**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Group I Polymers and Resins (40 CFR Part 63, Subpart**  **U) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  NESHAP for Group I Poly mers and Resins (40 CFR Part 63, Subpart U) (Renewal), EPA I CR Number 2410.03, OMB Control Number 2060

- 0 665

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Group I Pol ym ers and Resins were promulgated on September 5, 1996, and amended on: June 19, 2000 ; July 16, 2001 ; April 20, 2006 ; and April 21, 2011 . These regulations apply to existing and new facilities that are major sources of hazardous air pollutants (HAPs) in nine source categories: Butyl Rubber Production, Epichlorohydrin Elastomers Production, Ethylene Propylene Rubber Production, Hy

palon Production, Neoprene Production, Nitrile Butadiene Rubber (NB R) Production, Poly

butadiene Rubber Production, Poly sulfide Rubber Production, and Sty rene Butadiene Rubber and Latex Production. The 2011 final rule established emission standards for hydrochloric acid (HCl) from front

- end process vents in the Butyl Rubb er Production and Ethylene Prop yl ene Rubber Production source categories, and for organic HAP from back

- end process operations in the Butyl Rubber Production, Epichlorohydrin Elastomers Production, and the Neoprene Rubber Production categories. The rule also eliminated startup, shutdown, and malfunction (SSM) exemption, removed SSM plan requirement, added provisions to provide an affirmative defense against civil penalties for exceedances of emission standards caused b y malfunction, and added requirement f or electronic submittal of performance test data . This ICR covers the burden associated with the 2011 final rulemaking. This information is being collected to assure compliance with 40 CFR part 63, subpart U

. In general, all NESHAP standards require ini tial notifications, performance tests, and periodic reports by

the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affec ted facility , or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP

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

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

. S

. Environmental Protection Agency (EPA) regional office. Over the next three ye ars, we estimate that an average of 5 respondents per year will be subject to the emission standard s established in the 2011 final rule , and that no additional respondents per ye ar will become subject to the se standard s . In addition, all 19 existing2

respondents in the nine source categories subject to the NESHAP may use the affirmative defense provisions. The Office of Management and Budget ( OMB) approved the currentl y active I CR without any

“Terms of Clearance.” The “ Affected Public ” are faciliti es with elastomer product process units (EPPU) and associated equipment that are major sources of HAP. This I CR only covers the burden imposed by the 2011 final rule. The “burden ” to the Affected Public may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Group I Pol ym ers and Resins (40 CFR Part 63, Subpart U) (Renewal). The Federal Government ’s “burden ” is attributed entirel y to work performed b y either F ederal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Group I Poly mers and Resins (40 CFR Part 63, Subpart U) (Renewal). **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 A ct, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports;

(C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (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) prov ide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, HAP emissions from Group I Pol ym ers and Resins manufacturing facilities cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR part 63, subpart U

. **2(b) Practical Utility/Users of the Data**3

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

with the emission standard s . Continuous e mission monitors are used to ensure compliance with the se standard s at all times. Durin g the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the se standard s are used to inform th e Agency or delegated authority when a source becomes subject to the requirements of the se regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properl y installed and operated , leaks are being dete cted and repaired , and the standard s are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. **3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 63, subpart U

. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Pub lic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 78 FR 35023 ) on June 11, 2013

. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency ’s industry

experts have been consulted, and the Agency ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and4

reporting provisions in the standard, is the Online Tracking Inf ormation System (OTI S) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the A gency ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the se standard s as they were being developed and the standard s have been reviewed previously to determine the minimum information needed for compliance purposes. Indeveloping this ICR, we contacted : 1) the International Institute of Sy nthetic Rubber Producers, Inc. (IISRP) , at (713) 783

- 7511 ; and 2) Dow Chemical at (800) 258

- 2436

. IIS RP provided comment indicating that EPA’s initial estimate of 30 hours significantl y underestimated the time and effort required for affirmative defense. IISRP stated that a single affirmative defense event required approximately 128 technical labor hours, 8 management labor hours, 8 lawyer hours, and 1 administrative labor hour based on past experience. We have revised the respondent burden for affirmative defense to incorporate the comment received. It is our policy

to respond after a thorough review o f comments received since the last ICR renewal as well as those submitted in response to the first Federal Register notice. In this case, no comments were received. **3(d) Effects of Less Frequent Collection** Less frequent information collection would dec rease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required b y these standards was collected less frequentl y, then the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines** T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 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

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars 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 five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or non - existence of essential records.5

**3(f) Confidentiality** Any information submitted to the Agency for which a claim o f confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B

- Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** T he reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Information Requested 4(a)**  **Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are Group I Pol ym ers and Resins manufacturing facilities . The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards is SI C 2822 , which corresponds to the North American Industry

Classification Sy stem (NAICS ) code 325212 for sy nthetic rubber manufacturing

. **4(b) Information Requested (i) Data Items**  In this ICR , all the data that is recorded or reported is require d by the NESHAP for Group I Pol ym ers and Resins (40 CFR Part 63, Subpart U)

. A source must make the following reports:

**Notification s**  Notification of front

- end process vent s limit 63.485(q) Notification of back

- end process vents limit 63.499(f)(1)
**Reports** Back

- end process vents records in periodic reports 63.499(f), 63.506(e)(6) Front

- end process vents records in periodic reports 63.506(d), 63.506(e)(6) Reports of malfunctions that result in an exceedances of the standard for 63.480(j)(4)6 **Reports** the purpose of affirmative defense A source must keep the following records: **Recordkeeping** Records of notifications 63.506(e) Records that demonstrate continuous compliance 63.498(a)(4), 63.498(e), 63.506(d) Electronic Reporting 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 th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that none of the five respondents use electronic reporting. The 2011 final rule requires electronic submittal of performance test data to increase the ease and efficiency

of data submittal and to improve data accessibility

. Specificall y, owners and operators of Group I Poly mers and Resins facilities are required to submit electronic copies of applicable performance tests to EPA’s WebFIRE databa se using the Electronic Reporting Tool (ERT). **(ii) Respondent Activities Respondent Activities**  Read instructions. Perform initial performance test, Reference Method 1, 1A , 18, 25A, 26, or 26A test s , 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 and7 **Respondent Activities** sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities** EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information. **Agency Activities** Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are p roperl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comp ly with the emission standard, and note the operating conditio ns 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.8

In formation contained in the reports is entered into OTI S which is operated and maintained by

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

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegate d Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** The Small Business Administration defines a small entity as one that meets the Small Business Administration size standards for small businesses found at 13 CFR 121.201 (less than 1000 employees for NAICS 325212). We estimate that none of the facilities affected b y the new requirements are small entities. Accordingly , the rule does not impose significant economic impact on a substantial number of small businesses, and small business considerations do not apply

. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this requ est is shown below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Group I Pol ym ers and Resins (40 CFR Part 63, Subpart U) (Renewal)

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Red uction Act. Where 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 requirement s is estimated to be 315 hours ( Total Labor Hours from Table 1). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previousl y approved ICR, and any comments received.9

**6(b) Estimat ing Respondent Costs**  **(i) Estimating Labor Costs** This I CR uses the following labor rates: Managerial $ 68.29 ($ 32.52 + 110%) Technical $ 52.16 ($ 24.84 + 110%) Clerical $ 35.81 ($ 17.05 + 110%) Law $133.46 ($63.55 + 110%) These rates are from the U

. S

. Department of Labor, Bureau of Labor Statistics for NAICS 325200 , May

2012 , available at http://www.bls.gov/oes/current/naics4_325200.htm

. Wages for technical labor are based on "Productio n occupations: Chemical Equipment Operators & Tenders ". Wages for management labor are taken from "Production occupations: First

- line supervisors/managers of production and operating workers". Wages for clerical labor are based on "Office and administrative support occupations: Office clerks general ". Wages for law personnel are taken from “lawyers”. The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capita l/Startup and Operation and Maintenance Costs**  The only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. There are no capital/startup or operation and maintenance costs beca

use the final standards do not impose requirements for monitoring or other equipment

.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs.

**(iv) Affirmative Defense, Root Cause Analysis, and Malfunction Costs** EPA’s estimate for an affirmative defense and root cause anal ys is is based on IISRP’s past experience with a single affirmative defense event. In general, the burden involves the time and effort required of a source to review relevant data, interview plant employees, and reconstruct the events prior to a malfunction in order to det ermine primary and contributing causes. The level of effort also includes time to produce and retain the report in document form so that the source will have it available should EPA or state enforcement agencies ever request to review it. **6(c) Estimati ng Agency Burden and Cost** 10

The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the respond ents, 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 $ 0

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

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

. 21 (GS

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

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 3 General Schedule , which excludes locality

rates of pay

. 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 and Cos t

– NESHAP for Group I Poly mers and Resins (40 CFR Part 63, Subpart U) (Renewal). **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 5 existing respo ndents will be subject to the new provisions of the Group I Poly mers and Resins NESHAP . It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is 5 per year. While all 19 existing respondents could make use of the new affirmative defense provisions added to the rule, EPA estimates only

two total instances of the use of these provisions from all 19 facilities over the three

- ye ar IC R period. The number of respon dents is calculated using the following table that addresses the three ye ars covered b y this ICR :

**Number of Respondents**

Year (A) Number of New Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E) Number of Respondents (E=A+B+C

D)
1 0 5 0 0 5 2 0 5 0 0 511 **Number of Respondents** 3 0 5 0 0 5 Average 0 5 0 0 5 1 New respondents include sources with constructed, reconstructed and modified affected facilities. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 5

. The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D

Notification of the back

- end process limit 1 0 1 N/A 0
Notification of performance test for front

- end process limit 2 0 1 N/A 0
Affirmative defense reports 3 0.7 1 N/A 0.7 Semiannual reports 3 0 1 N/A 0 Total 0.7 1 We assume that the five facilities required to submit a one

- time notification of the back

- end process limit have already submitted these reports during the initial compliance period. 2 We assume that the two facilities required to submit a one

- time notification of performance tests and test reports for compliance with the front

- end process limit have already submitted these reports during the initial compliance period. 3 W e estimate 2 instances of affirmative defense over the 3

- year period of this ICR. 4 All facilities already submit semiannual reports as part of the existing rule; therefore, no additional burden is presented here for the new provisions.

The number of Total Annual R esponses is 1 (rounded)

. The total annual labor costs are $ 1 6 , 791

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

– NESHAP for Group IPol ym ers and Resins (40 CFR Part 63, Subpart U) (Renewal). **6(e) Bottom Line Burden Hours and Cost Tables**  The detailed bottom line burden hours and cost calculations for the respondents and the12

Agency are shown in Tables 1 and 2, respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 315 hours at a cost of $16,791

. Details regarding these estimates may

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

– NESHAP for Group I Poly

mers and Resins (40 CFR Part 63, Subpart U) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 315 hours per response

. There are no annual capital/startup and O&M costs to the regulated entity . The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be zero labor hours at a cost of $ 0 . See below in Table 2: Av erage Annual EPA Burden and Cost

– NESHAP for Group I Poly mers and Resins (40 CFR Part 63, Subpart U) (Renewal). **6(f) Reasons for Change in Burden** There is an adjustment increase in the respondent burden and a decrease in Agency burden since the last I CR. This is not due to any program changes. The respondent burden increased because this ICR revised the hours associated with affirmative defense, using latest estimates provided b y industry during consultation. However, the other burdens, including burden to the Agency

decreased because this ICR assumes that existing facilities have already met initial requirements, and only covers the burden associated with on

- going compliance. The previous I CR covers the burden associate d with initial compliance of the final standard, including one

- time notification of performance tests and notifications of the back

- end process limits.

**6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 315 hours per response. “ Burden ” means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or dis close or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with an y previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data source s; complete and review the collection of information; and13

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 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 I CR under Docket ID Number EPA

–HQ

–OECA

–2013

–0356

. 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 contents of the docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holiday s. The telephone number for the Reading Room is (202) 566

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

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include th e EPA Docket ID Number EPA

–HQ

–OECA

–2013

–0356 and OMB Control Number 2060

- 0665 in any correspondence. **Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.14

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

**– NESHAP for Group I Polymers and Res**  **ins (40 CFR Part 63, Subpart U) (Renewal)** 

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

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

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

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

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

**Cost ($) (c)**

1. Applications N/A 2. Survey and Studies N/A 3. Acquisition, Installation, and Utilization of Tech. and Systems See 5F 4. Reporting requirements A. Read instructions (d) 3.2 20 64 0 0 0 0 0 B. Required activities C. Create Information See 4B D. Gather existing information See 4B E. Write report Semiannual compliance reports 40 2 80 0 0 0 0 0 Leak detection and repair reports 24 2 48 0 0 0 0 0 Front

- end limit notification (a) 4 1 4 0 0 0 0 $0 Back

- end limit notification (b) 4 1 4 0 0 0 0 $0 Performance test notification 2 1 2 0 0 0 0 0 Performance test report (e) 8 1 8 0 0 0 0 0 Affirmative defense (f) 145 1 145 0.67 96.67 $ 5, 550.86 Other reports (i.e. quarterly periodic reports where a respondent did not qualify for semiannual reporting) 8 1 8 0 0 0 0 0 **Subtotal for**  **Reporting Requirements**  **9 6.**  **6 7**  **$ 5,550.86**  5 . Recordkeeping requirements A. Read instruction s (d) See 4A15

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

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

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

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

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

**Cost ($) (c)**

B. Plan activities See 5E C. Implement activities See 5E D. Develop record system See 5E E. Time to enter information Plan activities 2 20 40 0 0 0 0 0 Create, test, research, develop (d) 18 80 1440 0 0 0 0 0 Gather information, monitor, inspect 1 12 12 5 60 3 6 $3,549.55 Process, compile, review 1 12 12 5 60 3 6 $ 3,549.55 F. Train personnel (d) 3 10 30 0 0 0 0 0 G. Adjust existing ways to comply with prev. appl. reg. N/A H. Record and disclose information 1 2 2 5 10 0.5 1 $ 591.59 Store, file and maintain records 1 12 12 5 60 3 6 $ 3,549.55 I. Audits N/A **Subtotal for**  **Recordkeeping 21**  **8.5 $**  **11,240.23 TOTAL ANNUAL BURDEN AND COST**  **(rounded) 315**  **$ 16,791**  Assumptions: (a) There are 3 notifications of front

- end limits expected for the industry (3 notifications/ 3 years = 1 response) . Assume notifications have been submitted during the initial compliance period (previous ICR). (b) There are 5 notifications of back

- end limits expected for the industry (5 notifications/ 3 years

- 1.7 responses) . Assume notifications have been submitted during the initial compliance period (previous ICR). ( c ) Costs are based on the following hourly rates: technical $ 52.16 , managerial $ 68.29 , and clerical $ 35.81

. (d) One

- time occurrences, assumed to have already occurred for existing sources. No new sources are expected during the 3

- yr ICR period. (e) Assume initial performance test and test report have already been submitted during the initial compliance period.16

(f) Assumes 2 affirmative defense reports for the entire industry during the 3

- yr ICR period (2 reports/ 3 years = 0.7 responses)

.17

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

**– NESHAP for Group I Polymers and**  **Resins (40 CFR Part 63, Subpart U) (Renewal)** 

**Activity (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**  **(E)**

**Technical person**  **- hours**  **per year (E=CxD)**  **(F)**

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

**Clerical person**  **** **hours per year**  **(H) Cost ($) (c)** 

Performance Test: Initial 40 1 40 0 0 0 0 0 Performance Test: Repeat 40 1 40 0 0 0 0 0 Litigation (e) 2,080 0 0 0 0 0 0 0 Reports Revie w Com pliance status (d) 40 0 0 0 0 0 0 0 Revie w equipment leak monitoring 7 2 14 0 0 0 0 0 Front

- end limit notification (a) 3 1 3 0 0 0 0 0 Back

- end limit notification (b) 3 1 3 0 0 0 0 0 Construction/Reconstruction notification (d) 6 0 0 0 0 0 0 0 Anticipated startup notification (d) 6 0 0 0 0 0 0 0 Actual startup notification (d) 6 0 0 0 0 0 0 0 Performance Test notification (d) 6 1 6 0 0 0 0 0 Revie w of

test results (d) 24 1 24 0 0 0 0 0 Revie w periodic reports 3 2 6 0 0 0 0 0 Revie w other reports 6 1 6 0 0 0 0 0 **Total Burden and Cost** 0 $ 0 Assumptions: (a) Assume the 3 notifications of front

- end limits have been submitted during the initial compliance period (previous ICR). (b) Assume the 5 notifications of back

- end limits have been submitted during the initial compliance period (previous ICR). (C) Costs are based on the following hourly rates: technical $46.21, managerial $62.27, and clerical $25.01.18

(d) One

- time occurrences, assumed to have already occurred for existing sources. No new sources are expected during the 3

- yr ICR period. (e) Represents the cost of litigating and average of 1 case per year. It is assumed that there will be no more litigation.

**TABLE 3. Single Affirmative Defense Burden Estimate** 

**Personnel Total**  **Time**

**Requirement (hr)**  **Hourly Rate**

**($/hr) Total**  Technical Personnel 128 52.16 $6,676.48 Managerial Personnel 8 68.29 $546.32 Law 8 133.46 $1,067.68 Clerical Personnel 1 35.81 $35.81 Total 145 $8,326.29