### SUPPORTING STATEMENT **ENVIRONMENTAL PROTECTION AGENCY NESHAP for Source Categories: Generic Maximum Achievable Control Technology**  **Standards (40 CFR Part 63, Subpart YY) (Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR P art 63, S ubpart YY) (Renewal), EPA ICR Number 1871 .06 , OMB Control Number 2060

- 0420 **1(b) Short Characterization/Abstract** The N ational Emission Standards for Hazardous Air Pollutants (NESHAP ) for Source Categories: Generic Maximum Achievable Control Technology ( 40 CFR part 63, subpart YY ) were proposed on October 14, 1998 (63 FR 55178) , promulgated on June 29, 1999 (64 FR 34854) , and amended on : November 22, 1999 (64 FR 63695), November 2, 2001 (66 FR 55843), June 7, 2002 (67 FR 46257) and July 7, 2002 (67 FR 46289)

. These regulations apply to existing facilities and new facilities of the following four categories: Polycarbonates (PC) Production, Acrylic and Modacrylic Fibers (AMF) Production, Acetal Resins (AR) Production , and Hydrogen Fluoride (HF) Production . 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 YY

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

the owners/operators of the affected facilities. They are also required t o maintain records of the occurrence and duration of an y startup, shutdown, or malfunction in the operation of an affected facilit y, or an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essenti al 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 Age ncy (EPA) regional office. Over the next three ye ars, an average of 10 respondents per ye ar will be subject to the standard , and no additional respondents per y ear will become subject to the standard. The burden to the “Affected Public” may be below found in Table 1 : Annual Respondent Burden and Cost

- NESHAP for Source Categories: Generic Maximum Achievable Control Technology

Standards (40 CFR P art 63, S ubpart YY) (Renewal)

. T he burden to the “Federal Government” burden is attributed entirely to wor k performed b y either F ederal emplo ye es or

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government contractors. The burden to the “Federal Government” may be found below in Table 2: Average Annual EPA Burden and Cost

- NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standar ds (40 CFR Part 63, Subpart YY) (Renewal)

. The active (previous) IC R had the following Terms of Clearance (TOC):
This I CR is approved for three y ears. The Agency is reminded to continue to update estimates of the respondent universe and burden as appropriate prior to resubmission of this I CR for renewal.
EPA addressed each item of concern in the TOC . The respondent universe and burden have been thoroughly

checked and all estimates updated.
**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, durin g 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 reasonabl y require. In the Administrator's judgment, hazardous air pollutant (HAP) emissions from PC, AMF, AR and HF source categories 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 YY

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard(s) ensure compliance with

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the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidenc e 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 emission monitors are used to ensure compliance with the standard(s) at all times. D uring 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(s) are used to inf orm 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 properl y installed and operated , leaks are being detected 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 proced ures and for compliance determinations.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 6 3 , subpart YY

. **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, 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 I CR was published in the Federal Register ( 76 FR 26900 ) on May 9, 2011 . 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 y ears have been considered

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

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comment on the burden associated with the standard as it was being developed. For this renewal, EPA consulted with : 1) DuP ont , at ( 302 ) 773

- 0900 ; and 2) General Electric , at ( 864 ) 254

- 2966

. The estimates in this I CR have been updated based on comments received from industry

. 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 f irst Federal Register n otice. **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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
T hese 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

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

- ye ar statute of lim itations on which the permit program is based. T he retention of records for five ye ars allow s EPA to establish the compliance history of a source , an y 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 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 (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.

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**4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents are owners and operators of Pol ycarbonates (PC) Production, Acrylic and Modacrylic Fibers (AMF) Production, Acetal Resins (AR) Production , and Hydrogen Fluoride (HF) Production. The U

. S

. Standard Industrial Classification ( SI C ) code s for the respondents affected b y the standards , which corresponds to the North American Industry Classification Sy stem (NAI CS ) codes , are listed below for the source categories :

**Standard (40 CFR part 61, subpart YY)**  **SIC Codes NAICS Codes**  Polycarbonates (PC) Production (Sy nthetic Rubber Manufacturing) 2822 325212 Acrylic and Modacrylic Fibers (AMF) Production (Manmade Organic Fibers, Except Cellulosic) 2824 325222 Acetal Resins (AR) Production (Plastic Materials, Sy nthetic and Resins, and Nonvulcanizable Elastomers) 2821 325211 Hydrogen Fluoride (HF) Production (Industrial Inorganic Chemicals, Not Elsewhere Classified) 2819 325188
**4(b) Information Requested**  **(i) Data Items**
In this ICR , all the data that is r ecorded or reported is required b y NESHAP for Source Categories: Generic Maximum Achievable Contro l Technology Standards (40 CFR P art 63, S ubpart YY)

. A source must make the following reports:

**Notification s**  Application for approval of construction/reconstruction 63.5(d), 63.1110(a) Notification of initial startup 63.1110(b) Notification of initial applicability 63.09(b), 63.1110(a), 63.1110(c) Notification of compliance status 63.9(h), 63.1110(d)

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**Notification s**  63.1110(a) Notification of performance test and performance evaluation results 63.7(b), 63 .9(e), 63.10(d)(2), 63.1110(d), 63.1110(a) Rescheduled initial performance test 63.7(b)(2) Demonstration of continuous monitoring sy stem 63.9(g) Phy sical or operational change 63.8(a) Opacit y or visible emissions 63.10(d)(3) Develop startup, shutdown, malfunction plan and periodic reports 63.10(d)(5)(i), 63.1110(b), 63.1111 Excess emissions and continuous parameter monitoring s ys tems (CPMS) performance reports 63.1110(a)

**Reports** 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
Startup, shutdown and malfunction reports 63.1110(a), 63.1111(b) A source must keep the following records:
**Recordkeeping** 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 63.9(h), 63.1109(d)

### 7 **Recordkeeping** 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 Some of the r espondents 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 recordke eping at a plant site. Also, regulatory

agencies in cooperation with the 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 th at 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 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.

### 8 **Respondent Activities** Train personnel to be able to respond to a collecti on of information. Transmit, or otherwise disclose the information. Currently sources are using monitoring and reporting equipment that provided 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 Man**  **agement 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, 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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capab ility to compl y with the emission standard. 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 operat ion and maintenance, and for compliance determinations.
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 agenci es, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

### 9

The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibilit y**  All of the respondents are large entities (i.e. large businesses). There are no small entities (i.e., small businesses) affected b y this regulation. However, the impact on small entities (i.e. small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the t ypes of control equipment employ ed, the recordke eping and reporting requirements are the same for both small and large entities. The Agency

considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that large r businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **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 Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR Part 63, Subpart YY) (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 ver 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 display s a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three y ears from these recordkeeping and reporting requirements is estimated to be 3, 718 ( Total L abor Hours from Table 1 below ). 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 an y comments received.

### 10

**6(b) Estimating Respondent Costs (i)**  **Estimating Labor Costs**
This I CR uses the following labor rates: Managerial $1 21.42 ($ 57.82 + 110%) Technical $9 9.14 ($ 47.21 + 110%) Clerical $ 49.81 ($ 23.72 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2011 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 1 10 percent to account for the benefit packages available to those employ ed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated with the information collection activities in the s ubject standard is 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 ma intenance 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**
**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)
PC (use of non contractor) 1 $0 0 $0 $144.55 2 $289.10 PC (us contractor) 2 $0 0 $0 $53,128.85 2 $106,257.70 AM F 1 $0 0 $0 $144.55 3 $433.65
AR 1, 3 $0 0 $0 $144.55 2 $289.10 $7,500 2 $15,000 .00
HF 1, 4 $0 0 $0 $144.55 1 $144.55 $7,931.20 1 $7,931.20 Total $0 $ 130,345.30 Total (rounded) $0 $1 30 , 345
1 We have assumed that each source will respond 5 times per year to comply with the rule at a total cost of $144.55 per source to cover O&M

### 11

costs. This estimate is based on the assumption that it takes 0.5 hours to conduct these tasks at a clerical labor rate of $42.55 per hour for a total labor cost of $21.28 per response. First

- class postage is estimated at $7.63 per response. Thus, the total storage, filing, photocopying, and postage cost per response is $28.91. 2 Based on information we obtained, we have determined that two PC sources out of a total of four sources will use contractor s upport for CPMS O&M, at a total cost of approximately $53,000 per source. 3 Based on our consultation wi th affected entities, we estimate that $7,500 per year are require d on LDAR monitoring for the AR MACT. 4 Based on our consultation with affected entities, we estimate that 80 technical hours per year are required to maintain and c alibrate the scrubber, monitor, and related instruments for the HF MACT unit ($99.14/hr x 80 hr = $7,931 .20 )

. 

### The total capital/startup costs for this I CR are zero. This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I C R are $1 30 , 345

. 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 y ears of the IC R is estimated to be $ 1 30 , 345

. **6(c) Estimating Agency Burden and Cost** 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 maintained by the respondents , periodic inspection o f sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three y ears of the ICR is estimated to be $ 4,025. This cost is based on the average hourl y labor rate as follows:

Manag erial $ 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 1 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 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 Source Cat egories: Generic Maximum Achievable Control Technology Standards (40 CFR Part 63, Subpart YY) (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, approxi mately 10 existing respondents will be subject to the standard. 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 10 per year.

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The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR.
**Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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 10 0 0 10
2 0 10 0 0 10
3 0 10 0 0 10 Average 0 10 0 0 10 1 New respondent 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 10

. 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
Initial requirements for PC Production 0 1 N/A 0 Initial requirements for AMF Production 0 1 N/A 0 Initial requirements for AR Production 0 1 N/A 0 Initial requirements for HF Production 0 1 N/A 0 SSM reports for PC Production 4 1 N/A 4 SSM reports for AMF Production 3 1 N/A 3 SSM reports for AR Production 2 1 N/A 2 SSM reports for HF Production 1 1 N/A 1

### 13 **Total Annual Responses** Periodic reports for PC Production 4 2 N/A 8 Periodic reports for AMF Production 3 2 N/A 6 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 0 2 N/A 0 LDAR reports for AMF Production 0 2 N/A 0 LDAR reports for AR Production 0 2 N/A 0 LDAR reports for HF Production 0 2 N/A 0 Total 30


### The number of Total Annual Responses is 30. The total annual labor costs are $ 42 4, 571

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

- NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR Part 63, Subpart YY) (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 below in Tables 1 and 2, respectively , and summarized below. **(i) Respondent Tally**  The total annual labor hour s are 3, 718 at a cost of $424,571

. Details regarding these estimates may

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

- NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR Part 63, Subpart YY) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 24 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $1 30 , 345

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

**(ii) The Agency Tally**

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The average annual Ag ency burden and cost over next three y ears is estimated to be 69 labor hours at a cost of $ 4,025

. See below Table 2: Average Annual EPA Burden and Cost

NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards (40 CFR Part 63, Subpart YY) (Renewal)

. **6(f) Reasons for Change in Burden** There is an increase in costs for both the respondents and the Agency from the most recentl y approved ICR. The increase in burden cost is due to adjustments in labor rates

. This ICR uses update d labor rates from the Bureau of Labor Statistics to calculate burden costs

. There is a decrease of 286 labor hours for the respondents related to a ty pographical error in the previous I CR. There is no change in the estimation methodology for labor hours to the respondents. This is due to two considerations : 1) the regulations have not changed over the past three ye ars and are not anticipated to change over the next three years ; and 2) the growth rate for respondents is very

low, negative, or non

- e xistent. There is an increase in O&M costs to the respondents as compared to the previous I CR. The O&M costs were updated based on comments received during consultation with the affected entities, and the increase reflects the costs associated with the maintenance and calibration of emission controls and monitors. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 1 24 hours per response. Burden means the total time, effort, or financial resources expended b y 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 s y stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 display s 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 t his I CR under Docket ID Number EPA

- HQ

- OECA

- 2011

- 0251

. 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

### 15

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 al so 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 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 the EPA Docket ID Number EPA

- HQ

- OECA

- 20 11

- 0251 and OMB Control Number 2060

- 0420 in any correspondence.
**Par t B of the Supporting Statement**  This part is not applicable because no statistical methods were used in collecting this information.

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**Table 1: Annual Respondent Burden and Cost** 
**- NESHAP for Source Categories: Generic Maximum Achievable Control**  **Technology Standards (40 CFR Part 63, Subpart YY) (Renewal)**

Burden item (A) Person

hours per occurrence (B)

No. of occurrences per respondent per year (C )

Person

hours per respondent per year (C)=(Ax B) (D)

Respondents per year a (E)

Technical person hours per year (E)=(C x D) (F)

Management person - hours per year (E) x 0.05 (G)

Clerical person hours per year (E) x 0.1 (H)

Cost, $ b
1. Applications N/A 2. Survey and Studies N/A 3. Reporting Requirements A. Read Instructions c Polycarbonated (PC) Production 4 1 4 0 0 0 0 $0 Acrylic and Modacrylic Fibers (AMF) Production 4 1 4 0 0 0 0 $0 Acetal Resins (AR) Production 4 1 4 0 0 0 0 $0 Hydrogen Fluoride (HF) Production 4 1 4 0 0 0 0 $0 B. Required Activities for PC, AMF, AR, & HF c Included in 4C C. Create Information for PC, AMF, AR, & HF c Included in 4 C D. Gather existing information for PC, AM F, AR & HF c Included in 4C E. Write report i Initial requirements: notifications, initia l com

pliance determination, performance tests c

PC Production 52 1 52 0 0 0 0 $0 AMF Production 52 1 52 0 0 0 0 $0 AR Production 52 1 52 0 0 0 0 $0 HF Production 52 1 52 0 0 0 0 $0 ii Startup, Shutdown malfunction reports d PC Production 2 1 2 4 8 0.4 0.8 $ 1,050.87

AMF Production 2 1 2 3 6 0.3 0.6 $ 788.15

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Burden item (A) Person

hours per occurrence (B)

No. of occurrences per respondent per year (C )

Person

hours per respondent per year (C)=(Ax B) (D)

Respondents per year a (E)

Technical person hours per year (E)=(C x D) (F)

Management person - hours per year (E) x 0.05 (G)

Clerical person hours per year (E) x 0.1 (H)

Cost, $ b

AR Production 2 1 2 2 4 0.2 0.4 $ 525.43 HF Production 2 1 2 1 2 0.1 0.2 $ 262.71 iii Periodic reports e PC Production 8 2 16 4 64 3.2 6.4 $ 8,406.91 AMF Production 8 2 16 3 48 2.4 4.8 $6,305.19 AR Production 8 2 16 2 32 1.6 3.2 $ 4,203.45 HF Production 8 2 16 1 16 0.8 1.6 $ 2,101.73 iv Leak detection and repair (LDAR) reports c, f

PC Production 8 2 16 0 0 0 0 $0 AMF Production 8 2 16 0 0 0 0 $0 AR Production 8 2 16 0 0 0 0 $0 HF Production 8 2 16 0 0 0 0 $0 **Reporting Subtotal 207**  4. Recordkeeping Requirements a A. Read Instructions for c 4 1 4 0 0 0 0 $0 PC Production 4 1 4 0 0 0 0 $0 AMF Production 4 1 4 0 0 0 0 $0 AR Production 4 1 4 0 0 0 0 $0 HF Production 4 1 4 0 0 0 0 $0 B. Plan Activities for c 40 1 40 0 0 0 0 $0 PC Production 40 1 40 0 0 0 0 $0 AMF Production 40 1 40 0 0 0 0 $0 AR Production 40 1 40 0 0 0 0 $0 HF Production 40 1 40 0 0 0 0 $0 C. Implement Activities a i Material determinations c PC Production N/A AMF Production N/A AR Production N/A

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Burden item (A) Person

hours per occurrence (B)

No. of occurrences per respondent per year (C )

Person

hours per respondent per year (C)=(Ax B) (D)

Respondents per year a (E)

Technical person hours per year (E)=(C x D) (F)

Management person - hours per year (E) x 0.05 (G)

Clerical person hours per year (E) x 0.1 (H)

Cost, $ b

HF Production N/A ii Control equipment inspection a. Tanks PC Production N/A AMF Production 2 12 24 3 72 3.6 7.2 $ 9,457.77 AR Production 2 12 24 2 48 2.4 4.8 $ 6,305.19 HF Production N/A b. Closed

- vent system PC Production 2 2 4 2 8 0.4 0.8 $ 1,050.87 AMF Production 2 2 4 3 12 0.6 1.2 $1, 576.29 AR Production 2 2 4 2 8 0.4 0.8 $ 1,050.87 HF Production 2 2 4 1 4 0.2 0.4 $ 525.43 iii Control equipment leak mo nitoring
a. Cover vented to control device PC Production 1 2 2 2 4 0.2 0.4 $525.43 AMF Production 1 2 2 3 6 0.3 0.6 $ 788.15 AR Production 1 2 2 2 4 0.2 0.4 $ 525.43 HF Production 1 2 2 1 2 0.1 0.2 $ 262.71 b. Closed

- vent system PC Production 1 2 2 2 4 0.2 0.4 $ 525.43 AMF Production 1 2 2 3 6 0.3 0.6 $ 788.15 AR Production 1 2 2 2 4 0.2 0.4 $ 525.43 HF Production 1 2 2 1 2 0.1 0.2 $ 262.71 iv. Control devices a. Initial requirements design analysis, performance c Test PC Production 80 1 80 0 0 0 0 $0

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Burden item (A) Person

hours per occurrence (B)

No. of occurrences per respondent per year (C )

Person

hours per respondent per year (C)=(Ax B) (D)

Respondents per year a (E)

Technical person hours per year (E)=(C x D) (F)

Management person - hours per year (E) x 0.05 (G)

Clerical person hours per year (E) x 0.1 (H)

Cost, $ b

AMF Production 80 1 80 0 0 0 0 $0 AR Production 80 1 80 0 0 0 0 $0 HF Production 80 1 80 0 0 0 0 $0 b. Operate and maintain CMS PC Production 8 12 96 2 192 9.6 19.2 $ 25,220.73 AMF Production 8 12 96 3 288 14.4 28.8 $ 37,831.11 AR Production 8 12 96 2 192 9.6 19.2 $ 25,220.73 HF Production 8 12 96 1 96 4.8 9.6 $ 12,610.37 v. LDAR Program a. Initial requirement: Identify all effected streams c

PC Production 20 1 20 0 0 0 0 $0 AMF Production 20 1 20 0 0 0 0 $0 AR Production 20 1 20 0 0 0 0 $0 HF Production 20 1 20 0 0 0 0 $0 b. Perform monitoring/repairs PC Production 1) In

- house g 0.1 1,092 109.2 2 218.4 10.92 21.84 $ 28,688.59 2) Use of contractor support h 2 $8,000.00 AMF Production 16 12 192 3 576 28.8 57.6 $ 75,662.21 AR Production 16 12 192 2 384 19.2 38.4 $ 50,441.47 HF Production g 0.1 1,092 109 1 109.2 5.46 10.92 $ 14,219.69 vi. Container vapor tightness certification

PC Production N/A AMF Production N/A AR Production N/A HF Production N/A D. Develop Record System

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Burden item (A) Person

hours per occurrence (B)

No. of occurrences per respondent per year (C )

Person

hours per respondent per year (C)=(Ax B) (D)

Respondents per year a (E)

Technical person hours per year (E)=(C x D) (F)

Management person - hours per year (E) x 0.05 (G)

Clerical person hours per year (E) x 0.1 (H)

Cost, $ b

i. Develop startup, shutdown, malfunction plan c

PC Production 20 1 20 0 0 0 0 $0 AMF Production 20 1 20 0 0 0 0 $0 AR Production 20 1 20 0 0 0 0 $0 HF Production 20 1 20 0 0 0 0 $0 ii. Control equipment c PC Production 16 1 16 0 0 0 0 $0 AMF Production 16 1 16 0 0 0 0 $0 AR Production 16 1 16 $0 HF Production 16 1 16 0 0 0 0 $0 iii. LDAR Program c PC Production 40 1 40.00 0 0 0 0 $0 AMF Production 40 1 40.00 0 0 0 0 $0 AR Production 40 1 40.00 0 0 0 0 $0 HF Production 40 1 40.00 0 0 0 0 $0 E. Record Information (all information required by standard) i. Initial requirements: cover design, control device design, and control equipment testing c

PC Production 17 1 17 0 0 0 0 $0 AMF Production 17 1 17 0 0 0 0 $0 AR Production 17 1 17 0 0 0 0 $0 HF Production 17 1 17 0 0 0 0 $0 ii. Control equipment inspection PC Production 1 2 2 2 4 0.2 0.4 $ 525.43 AMF Production 1 2 2 3 6 0.3 0.6 $ 788.15 AR Production 1 2 2 2 4 0.2 0.4 $ 525.43 HF Production 1 2 2 1 2 0.1 0.2 $ 262.71

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Burden item (A) Person

hours per occurrence (B)

No. of occurrences per respondent per year (C )

Person

hours per respondent per year (C)=(Ax B) (D)

Respondents per year a (E)

Technical person hours per year (E)=(C x D) (F)

Management person - hours per year (E) x 0.05 (G)

Clerical person hours per year (E) x 0.1 (H)

Cost, $ b
iii. Control equipment monitoring i PC Production 1 52 52 2 104 5.2 10.4 $ 13,661.23 AMF Production 1 52 52 3 156 7.8 15.6 $ 20,491.85 AR Production 1 52 52 2 104 5.2 10.4 $ 13,661.23 HF Production 1 52 52 1 52 2.6 5.2 $ 6,830.61 iv. Control device CMS PC Production 1 12 12 2 24 1.2 2.4 $ 3,152.59 AMF Production 1 12 12 3 36 1.8 3.6 $ 4,728.89 AR Production 1 12 12 2 24 1.2 2.4 $ 3,152.59 HF Production 1 12 12 1 12 0.6 1.2 $ 1,576.29 v. LDAR program PC Production g 0.02 1,092 21.84 2 43.68 2.18 4.37 $ 5,737.42 AMF Production 2 12 24 3 72 3.6 7.2 $ 9,457.77 AR Production 2 12 24 2 48 2.4 4.8 $ 6,305.19 HF Production g 0.02 1,092 21.84 1 21.84 1.09 2.18 $ 2,868.45 F. Time to Train Personnel i. Material determination methods PC Production N/A AMF Production N/A AR Production N/A HF Production N/A ii. Control equipment inspection and mo nitoring j

PC Production 8 1 8 4 32 1.6 3.2 $ 4,203.45 AMF Pr o duction 8 1 8 3 24 1.2 2.4 $ 3,152.59 AR Production 8 1 8 2 16 0.8 1.6 $ 2,101.73 HF Production 8 1 8 1 8 0.4 0.8 $ 1,050.87 iii. LDAR program f, j PC Production 2 1 2 4 8 0.4 0.8 $ 1,050.87 AMF Production 2 1 2 3 6 0.3 0.6 $ 788 .15

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Burden item (A) Person

hours per occurrence (B)

No. of occurrences per respondent per year (C )

Person

hours per respondent per year (C)=(Ax B) (D)

Respondents per year a (E)

Technical person hours per year (E)=(C x D) (F)

Management person - hours per year (E) x 0.05 (G)

Clerical person hours per year (E) x 0.1 (H)

Cost, $ b

AR Production 2 1 2 2 4 0.2 0.4 $ 525.43 HF Production 2 1 2 1 2 0.1 0.2 $ 262.71 iv. Container leak tight method PC Production N/A AMF Production N/A AR Production N/A HF Production N/A **Recordkeeping Subtotal 3,511**  **Subtotals Labor Burdens and Costs 3,233.12**  **161.65 323.31**  **$424,570.83 TOTAL LABOR BURDEN AND COST (rounded)**  **3,718 $**  **424,571**
**Assu mptions:** 
a We have assumed that there are 10 existing sources, and that no additional new sources will become subject to the rule over the next three years. It is also assumed that affected facility owners and operators have already complied with the initial requi rem ents including the installation of any required equipment. In addition, we have assumed that two sources under this category will hire contractors to comply with the monito ring and recordkeeping requirements of the rule while reports are developed by the source personnel. b This ICR uses the following labor rates: $ 121.42 per hour for Executive, Administrative, and Managerial labor; $ 99.14 per hour for Technical labor, and $ 49.81 per hour for Clerical labor. These rates are from the United States Dep artment of Labor, Bureau of Labor Statistics, September 2011, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages av ailable to those employed by private industry.
c We have assumed that there will be no new sources over the next three years of this ICR. We have also assumed that all exist ing sources have already complied with this one

- tim e activity. d All major sources must submit startup, shutdown, malfunction reports semiannually when actions are taken in the event of a st artup, shutdown, or malfunction that are consistent with the source’s SSM plans. Sources can submit this information with the pe riodic reports.
e The rules requires that all sources submit periodic reports (semiannually or according to the schedule for Title V). f The standards for equipment leak requires the submittal of an initial report and semiannual reports of leak detectio n and repair (LDAR) and any changes to the processes, monitoring frequency and initiation of a quality improvement program. We have assumed that sources are sub mitting the required LDAR information with the periodic reports. g Visual inspections are requ ired once per shift with a total of three shifts per day, at seven days per week, for 52 w eeks per year. (3x7x52) for a total of 1,092 inspections per year. h We have determined that, based on the industry representative in the PC category, the two source s’ use of contractor support to complete the LDAR related monitoring will cost an estimated $8,000. i We have assumed that control equipment monitoring should be done on a weekly basis.

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j We have assumed that there will be some labor hours associated wi th rule analysis and training per year.

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**Table 2: Average Annual EPA Burden and Cost**
**- NESHAP for Source Categories: Generic Maximum Achievable Control**  **Technology Standards (40 CFR Part 63, Subpart YY) (Renewal)**

Burden item (A) Person

hours per occurrence (B) No. of

occurrences per respondent per year (C)

Person

hours per respondent per year (C)=(A) x (B) (D) Respondents per year a (E)

Technical person hours per year (E)=(C) x (D) (F) Management person - hours per year (E) x 0.05 (G)

Clerical person hours per year (E) x 0.1 (H) Cost, $ b

Revie w Reports 1. 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 0 00 0 0 $0 d. Performance test reports c, d 4 1 4 0 0 0 0 $0 2. Periodic requirements a. Startup, shutdown, malfunction reports e 2 1 2 0 0 0 0 $0 b. Periodic reports e 3 2 6 10 60 3 6 $ 4,024.89 c. Leak detection and repair (LDAR) reports f 3 2 6 0 0 0 0 $0 d. Title V compliance reports 2 **Subtotals Labor Burden and Cost 60**  **3 6**  **$ 4,024.89** 
**TOTAL LABOR BURDEN AND COST (rounded)**  **69 $**  **4,025**
**Assu mptions:** 
a We have assumed that there are 10 existing sources, and that no additional new sources will become subject to the rule over the next three years. b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government o verhead expenses: $62.27 for Managerial (GS

- 13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS

- 12, Step 1, $28.88 x 1.6) and $25 .01 Clerical (GS

- 6, Step 3, $15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.
c We have assumed that there will be no new sources over the next three years of this I CR, We have also assumed that all existing sources have already complied with this one

- tim e activity. d We have assumed that the Agency will not have additional burden from sources conducting performance tests due to a process ch ange that may or may not result in the source meeting additional requirements.

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e We have assumed that all sources have already developed a startup, shutdown and malfunction (SSM) plan. We have further assumed that sources are submitting their information on SSM with the periodic report which is submitted on a semiannual basis. f The equipment leak standards require the submittal of an initial report and semiannual report of leak detection and repair (L DAR) program experiencing any changes to the processes, monitoring fre quency and initiation of a quality improvement program. We have assumed that sources are submitting the required LDAR information with the periodic reports.