CR compared to the previous ICR. This is due to two considerations : 1) the regulations have not changed over the past three ye ars and are not anticipated to change over the next three years ; and 2) the growth rate for the industry

is very low, negative or non

- existent, so there is no significant change in the overall burde n. However, there is a slight increase of one burden hour for both the respondents and the Agency

due correction s of rounding error s in the previous I CR. There is an increase in burden costs for both the respondents and the Agency due to an adjustment i n labor rates. This I CR uses updated labor rates from the Bureau of Labor Statistics to calculate burden costs. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 34 hours per response. “ Burden ” means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; dev elop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 agenc y m ay

not conduct or sponsor, and a person is not required to respond to, a collection of information unless it display s 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 t his I CR under Docket ID Number EPA

–HQ

– OECA

–2012

– 0528. An electronic version of the public docket is available at http://www.regulations.gov/ which may be used to obtain a copy

of the draft13

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 sy stem , select “search,” then key in the docket ID number identified in this document. The documents are al so 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation 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

–2012

– 0528 and OMB Control Number 2060

- 0059 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.14

**Table 1: Annual Respondent Burden and Cost**

**– NSPS for Synthetic Fiber Production Faci**  **lities (40 CFR Part 60, Subpart HHH) (Renewal)** 

**Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**P erson**  **hours per respondent**  **per year (AxB)**  **(D) Respondents**  **per year a**  **(E)**

**Technical person**  **** **hours per year**  **(CxD) (F)**  **Managem ent**  **person**   ** hours per** **year (Ex0.05)**  **(G)**

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

1. Applications N/A 2. Survey and Studies N/A 3. Reporting Requirements A. Read instructions 1 1 1 0 0 0 0 $0 B. Required activities Initial performance test 72 1 72 0 0 0 0 $0 Repeat performance test c 72 1 72 0 0 0 0 $0 C. Create information See 3B D. Gather existing information See 3B E. Write report New Sour ces Notification of construction/ reconstruction d 2 1 2 0 0 0 0 $0 Notification of actual startup d 2 1 2 0 0 0 0 $0 Notification of initial performance test d 2 1 2 0 0 0 0 $0 Notification of demonstration of CMS d 2 1 2 0 0 0 0 $0 Report of initial performance test d See 3B Existing Sources Quarterly report of VOCs emission exceedances e 8 0.5 4 22 88 4.4 8.8 $9,799.06 Semiannual report of no exceedances f 2 2 4 22 88 4.4 8.8 $9,799.0615

**Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**P erson**  **hours per respondent**  **per year (AxB)**  **(D) Respondents**  **per year a**  **(E)**

**Technical person**  **** **hours per year**  **(CxD) (F)**  **Managem ent**  **person**   ** hours per** **year (Ex0.05)**  **(G)**

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

Notification of noncompliance g 2 1 2 0 0 0 0 $0 **Subtotal for**  **Reporting Requirements**  202 .4 $19,598.1 2 4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities See 4C C. Impl ement activities See 3B D. Develop record system See 4E E. Time to enter information Records of operating parameters h 0.25 250 62.5 22 1 , 375 68.75 137.5 $153,110.38 Records of monthly VOC emission i 0.25 12 3 22 66 3.3 6.6 $7,349.30 F. Time to train personnel N/A G. Time for audits N/A **Subtotal for**  **Recordkeeping Requirements**  1,657 .15 $160,459.6 8 **TOTAL LABOR BURDEN AND COST (rounded)**  1,8 60 $180,058

**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to the rule will be 22. There will be no additio nal new source that will become subject to the rule over the three

- year period of this ICR. b This ICR uses the following labor rates: $ 121.44 per hour for Executive, Administrative, and Managerial labor; $ 100.23 per hour for Technical labor, and $ 50.51 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2012 “ Table 2. Civilian Workers, by O ccupational and I ndustry Group. ” The rates are from column 1, “ Total compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry. c We have ass umed that 20 percent of initial performance tests will be repeated. d We have assumed that there will be no new sources over the three

- year period of this ICR.16

e We have assumed that each respondent will submit one quarterly report every other year due t o excess of volatile organic compounds (VOCs) emissions. f Semiannual reports are required of all respondents. g We have assumed that there are no existing solvent

- spun synthetic fiber producing facility subject to the exemption under section 60,600(a) that has exceeded the annual requirement of 500 mg. Therefore, no existing solvent

- spun synthetic fiber producing facility will submit a notification of exceeding the limits over the three

year period of the ICR. h We have assumed that respondents will e nter information on records of operating parameters 250 days per year. i Respondents are required to conduct monthly calculation of the 6 months VOC average emission which is considered a performanc e test. Respondents will have to determine this value by calculating the VOC emissions per unit of mass solvent feed from each affected facility for the current and proceeding five c onsecutive calendar mo nths.17

**Table 2: Average Annual EPA Burden and Cost**

**– NSPS for Synthetic Fiber Production Faci**  **lities (40 CFR Pa**  **rt 60, Subpart HHH) (Renewal)** 

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**  **hours per plant per**  **year (AxB)**  **(D)**

**Plants per**  **year a**  **(E) Technical**  **person**   ** hours per** **year (CxD)**  **(F)**

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per year**  **(Ex0.1) (H)** 

**Cost, $ b** 

Required Activities New Plant Initial performance test 24 1 24 0 0 0 0 $0 Repeat performance test c 24 0.2 4.8 0 0 0 0 $0 Report review New Plant Notification of construction 2 1 2 0 0 0 0 $0 Notification of actual startup 0.5 1 0.5 0 0 0 0 $0 Notification of initial test 0.5 1.2 0 .6 0 0 0 0 $0 Review test results 8 1.2 9.6 0 0 0 0 $0 Notification of demonstration of CMS 0.5 1 0.5 0 0 0 0 $0 Existing Plant Quarterly report of VOCs emission exceedances d 2 0.5 1 22 22 1.1 2.2 $1,140 Semiannual report of no VOC emission exceedances e 2 2 4 22 88 4.4 8.8 $4,561 Notification of noncompliance 2 0 0 0 0 0 0 $0 Subtotals Labor Burden and cost 110 5.5 11 $5,70 1 **TOTAL ANNUAL BURDEN AND COST (rounded)**  127 $5,701

**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to the rule will be 22. There will be no additio nal new source that will become subject to the rule over the three

- year period of this ICR.18

b This cost is ba sed on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead e xpenses: Managerial rate of $ 62.27 (GS

- 13, Step 5, $ 38.92 x 1.6), Technical rate of $ 46.21 (GS

- 12, Step 1, $ 28.88 x 1.6), and Cler ical rate of $ 25.01 (GS

- 6, Step 3, $ 15.63 x 1.6). These rates are from the Offic e of Personnel Management (OPM), “ 20 11 General Schedule ” which excludes locality rates of pay. c We have assumed that 20 percent of initial performance tests will be repeated. d We have assumed that each respondent will submit one quarterly report every other year due to excess of volatile organic comp ounds (VOCs) emissions. e Semiannual re ports are required of all respondents.