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SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Source Categories: Generic Maximum Achievable Control Technology

Standards (Revised)

1. Identification of the Information Collection

1(a) Title of the Information Collection

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Categories:

Generic Maximum Achievable Control Technology Standards (40 CFR Part 63, Subpart YY)

(Revised), EPA IC R Number 1871.0 8 , OMB Control Number 2060

- 0420.

1(b) Short Characterization/Abstract

The amendments to this ICR are a result of the review of the existing NESHAP for

Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR part

63, Subpart YY) as required by the Clean Air Act. The NESHAP published at 40 CFR part 63,

subpart YY were proposed on October 14, 1998, promulgated on June 29, 1999, and amended

on: November 22, 1999, November 2, 2001, June 7, 2002, and July 7, 2002. These regulations

apply to existing facilities and new facilities of the following four categories: Polycarbonates

(PC) Production, Acrylic and Modacrylic Fibers (AMF), Acetal Resins (AR) Production, and

Hydrogen Fluoride (HF) Production. The current rulemaking applies to hazardous air pollutant

(HAP) emissions from facilities in the PC and AMF source categories. This information is being

collected to assure compliance with 40 CFR part 63, subpart YY. Organic HAP emissions are the

pollutants regulated under this subpart.

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

periodic reports by the owners/operators of the affected facilities. These notifications, reports,

and records are essential in determining compliance, and are required of all affected facilities

subject to NESHAP. Semiannual summary reports are also required.

The rulemaking amend s title 40, chapter I, part 63 subpart YY to include emission

sources for which standards were not previously developed for the AMF so urce category. For the

PC and AMF source categories, it also revises the requirements for leak detection and repair

(LDAR) to allow only one of the previously available compliance options, although monitoring

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of connectors will not be required. For both so urce categories, the amendments also add

requirements to monitor each pressure relief device (PRD) that releases to the atmosphere using

a device or system that is capable of identifying and recording the time and duration of each

pressure release and of n otifying operators that a release has occurred . Information related to

these new provisions is required to be submitted in the semi

- annual reports required by the

existing NESHAP. We believe that the number of affected facilities under this subpart will

re main constant for these source categories. Burden changes associated with these amendments

result from new recordkeeping and reporting requirements associated with the PRD monitoring

requirements for all facilities subject to the AMF and PC MACT standards. The overall change

in burden found in this ICR reflect the provision changes, an update in the cost of labor, and

corrections to the number of affected facilities found in EPA ICR number 1871.0 6

.

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

without any “Terms of Clearance.” The overall change in burden found in this ICR reflect the

provision changes, an update in the cost of labor, and corrections to the number of affected

facilities found in EPA ICR number 1871.0 6

.

The perio d considered in this ICR and throughout this supporting statement is the first

three years following the promulgation of the amended NESHAP for Source Categories: Generic

Maximum Achievable Control Technology Standards (40 CFR part 63, Subpart YY) for the

AMF and PC source categories . The estimates of the size of the regulated universe are based on

data from the National Emissions Inventory (NEI) database, and information from the industries.

There is an annual average of 4 PC Production facilities and 1 AM F Production facility that will

be subject to the regulations. Due to the nature of the industries, it is estimated that no additional

sources will become subject to the standard over the next three years.

2. Need for and Use of the Collection

2(a) Need /Authority for the Collection

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

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

hazardous air pollutants (HAP). These standards are applicable to new or exis ting sources of

HAP and shall require the maximum degree of emission reduction. In addition, section 114(a)

states that the Administrator may require any owner or operator subject to any requirement of

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this Act to:

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

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

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

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

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

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

equipment parameters, production variables or other indirect data

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

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

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

reasonably require.

In the Administrator's judgment, HAP emissions from PC, AMF, AR and HF production

cause or contribute to air pollution that may reasonably be antici pated to endanger public health

or welfare . Therefore, the NESHAP sta ndards were promulgated for these source ca tegories at

40 CFR part 63, subpart YY.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard e nsure compliance with the

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

addition, the collected information is used for targeting inspections and as evidence in legal

proceedings.

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

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

ensure compliance with the standard at all times. During the performance tests, 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 ensure that the pollution control devices are properly

installed and operated, that leaks are being detected and repaired, and that the standards are being

met. Th e performance test may also be observed.

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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.

The information gene rated by the monitoring, recordkeeping and reporting requirements

described in this ICR is used by the Agency to ensure that facilities affected by the NESHAP

continues to operate the control equipment in compliance with the regulation.

3. Non

- duplicatio n, Consultations, and Other Collection Criteria

3(a) Non

- duplication

A search of EPA’s existing standards and ongoing ICR’s revealed no duplication of

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

duplicat e information required by this NESHAP. In these cases, a copy of the report submitted to

the State or local agency can be sent to the Administrator in lieu of the report required by the

Federal standards. Therefore, no duplication exists.

3(b) Public Noti ce Required Prior to ICR Submission to OMB

This ICR is related to amendments to 40 CFR part 63, subpart YY for the AMF and PC

source categories. Comments were solicited on the proposal package and the proposed ICR.

.

Comments were received regarding the pr oposed amendments, but no comments were received

regarding the ICR.

3(c) Consultations

Over the next t hree years, an average of 4 PC p roduction facilities , 1 AMF p roduction

facility , 2 AR production facilities and 1 HF production facility will be subject to the standard

and are affected by the amendments to 40 CFR part 63, subpart YY. In estimating the affected

number of sources and the growth rate of these source categories subject to this standard, we

referenced the most recent ICR, and used other resour ces to obtain the most recent data

available. We reviewed information available from the Online Tracking Information System

(OTIS) which is the primary source of information regarding the number of existing sources.

OTIS data was used in conjunction with i ndustry consultation to verify the number of sources

and the industry growth rate.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that

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

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

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

collected less frequentl y, the proper operation and maintenance of control equipment and the

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements are consistent with the regulations

established by OMB at 5 CFR part 1320, section 1320.5.

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

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

the standards. EPA believes that the five

- year records retention requ irement is consistent with the

Part 70 permit program and the five

- year statute of limitations on which the permit program is

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

source, any pattern of non

- comp liance, and to determine the appropriate level of enforcement

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

years. Without the five

- year record retention, EPA would be prevented from pursuing the

violators due to the destruction or nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made

will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2,

subpart B

- Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1,

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents

The respondents affected by the amendments to 40 CFR part 63, subpart YY are facilities

that produce p olycarbonates an d acrylic and modacrylic fibers . The United States Standard

Industrial Classification (SIC) codes, which correspond to the North American Industry

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Classification System (NAICS) codes, could be found in the following table:

Standard (40 CFR part 63, subpar t YY) SIC Codes NAICS

Codes

Polycarbonates (PC) Production (Synthetic Rubber

Manufacturing 2822 325211

Acrylic and Modacrylic Fibers (AMF) Production (Manmade

Organic Fibers, Except Cellulosic) 2824 325220

Acetal Resins (AR) Production (Plastic Materials, Synthetic

and Resins, and Nonvulcanizable Elastomers) 2821 325211

Hydrogen Fluoride (HF) Production (Industrial Inorganic

Chemicals, Not Elsewhere Classified) 2819 325188

4(b) Information Requested

None of these reporting and recordkeeping requirements violate any of the regulations

established by OMB at 5 CFR part 1320, section 1320.5.

(i) Data Items

All data in this ICR that is recorded and/or reported is required by National Emission

Standards for H azardous Air Pollutants for Source Categories: Generic Maximum Achievable

Control Technology Standards (40 CFR Part 63, Subpart YY)

.

A source must make the following reports:

Notifications for 40 CFR part 63, subpart YY

Application for approval of construction/reconstruction 63.5(d), 63.1110(a)

Notification of initial startup 63.1110(b)

Notification of initial applicability 63.9(b), 63.1110(a),

63.1110(c)

Notification of compliance status 63.9(h), 63.1110(d),

63.1110(a)

Notification and report of performance test and results 63.7(b), 63.9(e),

63.10(d)(2), 63.1110(d),

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63.1110(a)

Rescheduled initial performance test 63.7(b)(2)

Demonstration of continuous monitoring system 63.9(g)

Notification of physical or operational change 63.8(a)

Opacity or visible emissions 63.10(d)(3)

Excess emissions and continuous parameter monitoring systems

(CPMS) performance reports 63.1110(a)

Reports for 40 CFR part 63, subpart YY

Periodic reports (Semiannual or according to the schedule for

Title V) with information on excess emissions and on the

implementation of leak detection and repair standard provisions 63.1110(e), 63.1108(a),

63.1109

A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart YY

Maintain records of startup, shutdown, malfunctions periods

when excess emissions have occurred during the reporting

period 63.10(b)(2), 63.1109(a)

Maintain records of performance test and performance

evaluation results 63.1109(a)

Maintain records of all reports and notifications 63.10(b), 63.1109(a)

Maintain record of applicability 63.10(b)(3), 63.1109(d)

Maintain records of initial and compliance status notifications 63.1416(e)

Records of CPMS operation adjustments, calibration checks, and

maintenance 63.10(b)(2) (vii),

63.1109(a)

Records of implementation of leak detection and repair (LDAR)

standards provision 63.1107

Records are required to be retained for five years 63.10(b)(2)

Electronic Reporting

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Some of the respondents are using monitoring equipment that automatically records

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

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

a plant site.

Also, regulatory agencies in cooperation with the respondents continue to create reporting

systems to transmit data electronically. However, electronic reporting systems are still not widely

used. At this time, it is est imated that approximately 10 percent of the respondents use electronic

reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

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

supply pressure for CPMS.

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, install ing, and utilizing technology and

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

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

maintaining information

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

providing information

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

Transmit, or otherwise disclose the information

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

Management

5(a) Agency Activities

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

storage, and distribution of the required information.

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Agency Activities

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

,

and quality control plan for CMS required to be submitted by industry.

Audit facility records.

Maintain data in the Online Tracking Information System (OTIS)

5(b) Collection Methodology and Management

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

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

test reports are used by the Agen cy to discern a source’s initial capability to comply with the

emission standard, and note the operating conditions under which compliance was achieved.

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

compliance and en forcement programs. The semiannual reports are used for problem

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

determinations.

Information contained in the reports is entered into OTIS which is operated and

maintained by EPA's Office of Compliance. OTIS 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 OTIS for tracking air pollution compliance and

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

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

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

year s.

5(c) Small Entity Flexibility

The impact on small entities was taken into consideration during the development of the

regulation. Due to technical considerations involving the process operations and the type of

control equipment employed, th e recordkeeping and reporting requirements are the same for both

small and large entities. The Agency considers these requirements the minimum needed to

ensure compliance and, therefore, cannot reduce them further for small entities.

5(d) Collection Sched ule

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

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shown below in Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping

Requirements for Source Categories: Generic Maximum Achievable Control Tech nology

Standards (40 CFR Part 63, Subpart YY) (Revised).

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 industries for the subparts included in this ICR. The

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

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

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

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

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

6(a) Estimating Respon dent Burden

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

and reporting requirements is estimated to be 3 ,6 00 (Total Labor Hours from Table 1). These

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

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

approved ICR, and any comments received.

6(b ) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Technical $54.66 ($26.03 + 110%)

Managerial $115.96 ($55.22 + 110%)

Clerical $38.14 ($18.16 + 110%)

These labor rates are based on the May 2012 Nationa l Occupational Employment and Wage

Estimates for the United States , occupational codes 51

- 8091 for chemical plant and system

operators (technical), 11

- 1021 for general and operations managers (managerial) and 43

- 6010 for

secretaries and administrative assi stants (clerical).

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

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

subject standard are 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.

As part of the amendments to the AMF and PC NESHAP, facility owners or operators are

required to monitor each PRD that releases to the atmosphere using a device or system that is

capable of identifying and recording the time an d duration of each pressure release and of

notifying operators that a release has occurred. For purposes of estimating the costs of this

requirement, we assumed that operators would install electronic indicators on each PRD in

organic HAP service that vent s to the atmosphere. The cost of each monitoring system depends

on the number of PRDs at the facilities. The cost for this system for the one facility in the AMF

source category is expected to be $37,063, and the total cost for these capital expenditures f or the

4 facilities in the PC source category is estimated to be $ 50,596 . For equipment leaks, facility

owners or operators would also be required to follow the leak detection and repair (LDAR)

requirements of part 63, subpart UU, rather than part 63 subpa rt TT under the amendments to the

AMF and PC NESHAP, with the exception of the connector monitoring requirements. The

capital costs associated with this requirement are estimated to be $1,428 for the AMF source

category and $15,596 for the PC source catego ry.

Annualized costs are calculated by multiplying the capital recovery factor by the capital

cost. The capital recovery factor is 0.1098 based on an interest rate of 7 percent and an assumed

equipment life of 15 years. The total annualized capital cost fo r the PRD and LDAR

requirements for the AMF source category is $5,500 and is $9,380 for the PC source category.

The annual operation and maintenance costs are the ongoing costs to maintain the

monitors and other costs such as photocopying and postage. Bas ed on a previous ICR for the

Pesticide Active Ingredient source category, which estimated the annual O&M costs to be $1,450

per source in 2011 dollars, inflating this number from 2011 dollars to 2013 dollars gives $1,505

per source. The total annual O&M co st for the AMF source category is $1,505 and for the PC

source category it is $6,020.

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

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

(A)

Source Category

and Cost Type (B)

Capital/

Startup Cost

for One

Respondent (C)

Number of

Respondents (D)

Total

Capital/

Startup Cost

(B X C) (E)

Annual Costs

for One

Respondent (F)

Number of

Respondents (G)

Total

Annual

Cost

(E X F)

PC (O&M) $0 0 $0 $1,505 4 $6,020

PC (PRD) $ 12,649 4 $ 50,596 $1,804 4 $7,216

PC (LDAR) $3,899 4 $15,596 $541 4 $2,164

AMF (O&M) $0 0 $0 $1,505 1 $1,505

AMF (PRD) $37,063 1 $37,063 $5,277 1 $5,277

AMF (LDAR) $1,428 1 $1,428 $223 1 $223

AR 1 ,2 $0 0 $0 $134 2 $268

$7,500 2 $15,000

HF 1,3 $0 0 $0 $134 1 $134

$4,373 1 $4,373

Total $1 04 ,683 $42,180

1 We have assumed that each source will respond 5 times per year to comply with the rule a t a total cost of $134 per

source to cover costs. This estimate is based on the assumption that it takes 0.5 hours to conduct these tasks at a

clerical labor rate of $38.14 per hour for a total labor cost of $19.07 per response. First

- class postage is estimated at

$7.63 per res ponse.

2 Based on our consultation with affected entities, we estimate that $7,500 per year are required on LDAR

monitoring for the AR MACT.

3 Based on our consultation with affected entities, we estimate that 80 technical hours per year are required to

mai ntain and calibrate the scrubber, monitor, and related instrument s for the HF MACT unit ($54.66/hr x 80 hr =

$4,373 ).



### The total capital/startup costs for this ICR are $ 104,683 . This is the total of column D in

the above table. The total annualized capital costs and operation and maintenance (O&M) costs

for this ICR a re $42,180 and are shown in column G.

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6(c) Estimating Agency Burden and Cost

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

information. The EPA compliance and enforcement program includes activities such as: the

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

emissions; and the publication and distribution of collected information.

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

$4, 146

.

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

Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%)

Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS

- 6, S tep 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2013 General

Schedule, which excludes locality rates of pay (http://www.opm.gov/policy

- data

- oversight/pay

leave/salaries

- wages/2013/general

- schedule/2013

- gs

- hourlyovertime

- rates

- by

- grade

- and

- step/).

The rates have been increased by 60 percent to account for the benefit packages available to

government employees. Details upon which this estimate is based appear below in Table 2:

Average Annual EPA Burden for the NESHAP for So urce Categories: Generic Maximum

Achievable Control Technology Standards (40 CFR Part 63, Subpart YY) (Revised)

.

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

The number of respondents was updated based on the NEI database, which was used

during the analysis to determine the MACT and information from the industry. The number of

respondents is calculated using the following table which addresses the 3 years covered by this

ICR. Over the three year period of this ICR, we expect 8 existin g facilities to be respondents (4

in the PC source category, 1 in the AMF source category, 1 in the HF source category and 2 in

the AR source category)

.

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

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YEAR (A) (B) (C) (D) (E)

Number of

New

Respondents Number

Existing

Respondents Number of

Existing

Respondents

That Keep

Records But

Do Not Submit

Reports Number of

Existing

Respondents

That Are Also

New

Respondents Number of

Respondents

(E=A+B+C

- D)

1 0 8 0 0 8

2 0 8 0 0 8

3 0 8 0 0 8

Avg 0 8 0 0 8



### To avoid double

- counting respondents, column D is subtracted. As shown above, the average

Number of Respondents over the three

- year period of this ICR is 8

.

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

Total Annual Responses

(A)

Information Collection Activity (B)

Number of

Respondents (C)

Number of

Responses (D)

Number of

Existing

Respondents That

Keep Records But

Do Not Submit

Reports (E)

Total

Annual

Responses

E=(BxC)

Initial requirements for PC Production 4 1 N/A 4

Initial requirements for AMF Production 1 1 N/A 1

Periodic reports for PC Production 4 2 N/A 8

Periodic reports for AMF Production 1 2 N/A 2

Periodic reports for AR Production 2 2 N/A 4

Periodic reports for HF Production 1 2 N/A 2

LDAR reports for PC Production 4 2 N/A 8

LDAR reports for AMF Production 1 2 N/A 2

LDAR reports for AR Production 2 2 N/A 4

### 15

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)

LDAR reports for HF Production 1 2 N/A 2

Total Number of Annual Responses 37



### The number of Total Annual Responses is 3 7 (rounded)

.

The tota l annual labor costs are $2 08,709 for 3, 6 00 labor hours. Details regarding these

estimates may be found below in Table 1: Annual Respondent Burden and Cost of Reporting and

Recordkeeping Requirements for Source Categories: Generic Maximum Achievable Control

Technology Standards (40 CFR Part 63, Sub part YY) (Revised)

.

6(e) Bottom Line Burden Hours Burden Hours and Cost Tables

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

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

(i) Respondent Tally

The total annual labor hours are 3, 6 00 . Details regarding these estimates may be found

below in Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping

Requirements for Source Categories: Generic Maximum Achievable Control Technolo gy

Standards (40 CFR Part 63, Subpart YY) (Revised)

.

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

information is estimated to average 9 7 hours per response.

The total annual capital/startup and Operation and Main tenance (O&M) costs to the

regulated entity are $42,180 . The cost calculations are detailed in Section 6(b)(ii).

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 9 2

labor hours at a cost of $4, 146

. See below Table 2: Average Annual EPA Burden for the

NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards

### 16

(40 CFR Part 63, Subpart YY)

.

6(f) Reasons for Change in Burden

The rulemaking amend s title 40, chapter I, part 63 subpart YY to include emission

sources for which standards were not previously developed for the AMF source category,

revisions to the LDAR requirements for the PC and AMF source categories, and requirements to

monitor PRDs. The number of affected faciliti es under this subpart is not expected to increase.

At this time, none of the amendments will affect area sources. The overall change in burden

found in this ICR reflect the provision changes, an update in the cost of labor, and corrections to

errors found in EPA ICR number 1871.06

.

6(g) Burden Statement

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

is estimated to average 9 7 hours per response. Burden means the total time, effort, or financial

resources expended by persons to generate, maintain, retain, disclose or provide information to

or for a Federal agency. This includes the time needed to review instructions; to develop,

acquire, install, and utilize technology and systems for the purposes of collecting, val idating, and

verifying information, processing and maintaining information, and disclosing and providing

information; to adjust the existing ways to comply with any previously applicable instructions

and requirements; to train personnel to be able to respo nd to a collection of information; to

search data sources; to complete and review the collection of information; and to transmit or

otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a

coll ection of information unless it displays a valid OMB Control Number. The OMB Control

Numbers for EPA’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

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

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

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

Docket ID Number EPA

- HQ

- OAR

- 2012

- 0133 . An electronic version of the public d ocket is

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

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

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

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

### 17

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

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

Room 3334, 1301 Constitution Avenue, N.W., Washington, DC. The EPA Docket Center Public

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

holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone

number for the Enforcement and Compliance Docket and Information Center Docket is (202)

566

- 1752

. Also, you can send comments to the Office of Information and Regulatory Affairs,

Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention:

Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OAR

- 2012

- 0133

and OMB Control Number 2060

- 04 20 in any correspondence.

Part B of the Supporting Statement

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

information.

### 18

Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements for Source Categories: Generic

Maximum Achievable Control Technology Standards (40 CFR Part 63, Subpart YY) (Revised)

Burden Item (A)

Person

hours per

occurrence a (B)

No. of

occurrences

per source

per year b (C)

Person

- hours

per source

per year

(C=AxB) (D)

Respondents

per year c (E)

Technical

person

- hours

per year

(E=CxD) (F)

Management

person

- hours

per year

(Ex0.05) (G)

Clerical

person

- hours

per year

(Ex0.1) (H)

Cost,$ d

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read instructions N/A

B. Required Activities for PC, AMF, AR, HF (e) Included in 4C

C. Create Information for PC, AMF, AR, HF (e) Included in 4C

D. Gather Information for PC, AMF, AR, HF (e) Included in 4C

E. Write report

Initial notification requirements (e)(f)

Polycarbonates (PC) 4 1 4 4 16 0.8 1.6 $1,028

Acrylic and Modacrylic Fibers (AMF) 4 1 4 1 4 0.2 0.4 $257

Periodic reports (g)

Polycarbonates (PC) 13.5 2 27 4 108 5.4 10.8 $6,94 1

Acrylic and Modacrylic Fibers (AMF) 15.5 2 31 1 31 1.55 3.1 $1,99 2

Acetal Resins (AR) 8 2 16 2 32 1.6 3.2 $2,057

Hydrogen Fluoride (HF) 8 2 16 1 16 0.8 1.6 $1,028

Leak detection and repair reporting (e)(h)

Polycarbonates (PC) 12 2 24 4 96 4.8 9.6 $6,170

Acrylic and Modacrylic Fibers (AMF) 12 2 24 1 24 1.2 2.4 $1,543

Acetal Resins (AR) 8 2 16 2 32 1.6 3.2 $2,057

Hydrogen Fluoride (HF) 8 2 16 1 16 0.8 1.6 $1,028

REPORTING SUBTOTAL (Rounded) 4 3 1 $2 4,10 2

### 19

Burden Item (A)

Person

hours per

occurrence a (B)

No. of

occurrences

per source

per year b (C)

Person

- hours

per source

per year

(C=AxB) (D)

Respondents

per year c (E)

Technical

person

- hours

per year

(E=CxD) (F)

Management

person

- hours

per year

(Ex0.05) (G)

Clerical

person

- hours

per year

(Ex0.1) (H)

Cost,$ d

4. Recordkeeping Requirements

A. Read instructions (e)

Polycarbonates (PC) 4 1 4 4 16 0.8 1.6 $1,028

Acrylic and Modacrylic Fibers (AMF) 4 1 4 1 4 0.2 0.4 $257

B. Plan activities (e)

Polycarbonates (PC) 40 1 40 4 160 8 16 $10,284

Acrylic and Modacrylic Fibers (AMF) 40 1 40 1 40 2 4 $2,571

C. Implementation activities

Material determinations (e) N/A

Control equipment inspections

a. Tanks

Polycarbonates (PC) N/A

Acrylic and Modacrylic Fibers (AMF) 2 12 24 1 24 1.2 2.4 $1,543

Acetal Resins (AR) 2 12 24 2 48 2.4 4.8 $3,085

Hydrogen Fluoride (HF) N/A

b. Closed

- vent systems

Polycarbonates (PC) 2 2 4 4 16 0.8 1.6 $1,028

Acrylic and Modacrylic Fibers (AMF) 2 2 4 1 4 0.2 0.4 $257

Acetal Resins (AR) 2 2 4 2 8 0.4 0.8 $514

Hydrogen Fluoride (HF) 2 2 4 1 4 0.2 0.4 $257

Control equipment leak monitoring

a. Cover vented to control device

Polycarbonates (PC) 1 2 2 4 8 0.4 0.8 $514

Acrylic and Modacrylic Fibers (AMF) 1 2 2 1 2 0.1 0.2 $129

Acetal Resins (AR) 1 2 2 2 4 0.2 0.4 $257

Hydrogen Fluoride (HF) 1 2 2 1 2 0.1 0.2 $129

a. Closed vent system

Polycarbonates (PC) 1 2 2 4 8 0.4 0.8 $514

### 20

Burden Item (A)

Person

hours per

occurrence a (B)

No. of

occurrences

per source

per year b (C)

Person

- hours

per source

per year

(C=AxB) (D)

Respondents

per year c (E)

Technical

person

- hours

per year

(E=CxD) (F)

Management

person

- hours

per year

(Ex0.05) (G)

Clerical

person

- hours

per year

(Ex0.1) (H)

Cost,$ d

Acrylic and Modacrylic Fibers (AMF) 1 2 2 1 2 0.1 0.2 $129

Acetal Resins (AR) 1 2 2 2 4 0.2 0.4 $257

Hydrogen Fluoride (HF) 1 2 2 1 2 0.1 0.2 $129

Control devices

a. Initial requirements design analysis, performance test

(e)

Acrylic and Modacrylic Fibers (AMF) 80 1 80 1 80 4 8 $5,142

b. Operate and maintain CMS

Polycarbonates (PC) 8 12 96 4 384 19.2 38.4 $24,680

Acrylic and Modacrylic Fibers (AMF) 8 12 96 1 96 4.8 9.6 $6,170

Acetal Resins (AR) 8 12 96 2 192 9.6 19.2 $12,340

Hydrogen Fluoride (HF) 8 12 96 1 96 4.8 9.6 $6,170

Pressure relief devices

Polycarbonates (PC) 2 1 2 4 8 0.4 0.8 $514

Acrylic and Modacrylic Fibers (AMF) 2 1 2 1 2 0.1 0.2 $129

Leak detection and repair program

a. Initial requirements: Identify all affected streams (e)

Polycarbonates (PC) 2 1 2 4 8 0.4 0.8 $514

Acrylic and Modacrylic Fibers (AMF) 2 1 2 1 2 0.1 0.2 $129

b. Perform monitoring/repairs

Polycarbonates (PC) 4 $6,020

Acrylic and Modacrylic Fibers (AMF) 1 $1,505

Acetal Resins (AR) 16 12 192 2 384 19.2 38.4 $24,680

Hydrogen Fluoride (HF) ( i ) 0.1 1092 109 1 109 5. 5 10.9 $7,0 19

Container vapor tightness certification N/A

D. Develop Record System

Develop startup, shutdown, malfunction plan N/A

Control equipment (e)

### 21

Burden Item (A)

Person

hours per

occurrence a (B)

No. of

occurrences

per source

per year b (C)

Person

- hours

per source

per year

(C=AxB) (D)

Respondents

per year c (E)

Technical

person

- hours

per year

(E=CxD) (F)

Management

person

- hours

per year

(Ex0.05) (G)

Clerical

person

- hours

per year

(Ex0.1) (H)

Cost,$ d

Spinning Lines (AMF) 2 1 2 1 2 0.1 0.2 $129

Pressure relief devices

Polycarbonates (PC) 2 1 2 4 8 0.4 0.8 $514

Acrylic and Modacrylic Fibers (AMF) 2 1 2 1 2 0.1 0.2 $129

Leak detection and repair program

Polycarbonates (PC) 44 1 44 4 176 8.8 17.6 $11,312

Acrylic and Modacrylic Fibers (AMF) 44 1 44 1 44 2.2 4.4 $2,828

E. Record All Information Required by Standards

Initial requirements N/A

Control equipment inspections

Polycarbonates (PC) 1 2 2 4 8 0.4 0.8 $514

Acrylic and Modacrylic Fibers (AMF) 1 2 2 1 2 0.1 0.2 $129

Acetal Resins (AR) 1 2 2 2 4 0.2 0.4 $257

Hydrogen Fluoride (HF) 1 2 2 1 2 0.1 0.2 $129

Control equipment monitoring (j )

Polycarbonates (PC) 1 52 52 4 208 10.4 20.8 $13,369

Acrylic and Modacrylic Fibers (AMF) 1 52 52 1 52 2.6 5.2 $3,342

Acetal Resins (AR) 1 52 52 2 104 5.2 10.4 $6,684

Hydrogen Fluoride (HF) 1 52 52 1 52 2.6 5.2 $3,342

Control device CMS

Polycarbonates (PC) 1 12 12 4 48 2.4 4.8 $3,085

Acrylic and Modacrylic Fibers (AMF) 1 12 12 1 12 0.6 1.2 $771

Acetal Resins (AR) 1 12 12 2 24 1.2 2.4 $1,543

Hydrogen Fluoride (HF) 1 12 12 1 12 0.6 1.2 $771

Pressure relief devices

Polycarbonates (PC) 2 1 2 4 8 0.4 0.8 $514

Acrylic and Modacrylic Fibers (AMF) 2 1 2 1 2 0.1 0.2 $129

Leak detection and repair program

### 22

Burden Item (A)

Person

hours per

occurrence a (B)

No. of

occurrences

per source

per year b (C)

Person

- hours

per source

per year

(C=AxB) (D)

Respondents

per year c (E)

Technical

person

- hours

per year

(E=CxD) (F)

Management

person

- hours

per year

(Ex0.05) (G)

Clerical

person

- hours

per year

(Ex0.1) (H)

Cost,$ d

Polycarbonates (PC) 20 1 20 4 80 4 8 $5,142

Acrylic and Modacrylic Fibers (AMF) 20 1 20 1 20 1 2 $1,285

Acetal Resins (AR) 16 1 16 2 32 1.6 3.2 $2,057

Hydrogen Fluoride (HF) 16 1 16 1 16 0.8 1.6 $1,028

F. Time to Train Personnel

Material determination methods N/A

Control equipment inspection and monitoring ( k )

Polycarbonates (PC) 8 1 8 4 32 1.6 3.2 $2,057

Acrylic and Modacrylic Fibers (AMF) 8 1 8 1 8 0.4 0.8 $514

Acetal Resins (AR) 8 1 8 2 16 0.8 1.6 $1,028

Hydrogen Fluoride (HF) 8 1 8 1 8 0.4 0.8 $514

Leak detection and repair program (h, k )

Polycarbonates (PC) 10 1 10 4 40 2 4 $2,571

Acrylic and Modacrylic Fibers (AMF) 10 1 10 1 10 0.5 1 $643

Acetal Resins (AR) 2 1 2 2 4 0.2 0.4 $257

Hydrogen Fluoride (HF) 2 1 2 1 2 0.1 0.2 $129

Container leak tight method N/A

RECORDKEEPING SUBTOTAL (Rounded) 3, 16 9 $1 8 4,607

TOTAL LABOR BURDEN AND COST (Rounded) 3,600 $2 08

, 709

N/A = Not Applicable.

(a) Estimate of burden for each activity, technical hours only.

(b) Estimate based on average facilities.

(c) We have assumed that there are 8 existing sources (4 PC, 1 AMF, 2 AR, and 1 HF) and that no additional new sources will b ecome subject to the rule over the next three

years. We have also assumed that existing sources have already complied with this act ivity, except for facilities in the AMF and PC source categories subject to new

requirements.

(d) Costs are rounded and based on the following hourly rates: Technical at $54.66, Management at $115.96, and Clerical at $3 8.14 from May 2012 National Occupatio nal

Employment and Wage Estimates United States

- Occupations. Mean Hourly Rate (http://www.bls.gov/oes/current/oes_nat.htm#51

- 0000).

(e) We have assumed that there will be no new sources over the next three years of this ICR. For PRDs located at PC and AM F, facilities are required to submit a Notification of

Compliance Status within 150 days after the first applicable compliance date for pressure relief device monitoring.

### 23

(f) Initial notification requirements include: initial notifications, initial complia nce determination, and initial performance tests.

(g) The rules requires that all sources submit periodic reports (semiannually or according to the s chedule for Title V).

(h) The standards for equipment leak requires the submittal of an initial report and semiannual reports of leak detection and repair (LDAR) and any changes to the processes,

monitoring frequency and initiation of a quality improvement program. We have assumed that sources are submitting the require d LDAR information with the periodic repor ts

( i ) Visual inspections are required once per shift with a total of three shifts per day, at seven days per week, for 52 weeks p er year. (3x7x52) for a total of 1,092 inspections per

year.

( j ) We have assumed that control equipment monitoring should be done on a weekly basis.

( k ) We have assumed that there will be some labor hours associated with rule analysis and training per year.

### 24

Table 2: Average Annual EPA Burden for the NESHAP for Source Categories: Generic Maximum Achievable Control

Technology Standards (40 CFR Part 63, Subpart YY)

(A)

EPA person

hours per

occurrence (B)

No. of

occurrences

per plant

per year (C)

EPA person

hours per

plant per

year

(C=AxB) (D)

Plants

per

year a (E)

Technical

person

hours

per year

(E=CxD) (F)

Management

person

- hours

per year

(Ex0.05) (G)

Clerical

person

hours

per

year

(Ex0.1) (H)

Agency

Cost, $ b Burden Item

REPORT REVIEW

Initial Requirements

a. Initial notification (c) 2 1 2 0 0 0 0 $0

b. Performance test (c)(d) 2 1 2 0 0 0 0 $0

c. Compliance status (c) 4 1 4 5 20 1 2 $1,036

d. Performance test reports (c)(d) 4 1 4 0 0 0 0 $0

Periodic Requirements

a . Periodic reports 3 2 6 5 30 1.5 3 $1,555

b . Leak detection and repair reports 3 2 6 5 30 1.5 3 $1,555

TOTAL ANNUAL EPA BURDEN AND COST

(Rounded) 9 2 $4, 146

(a) We have assumed that there are 8 existing sources (4 PC, 1 AMF, 2 AR, and 1 HF) and that no additional new sources will b ecome subject to the rule over

the next three years.

(b ) Agency labor rates are from the Office of Personnel Management (OPM) 2013 General Schedule which excludes locality rates of pay. Salary Table 2013

- GS.

Labor rates are inflated to reflect average locality pay increase from base rates. Available at http://www.opm.gov/policy

- data

- oversight/pay

- leave/salaries

wages/2013/general

- sch edule/2013

- gs

- hourlyovertime

- rates

- by

- grade

- and

- step/

(c) We have assumed there will be no new sources over the next three years of this ICR. We have also assumed that existing so urces

have already complied with th is activity, except for facilities in the AMF and PC source categories subject to new requirements.

( d ) We have assumed that the Agency will not have additional burden from sources conducting performance tests due to a process change that may

or may not result in the source meeting additional requirements.