SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Chemical Manufacturing Area Sources (40 CFR Part 63, Subpart VVVVVV) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Chemical Manufacturing Area Sources (40 CFR Part 63, Subpart VVVVVV) 

(Renewal), EPA ICR Number 2323.06, OMB Control Number 2060-0621. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Chemical 

Manufacturing Area Sources were proposed on October 6, 2008, promulgated on October 29, 

2009, and most recently amended on December 21, 2012. The most recent amendment to the 

standard clarifies applicability and compliance issues to improve implementation. There are nine 

area source categories in the chemical manufacturing sector: Agricultural Chemicals and 

Pesticides Manufacturing, Cyclic Crude and Intermediate Production, Industrial Inorganic 

Chemical Manufacturing, Industrial Organic Chemical Manufacturing, Inorganic Pigments 

Manufacturing, Miscellaneous Organic Chemical Manufacturing, Plastic Materials and Resins 

Manufacturing, Pharmaceutical Production, and Synthetic Rubber Manufacturing. These 

regulations apply to process vents, storage tanks, equipment leaks, wastewater systems, transfer 

operations, and heat exchange systems at affected sources in each area source category and are 

combined in one subpart. New facilities include those that commenced construction or 

reconstruction after the date of proposal. This information is being collected to assure 

compliance with 40 CFR Part 63, Subpart VVVVVV.

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

periodic reports by the owners/operators of the affected facilities. Owners/operators are also 

required to maintain records of the occurrence and duration of any startup, shutdown, or 

malfunction in the operation of an affected facility, or any period during which the monitoring 

system 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 directly to the United 

States Environmental Protection Agency (EPA) regional office.

The burden to the “Affected Public” may be found in Table 1: Annual Respondent 

Burden and Cost – NESHAP for Chemical Manufacturing Area Sources (40 CFR Part 63, 

Subpart VVVVVV) (Renewal). The “Federal Government” burden is attributed entirely to work 

performed by federal employees or government contractors and may be found in Table 2: 
2

Average Annual EPA Burden and Cost – NESHAP for Chemical Manufacturing Area Sources 

(40 CFR Part 63, Subpart VVVVVV) (Renewal). 

Over the next three years, approximately 489 respondents per year will be subject to the 

standard, and 10 additional respondents per year will become subject to the standard. We derived 

this estimate by assuming an industry growth rate of 2 percent. 

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

without any “Terms of Clearance”.

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. 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) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from chemical manufacturing area 

sources 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 VVVVVV.

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. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.
3

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 test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard are being met. The 

performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart

VVVVVV.

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly 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 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

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (80 FR 32116) on June 5, 2015. 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 by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by the EPA Office of Compliance. OTIS is the EPA database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts.
4

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed. In developing 

this ICR, we contacted both the American Chemistry Council at (202) 249-6512; and the Society 

of Chemical Manufacturers & Affiliates at (202) 721-4100.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

applied and emission limitations are met. 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 do not violate any of the regulations 

promulgated by 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 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 five 

years. In addition, 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

The reporting or recordkeeping requirements in the standard do not include sensitive 
5

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are chemical 

manufacturing area sources. The United States Standard Industrial Classification (SIC) code for 

the respondents affected by the standards is SIC 28, which corresponds to North American 

Industry Classification System (NAICS) 325 for Chemical Manufacturing.

The chemical manufacturing area source category excludes: (1) production operations 

classified in NAICS codes 325222 (Non-cellulosic Organic Fiber Manufacturing), 325314 

(Fertilizer (Mixing Only) Manufacturing), 325413 (In-Vitro Diagnostic Substance 

Manufacturing), or 325998 (All Other Miscellaneous Chemical Product and Preparation 

Manufacturing); (2) facilities in NAICS 325 that are subject to standards for other listed area 

source categories (i.e., acrylic fibers/modacrylic fibers production, carbon black, chemical 

manufacturing: chromium compounds, polyvinyl chloride and copolymers production, paint and 

allied coatings, and mercury cell chlor-alkali manufacturing); (3) certain fabricating operations; 

(4) manufacture of photographic film, paper, and plate where material is coated or contains 

chemicals (only the manufacture of the photographic chemicals would be regulated); and (5) 

manufacture of radioactive elements or isotopes, radium chloride, radium luminous compounds, 

strontium, and uranium.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Chemical Manufacturing Area Sources (40 CFR Part 63, Subpart VVVVVV) (Renewal).

A source must make the following reports:

Notifications

Notification of intended construction/reconstruction 63.5(d)

Initial notification 63.5(d), 63.9(b)(2), (4), 

and (5)

Notification of performance test 63.7(b) and 63.9(e)

Performance test results 63.7(g) and 63.10(d)(2)

Notification of compliance status 63.9(h) and 63.11501(b)

Semiannual compliance reports (when reporting criteria are met) 63.11501(d)
6

A source must keep the following records:

Recordkeeping

Emissions estimates and total resource effectiveness (TRE) index 

calculations for process vents

63.11496(a), (b), (f)

Records are required to be retained for five years

63.10(b); 63.11410(g), 

(i), (j)(1); 

63.11496(f)(3); 

63.11501(c)

Heat exchange system inspection plan or monitoring plan

63.104, 63.11495(b), 

63.11499, and Table 8 

to Subpart VVVVVV

Metal process vent monitoring plan 63.11410(g)(2) and (h), 

63.11496(f)(3)

Records of wastewater streams, type of treatment, and if 

applicable, disposition of separated organic phases

Table 6 to Subpart 

VVVVVV

Inspections and monitoring results

60.115b, 60.116b, 

63.104(f), 63.998, 

63.11410(d) and (g)(4), 

63.11495

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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Write plans for heat exchange system monitoring and metal process vent monitoring.

Perform initial performance test, Reference Method 5, test, and repeat performance tests if 

necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.
7

Respondent Activities

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.

Agency Activities

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

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) 

and ICIS. 

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.
8

Information contained in the reports is reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and 

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

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

Many of the facilities affected by this final rule are small entities. The classification of a 

small entity is defined as having less than a specified number of employees. The specific number 

varies based on the NAICS code. For this overall source category, a small entity is defined as 

having less than 1,000 employees, less than 750 employees, or less than 500 employees, 

depending on the NAICS code. The impact on small entities was taken into consideration during 

the development of the regulation by mandating minimal notification and reporting requirements 

for all sources. The Agency considers these requirements the minimum needed to ensure 

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

recordkeeping and reporting for all facilities, only brief documentation of quarterly inspections is 

required, and compliance reports are required only if certain conditions are met during the 

reporting period.

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Chemical 

Manufacturing Area Sources (40 CFR Part 63, Subpart VVVVVV) (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 ICR. The 

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

concept of burden under the Paperwork Reduction 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 requirements is estimated to be 9,590 (Total Labor Hours from Table 1). These 
9

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

regulation, Agency knowledge and experience with the NSPS program, the previously approved 

ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 

2014, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

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

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

subject standard are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor and other costs such as photocopying and postage.

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
10

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

(A)

Continuous 

Monitoring Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents

with O&M

(G)

Total O&M,

(E X F)

Metal process vent 

performance tests1,2 $8,740 0.2 $1,748

Fabric filter for 

metal process vents

1,2,3,4

$17,533 0.2 $3,507 $4,827 247 $1,193,531

Batch process vent 

and continuous 

process vent 

performance tests5

$24,420 0 $0

Temperature 

monitoring system 

for batch and 

continuous process 

vents6

$3,620 0 $0 $1,202 33 $39,666

Initial wastewater 

sampling and 

analysis 7

$3,370 2.96 $9,970

Cooling water 

sampling and 

analysis8

$0 $0

Total 9$15,200 $1,230,000

1 All new sources with a chemical manufacturing process unit (CMPU) having uncontrolled metal HAP emissions exceeding 

400 lb/yr must prepare a metal process vent monitoring plan. The generally available control technologies or management 

practices (GACT) analysis conducted for the NESHAP estimated there to be 27 existing sources meeting this criterion.

Assuming an industry growth rate of 2%, we estimate that 1 new source per year (27 x 2% = 1, after rounding) will conduct 

this activity.

2

Per footnote 1, we estimate that 1 new source per year will have uncontrolled metal HAP emissions exceeding 400 lb/yr.

Each new source must demonstrate compliance by conducting either a performance test or a design evaluation. We assume 

that 20 percent of sources will conduct performance testing while the remaining 80 percent will opt for design evaluation 

instead. Assumes average cost for a performance test using Method 5 is $8,740 per test.

3 Assumes each source with a control device for metal process vents uses a fabric filter. Assumes total purchase and 

installation costs for a bag leak detection system is $17,533.

4 We assume all metal HAP emissions sources will spend $1,219 per bag leak detection system per year. We estimate that 

each source also will spend $3,608 per year to operate and maintain these systems, assuming 36 hours per year and technical 

labor rate of $100.23 per hour (36 hr/yr x $100.23/hr = $3,608/yr, after rounding). The total annual O&M cost is $4,827 per 

source.

5 Assumes 5 existing sources have continuous process vents, 28 existing sources have batch process vents, and no new 

sources in the 3 years of this ICR have subject batch or continuous process vents. Assumes average cost for a performance 

test using Method 18 is $24,420.

6Assumes a temperature monitoring system is needed for each control device used to control batch process vents or 

continuous process vents. Assumes the monitoring equipment cost is $3,620 per system

7We assume all sources with organic HAP emissions have process wastewater and must determine HAP concentrations in 

each stream. We also assume that 50 percent will use sampling and analysis, resulting in the incursion of capital costs. The 

other 50 percent of sources will use process knowledge to characterize HAP concentrations (i.e., no capital costs). Assuming 
11

an average of 2 streams per source and 1 sample per stream, we estimate a total cost of $3,370 per source (2 streams/source 

x 1 sample/stream x $435/sample + $125/hr x 20 hr/source = $3,370/source).

8Assumes cost of sampling and analysis is part of the monitoring program cost.

9 Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

The total capital/startup costs for this ICR are $15,200. This is the total of column D in 

the above table. 

The total operation and maintenance (O&M) costs for this ICR are $1,230,000. This is 

the total of column G. 

The average annual cost for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is estimated to be $1,250,000.

6(c) Estimating Agency Burden and Cost

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

information. EPA's overall 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 

$23,800.

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2015 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 Cost – NESHAP for Chemical 

Manufacturing Area Sources (40 CFR Part 63, Subpart VVVVVV) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

489 existing respondents will be subject to the standard. Based on a 2 percent industry growth 

rate, it is estimated that an additional 10 respondents per year will become subject. The overall 

average number of respondents, as shown in the table below, is 489 per year.

The number of respondents is calculated using the following table that addresses the three 
12

years covered by this ICR.

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

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 10 479 0 0 489

2 10 489 0 0 498

3 10 498 0 0 508

Average 10 489 0 0 498

1

New respondents include sources with constructed, reconstructed and modified affected facilities; and 

assume 2 percent growth per year. 

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 498. 

The number of respondents is broken out into three groups listed in the following table. 

It is assumed that 50% of the respondents only emit organic HAP, 40% of the respondents only 

emit metal HAP, and the remaining 10% of the respondents emit both organic and metal HAP.

Number of Respondents by Emissions Type

Emissions Type Existing Respondents New Respondents Existing & New 

Respondents

Only Organic HAP 246 4.9 251

Only Metal HAP 193 3.9 197

Both HAP 50 1.0 51

Total 489 10 498

The total number of annual responses per year is calculated using the following table: 
13

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification of 

construction/reconstruction

10 1 0 10

Initial notification 10 1 0 10

Notification of compliance status 10 1 0 10

Notification of initial 

performance test

0.2 1 0 0.2

Semiannual compliance report 99.68 2 391 590

Total 620

Note: We assume 20 percent of existing sources will meet the conditions requiring submittal of a 

semiannual compliance report. The remaining 80 percent will keep records of these reports but will not 

submit them.

The number of Total Annual Responses is 620.

The total annual labor costs are $965,000. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost – NESHAP for Chemical Manufacturing 

Area Sources (40 CFR Part 63, Subpart VVVVVV) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

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

(i) Respondent Tally

The total annual labor hours are 9,590. Details regarding these estimates may be found in 

Table 1: Annual Respondent Burden and Cost – NESHAP for Chemical Manufacturing Area 

Sources (40 CFR Part 63, Subpart VVVVVV) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

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

information is estimated to average 15 hours per response.
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The total annual capital/startup and O&M costs to the regulated entity are $1,250,000.

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 520

labor hours at a cost of $23,800. See Table 2: Average Annual EPA Burden and Cost – NESHAP 

for Chemical Manufacturing Area Sources (40 CFR Part 63, Subpart VVVVVV) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment decrease in the respondent burden and number of responses from 

the most recently approved ICR. The decrease occurred because the rule has been in effect for 

three years, and the burden associated with initial compliance (e.g. initial performance tests and 

notification reports) differ from the burden for ongoing compliance (e.g. submittal of semiannual 

reports). However, there is an adjustment increase in the total capital and O&M cost. This is 

primarily due to two reasons: 1) the previous ICR presented capital costs as annualized costs

over 15 years, rather than one-time costs; and 2) the total number of sources with O&M cost (i.e. 

maintain systems and monitors) has increased now that the rule is fully implemented. 

6(g) Burden Statement

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

is estimated to average 15 hours per response. Burden means the total time, effort, or financial 

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

to or for a Federal agency. This includes the time needed to review instructions; 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; adjust the existing ways to comply with any previously applicable instructions and 

requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

An 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 
15

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

Docket ID Number EPA-HQ-OECA-2012-0525. 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 system, 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), EPA West, 

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

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

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2012-0525 and OMB Control Number 2060-0621 in any

correspondence. 

Part B of the Supporting Statement

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

information.
16

Table 1: Annual Respondent Burden and Cost – NESHAP for Chemical Manufacturing Area Sources (40 CFR Part 63, 

Subpart VVVVVV) (Renewal)

A B C D E F G H

Burden Item Hours 

per occurrence

No. of 

occurrences

per 

respondent

per year

Hours

per 

respondent

per year

Respondents

per year a

Technical 

hours per 

year

Management 

hours per 

year

Clerical 

hours per 

year

Total costs per 

year ($)b

(A x B) (C x D) (E x 0.05) (E x 0.10)

1. APPLICATIONS N/A

2. SURVEY AND STUDIES

 Heat exchange system monitoring plan c

40 1 40 0 0 0 0 $0

 Metal process vent monitoring plan d30 1 30 1 30 1.5 3 $3,469.37

3. REPORTING REQUIREMENTS

A. Familiarize with rule requirement e

4 1 4 498 1,993.67 99.7 199.4 $230,558.61

B. Required Activities

 Initial Performance test f

24 1 24 0.2 4.8 0.24 0.48 $555.10

 Design evaluation for process vent 

sources f40 1 40 0.8 32 1.6 3.2 $3,700.66

 Repeat Performance test g

24 1 24 0 0 0 0 $0

C. Create Information Included in 3B

D. Gather Existing Information Included in 3E

E. Write Report

 Notification of 

construction/reconstruction h2 1 2 10 20 1.0 2.0 $2,260.38

 Initial notification i

2 1 2 10 20 1.0 2.0 $2,260.38

 Notification of compliance status j

8 1 8 10 78 3.9 7.8 $9,041.51

 Notification of initial performance test k

2 1 2 0.2 0.4 0.02 0.04 $46.26

 Report of performance test Included in 3B

 Semiannual compliance reports l8 2 16 99.68 1,594.93 80 159 $184,446.89
17

A B C D E F G H

Burden Item Hours 

per occurrence

No. of 

occurrences

per 

respondent

per year

Hours

per 

respondent

per year

Respondents

per year a

Technical 

hours per 

year

Management 

hours per 

year

Clerical 

hours per 

year

Total costs per 

year ($)b

(A x B) (C x D) (E x 0.05) (E x 0.10)

Reporting subtotal 4,339 $436,339.15

4. RECORDKEEPING 

REQUIREMENTS

A. Familiarize with rule requirement e4 1 4 498 1,993.67 99.7 199.4 $230,558.61

B. Plan Activities Included in 3B

C. Implement Activities

 Initial calculations and demonstrations

 TRE calculation for continuous process 

vents m

3 1 3 1.48 4.44 0.22 0.44 $513.22

 Calculation of batch process vent 

emissions n6 1 6 4.44 26.6 1.33 2.66 $3,079.32

 Calculation of metal HAP emissions o2 1 2 2 4 0.2 0.4 $462.58

 Capacity and MTVP calculations for 

storage tanks p1 1 1 0 0 0 0 $0

 Inspection or seal gap measurement for 

storage tanks q2 1 2 0 0 0 0 $0

 Determination of HAP concentrations 

in wastewater streams r20 1 20 2.96 59 3.0 6 $6,842.94

 Recurring calculations and tracking 

requirements

 Organic HAP batch process vent 

emissions s0.5 12 6 4.44 27 1.33 2.7 $3,079.32

 Metal process vent emissions t0.5 12 6 1 6 0.3 0.6 $693.87

 Quarterly CMPU management practice 

inspections u3 4 12 0 0 0 0 $0
18

A B C D E F G H

Burden Item Hours 

per occurrence

No. of 

occurrences

per 

respondent

per year

Hours

per 

respondent

per year

Respondents

per year a

Technical 

hours per 

year

Management 

hours per 

year

Clerical 

hours per 

year

Total costs per 

year ($)b

(A x B) (C x D) (E x 0.05) (E x 0.10)

D. Develop Record System 20 1 20 10 195 10 20 $22,603.79

E. Time to Enter Information

 Operating parameters for control devices 

(batch and continuous process vents)v0.25 52 13 21.12 275 14 27 $31,758.10

 Records of CMPU leak inspections Included in emission control option costs

 Records of heat exchange system

monitoring Included in emission control option costs

 Information related to bag leak detection 

systems w2 4 8 247 1,978.09 98.9 197.8 $228,757.38

 Records of inspections or seal gap 

measurements for storage tanks equipped 

with floating roofs Included in implementation costs

F. Train Personnel 

 Initial N/A

 Refresher and new personnel N/A

G. Audits N/A

Recordkeeping subtotal 5,254 $528,349.14

TOTAL ANNUAL BURDEN x9,590 $965,000

Capital and O&M Cost (see Section 

6(b)(iii)): x$1,250,000 

TOTAL COST: x

$2,220,000 

Assumptions:
19

a Over the next three years, approximately 489 existing respondents per year will be subject to the standard, and 10 additional respondents per year will become 

subject to the standard (assuming 2 percent growth per year). Of these existing respondents (and new respondents), 246 have only organic HAP emissions (5 new 

respondents), 193 have only metal HAP emissions (4 new respondents), and 50 have both types of emissions (1 new respondent).

b This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Managerial $129.93 ($61.87+ 110%); and Clerical $51.79 ($24.66 + 110%). These 

rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by occupational and industry group.”

The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed 

by private industry. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.

c We assume 80 percent of new sources with organic HAP emissions have heat exchange systems and will need to prepare a heat exchange system inspection or 

monitoring plan. However, this cost was included as part of the heat exchange system monitoring program cost.

d All new sources with a chemical manufacturing process unit (CMPU) having uncontrolled metal HAP emissions exceeding 400 lb/yr must prepare a metal 

process vent monitoring plan. The generally available control technologies or management practices (GACT) analysis conducted for the NESHAP estimated there 

to be 27 existing sources meeting this criterion. Assuming an industry growth rate of 2%, we estimate that 1 new source per year (27 x 2% = 1, after rounding) 

will conduct this activity.

e We assume all facilities will spend an average of 8 hours per facility to read and understand monitoring, recordkeeping, and reporting requirements. This time is 

split evenly between items 3A and 4A in this table.

f

Per footnote d, we estimate that 1 new source per year will have uncontrolled metal HAP emissions exceeding 400 lb/yr. Each new source must demonstrate 

compliance by conducting either a performance test or a design evaluation. Although a small percentage of new sources are expected to meet NESHAP emissions 

control requirements for process vents, we assume that none will be constructed over the 3-year period of this ICR. We also assume that source technical staff will 

spend 24 hours on performance tests or 40 hours on design evaluations, and that 20 percent of sources will conduct performance testing while the remaining 80 

percent will opt for design evaluation instead.

g We assume 20 percent of performance tests must be repeated. Per footnote f, we assume that only 1 new source per year having uncontrolled metal HAP 

emissions exceeding 400 lb/yr will become subject to the NESHAP, and that it will opt for design evaluation instead of performance testing. Therefore, this ICR 

does not estimate the cost for a repeat performance test.

h All new sources must submit notification of construction/reconstruction.

i All new sources must submit initial notification.

j All new sources must submit notification of compliance status. We assume that none of these sources will elect to comply with the overlapping rule provisions, 

which means no stringency determinations will be conducted (such determinations could double the cost of preparing the notification).

k We assume 2 hours per notification. Also, per footnote f, we assume that 20 percent of sources will conduct performance testing.

l We assume 20 percent of sources will meet the conditions requiring submittal of a semiannual compliance report. Both existing and new sources must submit 

these reports.

m We assume that 25 percent of new sources with organic HAP emissions have continuous process vents, and that each source must calculate the total resource 

effectiveness (TRE) index.
20

n Assume 75 percent of new sources with organic HAP emissions must calculate the total emissions from batch process vents. We also assume that there are 25 

steps per process and 1 batch process per facility, which corresponds to approximately 6 hours of effort per respondent.

o We assume 2 new source per year with metal HAP emissions must calculate total metal HAP emissions.

p We assume an average of 10 storage tanks at existing sources meet the thresholds for control. Records of tank dimensions, capacity, and maximum true vapor 

pressure (MTVP) are required for all storage tanks requiring control. We also assume no storage tanks at new sources meet the thresholds for control over the 3-

year period of this ICR.

q We assume an average of 10 storage tanks at existing sources meet the thresholds for control, and that all are equipped with either an internal or external floating 

roof. We also assume no storage tanks at new sources meet the thresholds for control over the 3-year period of this ICR.

r We assume each source with organic HAP emissions has process wastewater and must determine HAP concentrations in each stream. We also assume that 50 

percent of sources will use process knowledge to characterize HAP concentrations. The other 50 percent will use sampling and analysis, resulting in the incursion 

of capital costs but not labor costs. Capital costs are calculated separately in this ICR, see Section 6(b).

s We assume that 75 percent of sources with organic HAP emissions have batch process vents. All organic HAP emissions sources with batch process vents, 

except those using control devices, must track emissions from batch process vents or HAP usage. However, only new sources must comply during the 3 years of 

this ICR. We assume that none of these new sources will use control devices.

t All sources having uncontrolled metal HAP emissions must track those emissions from metal process vents or track HAP usage. However, only new sources 

must comply during the 3 years of this ICR. We estimate 1 new source per year.

u Only new sources must comply over the 3-year period of this ICR. We assume all new sources would be performing the required inspections in the absence of 

the rule; therefore, no burden is incurred as a result of the NESHAP.

v We estimate approximately 7% of sources of organic HAP emissions have continuous and batch process vents and are required to monitor operating parameters 

on control devices. We also assume that when operating parameters must be monitored, sources will collect the data automatically, so that the only burden will be 

0.25 hours per week to review results and verify proper system operation.

w All sources using a baghouse to control metal HAP emissions must keep records of bag leak detection systems. We estimate new and existing sources with metal 

HAP emissions uses a baghouse system.

x Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
21

Table 2: Average Annual EPA Burden and Cost – NESHAP for Chemical Manufacturing Area Sources (40 CFR Part 63, 

Subpart VVVVVV) (Renewal)

A B C D E F G H

Burden Item

EPA Hours 

per 

Occurrence

No. of 

occurrences

per plant

per year

EPA hours

per plant

per year

Plants

per year

EPA

technical 

hours

per year

EPA

managerial 

hours

per year

EPA

clerical 

hours

per year

Total cost

per yeara

($)

(A x B) (C x D) (E x 0.05) (E x 0.10)

Attendance of Initial Performance Test

b,c

24 1 24 0.2 5 0 0 $251 

Attendance of Repeat Performance 

Tests d

24 1 24 0 0 0 0 $0 

Report Review

 Notification of 

construction/reconstruction e

2 1 2 10 20 1.0 2.0 $1,023.02 

 Initial Notification e0.5 1 0.5 10 4.9 0.24 0.49 $255.76 

 Notification of compliance status e,f 2.5 1 2.5 10 24.4 1.22 2.44 $1,278.78 

 Notification of initial test g0.5 1 0.5 0.2 0 0 0 $5.23 

 Review test results g0.5 1 0.5 0.2 0 0 0 $5.23 

 Semiannual compliance reports h2 2 4 99.68 399 19.9 40 $20,869.71 

Subtotal 520.49 $23,688.97 

Travel Expenses i$130

TOTAL ANNUAL BURDEN j520 $23,800 

Assumptions:

a This cost is based on the average hourly labor rate as follows: Technical $46.67 (GS-12, Step 1, $29.17 + 60%); Managerial $62.90 (GS-13, Step 5, $39.31 + 

60%); and Clerical $25.25 (GS-6, Step 3, $15.78 + 60%). This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 

percent of Technical hours. These rates are from the OPM, 2015 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.
22

b All new sources with a chemical manufacturing process unit (CMPU) having uncontrolled metal HAP emissions exceeding 400 lb/yr must prepare a metal 

process vent monitoring plan. The generally available control technologies or management practices (GACT) analysis conducted for the NESHAP estimated there

to be 27 existing sources meeting this criterion. Assuming an industry growth rate of 2%, we estimate that 1 new source per year (27 x 2% = 1, after rounding) 

will conduct this activity.

c

Per footnote b, we estimate that 1 new source per year will have uncontrolled metal HAP emissions exceeding 400 lb/yr. Each new source must demonstrate 

compliance by conducting either a performance test or a design evaluation. Although a small percentage of new sources are expected to meet NESHAP emissions 

control requirements for process vents, we assume that none will be constructed over the 3-year period of this ICR. We also assume that source technical staff will 

spend 24 hours on performance tests or 40 hours on design evaluations, and that 20 percent of sources will conduct performance testing while the remaining 80 

percent will opt for design evaluation instead.

d We assume 20 percent of performance tests must be repeated. Per footnote b, we assume that only 1 new source per year having uncontrolled metal HAP 

emissions exceeding 400 lb/yr will become subject to the NESHAP, and that it will opt for design evaluation instead of performance testing. Therefore, this ICR 

does not estimate the cost for a repeat performance test.

e All new sources must submit notification of construction/reconstruction, initial notification, and notification of compliance status.

f We assume that none of these sources will elect to comply with the overlapping rule provisions, which means no stringency determinations will be conducted 

(such determinations could double the cost of preparing the notification).

g

Per footnote c, we assume that 20 percent of sources will conduct performance testing.

h We assume 20 percent of sources will meet the conditions requiring submittal of a semiannual compliance report. Both existing and new sources must submit 

these reports.

i Travel Expenses = (1 person x 0.2 plants/year x 3 days/plant x $50 per diem) + ($500 round trip/plant x 0.2 plants/year) = $130/year.

j Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.