### SUPPORTING STATEMENT **ENVIRONMENTAL PROTECTION AGENCY**
**NESHAP for Source Categories: Generic Maximum Achievable Control Technology**  **Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (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 for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal) , EPA I CR Number 1871.0 9 OMB Control Number 2060

- 0420. **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS ) for the regulations publ ished at regulatory

citation were proposed on October 14, 2998 , and promulgated on June 29, 1999 and amended on November 22, 1999, November 2, 2001, June 7, 2002 , July 12 , 2002 , and October 8, 2014 . These regulations apply to new and existing facilities o f 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 reconstructi on 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 th e affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility , or any period during which the monitoring sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain th e 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 United States Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). The PC industry

consists of facilities that produce polycarbonates, a process that involves a poly merization reaction using either a solution or suspension process in either a batch or continuous mode. All production of polycarbonates in the United States is currentl y based on the

### 2

poly merization reaction of bisphenols with phosgene in the presence of cataly sts, solvents (mainly methylene chloride) and other additives.
The AMF industry

consists of facilities that produce acrylic and modacrylic fibers, whic h are manufactured s ynthetic fibers in which the fiber

- forming substance is any long

- chain sy nthetic pol ym er containing acrylonitrile units. The AR industry

consists of facilities that produce homopoly mers and/or copoly

mers of alternating ox ym ethyl ene uni ts. Acetal resins are also known as polyoxy methylenes, pol ya cetals, and aldehyde resins. The HF industry

consists of facilities that produce and recover hydrogen fluoride by reacting calcium fluoride with sulfuric acid. In this subpart, hydrogen fluoride production is not a process that produces gaseous hydrogen fluoride for direct reaction with hydrated aluminum to form aluminum fluoride (i.e., the hydrogen fluoride is not recovered as an intermediate or final product prior to reacting with the hydrated aluminum).
Over the n ext three years, approximately 3 PC production facilities, 1 AMF production facility , 2 AR production facilities and 1 HF production facility will be subject to the standard and no additional respondents per ye ar will become subject to the standard. The Office of Management and Budget (OMB) approved the currentl y active I CR without any

Terms of Clearance.
The burden to the “Affected Public” may be found in Table 1 : Annual Respondent Burden and Cost

– NESHAP for Source Categories: Generic Maximum Achievable Control Technology

Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal)

. The burden to the Federal Government is attributed entirely to work performed by

federal employees or government contractor s and can be found in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal)

. **2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 112 of the Clean Air 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

. Inaddition, section 114(a) states that the Administrator may require any

owner/operator subject to any requirement of this Act to:

### 3 (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 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 ensure compliance with the applicable regulations which w ere promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected f acility ’ 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 achiev ed 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 regulat ions. 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 is 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. The information generated by the monitoring, recordkeeping and reporting requirements described in this I CR is used by the Agency

to ensure that facilities affected by the NESHAP continues to operate the control equipment in compliance with the regulation. **3. Nonduplication, Consultations, and Other Collection Criter ia** 

### 4

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

. **3(a) Nonduplication** 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 No tice 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 ( 79 FR 30117 ) on May 27, 2014 . No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency

has consulted industry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeeping and reporting provisions in the standard, is Enforcement and Compliance History Online (ECHO), which is operated and maintained by EPA's Office of Compliance. ECHO is EPA ’ s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts.
Industry trade association and other interested parties were provided an opportunity to comment on the burden ass ociated with the standard as it was being developed

. In developing this I CR, we contacted DuPont at (302)773

- 0900 and General Electric at (864) 254

- 2966. 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. In this case, no comments were received. **3(d) Effects of Less Frequent Colle ction**  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.

### 5

**3(e) General Guidelines**
These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR Part 1320, Section 1320.5. These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five ye ar records retention requirement is consistent with the Part 70 permit program and the five ye ar statute o f limitations on which the permit program is based. The retention of records for five years allow s 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 fo und 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 submitte d 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 b y 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 questions. **4. The Respondents and the Information Requested**  **4(a) Respondents/SIC Codes** The respondents to the recordkeeping and reporting requirements are owners and operators of PC, AMF, AR, and HF production facilities

. The United States Standard Industrial Classification ( SI C ) code s for the respondents affected b y the standards , and the corresponding North American Industry Classification System (NAI CS ) codes, are listed below for the source categories

.
**Standard (** **40 CFR Part 63, Subpart YY) SIC Codes**  **NAICS Codes** Polycarbonates (PC) Production (Sy nthetic Rubber Manufacturing) 2822 32521 2

### 6

**Standard (** **40 CFR Part 63, Subpart YY) SIC Codes**  **NAICS Codes** Acrylic and Modacrylic Fibers (AMF) Production ( Organic Fibers

- Noncellulosic, and Artificial and Sy nthetic Fibers and Flaments Manufacturing) 2824 32522 0

Acetal Resins (AR) Production (Plastic Materials and Resins) 2821 325211
Hydrogen Fluoride (HF) Production (Industrial Inorganic Chemicals, and Other Basic Inorganic Chemical Manufacturing ) 2819 32518 0

**4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal). A source must make the following reports:

**Notification s**  Application for approval of construction/reconstruction 63.5(d), 63.1110(a) Notification of anticipated date of initial startup. 63.5 Notification of actual date of initial startup (if not submitted under 63.5) 63.1110(a) 63.1110(b) 63.1066(a) Notification of initial applicability 63.1110(a), 63.1110(c) Notification of compliance status 63.999(b), 63.1110(d) 63.1110(a) , 63.1039(a), Notification of performance test and performance evaluation results 63.999(a), , 63.1110(d),

### 7

**Notification s**  63.1110(a) , 63.987(c), 63.988(b), 63.997(a) Rescheduled initial performance test 63.999(a)(1)(i) Develop startup, shutdown, malfunction plan and periodic reports 63.10(d)(5)(i), 63.1110( a), 63.1111 Operating parameter value and rationale selection 63.1110(a), 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 63.999(c), 63.1110(e), 63.1108(a), 63.1109 , 63.1030(b) 63.1066(b) Startup, shutdown and malfunction reports (for AR and HF onl y) 63.1110(a) , 63.1111
A source must keep the following records:
**Recordkeeping** Maintain records of startup, shutdown, malfunctions periods when excess emissions have occurred during the reporting period (AR and HF onl y) 63.1109(a) , 63.998(d)

Records of verification of DOT tank certification or Method 27 of appendix A to 40 CFR Part 60 testing (HF Only) 63.1105(i) Records of maintenance 63.1109(a) Maintain records of performance test and performance evaluation results 63.1109(a) , 63.998(a)

### 8
**Recordkeeping** Maintain records of all reports and notifications 63.63.998(a) , 63.1109(a) Maintain record of applicability 63.998(a), 63.1109( a) Records of CPMS operation adjustments, calibration checks, and maintenance 63.998(c), 63.1109(a) Records of nonflare control and recovery device regulated source monitoring 63.998(c) Records of closed vent systems 63.998(d) Records of storage vessel and transfer racks 63.998(d) Records of equipment leaks 63.998(d) Records of monitored parameters out of range 63.998(d) Records of malfunctioning or inoperative CPMS 63.998(c) Records of implementation of leak detection and repair (LDAR) standards provision 63.1107 , 63.998(d), 63.1038(b)

- (c) Records of vessel dimensions and capacity 63.1065(a) Records of floating roof inspection results for storage vessels (tanks) 63.1065(b) Records of floating roof landing 63.1065(c) Records are required to be retained for five years 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 recordke eping at
a plant site. **(ii) Respondent Activities**
**Respondent Activities** Familiarization with the regulatory requirements. 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.

### 9
**Respondent Activities** Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.

**5. The Information Collected: Agency Activities, Collection Methodology, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information.
**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 Integrated Compliance Information System (I CI S) and ECHO.
**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 capability to comply

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 operation and maintenance, and for compliance determinations.

### 10

In formation contained in the reports is reported b y state and local governments in the IC IS Air database which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibi lity**  All of the respondents are large entities (i.e. large businesses). 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 ty pes of control equipment employed, the recordkeeping 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, therefo re, cannot reduce them further for small entities. **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 for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (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 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 requirement s is estimated to be 3, 240 ( Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previously

### 11

approved ICR , and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs** 
This I CR uses the following labor rates: Managerial $ 117.20 ($ 55.81 + 110%) Technical $ 55.25 ($ 26.31 + 110%) Clerical $ 38.62 ($ 18.39 + 110%)
These labor rates are based on the May 2013 National Occupational Employ ment and Wage Estimates for the United States, occupational codes 51

- 8091 for chemical plant and system operators (technical), 11

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

- 6010 for secretaries and administrative assistants (clerical).

**(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe 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 Capital/Startup and Operation and Maintenance (O&M) Costs** 
(A) Source Category and Cost Type (B)

Capital/ Startup Cost for One Respondent (C)

Number of Respondents (D)

Total Capital/ Startup Cost (B X C) (E)

Annual Costs for One Respondent (F)

Number of Respondents (G)

Total Annual Cost (E X F) PC (O&M) $0 0 $0 $1,505 3 $4,515 PC (PRD) $12,649 3 $ 37,947 $1,804 3 $5,412 PC (LDAR) $3,899 3 $ 11,697 $541 3 $1,623
AM F (O&M) $0 0 $0 $1,505 1 $1,505
AM F (PRD) $37,063 1 $ 37,063 $5,277 1 $5,277
AM F (LDAR) $1,428 1 $ 1,428 $223 1 $223

AR 1,2 $0 0 $0 $1 35 2 $ 270 $7,500 2 $15,000

### 12 **Capital/Startup and Operation and Maintenance (O&M) Costs**
(A) Source Category and Cost Type (B)

Capital/ Startup Cost for One Respondent (C)

Number of Respondents (D)

Total Capital/ Startup Cost (B X C) (E)

Annual Costs for One Respondent (F)

Number of Respondents (G)

Total Annual Cost (E X F)

HF 1,3 $0 0 $0 $1 35 1 $ 135 $ 4,420 1 $ 4,420 Total (rounded) $ 88, 100 $ 38, 400 Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. 1 We have assumed that each source will respond 5 times per year to comply with the rule at a total cost of $13 5 per source to cover costs. This estimate is based on the assumption that it takes 0.5 hours to conduct these tasks at a clerical labor rate of $38. 62 per hour for a total labor cost of $19. 31 per response. First

- class postage is estimated at $7.63 per response. 2 Based on our consultation with affected entities, we estimate that $7,500 per year are required on LDAR
mo nitoring for the AR MACT. 3 Based on our consultation with affected entities, we estimate that 80 technical hours per year are required to maintain and calibrate the scrubber, monitor, and related instruments for the HF MACT unit ($5 5.25 /hr x 80 hr = $4, 420 ). 

### The total capital/startup costs for this I CR are $88, 100 . This is the total o f column D in the above table.
The to tal operation and maintenance ( O&M) costs for this I CR are $ 38, 400

. 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 IC R is estimated to be $ 127 , 0 00

. These are recordkeeping costs. **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 maint ained 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 $5, 230

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% )

### 13

These rat es are from the Office of Personnel Management (OPM) , 20 1 4 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 Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (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, approximately 7 existing respondents will be subject to the s tandard (3 in the PC source category , 1 in the AMF source category , 1 in the HF source c ateg ory and 2 in the AR source category) . It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as s hown in the table below, is 7 per year. 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 7 0 0 7
2 0 7 0 0 7
3 0 7 0 0 7 Average 0 7 0 0 7 1 New respondents include sources with constructed, reconstructed and modified affected facilities.


### C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 7. The total number of annual responses per ye ar is calculated using the following table:
**Total Annual Responses**

### 14
**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 3 1 N/A 3 Initial requirements for AMF Production 1 1 N/A 1 Initial requirements for AR Production 0 1 N/A 0 Initial requirements for HF Production 0 1 N/A 0 SSM reports for AR Production 2 1 N/A 2 SSM reports for HF Production 1 1 N/A 1 Periodic reports for PCP roduction 3 2 N/A 6 Periodic reports for AMF Production 1 2 N/A 2 Periodic reports for AR Production 2 2 N/A 4 Periodic reports for HF Production 1 2 N/A 2 LDAR reports for PC Production 3 2 N/A 6 LDAR reports for AMF Production 1 2 N/A 2
LDAR reports for AR Production 2 2 N/A 4 LDAR reports for HF Production 1 2 N/A 2 Total 3 5 

### The number of Total Annual Responses is 35

. The total annual labor costs are $ 190 , 000

. 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 for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (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 in Tables 1 and 2 below , respectively , and summarized below. **(i) Respondent Tally**
The total annual labor hours are 3, 240

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

– NESHAP for Source Categories: Generic

### 15

Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal)

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

pical tasks for managers are to review and a pprove reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records. Furthermore, the annual public reporting and re cordkeeping burden for this collection of information is estimated to average 93 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $ 126,515

. 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 115 labor hours at a cost of $ 5, 230 . See Table 2: Average Annual EPA Burden and Cost

– NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal)

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

pical 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 ty pical duties of clerical s taff are to proofread the reports, make copies and maintain records. **6(f) Reasons for Change in Burden**
There is a decrease in the total estimated respondent burden compared with the I CR currentl y approved b y OMB. The decrease in burden from the most recently approved ICR is primarily because the number of sources in the PC and AMF has decreased

. However, there is a small increase in EPA burden and other changes to the burden calculation in this I CR. This I CR inc orporates the requirements of the rule amendment to the PC and AMF subcategories. The rule amendment added requirements related to leak detection and repair (LDAR) and pressure relief devices (PRD) for subject PC and AMF facilities

. We assume existing PC and AMF facilities will come into compliance with the new requirements during the three

- ye ar period covered under this I CR.
There is also an overall decrease in capital/startup vs. operation and maintenance (O&M) costs as calculated in section 6(b)(iii) compared with the ICR currentl y approved by OMB due to the decrease in overall number of respondents and also due to a revision to the assumptions

### 16

regarding the use of contractors to perform O&M in the PC production industry

. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 93 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 ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collecti on 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 sugg ested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 201 4

- 0069 . 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 Doc ket 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 i s (202) 566

- 1927

. 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 1 4

- 0069 and OMB Control Number 2060

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

### 17

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

**– NESHAP for Source Categories: Generic**  **Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40**  **CFR Part 63, Subpart YY) (Renewal)**

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

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

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

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

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

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

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

**Total Cost Per year**  **d**

1. Applications N/A 2. Survey and Studies N/A 3. Reporting Requirements A. Familiarize with Rule Requirement s e See 4A B. Required Activities for PC, AMF, AR, HF e Included in 4C C. Create Information for PC, AMF, AR, HF e Included in 4C D. Gather Information for PC, AMF, AR, HF e Included in 4C E. Write report Initial notification requirements for pressure relief devices Polycarbonates (PC) 4 1 4 3 12 0.6 1.2 $779.66 Acrylic and Modacrylic Fibers (AMF) 4 1 4 1 4 0.2 0.4 $259.89 General initial notification requirements e, f Polycarbonates (PC) 52 1 52 0 0 0 0 $0 Acrylic and Modacrylic Fibers (AMF) 52 1 52 0 0 0 0 $0 Acetal Resins (AR) 52 1 52 0 0 0 0 $0 Hydrogen Fluoride (HF) 52 1 52 0 0 0 0 $0 Startup, shutdown and malfunction reports g

### 18

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

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

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

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

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

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

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

**Total Cost Per year**  **d**

Polycarbonates (PC) N/A Acrylic and Modacrylic Fibers (AMF) N/A Acetal Resins (AR) 2 1 2 2 4 0.2 0.4 $259.89 Hydrogen Fluoride (HF) 2 1 2 1 2 0.1 0.2 $129.94 Periodic reports h Polycarbonates (PC) 13.5 2 27 3 108 5.4 10.8 $7,016.98 Acrylic and Modacrylic Fibers (AMF) 15.5 2 31 1 31 1.55 3.1 $2,014.13 Acetal Resins (AR) 8 2 16 2 32 1.6 3.2 $2,079.10 Hydrogen Fluoride (HF) 8 2 16 1 16 0.8 1.6 $1,039.55 Leak detection and repair reporting i Polycarbonates (PC) 12 2 24 3 72 3.6 7.2 $4,677.98 Acrylic and Modacrylic Fibers (AMF) 12 2 24 1 24 1.2 2.4 $1,559.33 Acetal Resins (AR) 8 2 16 2 32 1.6 3.2 $2,079.10 Hydrogen Fluoride (HF) 8 2 16 1 16 0.8 1.6 $1,039.55 **Subtotal for Reporting Requirements 406**  **$ 22,935**  4. Recordkeeping Requirements A. Familiarize with Rule Requirements Polycarbonates (PC) 4 1 4 3 12 0.6 1.2 $779.66 Acrylic and Modacrylic Fibers (AMF) 4 1 4 1 4 0.2 0.4 $259.89 Acetal Resins (AR) 4 1 4 2 8 0.4 0.8 $519.78 Hydrogen Fluoride (HF) 4 1 4 1 4 0.2 0.4 $259.89 B. Plan activities Polycarbonates (PC) 40 1 40 3 120 6 12 $7,796.64 Acrylic and Modacrylic Fibers (AMF) 40 1 40 1 40 2 4 $2,598.88

### 19

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

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

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

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

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

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

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

**Total Cost Per year**  **d**

Acetal Resins (AR) e 40 1 40 0 0 0 0 $0 Hydrogen Fluoride (HF) e 40 1 40 0 0 0 0 $0 C. Implementation activities Material determinations e N/A Control equipment inspections a. Tanks Polycarbonates (PC) N/A Acrylic and Modacrylic Fibers (AMF) 2 12 24 1 24 1.2 2.4 $2,775.49 Acetal Resins (AR) 2 12 24 2 48 2.4 4.8 $5,550.98 Hydrogen Fluoride (HF) N/A b. Closed

- vent systems Polycarbonates (PC) 2 2 4 3 12 0.6 1.2 $1,387.75 Acrylic and Modacrylic Fibers (AMF) 2 2 4 1 4 0.2 0.4 $462.58 Acetal Resins (AR) 2 2 4 2 8 0.4 0.8 $925.16 Hydrogen Fluoride (HF) 2 2 4 1 4 0.2 0.4 $462.58 Control equipment leak monitoring a. Cover vented to control device Polycarbonates (PC) 1 2 2 3 6 0.3 0.6 $693.87 Acrylic and Modacrylic Fibers (AMF) 1 2 2 1 2 0.1 0.2 $231.29 Acetal Resins (AR) 1 2 2 2 4 0.2 0.4 $462.58 Hydrogen Fluoride 1 2 2 1 2 0.1 0.2 $231.29

### 20

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

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

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

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

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

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

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

**Total Cost Per year**  **d**

(HF) b . Closed vent system Polycarbonates (PC) 1 2 2 3 6 0.3 0.6 $693.87 Acrylic and Modacrylic Fibers (AMF) 1 2 2 1 2 0.1 0.2 $231.29 Acetal Resins (AR) 1 2 2 2 4 0.2 0.4 $462.58 Hydrogen Fluoride (HF) 1 2 2 1 2 0.1 0.2 $231.29 Control devices a. Initial requirements design analysis, performance test Polycarbonates (PC) e 80 1 80 0 0 0 0 $0 Acrylic and Modacrylic Fibers (AMF) 80 1 80 1 80 4 8 $5,197.76 Acetal Resins (AR) e 80 1 80 0 0 0 0 $0 Hydrogen Fluoride (HF) e 80 1 80 0 0 0 0 $0 b. Operate and maintain CMS Polycarbonates (PC) 8 12 96 3 288 14.4 28.8 $33,305.90 Acrylic and Modacrylic Fibers (AMF) 8 12 96 1 96 4.8 9.6 $11,101.97 Acetal Resins (AR) 8 12 96 2 192 9.6 19.2 $22,203.94 Hydrogen Fluoride (HF) 8 12 96 1 96 4.8 9.6 $11,101.97 Pressure relief devices Polycarbonates (PC) 2 1 2 3 6 0.3 0.6 $693.87 Acrylic and Modacrylic Fibers 2 1 2 1 2 0.1 0.2 $231.29

### 21

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

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

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

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

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

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

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

**Total Cost Per year**  **d**

(AMF) Leak detection and repair program a. Initial requirements: Identify all affected streams Burden as a result of October 2014 Rule Amendment Polycarbonates (PC) 2 1 2 3 6 0.3 0.6 $389.83 Acrylic and Modacrylic Fibers (AMF) 2 1 2 1 2 0.1 0.2 $129.94 General Burden e Polycarbonates (PC) 20 1 20 0 0 0 0 $0 Acrylic and Modacrylic Fibers (AMF) 20 1 20 0 0 0 0 $0 Acetal Resins (AR) 20 1 20 0 0 0 0 $0 Hydrogen Fluoride (HF) 20 1 20 0 0 0 0 $0 b. Perform monitoring/repairs Polycarbonates (PC) 3 $6,020.00 Acrylic and Modacrylic Fibers (AMF) 1 $1,505.00 Acetal Resins (AR) 16 12 192 2 384 19.2 38.4 $24,949.25 H ydrogen Fluoride (HF) j 0.1 1092 109.2 1 109.2 5.46 10.92 $7,094.94 Container vapor tightness certification N/A D. Develop Record System

### 22

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

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

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

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

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

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

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

**Total Cost Per year**  **d**

Develop startup, shutdown, malfunction plan g Polycarbonates (PC) N/A Acrylic and Modacrylic Fibers (AMF) N/A Acetal Resins (AR) e 20 1 20 0 0 0 0 $0 Hydrogen Fluoride (HF) e 20 1 20 0 0 0 0 $0 Control equipment Burden as a result of October 2014 Rule Amendment Spinning Lines (AMF) 2 1 2 1 2 0.1 0.2 $129.94 General Burden e Polycarbonates (PC) 16 1 16 0 0 0 0 $0 Acrylic and Modacrylic Fibers (AMF) 16 1 16 0 0 0 0 $0 Acetal Resins (AR) 16 1 16 0 0 0 0 $0 Hydrogen Fluoride (HF) 16 1 16 0 0 0 0 $0 Pressure relief devices Polycarbonates (PC) 2 1 2 3 6 0.3 0.6 $389.83 Acrylic and Modacrylic Fibers (AMF) 2 1 2 1 2 0.1 0.2 $129.94 Leak detection and repair program Polycarbonates (PC) 44 1 44 3 132 6.6 13.2 $8,576.30 Acrylic and Modacrylic Fibers (AMF) 44 1 44 1 44 2.2 4.4 $2,858.77 Acetal Resins (AR) e 40 1 40 0 0 0 0 $0 Hydrogen Fluoride (HF) e 40 1 40 0 0 0 0 $0 E. Record All Information Required

### 23

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

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

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

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

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

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

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

**Total Cost Per year**  **d**

by Standards Initial requirements e Polycarbonates (PC) 17 1 17 0 0 0 0 $0 Acrylic and Modacrylic Fibers (AMF) 17 1 17 0 0 0 0 $0 Acetal Resins (AR) 17 1 17 0 0 0 0 $0 Hydrogen Fluoride (HF) 17 1 17 0 0 0 0 $0 Control equipment inspections Polycarbonates (PC) 1 2 2 3 6 0.3 0.6 $389.83 Acrylic and Modacrylic Fibers (AMF) 1 2 2 1 2 0.1 0.2 $129.94 Acetal Resins (AR) 1 2 2 2 4 0.2 0.4 $259.89 Hydrogen Fluoride (HF) 1 2 2 1 2 0.1 0.2 $129.94 Control equipment monitoring k Polycarbonates (PC) 1 52 52 3 156 7.8 15.6 $10,135.63 Acrylic and Modacrylic Fibers (AMF) 1 52 52 1 52 2.6 5.2 $3,378.54 Acetal Resins (AR) 1 52 52 2 104 5.2 10.4 $6,757.09 Hydrogen Fluoride (HF) 1 52 52 1 52 2.6 5.2 $3,378.54 Control device CMS Polycarbonates (PC) 1 12 12 3 36 1.8 3.6 $2,338.99 Acrylic and Modacrylic Fibers (AMF) 1 12 12 1 12 0.6 1.2 $779.66 Acetal Resins (AR) 1 12 12 2 24 1.2 2.4 $1,559.33 Hydrogen Fluoride (HF) 1 12 12 1 12 0.6 1.2 $779.66 Pressure relief devices Polycarbonates (PC) 2 1 2 3 6 0.3 0.6 $389.83 Acrylic and Modacrylic Fibers (AMF) 2 1 2 1 2 0.1 0.2 $129.94 L eak detection and repair program

### 24

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

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

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

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

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

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

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

**Total Cost Per year**  **d**

Polycarbonates (PC) 20 1 20 3 60 3 6 $3,898.32 Acrylic and Modacrylic Fibers (AMF) 20 1 20 1 20 1 2 $1,299.44 Acetal Resins (AR) 16 1 16 2 32 1.6 3.2 $2,079.10 Hydrogen Fluoride (HF) 16 1 16 1 16 0.8 1.6 $1,039.55 F. Time to Train Personnel Material determination methods N/A Control equipment inspection and
mo nitoring l Polycarbonates (PC) 8 1 8 3 24 1.2 2.4 $1,559.33 Acrylic and Modacrylic Fibers (AMF) 8 1 8 1 8 0.4 0.8 $519.78 Acetal Resins (AR) 8 1 8 2 16 0.8 1.6 $1,039.55 Hydrogen Fluoride (HF) 8 1 8 1 8 0.4 0.8 $519.78 Leak detection and repair program

h,l Polycarbonates (PC) 10 1 10 3 30 1.5 3 $1,949.16 Acrylic and Modacrylic Fibers (AMF) 10 1 10 1 10 0.5 1 $649.72 Acetal Resins (AR) 2 1 2 2 4 0.2 0.4 $259.89 Hydrogen Fluoride (HF) 2 1 2 1 2 0.1 0.2 $129.94 Container leak tight method N/A **Subtotal for Recordkeeping Requirements 2,**  **833 $** **167,564 TOTAL**  **ANNUAL BURDEN AND COST (r**  **ounded) :**  **3,2 40**  **$1 90,000**  **Capital and O&M Cost (see Section 6(b)(iii)): $** **12 7,000**  **GRAND TOTAL (Labor Cost +**  **Capital /O&M)**  **$ 317**  **, 000**  Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. **Assu mptions:** 

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

### 25

b Estimate based on average facilities.

c We have assumed that there are 7 existing sources (3 PC, 1 AMF, 2 AR, and 1 HF) and that no additional new sources will become subject to the rule over the next three years.
d Costs are rounded and based on the following hourly rates: Technical at $55.25, Management at $117.20, and Clerical at $38.62. These labor rates are based on the May 2013 National Occupational Employment and Wage Estimates for the United States, occupational codes 51

- 8091 for chemical plant and system operators (technical), 11

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

- 6010 for secretaries and administrative assistants (clerical).

e We have assumed that affected facility owners and operators have already complied with this one

- time activity.
f Initial notification requirements include: initial notifications, initial compliance determination, and initial performance tests.

g All major sources except for those in the PC and AMF subcategories must submit startup, shutdown, malfunction reports semiannually when actions are taken in the event of a startup, shutdown, or malfunction that are consistent with the source’s SSM plans. Sources can submit this in formation with the periodic reports.
h The rules requires that all sources submit periodic reports (semiannually or according to the schedule for Title V).

i The standards for equipment leak requires the submittal of an initial report and semiannual reports of leak detection and rep air (LDAR) and any changes to the processes, monitoring frequency and initiation of a quality improvement program. We have assumed that sources are submitting the required periodic LDAR information with the semiannual reports and that affected facility owners and o perators have already complied with the one

- time initial report.
j Visual inspections are required once per shift with a total of three shifts per day, at seven days per week, for 52 weeks per year. (3x7x52) for a total of 1,092 inspections per year.
k We have assumed that control equipment monitoring should be done on a weekly basis.

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

### 26

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

**– NESHAP**  **for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40**  **CFR Part 63, Subpart YY) (Renewal)**

**Activity (A)**  **EPA person**  **** **hours per occurr**  **ence (B)** 

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

**EPA person**

  ** hours per** **plant per year (C=AxB)**  **(D)**

**Plants per**  **year a**  **(E)**

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

**Managem e**  **nt person**
  ** hours per** **year (Ex0.05)**  **(G)**

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

**Cost, $ b** 

Report Review Initial Requirements a. Initial notification c 2 1 2 0 0 0 0 $0 b. Performance test c, d 2 1 2 0 0 0 0 $0 c. Compliance status e 4 1 4 4 16 0.8 1.6 $837.44 d. Performance test reports c, d 4 1 4 0 0 0 0 $0 Periodic Requirements a. Periodic reports 3 2 6 7 42 2.1 4.2 $2,198.28 b. Leak detection and repair reports c, f 3 2 6 7 42 2.1 4.2 $2,198.28 c. Startup, shutdown, malfunction reports c, g 2 1 2 0 0 0 0 $0 **TOTAL ANNUAL EPA BURDEN AND COST (Rounded) 115**  **$5, 230**  Note: Totals have been rounded to 3 significant digits. Figures may not add exactly due to rounding. **Assu mptions**  (a) We have assumed that there are 7 existing sources (3 PC, 1 AMF, 2 AR, and 1 HF) and that no additional new sources will b ecome subject to the rule over the next three years. (b) These rates are from the Office of Personnel Management (OPM), 2014 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. (c) We have assumed there will be no new sources over the next three years of this ICR. We have also assumed that existing sources have already complied with this activity. (d) We have assumed that the Agency will not have additional burden from sources conducting performance tests due to a proces s change that may or may not result in the source meeting additional requirements. (e) We have assumed that existing sources have already complied with this activity, except for facilities in the AMF and PC s ource categories subject to new requirements.

### 27

(f) The equipment leak standards require the submittal of an initial report and semiannual report of leak detection and repair (LDAR) program experiencing any changes to the processes, monitoring frequency and initiation of a quality improvement program. We have assumed that sources are submitting the required LDAR information with the periodic reports. (g) All major sources except for those in the PC and AMF subcategories must submit startup, shutdown, malfunction reports semiannually when actions are taken in the event of a startup, shutdown, or malfunction that are consistent with the source’s SSM plans. We have assumed that all sources have already develop ed a startup, shutdown and malfunction (SSM) plan. We have further assumed that sources are submitting their information on SSM with the periodic report w hich is submitted on a semiannual basis.