1

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 ICR Number 1871.08, 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 amends title 40, chapter I, part 63 subpart YY to include emission 

sources for which standards were not previously developed for the AMF source 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 source 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 notifying 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 

remain 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 1871.06.

The Office of Management and Budget (OMB) approved the currently 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 1871.06.

The period 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 AMF 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 existing 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 anticipated to endanger public health 

or welfare. Therefore, the NESHAP standards were promulgated for these source categories at 

40 CFR part 63, subpart YY.

2(b) Practical Utility/Users of the Data

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

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

addition, the collected information is 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 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. The 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 generated 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-duplication, 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 

duplicate 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 Notice 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 proposed amendments, but no comments were received 

regarding the ICR.

3(c) Consultations

Over the next three years, an average of 4 PC production facilities, 1 AMF production 

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 resources 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 industry 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 frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements 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 requirement is consistent with the 

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

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

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

action. EPA has found that the most flagrant violators have violations extending beyond 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 polycarbonates and 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, subpart 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 Hazardous 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 estimated 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, installing, and utilizing technology and 

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

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

maintaining information

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

providing information

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

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 reports, 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 Agency to discern a source’s initial capability to comply with the 

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

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

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

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

determinations.

Information contained in the reports is 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 

enforcement 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 for five 

years.

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, the 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 Schedule

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 Technology 

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 identified. Responses to this information collection are mandatory.

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

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

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 3,600 (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 National 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 assistants (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 and 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 vents 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 for 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 subpart 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 category.

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 for 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. Based 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 cost 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 

AR1,2 $0 0 $0

$134 2 $268

$7,500 2 $15,000

HF1,3 $0 0 $0

$134 1 $134

$4,373 1 $4,373

Total $104,683 $42,180

1We have assumed that each source will respond 5 times per year to comply with the rule at 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 response. 

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

monitoring for the AR MACT.

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

maintain and calibrate the scrubber, monitor, and related instruments 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 are $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 the 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, Step 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/payleave/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 Source 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 existing 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.

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of 

Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports

(E)

Total 

Annual 

Responses

E=(BxC)

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
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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 37 (rounded).

The total annual labor costs are $208,709 for 3,600 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, Subpart 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 3,600. 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, Subpart YY) (Revised).

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

information is estimated to average 97 hours per response.

The total annual capital/startup and Operation and Maintenance (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 92

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
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(40 CFR Part 63, Subpart YY). 

6(f) Reasons for Change in Burden

The rulemaking amends 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 facilities 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 97 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, validating, 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 respond 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 

collection 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 docket is 

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

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

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

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

Room 3334, 1301 Constitution 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, excluding 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 2060-0420 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)

Personhours per

occurrencea

(B)

No. of

occurrences

per source

per yearb

(C)

Person-hours

per source

per year

(C=AxB)

(D)

Respondents

per yearc

(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 $6,941

 Acrylic and Modacrylic Fibers (AMF) 15.5 2 31 1 31 1.55 3.1 $1,992

 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) 431 $24,102
19

Burden Item

(A)

Personhours per

occurrencea

(B)

No. of

occurrences

per source

per yearb

(C)

Person-hours

per source

per year

(C=AxB)

(D)

Respondents

per yearc

(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)

Personhours per

occurrencea

(B)

No. of

occurrences

per source

per yearb

(C)

Person-hours

per source

per year

(C=AxB)

(D)

Respondents

per yearc

(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 $7,019

 Container vapor tightness certification N/A

 D. Develop Record System

 Develop startup, shutdown, malfunction plan N/A

 Control equipment(e)
21

Burden Item

(A)

Personhours per

occurrencea

(B)

No. of

occurrences

per source

per yearb

(C)

Person-hours

per source

per year

(C=AxB)

(D)

Respondents

per yearc

(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)

Personhours per

occurrencea

(B)

No. of

occurrences

per source

per yearb

(C)

Person-hours

per source

per year

(C=AxB)

(D)

Respondents

per yearc

(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) 3,169 $184,607

TOTAL LABOR BURDEN AND COST (Rounded) 3,600 $208,709

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 become subject to the rule over the next three 

years. We have also assumed that existing sources have already complied with this activity, 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 $38.14 from May 2012 National Occupational 

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 AMF, 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 compliance determination, and initial performance tests.

(g) The rules requires that all sources submit periodic reports (semiannually or according to the schedule 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 required LDAR information with the periodic reports

(i) Visual inspections are required once per shift with a total of three shifts per day, at seven days per week, for 52 weeks per 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 personhours per

occurrence

(B)

No. of

occurrences

per plant

per year

(C)

EPA personhours per

plant per

year

(C=AxB)

(D)

Plants

per

yeara

(E)

Technical

personhours

per year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

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) 92 $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 become 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/salarieswages/2013/general-schedule/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 sources 

have already complied with this 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.