p.1 

OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

95) IV-H-2 

Docket Number: 

A-81-21 

Printed 4/14/2008 8:47:03 AM Sheet 95 of 106 
P.2 

Standard Form 83 

(•M.Saa«MiMrl9B3) 

yuc A-81- 21 

IV-H-2 

Request for OMB Review 

Important 

Read instructions before completing form. Oo not use the same SF 83 

to request both an Executive Order 12291 review and approval under 

the Paperwork Reduction Act. 

Answer ail questions in Part I. If this request is for review under E.O. 

12291. complete Part II and sign the regulatory certification. If this 

request is for approval under tht Paperwork Reduction Act and 5 CFR 

1320. skip Part II. complete Part III and sign the paperwork certification. 

Send three copies of this form, the material to be reviewed, and fo 

paperwork—three copies of the supporting statement, to: 

Office of Information and Regulatory Affairs 

Office of Management and Budget 

Attention: Docket Library. Room 3201 

Washington. DC 20503 

PART I.—Complete This Part for All Requests. 

L Department/agency and Bureau/office originating request 

EPA/OAR/OAQPS/SSCD 

3. Name of person who can best answer questions regarding this request 

Doreen Cantor 

2. Agency code 

0 0 

Telephone number 

( 202 ) 382-2874 

4. Title of infonnation collection or rulemaking 

NESHAP for Vinyl Chloride (subpart F) 

- Information Requirements 

5. Legal authority for information collection or rule (a:* Umteti States Cod*. Public Law, or Executive Order) 

42 ^ 4711 

.or. 

«. Affected public (cftee* all Out apply) 

1 Q Individuals or households 

2 Q State or local governments 

3 • Farms 

4 5 ] Businesses or other for-profit 

5 D Federal agencies or employees 

6 Q Non-prof it institutions 

7 Q Small businesses or organizations 

PART II.—Complete This Part Only if the Request Is for OMB Review Under Executive Order 12291 

7. Regulation Identifier Number (RIN) 

tb Type of submission (chick one in eaeh category) 

CtataMkaOoa 

1 G Major 

2 Q Nonmaior 

or. None assigned Q 

Scage or #eve4eawiefra 

1 Q Proposed or draft 

2 D Pinal or interim final, with prior proposal 

3 Q Final or intehm final, without prior proposal 

Type of review requested 

1 D Standard 

2 D Pending 

3 D Emergency 

4 D Statutory or judicial deadline 

9. CFR section affected 

m . 

10. Does this regulation contain reporting or recordkeeping requirements that require OMB approval under the Paperwork Reduction Act 

and 5 CFR 1320' PI Yes R ( 

Certification for Regulatory Submissions 

In submitting this request for OMB review, the authorized regulatory contact and the program official certify that the requirements of E.0. 12291 and any apoiiea&lc 

policy directives have been complied with. 

Signature of program official 

Signature of authorized regulatory contact 

Date 

Oate 

12. (OMB uae only) 
P.3 

PART lll.--Complete This Part Only if the Request is for Approval of a Collection 

1

 of Information Under the Paperwork Reduction Act and 5 CFR 1320. 

llbAbstrect—Describe needs, uses and affected public in 50 words or less The owner or operato r must submit an applicatio n 

for approval of construction or modification (new sources), notification of startup 

(new sources), waiver of emission test if desired, report within 10 days of each manual 

vent or relief valve discharge, and quarterly reports. EPA uses this information to 

directly determine the compliance status of sources in lieu of on-site surveillance 

14. Type of infonnation collection (cftec* only one) 

Information collections not contained In rvha 

1 D Regular submission 

Information collections contained ki rules 

3 D Existing regulation (no change proposed; 

4 D Notice of proposed rulemaking (NPRM) 

5 LH Final. NPRM was previously published 

2 D Emergency submission (c*rt//»cef/on attached) 

6 Final or interim final without prior NPRM 

A Q Regular submission 

BPj Emergency submission (certification attached) 

7. Enter date of expected or actual Federal 

Register publication at this stage of rulemaking 

(month, day. yoar): August 1986 

15. Type of review requested (check only one) 

1 D New collection 

2 LH Revision of a currently approved collection 

3 D Extension of the expiration date of a currently approved collection 

without any change in the substance or in the method of collection 

4 D Reinstatement of a previously approved collection for which approval 

has aspired 

5 D Existing collection in use without an OMB control number 

22. Purpose of information collection (check as many as apply) 

1 D Application for benefits 

2 D Program evaluation 

3 D General purpose statistics 

4 12 Regulatory or compliance 

5 D Program planning or management 

6 D Research 

7Q Aud« 

16. Agency report form numbers) (include standard/optional form numbers)) 

0191/0186 

17. Annual reporting or disclosure burden 

1 Number of respondents 

2 Number of responses per respondent . . 

3 Total annual responses (lino I tones line 2) 

4 Hours par response 

5 Total hours (line 3 times line 4) . . . . 

44 

308 

54.86 

16^896 

18. Annual recordkeeping burden 

1 Number of recordkeepers 

2 Annual hours per recordkeeper 

3 Total recordkeeping hours (line 1 times line 2) 

4 Recordkeeping retention period 

44 

142 

23b Frequency of recordkeeping or reporting (check all that apply) 

1 Q Recordkeeping 

6,248 

years 

19. Total annual burden 

1 Requested (line J 7-5 pfus Una 18-3) 

2 In current OMB inventory . . . . 

3 Difference (line 1 leas line 2) . . . 

Explanation of difference 

4 Program change 

5 Adjustment 

23,144 

T7TBTT 

21,984 

21.984 

2 Ql On occasion 

3 D Weekly 

4 D Monthly 

5 (S Quarterly 

6 Cu Semi-annually 

7 D Annually 

8 D Biennially 

9 D Other (describe): 

20. Cunent (most recant) OMB control number or comment number 

2060 - 0071 

21. Requested expiration date 

August 1989 

24. Respondents' obligation to comply (check the strongest obligation thatapp

1 D Voluntary 

2 D Required to obtain or retain a benefit 

3 E Mandatory 

25. Are the respondents primarily educational agencies or institutions or is tne pnmary purpose of the collection related to Federal education programs? D v«* 03 r 

26. Does the agency use sampling to select respondents or does the agency recommend or prescribe the use of sampling or statistical analysis •—• --, 

by respondents? LJ Vos UJ r 

27. Regulatory aAjthority tor the information collection 9/) _ 

40 era, §61.07 . 09,1? , fid-7lY^4/ FR :or.OtherrspecfW. 

Paperwork CortHliaHori 

fn submitting this request for OMB approval, the agency head, the senior official or an authonzed representative, certifies that the requirements of 5 CFR 1320. 

Privacy Act. statistical standards or directives, and any other applicable information policy directives have been complied with. 

Signature of program official Date 

Signature of agency head, the senior official or an authorized representative Date 
P.4 

SF-83 SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY 

EMISSION STANDARDS FOR VINYL CHLORIDE 

A. Background 

The NESHAP for vinyl chloride was proposed on December 24, 1975, 

promulgated on October 21, 1976. Based on a review of the vinyl chloride 

standard, several administrative revisions to the current standards were 

proposed on January 9, 1985. Three of these proposed administrative 

revisions affect the reporting and recordkeeping requirements of the 

standard. 

The vinyl chloride standard applies to exhaust gases and 

oxychlorination vents at ethylene dichloride (EDC) plants; exhaust gases at 

vinyl chloride monomer (VCM) plants; and exhaust gases, reactor opening 

losses, manual vent valves, and stripping residuals at polyvinyl chloride 

(PVC) plants. The standard also applies to relief valves and fugitive 

emission sources at all three types of plants. The standard currently 

applies to 44 sources, and no new sources are expected in the next three 

years. 

On October 29, 1985, a Standard Form 83 (SF-83) with accompanying 

support statement was submitted to the Office of Management and Budget 

seeking reinstatement of the approval of the information collection request 

for the current standard. The October 29, 1985 document discusses the 

reporting and recordkeeping requirments of the existing standard and 

presents calculations of the burdens on government and on private 
P.5 

respondents created by those requirements. In lieu of repeating the 

discussions and calculations presented in that previous document, this 

supporting statement will focus on the changes brought about by the 

revisions to the reporting and recordkeeping requirements being promulgated 

in this action. 

One revision to the reporting requirements being promulgated requires 

quarterly reporting of vinyl chloride emissions from stripping, reactor 

openings, and exhaust gases, in lieu of semi-annual reporting. In addition, 

these reports are being modified to require reporting of periods of excess 

emissions instead of all emission measurements. Data from stripper and 

reactor opening losses will be used directly to judge compliance with the 

numerical limits of the standard. The second revision to the reporting 

requirements of the standard incorporates the reporting requirements of 

Subpart V of 40 CFR Part 61 into this standard. Subpart V establishes 

requirements for detecting and eliminating leaks of volatile hazardous air 

pollutants from process equipment, and for the reporting of such leaks on a 

semi-annual basis. The third revision increases the recordkeeping 

requirement from 2 to 3 years. 

The reporting and recordkeeping provisions of the original vinyl 

chloride standard require owners or operators of the affected sources to 

make the following one-time-only reports: application for approval of 

construction or modification; notification of startup; application of waiver 

of testing (if desired by source); application for equivalency (if desired 

by source); and initial report, which is to include a list of the equipment 

installed for compliance, a description of the physical and functional 
P.6 

characteristics of each piece of equipment, a description of the methods 

which have been incorporated into the standard operating procedures for 

measuring or calculating emissions, and a statement that the equipment and 

procedures are in place and are being used. 

Owners or operators are also required to maintain records of leaks 

detected by vinyl chloride monitors, vinyl chloride emissions as measured by 

the continuous emission monitor, and operating parameters (pressure and 

temperature) of the PVC reactor. Owners or operators are also required to 

report within 10 days of each relief valve discharge. 

Generally, the one-time-only reports are required of all sources 

subject to a NESHAP. The recordkeeping and other reporting requirements are 

specific to this NESHAP. To fulfill the recordkeeping requirement, sources 

detect leaks in accordance with an approved leak detection and elimination 

program, which generally consists of an area VC monitoring system and a 

portable HC detector to find small leaks of VC and to pinpoint major VC 

leaks indicated by the area system. Action taken to repair leaks must also 

be recorded and kept on file. Excess stack emissions are generally recorded 

automatically by a continuous emission monitor. Reactor operating 

parameters (temperature and pressure) are also recorded automatically by a 

device that continuously monitors these parameters. 

To fulfill the reporting requirements, in addition to the action above, 

the owner or operator must measure the VC concentration each time a reactor 

is opened, and also must measure the VC residual in the stripped resin 

according to prescribed test procedures. When relief valve discharges 

occur, the owner or operator must submit a report containing the source, 
P.7 

nature and cause of the discharge, the approximate VC loss, the method used 

to determine this loss, the action taken to prevent the discharge, and the 

measures adopted to prevent future discharges. 

All reports are sent to the delegated State authority. In the event 

that there is no such delegated State authority then the reports are sent 

directly to the EPA Regional Office. Notifications are used to inform the 

Agency or delegated State authority when a source becomes subject to the 

standard. The reviewing authority may then inspect the source to check if 

the source has installed the proper pollution control devices, and to check 

that the devices are properly operated. Enforcement action may be taken 

solely on the basis of the quarterly reports and also on the basis of the 

discharge reports. These are also used to spot trends and to plan 

strategies. 

B. Justification 

(1) Need for the Information Collection. The EPA is charged under 

Section 112 of the Clean Air Act, as amended, to establish national emission 

standards for hazardous air pollutants that reflect: 

.... the level which . . . provides an ample margin of safety 

to protect the public health from such hazardous air pollutants 

[Section 112(b)(1)(B)]. 

In addition, Section 114(a) states that: 

. . . the Administrator may require any owner or 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 or methods (in 
P.8 

accordance with such methods at such locations, at such 

intervals, and in such manner as the Administrator shall 

prescribe), and (d) provide such other information, as he 

may reasonably require. 

In the Administrator's judgment, vinyl chloride emissions from PVC, 

EDC, and VCM plants cause or contribute to air pollution that may reasonably 

be anticipated to result in an increase in mortality or an increase in 

serious irreversible, or incapacitating reversible illness. Therefore, 

emission standards known as National Emission Standards for Hazardous Air 

Pollutants (NESHAPs) have been promulgated for this source category. 

The control of emissions of vinyl chloride from PVC, EDC, and VCM 

plants require not only the installation of properly designed equipment, but 

also the operation and maintenance of that equipment, and the use of proper 

work practices by trained operators. Vinyl chloride emissions from PVC, 

EDC, and VCM plants are the result of volatilization of vinyl chloride from 

reactors and stripped resins; as it escapes through relief valves, manual 

vent valves, and equipment leaks; and emissions from the stack gas control 

devices. These standards rely on the control of vinyl chloride by such 

means as equipment installation, operator training, proper work practices, 

computerization, and other possibilities depending on each plant's 

configuration and needs. 

In order to ensure compliance with such standards, adequate reporting 

is necessary. In the absence of such information enforcement personnel 

would be unable to determine whether the standards are being met and that 

public health is being protected, as required by the Clean Air Act. 
P.9 

(2) Description and Practical Utility of the Information Collection 

Activity. Table 1 presents a cross-reference between the reporting 

requirements of the VC standard and the associated section of the 

regulation. The primary purpose of the required records and reports is to 

enable the EPA to determine whether plants are in compliance with various 

parts of the standard and to reveal misunderstandings by plant personnel 

about how the requirements of the standard are to be met. In addition, the 

EPA can assess the need and scope for plant inspections based on reported 

information. In the absence of the described reports and records, 

circumvention of the standard may result. 

The standard being promulgated requires quarterly reporting of vinyl 

chloride emissions from stripping, reactor openings, and exhaust gases. 

This reporting requirement is an increase over the semi-annual reporting 

requirement in the original standard. However, EPA believes that quarterly 

reporting of these emissions is necessary for this source category because 

of the toxic nature of vinyl chloride and the capability and desire of 

enforcement agencies to take quick action. The quarterly reporting period 

is also consistent with EPA's generic reporting scheme, which recommends 

quarterly reporting for all NESHAP sources and for any other sources where 

direct compliance information is obtained. This standard fits into both of 

these categories. Previously, sources were required to include in the 

semi-annual report all emission measurements required by the emission 

standards for resin stripping, reactor openings, and exhaust gases; the 

promulgated standard allows sources to report only periods of excess 

emissions in the quarterly report. 
P.10 

In addition to the quarterly reports described above, all respondents 

with equipment components in VC service are also required to submit 

semi-annual reports summarizing the status of the leak detection and repair 

program at the plant. These reports will include information on the number 

of leak occurrences, the number that could not be repaired, and the reasons 

for unsuccessful or delayed repair. 

Under the standard, the data collected by the affected industry would 

be retained at the facility for a minimum of 3 years and made available for 

inspection by the Administrator. This represents an increase in 

recordkeeping requirements from 2 to 3 years. 

The information generated by the monitoring, recordkeeping and 

reporting requirements described above will be used by the Agency (in 

conjunction with the other reporting and recordkeeping requirements of the 

standard discussed in the previous SF-83 and Support Statement) to ensure 

that facilities affected by the NESHAP continue to operate the control 

equipment and use proper work practices to achieve compliance with the 

NESHAP. 

If the information required by the standard were not collected, the 

Agency would have no means for ensuring that compliance with the NESHAP is 

achieved and maintained by the sources subject to regulation. Under these 

circumstances, an owner or operator could elect to reduce operating expenses 

by not installing, maintaining or otherwise operating, the control 

technology or by not using adequate work practices to comply with the 

standards. In the absence of the information collection requirements, 

compliance with the standards could be ensured only through continuous 
P.11 

on-site inspections by regulatory agency personnel. Consequently, not 

collecting the information would result in either greatly increased 

expenditures of resources, or the inability to ensure compliance with the 

standards. 

The information collected from recordkeeping and reporting requirements 

is reviewed at the State and/or EPA level and is necessary for several 

purposes in addition to those stated above. The information may be and is 

used in targeting inspections. The information is also frequently used in 

court proceedings as evidence of non-compliance. 

(3) Minimizing Burden. The burden to respondents has been minimized 

by requiring the collection of only that information which the Agency 

considers essential to ensure that PVC, EDC, and VCM plants are properly 

maintained and operated on a continuing basis. The revision changing 

semi-annual reporting to quarterly reporting should not involve a 

significant increase in the burden imposed by the reporting and 

recordkeeping requirements of the standard. This revision only requires 

that information be submitted more frequently, and does not require any 

increase in the quantity of information being submitted. In fact, the 

quantity of information being submitted should decrease for most sources 

because only excess emission periods are required to be reported. 

e 

Therefore, although the number of reports per year is doubled, the number of 

hours spent on the preparation of each report is essentially halved. 

Similarly, the inclusion of the reporting requirements of Subpart V will 

also have little impact on the burden of the standard on industry. The 

information required to be maintained and reported under these provisions 
P.12 

duplicates information which would be maintained by industry in the absence 

of a standard. 

The burden has been minimized by requiring sources to submit release 

valve discharge (RVD) reports within 10 days, instead of within a shorter 

period (e.g., 24 hours) as has been suggested. The EPA feels that a shorter 

reporting period may be desirable for individual sources, but not 

across-the-board. States may, however, shorten the reporting period for 

•individual sources if warranted by specific circumstances. 

(4) Non Pup!ication. Certain reports required by State or local 

agencies may duplicate information required by the recommended standards. 

In such case, 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 

recommended standard. 

There are no other sources of similar information since the standards 

ask for records and reports of vinyl chloride from several emission points 

unique to each of the PVC, EDC, and VCM plants. The Information Management 

Section of the EPA's Office of Policy, Planning, and Evaluation will conduct 

a search of the Federal Information Locator System to determine if any 

duplication is indicated there. 

(5) Consideration of Alternatives. The alternatives considered 

involved the frequency and quantity of the reporting requirements. The 

Agency is requiring that only the initial reports, 10-day reports of relief 

valves discharges and manual vent valve discharges, reports concerning leak 

detection and elimination, and quarterly reports need to be submitted. The 
10-day reports of discharges are made only if discharges were experienced by 

the plant. 

One alternative considered was to allow plants to report relief valve 

discharges when they submitted the quarterly reports. The standard was, in 

fact, proposed with this alternative. However, this was decided against for 

several reasons: 

(1) The quarterly reports address emissions which are generally 

low-level and steady state. When exceedances of the stack gas, stripping, 

or reactor opening loss standard occur, they are serious because of their 

effect over time. However, relief valve and manual vent valve discharges 

involve large quantities of vinyl chloride (one discharge was estimated at 

72 tons) over very short periods of time, therefore making them much more 

serious in the short-run. In some catastrophic cases, the public must be 

notified of such discharges and given appropriate instructions. Therefore, 

a short reporting time is essential. 

(2) Two of the States with the largest number of vinyl chloride 

sources allow an even shorter reporting time. One requires plants to report 

within 48 hours, and the other requires selected plants to report 

immediately, and would consider criminal action if a plant waited even hours 

before reporting. With the newly-recognized potential for chemical 

catastrophes, these shorter reporting times may be more beneficial. 

(3) States routinely take action on these reports within a short time 

period. One State reported that their investigations are usually completed 

within 45 days of the release. 

10 
P.M 

(4) Comments received on this proposed change were negative. Comments 

were received from one citizen's group, one member of Congress, and one 

State agency. All three commenters recommended that the 10-day reporting 

requirement be retained or that this period be made even shorter. Reasons 

for this included (a) a shorter reporting period gives the public access to 

information they have the right to know regarding their exposure to 

hazardous substances, (b) a short reporting period gives local, State, and 

EPA officials prompt notice that a carcinogenic substance has been released 

into the atmosphere and allows prompt follow-up action to aid in the 

prevention of repeat incidents, (c) a longer reporting period promotes a 

perception that the discharge is merely "past history", (d) a longer 

reporting time would allow details of the event to become clouded in the 

memories of those involved before an investigation could take place, and 

(e) prompt notification, investigation, and enforcement action (if 

justified) has been found to work to the mutual advantage of industry and 

the enforcement agencies. We agree that these arguments have merit and that 

States should and do take prompt action to modify source procedures on the 

basis of these reports. 

The 10-day reporting period represents a reasoned balance between the 

EPA's need to obtain information quickly and the time needed by the source 

to assemble the information to be reported (i.e., cause of discharge, 

remedial actions taken, etc.). Therefore, EPA believes that including 

reports of discharges with the quarterly reports is not warranted, and 

retains the 10-day reporting period for relief valve discharges. This 

11 
P.15 

change will ensure that State agencies will not be hindered in their current 

practice of taking swift action when a discharge occurs. 

(6) Minimizing of Burden for Small Businesses. Not applicable because 

the number of employees at PVC, EDC, and VCM plants exceeds the criterion 

for small businesses. 

(7) Consideration of Collections. If the information required by 

these standards was collected less frequently, the main consequence would be 

that the chances of detecting poor operation and maintenance of control 

equipment would decrease and that the public would risk exposure to harmful 

quantities of VC. Less frequent information collection would decrease the 

margin of assurance that facilities are continuing to meet the required 

standards. Requirements for information gathering and recordkeeping is a 

useful technique to ensure that good operation and maintenance practices are 

applied. 

(8) Paperwork Reduction Act Guidelines. There are no special 

circumstances that require the information collection to be conducted in a 

manner inconsistent with the guidelines in 5 CFR 1320.6. 

(9) Consultations. In developing the standards, a number of State 

agencies, owners and operators of affected facilities, and other interested 

parties were contacted. Information gathered from these sources helped 

formulate the information collection requirements. 

(10) 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, 

12 
P.16 

September 1, 1976; amended by 43 FR 39999, September 8, 1978; 43 FR 42251, 

September 28, 1978; 44 FR 17674, March 23, 1979). 

(11) Sensitive Questions. Not applicable. Information consists of 

emissions data and other information that have been determined not to be 

private (also see item number 10). 

(12) Cost to the Government and to the Respondents. 

a. Cost to the Federal Government. Because the information 

collection requirements were developed as an incidental part of the standard 

development, no development costs can be attributed. Because reporting and 

recordkeeping requirements on the part of the respondents are required under 

Section 114 of the Clean Air Act, no operational costs will be incurred by 

the Federal Government. The only Federal costs that will accrue are user 

costs associated with the analysis of the reported information. Publication 

and distribution of the information are part of the Compliance Data System 

(as discussed in Section 15) with the result that no Federal costs can be 

directly attributed to the ICR. Examination of records to be maintained by 

the respondents will incidentally occur as part of periodic inspection of 

sources, which is part of the EPA's overall compliance and enforcement 

program. 

The average annual Federal Government cost during each of the next 3 

years of the ICR is estimated to be $93,280. This cost is based on an 

average wage of $12.60 per hour ($26,168 per year) and a 110 percent 

overhead rate. Details upon which this estimate is based appear in Table 2. 

Breakdown of costs by cost category is presented as follows: 

13 
P.17 

Average Direct Personnel Cost $93,280.00 

(including overhead) 

Other Direct Costs 0 

Total $93,280.00 

b. Cost to the Respondents. The only type of industry costs 

associated with the information collection activity in the standards are 

labor costs. These respondent costs have been calculated on the basis of 

$26,168 per year for 2,080 hours per year plus 110 percent overhead, and 

they are based on the burden estimates in Table 3. The average annual 

respondent cost during each of the next 3 years of the ICR is estimated to 

be $613,316. 

13. Estimation of Respondent Burden. The annual burden estimates for 

reporting and recordkeeping for new facilities are presented in Table 2. 

These numbers were derived from standard estimates based on the EPA's 

experience with other standards. 

No applications, surveys, or other studies are required by the 

standards. Reporting requirements consist of the following one-time-only 

report: 

Application for approval of construction or modification. 

Notification of start-up. 

Application for waiver of testing (if desired by source). 

Application for equivalency (if desired by source). 

Initial report. 

Quarterly reports of reactor opening losses, stripping residuals, and 

exhaust emissions are also required. In addition, the burden includes 

14 
P.18 

reports of relief valve discharges which are submitted if a source 

experiences a discharge. 

Recordkeeping requirements involve only those activities associated 

with entering and maintaining the information required by the standard. It 

is estimated that 142 person-hours per source per year would be needed to 

conduct these activities. 

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

these reporting and recordkeeping requirements is estimated to be 1,494 

person-hours. 

14 Change in Burden. No increase in the burden hours from that 

estimated in the October 29, 1985 submittal is anticipated to follow from 

the change from semi-annual reporting to quarterly reporting, or from the 

inclusion of the Subpart V reporting requirements in this standard. In the 

first instance, the change to quarterly reporting does not entail the 

submittal of any information in addition to that required under the previous 

semi-annual reporting requirement. (In fact, less information will be 

required in most cases because only excess emissions are to be reported.) 

Further, no additional information gathering activities are required under 

the new requirement. The only requirement is for this information to be 

forwarded to EPA on a more frequent basis. 

Similarly, the information required by the addition of the Subpart V 

requirements to the VC standard will not require additional information to 

be gathered. It is anticipated that all of the information that is required 

by Subpart V will be gathered by the industrial source in any case, in order 

to assure the proper operation and efficiency of the leak detection and 

15 
P.19 

elimination system. Consequently, the addition of a requirement that this 

information be reported to EPA does not add significantly to the burden 

previously imposed on the respondents. 

15 Scheduling. Inormation contained in the one-time reports will be 

entered into the Compliance Data System operated and maintained by the EPA's 

Division of Stationary Source Compliance. Data obtained through 10-day and 

quarterly reports and periodic visits by Agency personnel from records 

maintained by the respondents and any requested performance tests will be 

tabulated and published for internal Agency use in compliance and 

enforcement programs. The records required by this NSPS must be retained by 

the owner or operator for two years. 

16. Standard Industrial Classifications (SIC). The SIC code for the 

respondents affected by this standard is 2821. 

C. Collections of Information Employing Statistical Methods. 

Not applicable. 

16 
P.20 

TABLE 1. SOURCE DATA AND INFORMATION REQUIREMENTS -

VINYL CHLORIDE NESHAP SUBPART F 

Requirement Regulatory Reference 

Application for approval of 40 CFR §61.07 

construction or modification 

Notification of startup 40 CFR §61.09 

Application for waiver of testing 40 CFR §61.13 

Application for equivalent equipment 40 CFR §61.66 

and procedures 

Initial Report 40 CFR §61.69 

Quarterly Report 40 CFR §61.70 

Relief valve discharge report 40 CFR §61.65(a) 

Recordkeeping 40 CFR §61.71 

Leak detection and elimination 40 CFR §61.247 
TABLE 2. AVERAGE ANNUAL EPA RESOURCE REQUIREMENT 

Activity 

(A) 

EPA hr/ 

Occurrence 

(B) 

Occurrences/ 

Plant/yr 

(C)a 

EPA hr/ 

Plant/yr 

(D) 

Plants/yr 

(E)D 

EPA 

hr/yr 

Monitoring emission tests 

Initial test 

Report testc 

24 

24 

1 

0.2 

24 

4.8 

0 

0 

Report Review 

Application for approval of 

construction or modification 

Notification of startup 

Application for waiver of testing 

Application for equivalency 

Initial report 

Quarterly report 

RVD report 

TOTAL ANNUAL HOURS 

Travel expenses 

(1 person x 0 plants/yr x 3 day/plant x $50 per diem) + ($250 round trip/plant x 0 plants/yr) 

= $0/yr 

Salary 

(1 person x 3,520 hr/yr x $26.50/hr) = $93,280/yr 

0 

0 

0.5 

24 

24 

8 

2 

24 

1 

1 

1 

1 

4 

3 

0.5 

24 

24 

8 

8 

72 

0 

0 

0 

0 

44 

44 

0 

0 

0 

0 

352 

3,168 

3,520 

TOTAL ANNUAL COST = $93,280 

'AxB = C. 

?CxD = E. 

"Assume 20 percent of initial emission tests must be repeated due to failure. 
TABLE 3. ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS AS A RESULT OF THE STANDARDS" 

Hours per 

Occurrence 

(A) 

Occurrences/ 

Respondent/ 

year 

(B) 

Hours/ 

Respondent/ 

year 

(C = A X B) 

Respondents 

per year 

(D) 

Hours 

per year 

(E - C X D) 

Cost per 

year 

(F) 

1. APPLICATIONS 

3. 

4. 

SURVEY AND STUDIES 

REPORTING KEQUIREMENTS 

A. Read Instructions 

B. Required Activities 

Initial performance test 

Repeat of performance test 

C. Create Information 

D. Gather Existing Infonnation 

E. Write Report 

Application for approval of 

construction or modification 

Notification of startup 

Application for waiver of testing 

Application for equivalency 

Initial report 

Quarterly report 

RVD report 

RECORDKEEPING REQUIREMENTS 

A. Read Instructions 

Plan Activities 

Implement Activities 

B. 

C. 

D. 

E. 

60 

60 

Included 

Included 

2 

2 

9 8 

40 

24 

90 

8 

Included 

Included 

Included 

in 

in 

in 

in 

in 

3B. 

3E. 

3A. 

4C. 

3B. 

1 

0.2 

1 

F. 

G. 

Develop Record System 

Time to Enter Information 

Records of reactor parameters 

and emissions 

Records of leaks detected 

Train Personnel 

Audi ts 

0.25 365*-

52 

Not Applicable 

Not Applicable 

1 

60 

12 

2 

8 

40 

24 

360 

24 

Not Applicable 

90 

52 

Not Applicable 

Not Applicable 

0 

0 

0 

0 

44 

44 

44 

44 

0 

0 

0 

0 

15,840 

1.056 

3,960 

2,288 

0 

0 

0 

0 

0 

0 

419,760 

27,984 

104,940 

60,632 

TOTAL: ANNUAL BURDEN 23.144 613,316 

aAssume an hourly wage of $12.60 plus 110 percent overhead costs which equals $26.50. This amount was multiplied by 

the hours per year in Column E. 

Assume 20 percent of initial performance tests must be repeated due to failure. 

cAssuine operation 365 days per year as specified in the NESHAP review document.