J"- , 

OAR Box 1384 

Prepped by Charmelle Mathews 

Document Number: 

JM^SSJ ll-F-4 

Docket Number: 

A-94-52 

Printed 7/2/2008 8:42:12 AM Sheet 255 of 264 
P.2 

PAPERWORK REDUCTION ACT SUBMISSION 

Please read the instructions before completing this form. For additional forms or assist! .. (~\\J /~r\ 

Clearance Officer. Send two copies of this form, the collection instrument to be review / A -' j ] ~" j CN. 

Office of Information and Regulatory Affairs, Office of Management and Budget, Dock 

20503. '^^^^^^^^ M 

JT-F- H 

1. Agency/Subagency originating request 

EPA/Office of Air Quality Planning and Standards 

2. OMB control number 

b. B None 

2060 

3. Type of information collection (check one) 

a. B New collection 

b. • Revision of a currently approved collection 

c. • Extension of a currently approved collection 

d. D Reinstatement, without change, of a previously approved 

collection for which approval has expired 

e. • Reinstatement, with change, of a previously approved 

collection for which approval has expired 

f. D Existing collection in use without an OMB control number 

For b-f note item A2 of Supporting Statement Instructions 

4. Type of review requested (check one) 

a. B Regular 

b. • Emergency - Approval requested by: 

c. D Delegated 

/ / 

5. Small entities 

Will this information collection have a significant economic 

impact on a substantial number of small entities? 

B Yes • No 

6. Requested expiration date 

a. E3 Three years from approval date b. • Other Specify: / / 

7. Title 

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Reinforced Plastic Composites Production 

8. Agency form number(s) 1976.01 

9. Keywords 

Administrative Practice and Procedure, Air Pollution Control,Reinforced Plastic Composites, Composites Fabrication, Clean Air Act, Environmental 

Protection, Hazardous Substances, Intergovernmental Relations, Reporting and Recordkeeping Requirements 

10. Abstract 

Respondents are owners and operators of reinforced plastic composites production operations. Respondents must submit notifications and 

reports and maintain records required by the General Provisions (40 CFR part 63, subpart A). Recordkeeping of parameters related to air pollution 

control technologies is required. The reports and records will be used to demonstrate compliance with the emission limitations and work practice 

standards. 

11. Affected public (Mark primary with "P " and all others that apply 

with "X") 

a. _ Individuals or households d. Farms 

b. _P Business or other for-profit e. X_ Federal Government 

c. _ Not-for-profit institutions f. X_ State, Local or Tribal 

Government 

12. Obligation to respond (Mark primary with "P" and all others that apply 

with "X") 

a. _ Voluntary 

b. _ Required to obtain or retain benefits 

c. P_ Mandatory 

13. Annual reporting and recordkeeping hour burden 

a. Number of respondents 

b. Total annual responses 

1. Percentage of these responses 

collected electronically 

c. Total hours requested 

d. Current OMB inventory 

e. Difference 

f. Explanation of difference 

1. Program Change 

2. Adjustment 

467 

540 

0% 

15,122 

0 

15,122 

15,122 

14. Annual reporting and recordkeeping cost burden (in thousands of 

dollars) 

a. Total annualized capital/startup costs $ 0 

b. Total annual costs (O&M) 

c. Total annualized cost requested 

d. Current OMB inventory 

e. Difference 

f. Explanation of difference 

1. Program change 

2. Adjustment 

$ 17 

$ 17 

$0 

$ 17 

$ 17 

15. Purpose of information collection (Markprimary With "P" and all 

others that apply with "X") 

a. Application for benefits e. Program planning or management 

b. Program evaluation f. Research 

c. General purpose statistics g. P Regulatory or compliance 

d. _Audit 

16. Frequency of recordkeeping or reporting (check all that apply) 

a. B Recordkeeping b. D Third party disclosure 

c. H Reporting 

1. D On occasion 

4. • Quarterly 

7. • Biannually 

2. • Weekly 3. a Monthly 

5. H Semi-annually 6. • Annually 

8. B Other (describe) Initial 

17. Statistical methods 

Does this information collection employ statistical methods? 

• Yes B No 

18. Agency contact (person who can best answer questions regarding the 

content of this submission) 

Name: Keith Barnett 

Phone: (919)541-5605 

OMB 83-1 10/95 
P.3 

.19: ^Certification for Paperwork Reduction Act Submissions 

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 

5 CFR 1320.9. 

NOTE: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3), appear at the end of the instructions. The 

certification is to be made with reference to those regulatory provisions as set forth in the instructions. 

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers: 

(a) It is necessary for the proper performance of agency functions; 

(b) It avoids unnecessary duplication; 

(c) It reduces burden on small entities; 

(d) It uses plain, coherent, and unambiguous terminology that is understandable to respondents; 

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices; 

(f) It indicates the retention periods for recordkeeping requirements; 

(g) It informs respondents of the information called for under 5 CFR 1320.8(b)(3): 

(i) Why the information is being collected; 

(ii) Use of information; 

(iii) Burden estimate; 

(iv) Nature of response (voluntary, required for a benefit, or mandatory); 

(v) Nature and extent of confidentiality; and 

(vi) Need to display currently valid OMB control number; 

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the 

information to be collected (see note in Item 19 of the instructions); 

(i) It uses effective and efficient statistical survey methodology; and 

(j) It makes appropriate use of information technology. 

If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in Item 18 of the 

Supporting Statement. 

Signature of Program Office Official Date 

Signature of Senior Official or Designee 

OMB 83-1 

Date 

Oscar Morales, Director 

Collection Strategies Division 

Office of Environmental Information 

10/95 
P.4 

Certification Requirement for Paperwork Reduction Act Submissions 

5 CFR 1320.9 reads "As part of the agency submission to OMB of a proposed collection of information, the agency (through the head of 

the agency, the Senior Official or their designee) shall certify (and provide a record supporting such certification) that the proposed 

collection of information -

"(a) is necessary for the proper performance of the functions of the agency, including that the information to be collected will have 

practical utility; 

"(b) is not unnecessarily duplicative of information otherwise reasonably accessible to the agency; 

"(c) reduces to the extent practicable and appropriate the burden on persons who shall provide information to or for the agency, 

including with respect to small entities, as defined in the Regulatory Flexibility Act 5 U.S.C § 601(6)), the use of such techniques as: 

"(1) establishing differing compliance or reporting requirements or timetables that take into account the resources available to 

those who are to respond; 

"(2) the clarification, consolidation, or simplification of compliance and reporting requirements; or collection of information , 

or any part thereof; 

"(3) an exemption from coverage of the collection of information, or any part thereof; 

"(d) is written using plain, coherent, and unambiguous terminology and is understandable to those who are to respond; 

"(e) is to be implemented in ways consistent and compatible, to the maximum extent practicable, with the existing reporting and 

recordkeeping practices of those who are to respond; 

"(f) indicates for each recordkeeping requirement the length of time persons are required to maintain the records specified; 

"(g) informs potential respondents of the information called for under § 1320.8(b)(3); [see below] 

"(h) has been developed by an office that has planned and allocated resources for the efficient and effective management and use of the 

information to be collected, including the processing of the information in a manner which shall enhance, where appropriate, the utility of 

the information to agencies and the public; 

"(i) uses effective and efficient statistical survey methodology appropriate to the purpose for which the information is to be collected; 

and 

"(j) to the maximum extent practicable, uses appropriate information technology to reduce burden and improve data quality, agency 

efficiency and responsiveness to the public." 

NOTE: 5 CFR 1320.8(b)(3) requires that each collection of information: 

"(3) informs and provides reasonable notice to the potential persons to whom the collection of information is addressed of: 

"(i) the reasons the information is planned to be and/or has been used to further the proper performance of the functions of 

the agency; 

"(ii) the way such information is planned to be and/or has been used to further the proper performance of the functions of the 

agency; 

"(iii) an estimate, to the extent practicable, of the average burden of the collection (together with a request that the public 

direct to the agency any comments concerning the accuracy of this burden estimate and any suggestions for reducing this 

burden); 

"(iv) whether responses to the collection of information are voluntary, required to obtain or retain a benefit (citing authority), 

or mandatory (citing authority); 

"(v) the nature and extent of confidentiality to be provided, if any (citing authority); and 

"(vi) the fact that any 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." 

OMB 83-1 (Instructions) 10/95 
P.5 

STANDARD FORM 83 SUPPORTING STATEMENT 

ICR N0.1976-- NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR 

POLLUTANTS FOR REINFORCED PLASTIC COMPOSITES PRODUCTION 

(40 CFR PART 63, SUBPART WWWW) 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

August 2000 
P.6 

PART A OF THE SUPPORTING STATEMENT: 

JUSTIFICATIONS 

1. Identification of the Information Collection 

(a) Title and Number of the Information Collected 

The title of this information collection request (ICR) is 

"Recordkeeping and Reporting Requirements for the National 

Emission Standards for Hazardous Air Pollutants (NESHAP) for 

Reinforced Plastic Composites Production." This is a new ICR 

that has been assigned Environmental Protection Agency (EPA) ICR 

number 1976.01. 

(b) Short characterization/abstract 

The proposed standards regulate reinforced plastic 

composites (RPC) production operations and processes. The 

emissions from these operations and processes are fugitive 

emissions. Fugitive emissions are the result of hazardous air 

pollutants (HAP) evaporating from the resins, gel coats, and 

cleaning solvents used in the reinforced plastic composite 

production operations and processes. 

Each owner or operator of a source affected by the proposed 

standards would be required to submit an initial notification 

that the source is subject to the standard. Each respondent 

would submit semiannual compliance reports. Additional records 

and reports would depend on how the owner or operator must comply 

with the standards. The owner or operator of a RPC manufacturing 

facility that is subject to these proposed standards must control 

HAP by either limiting the HAP content of materials used and 

using non-atomized spray application in the manufacturing 

processes or by using an enclosure and add-on control device. 

Respondents that can comply by limiting the HAP content of 

their raw materials would monitor and record (in a spreadsheet) 
P.7 

the monthly consumption of material and show the weighted-average 

HAP content over the past 12 months. However, if all the 

materials in an operation meet the HAP content limit, then each 

respondent would need only to record HAP content and would not 

need to track monthly consumption or record the computations. 

For open molding and centrifugal casting operations at RPC 

production facilities, respondents would also have the option of 

averaging among thirteen different processes (open molding) and 

two different processes (centrifugal casting). Respondents would 

use options in the regulation to calculate actual and allowable 

emissions for the combined open molding and centrifugal casting 

operations. Compliance would be based on a 12-month rolling 

average. 

Respondents who must use an enclosure and an add-on control 

device would submit a control device performance test report, 

including operating ranges for monitored parameters; and annual 

start-up, shutdown, and malfunction reports. Respondents would 

be required to monitor and keep records of specific operating 

parameters for each control device. 

2. Need for and Use of the Collection 

(a) Need/Authority for the Collection 

The EPA needs this information to ensure that HAP emissions 

are reduced in the processes and operations that constitute 

Reinforced Plastic Composites Manufacturing. 

The EPA is required under section 112(d) of the Clean Air 

Act (CAA) to regulate emissions of the HAP listed in 

section 112(b) of the CAA. The major HAP identified by EPA as 

being emitted from the Reinforced Plastic Composites 

Manufacturing Source Category include styrene, methyl 

methacrylate (MMA), and methylene chloride (dichloromethane). 
P.8 

In the Administrator's judgment, HAP emissions from RPC 

manufacturing processes and operations cause or contribute 

significantly to air pollution that may reasonably be anticipated 

to endanger public health. Consequently, NESHAP for this source 

category has been developed and are being proposed. 

Section 114 of the CAA allows the Administrator to require 

inspections, monitoring, and entry into facilities to ensure 

compliance with a section 112 emission standard. 

Section 114(a)(1) specifically states: 

"The Administrator may require any person who owns or 

operates any emission source...who is subject to the 

provisions of the CAA on a one-time, periodic, or 

continuous basis 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; 

(E) keep records on control equipment parameters, 

production variables or other indirect data when direct 

monitoring of emissions is impractical; 

(F) submit compliance certifications in accordance with 

section 114(a)(3); and 

(G) provide such other information as the Administrator may 

reasonably require." 

Certain records and reports are necessary to enable the 

Administrator to identify sources subject to the standard and to 

ensure that the standard, which is based on a maximum achievable 

control technology (MACT), is being achieved. 

(b) Practical Utility/Users of Collected Information 
P.9 

The information will be used by EPA to: (1) identify new, 

modified, reconstructed, and existing sources subject to the 

standards; (2) identify the control methodologies being applied; 

and (3) ensure that emission control devices are being properly 

operated and maintained. 

In addition, records and reports are necessary to enable EPA 

to identify facilities that may not be in compliance with the 

standards. Based on reported information, EPA can decide which 

facilities should be inspected and what records or specific 

emission sources should be inspected at each facility. Also, the 

records that facilities maintain provide an indication to EPA 

whether facility personnel are calculating emissions properly. 

To minimize burdens, much of the information EPA would need 

to determine compliance would be recorded and retained on-site at 

the facility. Such information would be reviewed by enforcement 

personnel during an inspection and would not need to be routinely 

reported to EPA. In addition, in many cases EPA has selected 

parameters for monitoring that are readily available or are 

already monitored by the industry for other purposes. 

3. Nonduplication, Consultations, and Other Collection Criteria 

(a) Nonduplication 

Some facilities subject to this NESHAP will also be subject 

to requirements under the Plastic Parts and Products NESHAP 

currently under development. The burden requested for this 

NESHAP does not duplicate any of the burden accounted for under 

subpart II. None of the information requested in this ICR is 

available from other resources, such as the Toxic Release 

Inventory. 

Certain reports required by State or local agencies may 

duplicate information required by the standards. In such cases, 
P.10 

a copy of the report submitted to the State or local agency may 

be sent to the Administrator in lieu of the report required by 

the standards. 

(b) Public Notice Required Prior to ICR Submission to the Office 

of Management and Budget 

The EPA solicited public comments on the need for this 

information, the accuracy of the burden estimates, and any 

suggested methods for minimizing respondent burden in the 

proposed rule announced in the Federal Register. The final rule 

will respond to any comments from the public on these information 

collection requirements. 

(c) Consultations 

The EPA involved RPC manufacturers, including 17 small 

firms, and their trade association in the development of this 

NESHAP and the associated recordkeeping and reporting 

requirements. These groups have been fully involved in this 

rulemaking effort. The EPA has considered their comments and 

concerns in developing the proposed regulation. 

(d) Effects of Less Frequent Collection 

Failure to require periodic reporting of HAP emissions would 

result in the inability of the Administrator to determine if a 

source is in compliance with the NESHAP. If the reports and data 

parameters were collected less frequently, EPA would not be able 

to identify potential compliance problems in a timely fashion. 

A typical NESHAP requires quarterly reporting; however, because 

this NESHAP is based on pollution prevention, semiannual reports 

are required. Semiannual reports are required so that EPA can 

ensure that timely corrective action is being taken. 
P.11 

Respondents who must use an enclosure and an add-on control 

device would submit a control device performance test report, 

including operating ranges for monitored parameters; and annual 

start-up, shutdown, and malfunction reports. Respondents would 

be required to monitor and keep records of specific operating 

parameters for each control device. A quarterly report is 

required if a facility using an add-on control device exceeds the 

emission limits. If this information were collected less 

frequently, the main consequence could be decreased performance 

of emission control measures due to lack of regular inspection, 

which could result in increased HAP emissions. 

(e) General Guidelines 

This information collection meets the Office of Management 

and Budget's (OMB) general guidelines for information collections 

and therefore does not require justification for any deviation 

from OMB's general guidelines. 

(f) Confidentiality 

All information submitted to EPA for which a claim of 

confidentiality is made will be safeguarded according to EPA 

policies in 40 CFR part 2, subpart B, Confidentiality of Business 

Information. 

(g) Sensitive questions 

This information collection does not request any information 

concerning sexual behavior or attitudes, religious beliefs, or 

other matters usually considered private. 

4. The Respondents and the Information Requested 
P.12 

(a) Respondents/North American Industrial Classification System 

and Standard Industrial Classification Codes 

Respondents are owners or operators of RPC manufacturing 

facilities. The following processes and operations constitute 

RPC manufacturing: closed mold and open mold fiberglass 

manufacturing; resin and gel coat mixing; resin and gel coat 

application equipment cleaning; and resin and gel coat storage. 

Entities potentially regulated by this action are those major 

sources of HAP that manufacture reinforced plastic composites. 

The promulgation of this NESHAP would affect the North American 

Industrial Classification System (NAICS) and Standard Industrial 

Classification (SIC) codes listed in the following table. 

POTENTIALLY REGULATED ENTITIES 

Category 

NAICS 

code 

SIC 

code Examples of regulated entities 

Industry 325991 

326122 

326191 

326199 

327991 

336211 

336213 

336214 

3087 

3084 

3089 

3088 

3089 

3999 

3281 

3713 

3716 

3792 

Reinforced plastic composites 

production facilities that 

manufacture and/or repair 

intermediate and/or final 

products using HAP containing 

thermoset resins and gel 

coats. 

Federal 

Government 

Federally owned facilities 

that manufacture and/or repair 

intermediate and/or final 

products using HAP containing 

thermoset resins and gel 

coats. 

This table is not intended to be exhaustive, but rather 

provides a guide for readers regarding entities likely to be 

regulated by this action. To determine whether your facility is 

regulated by this action, you should examine the applicability 
P.13 

criteria in section II.A of the preamble of the proposed rule 

published in the FEDERAL REGISTER. 

(b) Information Requested 

Attachment 1 presents the list of the source data and information 

requirements. Tables 1 through 4 of attachment 2 present a 

listing of information and recordkeeping activities. 

(i) Data items, including recordkeeping requirements: 

Test report. Facilities required to use an add-on control 

device will be required to install a continuous parameter 

monitoring system; establish operating parameters; prepare a 

start-up, shutdown, and malfunction plan; and submit a 

notification of performance tests and an initial add-on control 

device performance test report. 

Initial report. The owner or operator of each facility 

would be required to submit an initial notification report that 

the source is subject to the standard. 

Notification reports. The owner or operator of each new 

facility would be required to submit notifications of intent to 

construct, construction start date, anticipated start-up date, 

and actual start-up date. Facilities also would be required to 

submit a notification of compliance status. 

Compliance reports. The owner or operator of each facility 

would be required to submit semiannual compliance reports. 

Sources using an add-on control device with exceedances would 

need to submit quarterly compliance reports and a request to 

return to semiannual compliance reporting. 

Test reports. The owner or operator of each facility using 

add-on control devices must submit a control device performance 

test report, operating range for monitored parameters report, and 

start-up, shutdown, and malfunction reports. 

(ii) Respondent activities: 

8 
P.14 

Spreadsheet. Facilities complying with point value limits 

on a weighted average basis will develop a recordkeeping system 

and enter information into the system for regulated operations. 

If all facilities in an operation continuously meet an applicable 

point value limit based on the raw material HAP content, 

facilities will only need to keep copies of the HAP content 

certifications. 

5. The Information Collected-Agency Activities, Collection 

Methodology, and Information Management 

(a) Agency Activities 

A list of Agency activities is provided in Tables 5 

through 7 of attachment 3. 

(b) Collection Methodology and Management 

This collection of information does not require the use of 

automated collection techniques because of the relatively small 

number of respondents affected. 

(c) Small Entity Flexibility 

The EPA has determined that 278 of the 356 companies owning 

reinforced plastics facilities potentially affected by this rule 

are small businesses. As required by section 609(b) of the 

Regulatory Flexibility Act (RFA), as amended by the Small 

Business Regulatory Enforcement Fairness Act (SBREFA), EPA 

conducted outreach to small entities and convened a Small 

Business Advocacy Review (SBAR) Panel to obtain advice and 

recommendations of representatives of the small entities that 

potentially would be subject to the rule's requirements. This 

Panel convened on April 6, 2000. The Panel consisted of 

representatives from the Office of Management and Budget, the 
P.15 

Small Business Administration Office of Advocacy, the EPA Small 

Business Advocacy Chair, and the Emissions Standards Division of 

the Office of Air Quality Planning and Standards of EPA. The 

Panel was advised by seventeen small entity representatives 

(SERs) from a cross section of the different industry sectors 

potentially affected by this rulemaking. All panel 

recommendations concerning minimizing the reporting and 

recordkeeping burden on small businesses have been incorporated 

into the proposed rule. 

In developing these proposed standards, EPA has provided the 

maximum degree of flexibility to minimize impacts on small 

businesses by providing several different compliance options, 

several of which require a minimum amount of recordkeeping and 

reporting requirements. Small entities that would be subject to 

the regulation would not be systematically impacted more than 

larger entities. 

Although the recordkeeping requirements are the same for 

small and large businesses, EPA considers these requirements the 

minimum needed to ensure compliance and, therefore, cannot reduce 

them further for small businesses. 

(d) Collection Schedule 

Year 1 includes the one-time activity of reading the 

regulation and submitting notification that the source is subject 

to the standard. 

New major sources would submit the following one-time only 

notifications: intent to construct, start of construction date, 

anticipated start-up date, and actual start-up date. These 

notifications generally would be submitted within 60 days of the 

activity. 

In year 3, existing major sources would begin complying with 

the HAP content requirements, developing spreadsheets, and 

10 
P.16 

entering data as described in section 4(b). Also, existing 

respondents who choose to use add-on control devices would begin 

complying in the year 3. 

The EPA expects 17 new major sources to be constructed for 

each of the first 2 years and 19 in the third year. The EPA 

assumes that because compliance is not required until year 3 for 

existing facilities, existing facilities will wait until year 3 

to begin complying with the HAP content requirements. 

6. Estimating the Burden and Cost of the Collection 

(a) Estimating Respondent Burden 

The EPA expects this regulation to affect 433 existing and 

53 new RPC manufacturing facilities over the next 3 years. The 

average number of respondents over the next three years will be 

467. Tables 1 through 3 in attachment 2 present an itemized 

breakdown of the reporting and recordkeeping requirements for the 

respondents affected by these standards. 

(b) Estimating Respondent Costs 

The information collection activities for sources subject to 

these requirements are presented in Tables 1 through 3 and 

summarized in table 4 of attachment 2. The total cost for each 

respondent activity includes labor costs, capital/start-up costs, 

and operating and maintenance (O&M) costs. 

(i) Estimating Labor Costs. Labor rates, on a per-hour 

basis, are taken from information available from the bureau of 

labor statistics. These are typical industry wage rates and are 

the same as the rates developed in the National Volatile Organic 

Compound Emission Standards for Architectural Coatings 

rulemaking. These rates are shown in the table below. 

11 
P.17 

A 

Labor Class 

Clerical 

Technical 

Management 

B 

Base labor 

rate from 

the bureau 

of labor 

statistics 

(BLS) 

$11.95/hr 

$18.86/hr 

$28.54/hr 

C 

Fringe 

benefit 

loading 

rate from 

BLS 

1.41 

1.43 

1.40 

D 

Overhead 

and profit 

rate from 

MWC ICR 

1.67 

1.67 

1.67 

E 

"Loaded" 

wage rate 

(B x C x D) 

$28.14/hr 

$45.04/hr 

$66.73/hr 

(ii) Estimating Capital/Start-up Costs. The EPA does not 

expect capital and start-up costs specifically for reporting and 

recordkeeping. Facilities that have control devices will have to 

have certain parameter monitoring of those devices. However, we 

are assuming these monitoring devices are integral parts of the 

control device. The available cost data did not allow us to 

specifically break out capital costs attributable only to 

reporting and recordkeeping requirements. Other initial costs, 

such as reading the rule and one time training costs, were not 

treated as a capital cost and amortized. These costs are 

expensed in the year they occur. For the purpose of this 

subpart, EPA assumes that each owner or operator owns a computer 

with spreadsheet software. 

(iii) Total O&M and Purchase of Service Costs. 

Operating and maintenance costs include those costs 

associated with the general upkeep of startup capital equipment, 

as well as those costs associated with a paperwork requirement 

incurred continuously over the life of the ICR. For example, the 

O&M costs for rules that require respondents to submit reports to 

the Agency and maintain records should be estimated as costs for 

file storage, photocopying, and postage. File storage and 

12 
P.18 

photocopying costs per response are estimated as $12.50 per hour 

of clerical labor. First class postage is estimated at $7.63 per 

response for mailing to regulatory agencies. The estimated 

operation, maintenance, and purchase of services costs averaged 

over the first 3 years are expected to be $17,265. 

(c) Estimating Agency Burden and Cost. 

Because the ICRs were developed as an incidental part of 

standards development, no costs can be attributed to the 

development of ICRs. Because reporting and recordkeeping 

requirements on the part of the respondents are required under 

section 112 of the CAA, no additional operational costs would be 

incurred by the Federal Government. Examination of records to be 

maintained by the respondents would occur incidentally as part of 

the periodic inspection of sources that is part of EPA's overall 

compliance and enforcement program and, therefore, could not be 

attributable to the ICR. 

A list of Agency activities is provided in tables 5 

through 7 in attachment 3. 

Labor rates for the Federal employees are based on the 

estimated hourly rates of $40.32 for technical personnel (GS-12, 

Step 5); $66.56 for management personnel (GS-15, Step 5); and 

$22.74 for clerical personnel (GS-7, Step 5). These values 

include a 1.6 multiplier to account for overhead and fringe 

benefit costs. 

(d) Estimating the Respondent Universe and Total Burden 

Costs. 

The total number of respondents also is referred to as the 

respondent universe. The respondent universe for this ICR is 

based on EPA's RPC manufacturing data base. Industry burden is 

13 
P.19 

calculated based on the assumption that 17 new RPC manufacturing 

facilities will be constructed years 1 and 2 and 19 in year 3. 

Additional estimates regarding the respondent universe are 

included in the industry burden determination. In year 1, new 

RPC manufacturing facilities will read the rule, develop the 

recordkeeping system (spreadsheet), and enter the information. 

For each year, 17 new facilities (19 in year 3) will submit 

initial notifications for new facilities, compliance status, and 

semiannual compliance status reports. In year 2, 34 new RPC 

manufacturing facilities will develop the recordkeeping system, 

enter the information, and submit semiannual compliance status 

reports. In year 3, the 433 existing manufacturing facilities 

will submit an initial notification that the existing source is 

subject to the standard, develop and enter information into the 

recordkeeping system, and submit notification of compliance 

status. 

(e) Bottom Line Burden Hours and Cost Tables. 

(i) The Respondent Tally. A breakdown for each of the 

collection, reporting, and recordkeeping activities required by 

the regulation is presented in tables 1 through 3 of attachment 

2. The estimate of total annual hours requested from the 

respondents is based on the assumptions outlined in section 6(d) 

of this supporting statement. The EPA estimated the respondent 

burden by totaling the hours for the first 3 years after the 

implementation of the regulation for technical, managerial, and 

clerical staff at the facility. This total was then divided by 3 

to arrive at the average annualized burden in the first 3 years 

following promulgation (see table 4). A similar approach was 

taken for estimating average annual labor and non-labor costs. 

For the first 3 years after the implementation of the regulation, 

EPA estimates that industry would expend 15,122 hours annually at 

14 
P.20 

a cost of $690,385 per year to meet the monitoring, 

recordkeeping, and reporting requirements. The average annual 

operation and maintenance cost is expected to be $17,265 (see 

table 4). 

(ii) The Agency Tally. The bottom line agency burden hours 

and costs, presented in tables 5 through 7, are calculated by 

totaling the hours per year for technical, managerial, and 

clerical staff, and by totaling the cost column. Table 8 

(attachment 3) summarizes the agency burden for each of the first 

3 years and calculates the average annual burden by dividing the 

3 year total by 3. The estimated average annual burden, over the 

first 3 years, for the Agency would be 11,293 hours at a cost of 

$450,972 per year. 

(iii) Variations in the Annual Bottom Line. 

Calculating the average annual costs underestimates costs in 

a typical year for a NESHAP. In years 1 and 2, 433 sources are 

not included. Calculating each year individually provides a more 

accurate account of how facilities will be affected in the first 

3 years following promulgation. 

During years 1 and 2, there is little burden for existing 

facilities because existing facilities are not required to begin 

compliance until year 3. Therefore, the year 3 burden for 

industry and the government is much higher than years 1 and 2. 

(f) Reasons for Change in Burden 

This is a new collection and there is no change in burden. 

(g) Burden Statement 

Burden means the total time, effort, or financial resources 

expended by persons to generate, maintain, retain, or disclose or 

provide information to or for a Federal agency. This includes 

15 
P.21 

the time needed to review instructions; develop, acquire, 

install, and utilize technology and systems for the purposes of 

collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any 

previously applicable instructions and requirements; train 

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

search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information. 

An Agency may not conduct or sponsor, and a person is not 

required to respond to a collection of information unless it 

displays a currently valid OMB control number. The OMB control 

numbers for EPA's regulations are listed in 40 CFR part 9 and 

48 CFR chapter 15. 

Comments are requested on the Agency's need for this 

information, the accuracy of the provided burden estimates, and 

any suggested methods for minimizing respondent burden, including 

through the use of automated collection techniques. Send 

comments on the ICR to the Director, Office of Environmental 

Information, Collection Strategies Division (2822), U.S. EPA, 

1200 Pennsylvania Avenue NW, Washington, DC 20460; and to the 

Office of Information and Regulatory Affairs, OMB, 725 17th 

Street, NW, Washington, DC 20503, marked "Attention: Desk Officer 

for EPA." Include the ICR number in any correspondence. 

16 
P.22 

Attachment 1 

Source Data and Information Requirements 

Requirement 40 CFR part 63 

RECORDKEEPING 

5-year retention of records 63.5764(b) 

Recordkeeping requirements for 63.10(b)(3) 

applicability determinations 

Copy of each notification and 63.5764(a) and (b) 

report as submitted and 

associated documentation 

Recordkeeping relevant to 63.10(b)(2)(i)through (xi) 

start-up, shutdown, and 

malfunction periods and 

continuous monitoring system 

General recordkeeping 63.10(b)(2) 

REPORTING 

Initial notification for 63.5755(a) 

existing sources 

Notification of intent to 63.5755(a) 

construct 

Notification of start 63.5 

construction 

Notification of anticipated 63.5 

start-up date 

Notification of actual start- 63.5 

up date 

Notification of compliance 63.5755(a) 

status 

Notification of performance 63.5755(a) 

test 

Notification of CEMS 63.5755(a) 

performance evaluation 

Semi-annual compliance report 63.5758(b) and (c) 

Start-up, shutdown, and 63.5758(d) 

malfunction plan 
P.23 

Attachment 2 

TABLES 1, 2, 3, and 4 

Table 1: Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements for 

National Emission Standards for Hazardous Air 

Pollutants for RPC Manufacturing--40 CFR Part 

63, Subpart WWWW - Year 1 

Table 2: Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements for 

National Emission Standards for Hazardous Air 

Pollutants for RPC Manufacturing--40 CFR Part 

63, Subpart WWWW - Year 2 

Table 3: Annual Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements for 

National Emission Standards for Hazardous Air 

Pollutants for RPC Manufacturing--40 CFR Part 

63, Subpart WWWW - Year 3 

Table 4: Summary of Respondent Burden and Cost of 

Recordkeeping and Reporting Requirements for 

National Emission Standards for Hazardous Air 

Pollutants for RPC Manufacturing--40 CFR Part 

63, Subpart WWWW - Years 1 through 3 and 

Average 
TABLE 1. RESPONDENT COSTS FOR YEAR 1. 

Burden Item 

Plant Hours 

per 

Occurrence 

(A) 

Number of Plant 

Occurrences Hours 

per Plant 

(B) (C = AXB) 

Number of 

Plants 

a 

(D)a 

Technical 

Personnel 

Hours 

(E=CxD) 

Management 

Personnel 

Hours 

(F=Ex0.05) 

Clerical 

Personnel 

Hours 

(G=Ex0.1) 

Total Labor 

Costs 

b 

(H) 

O&M 

Costs 

(l) 

Total 

Costs 

(J=H+I) 

Footnotes 

1. Applications 

2. Survey and Studies 

3. Acquire and install recordkeeping technology and systems 

4. Read and understand rule requirements 

A. Facilities with 2 groups of operations 

B. Facilities with 3 groups of operations 

C. Facilities with 4 groups of operations 

D. Facilities with 5 groups of operations 

E. Facilities with 6 groups of operations 

F. Facilities with 7 groups of operations 

5. Required activities for sources with add-on control devices 

A. Initial add-on control device performance test and repor 

B. Establish operating parameters 

C. Prepare startup, shutdown, and malfunction plan 

D. Prepare operation and maintenance plan 

E. Continuous parameter monitoring 

1) Initial costs 

2) Annual costs 

6. Employee Training Requirements 

A. Development of operator training course 

B. Time to train personnel 

1) Small facilities (100 or fewer employees) 

2) Medium facilities (more than 100 to 250 employees) 

3) Large facilities (more than 250 employees) 

C. Records of operator completing training course 

7. Required activities for recordkeeping systems 

A. Develop recordkeeping system (spreadsheets) 

1) Develop system for low HAP resins 

2) Develop system for work practices 

3) Develop system for add-on control devices 

B. Enter information into recordkeeping system 

1) Enter information on low HAP resins 

2) Enter information on work practices 

3) Enter infonnation on add-on control devices 

8. Create Information 

9. Gather information 

n/a 

n/a 

n/a 

10 

11 

12 

13 

14 

15 

320 

Included in 5A 

20 

40 

0 

0 

4 

1 

2 

10 

n/a 

n/a 

Included in 7B 

Included in 7B 

10 

11 

12 

13 

14 

15 

24 

57 

233 

128 

7 

1 

240 

627 

2,796 

1,664 

98 

15 

12.0 

31.4 

139.8 

83.2 

4.9 

0.8 

24.0 

62.7 

279.6 

166.4 

9.8 

1.5 

$12,286 

$32,096 

$143,129 

$85,181 

$5,017 

$768 

$12,286 

$32,096 

$143,129 

$85,181 

$5,017 

$768 

320 

4 

1 

2 

10 

0 

0 

17 

14 

2 

1 

17 

2 

17 

1 

2 

17 

1 

320 

136 

28 

7 

10 

34 

8 

17 

2 

20 

0 

0 

16.0 32.0 $16,381 

6.8 

1.4 

0.4 

0.5 

1.7 

0.4 

0.9 

0.1 

1.0 

0.0 

0.0 

13.6 $6,962 

$400 

$170 

$16,781 

20 

40 

0 

0 

1 

1 

0 

0 

20 

40 

0 

0 

1.0 

2.0 

0.0 

0.0 

2.0 

4.0 

0.0 

0.0 

$1,024 

$2,048 

$0 

$0 

$25 

$50 

$0 

$0 

$1,049 

$2,098 

$0 

$0 

$7,132 

2.8 

0.7 

1.0 

3.4 

0.8 

1.7 

0.2 

2.0 

0.0 

0.0 

$1,431 

$362 

$515 

$1,740 

$410 

$870 

$102 

$1,024 

$0 

$0 

$35 

$9 

$13 

$43 

$10 

$21 

$3 

$25 

$0 

$0 

$1,466 

$371 

$528 

$1,783 

$420 

$891 

$105 

$1,049 

$0 

$0 

2-1 
TABLE 1. RESPONDENT COSTS FOR FIRST YEAR 1 (continued) 

n/a 

2 

2 

2 

n/a 

n/a 

2 

4 

10 Notification requirements 

A. Initial notification that existing sources are subject to the 

Standard 

B. Notifications for new major sources 

1) Notification of start of construction 

2) Notification of anticipated startup date 

3) Notification of actual startup date 

C. Request for compliance extension 

D. Notification of special compliance requirements 

E. Notification of performance tests 

F. Notification of compliance status 

11 Recordkeeping requirements 

A. Read instructions Included in 4 

B. Plan and develop record system Included in 7A. 

C. Record information Included in 7B. 

D. Records for area sources not subject to the standard n/a 

12 Reporting requirements 

A. Semiannual compliance reports for all sources 

1) No exceedances 8 

2) With exceedances 16 

B. Additional reports for sources with add-on control devices 

1) Control device performance test report Included in 5A. 

2) Operating range for monitored parameters Included in 5A. 

3) Startup, shutdown, malfunction reports 2 

8 

16 

17 

17 

17 

1 

17 

13.6 

3.4 

34 

34 

34 

2 

68 

109 

54 

0.0 

0.1 

3.4 

0.0 

5.4 

2.7 

0.1 

$0 $0 $0 

3.4 

3.4 

3.4 

0.2 

6.8 

$1,740 

$1,740 

$1,740 

$102 

$3,481 

$172 

$172 

$172 

$10 

$215 

$1,912 

$1,912 

$1,912 

$112 

$3,696 

10.9 $5,570 $240 $5,810 

5.4 $2,785 $93 $2,878 

f.g 

f, h 

0.2 $102 $10 $112 

TOTAL NUMBER OF PLANTS 

TOTAL BURDEN ANNUAL COSTS 

TOTAL ANNUAL HOURS 

450 

6,419 321 

$328,606 $1,887 $330,493 

642 7,382 

FOOTNOTES 

a Based on 17 new facilities beginning operation in Year 1 and 433 existing facilities. 

b Costs are based on the following hourly rates (the costs are loaded rates): Technical $45.04, Management $66.73, and clerical $28.14. 

c Applies only to new facilities with an add-on control device. 

d Applies to the 17 new facilities beginning operation in Year 1. 

e Applies only to new facilities with open molding and/or centrifugal casting operations. 

f Assumes that one semiannual report will be required in the first year of operation. 

g Assumes 80 percent of the 17 facilities prepare a semiannual compliance report indicating no exceedances. 

h Assumes 20 percent of the 17 facilities prepare a semiannual compliance report indicating an exceedance. 

2-2 
TABLE 2. RESPONDENT COSTS IN YEAR 2. 

Costs for facilities that start up in year 2 

Burden Item 

Plant Hours 

per 

Occurrence 

Number of 

Occurrences 

per Plant 

(B) 

Plant 

Hours 

(C = AXB) 

Number of 

Plants 

a 

(D)a 

Technical 

Personnel 

Hours 

(E=CxD) 

Management 

Personnel 

Hours 

(F=Ex0.05) 

Clerical 

Personnel 

Hours 

(G=Ex0.1) 

Total Labor 

Costs 

b 

(H) 

O&M 

Costs 

(D 

Total 

Costs 

(J=H+I) 

Footnotes 

1. Applications n/a 

2. Survey and Studies n/a 

3. Acquire and install recordkeeping technology and systems n/a 

4. Read and understand rule requirements 

A. Facilities with 2 groups of operations 10 

B. Facilities with 3 groups of operations 11 

C. Facilities with 4 groups of operations 12 

D. Facilities with 5 groups of operations 13 

E. Facilities with 6 groups of operations 14 

F. Facilities with 7 groups of operations 15 

5. Required activities for sources with add-on control devices 

A. Initial add-on control device performance test and report 320 

B. Establish operating parameters Included in 5A 

C. Prepare startup, shutdown, and malfunction plan 20 

0. Prepare operation and maintenance plan 40 

E. Continuous parameter monitoring 

1) Initial costs 0 

2) Annual costs 0 

6. Employee Training Requirements 

A. Development of operator training course 8 

B. Time to train personnel 

1) Small facilities (100 or fewer employees) 2 

2) Medium facilities (more than100 to 250 employees) 4 

3) Large facilities (more than 250 employees) 8 

C. Records of operator completing training course 2 

7. Required activies for recordkeeping systems 

A. Develop recordkeeping system (spreadsheets) 

1) Develop system for low HAP resins 4 

2) Develop system for work practices 1 

3) Develop system for add-on control devices 2 

B. Enter information into recordkeeping system 

1) Enter information on low HAP resins 10 

2) Enter information on work practices n/a 

3) Enter infonnation on add-on control devices n/a 

8. Create Information Included in 7B 

9. Gather information Included in 7B 

10 

11 

12 

13 

14 

15 

0 

0 

8 

8 

0 

1 

0 

0 

96 

104 

0 

15 

0.0 

0.0 

4.8 

5.2 

0.0 

0.8 

0.0 

0.0 

9.6 

10.4 

0.0 

• 1.5 

$0 

$0 

$4,914 

$5,324 

$0 

$768 

320 640 

136 

32.0 $32,762 $800 

6.8 13.6 $6,962 $170 

$0 

$0 

$4,914 

$5,324 

$0 

$768 

$33,562 

20 

40 

0 

0 

2 

2 

0 

O 

40 

80 

0 

0 

2.0 

4.0 

0.0 

0.0 

4.0 

8.0 

0.0 

0.0 

$2,048 

$4,095 

$0 

$0 

$50 

$100 

so 

$0 

$2,098 

$4,195 

$0 

$0 

$7,132 

2 

4 

8 

2 

4 

1 

2 

10 

0 

0 

14 

2 

1 

17 

0 

17 

2 

0 

17 

2 

28 

7 

10 

34 

0 

17 

4 

0 

0 

0 

1.4 

0.4 

0.5 

1.7 

0.0 

0.9 

0.2 

0.0 

0.0 

0.0 

2.8 

0.7 

1.0 

3.4 

0.0 

1.7 

0.4 

0.0 

0.0 

0.0 

$1,431 

$362 

$515 

$1,740 

$0 

$870 

$205 

$0 

$0 

$0 

$35 

$9 

$13 

$43 

$0 

$21 

$5 

$0 

$0 

so 

$1,466 

$371 

$528 

$1,783 

$0 

$891 

$210 

$0 

$0 

so 

d 

c 

d 

c 

2-3 
TABLE 2. RESPONDENT COSTS IN YEAR 2. (Continued) 

10 Notification requirements 

A. Initial notification that existing sources are subject to the 

Standard 

B. Notifications for new major sources 

1) Notification of start of construction 

2) Notification of anticipated startup date 

3) Notification of actual startup date 

C. Request for compliance extention 

D. Notification of special compliance requirements 

E. Notification of performance tests 

F. Notification of compliance status 

11 Recordkeeping requirements 

A. Read instructions 

B. Plan and develop record system 

C. Record information 

D. Records for area sources not subject to the standard 

12 Reporting requirements 

A. Semiannual compliance reports for all sources 

1) No exceedances 

2) With exceedances 

B. Additional reports for sources with add-on control devices 

1) Control device performance test report 

2) Operating range for monitored parameters 

3) Startup, shutdown, malfunction reports 

n/a 

2 

2 

2 

n/a 

n/a 

2 

4 

Included in 4. 

Included in 7A. 

Included in 7B. 

n/a 

8 

16 

Included in 5A. 

Included in 5A. 

2 

1 

1 

1 

1 

1 

1 

1 

1 

0.0 $0 $0 $0 

2 

2 

2 

2 

4 

17 

17 

17 

2 

17 

34 

34 

34 

4 

68 

1.7 

1.7 

1.7 

0.2 

3.4 

3.4 

3.4 

3.4 

0.4 

6.8 

$1,740 

$1,740 

$1,740 

$205 

$3,481 

$172 

$172 

$172 

$20 

$215 

$1,912 

$1,912 

$1,912 

$225 

$3,696 

8 

16 

14 

3.4 

109 

54 

5.4 

2.7 

10.9 

5.4 

$5,570 

$2,785 

$161 

$53 

$5,731 

$2,838 

e,f 

e.g 

c 

0.1 0.2 $102 $10 $112 

TOTAL NUMBER OF PLANTS 

TOTAL BURDEN ANNUAL COSTS 

TOTAL ANNUAL HOURS 

17 

1,550 78 155 

$79,360 

1,783 

$2,220 $81,580 

FOOTNOTES 

Based on 17 new facilities beginning operation in Year 2. 

Costs are based on the following hourly rates (the costs are loaded rates): Technical $45.04, Management $66.73, and clerical $28.14. 

Applies only to facilities with an add-on control device. 

Applies only to facilities with open molding and/or centrifugal casting operations. 

Assumes that one semiannual report will be required in the first year of operation. 

Assumes 80 percent of the 17 facilities prepare a semiannual compliance report indicating no exceedances. 

Assumes 20 percent of the 17 facilities prepare a semiannual compliance report indicating an exceedance. 

2-4 

ro 

^i 
TABLE 2. RESPONDENT COSTS IN YEAR 2. (Continued) 

Costs for Existing facilities and Facilities that Started Up in Year 1 

Burden Item 

1. Applications "~TM — " " " 

2. Survey and Studies 

3. Acquire and install recordkeeping technology and systems 

4. Read and understand rule requirements 

A. Facilities with 2 groups of operations 

B. Facilities with 3 groups of operations 

C. Facilities with 4 groups of operations 

D. Facilities with 5 groups of operations 

E. Facilities with 6 groups of operations 

F. Facilities with 7 groups of operations 

5. Required activities for sources with add-on control devices 

A. Initial add-on control device performance test and report 

B. Establish operating parameters 

C. Prepare startup, shutdown, and malfunction plan 

D. Prepare operation and maintenance plan 

E. Continuous parameter monitoring 

1) Initial costs 

2) Annual costs 

6. Employee Training Requirements 

A. Development of operator training course 

B. Time to train personnel 

1) Small facilities (100 or fewer employees) 

2) Medium facilities (more than 100 to 250 employees) 

3) Large facilities (more than 250 employees) 

C. Records of operator completing training course 

7. Required aclrvies for recordkeeping systems 

A. Develop recordkeeping system (spreadsheets) 

1) Develop system for low HAP resins 

2) Develop system for work practices 

3) Develop system for add-on control devices 

B. Enter information into recordkeeping system 

1) Enter information on low HAP resins 

2) Enter information on wo * practices 

3) Enter information on add-on control devices 

8. Create Information 

9. Gather information 

Plant Hours 

per 

Occurrence 

(A) 

n/a 

n/a 

n/a 

Number of 

Occurrences 

per Plant 

(B) 

Plant 

Hours 

(C = A X B) 

Number of 

Plants 

a 

(D)a 

Technical 

Personnel 

Hours 

(E=CxD) 

Management 

Personnel 

Hours 

(F=Ex0.05) 

Clerical 

Personnel 

Hours 

(G=Ex0.1) 

Total Labor 

Costs 

b 

(H) 

O&M 

Costs 

(I) 

Total 

Costs 

(J=H+I) 

Footnotes 

Included in 5A 

0 

0 

0 

0 

0 

0 

0 

10 

n/a 

n/a 

Included in 7B 

Included in 7B 

1 0 

1 0 

1 7 

1 10 

1 0 

1 0 

0 

0 

7 

10 

0 

0 

0.0 

0.0 

0.4 

0.5 

0.0 

0.0 

0.0 

0.0 

0.7 

1.0 

0.0 

0.0 

$0 

$0 

$358 

$512 

$0 

$0 

17 

0.0 0.0 $0 

0.0 0.0 $0 

$0 

$0 

$0 

$0 

$358 

$512 

$0 

$0 

$0 

0 

0 

0 

0 

1 

1 

0 

0 

0 

0 

0 

0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

0 

0 

0 

2 

0 

0 

0 

10 

0 

0 

14 

2 

1 

17 

2 

17 

1 

2 

17 

1 

0 

0 

0 

34 

0 

0 

0 

20 

0 

0 

0.0 

0.0 

0.0 

1.7 

0.0 

0.0 

0.0 

1.0 

0.0 

0.0 

0.0 

0.0 

0.0 

3.4 

0.0 

0.0 

0.0 

2.0 

0.0 

0.0 

$0 

$0 

$0 

$1,740 

$0 

$0 

$0 

$1,024 

$0 

$0 

$0 

$0 

$0 

$43 

$0 

$0 

$0 

S25 

$0 

$0 

$0 

$0 

$0 

$1,783 

$0 

so 

$0 

$1,049 

$0 

$0 

d 

c 

d 

c 

2-5 
TABLE 2. RESPONDENT COSTS IN YEAR 2. (Continued) 

10 Notification requirements 

A. Initial notification that existing sources are subject to the Stan 

B. Notifications for new major sources 

1) Notification of start of construction 

2) Notification of anticipated startup date 

3) Notification of actual startup date 

C. Request for compliance extention 

D. Notification of special compliance requirements 

E. Notification of performance tests 

F. Notification of compliance status 

11 Recordkeeping requirements 

A. Read instructions 

B. Plan and develop record system 

C. Record infonnation 

D. Records for area sources not subject to the standard 

12 Reporting requirements 

A. Semiannual compliance reports for all sources 

1) No exceedances 

2) With exceedances 

B. Additional reports for sources with add-on control devices 

1) Control device performance test report 

2) Operating range for monitored parameters 

3) Startup, shutdown, malfunction reports 

n/a 

0 

0 

0 

n/a 

n/a 

0 

0 

Included in 4. 

Included in 7A. 

Included in 7B. 

n/a 

8 

16 

Included in 5A. 

Included in 5A. 

2 

1 

1 

1 

1 

1 

2 

2 

1 

16 

32 

14 

3.4 

218 

109 

0.0 0.0 $0 

10.9 

5.4 

0.1 

21.8 

10.9 

0.2 

$11,139 

$5,570 

$102 

$0 

$379 

$162 

$10 

$0 

0 

0 

0 

0 

0 

17 

17 

17 

1 

17 

0 

0 

0 

0 

0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

so 

$0 

$0 

$0 

$0 

$0 

$11,518 

$5,732 

$112 

TOTAL NUMBER OF PLANTS 

TOTAL BURDEN ANNUAL COSTS 

TOTAL ANNUAL HOURS 399 20 40 

$20,445 

459 

$619 $21,064 

FOOTNOTES 

a Based on the 17 facilities that began operation in Year 1. 

b Costs are based on the following hourly rates (the costs are loaded rates): Technical $45.04, Management $66.73, and clerical $28.14. 

c Applies only to facilities with an add-on control device. 

d Applies only to facilities with open molding and/or centrifugal casting operations. 

e Assumes 80 percent of the 17 facilities prepare a semiannual compliance report indicating no exceedances. 

f Assumes 20 percent of the 17 facilities prepare a semiannual compliance report indicating an exceedance. 

Total Year 2 Costs for All Facilities 

TOTAL NUMBER OF PLANTS 

TOTAL BURDEN ANNUAL COSTS 

TOTAL ANNUAL HOURS 

34 

1,950 97 195 

34 

$102,644 

2,242 

2-6 
Costs for Facilities that Start Up in Year 3 

TABLE 3. RESPONDENT COSTS IN YEAR 3. 

Burden Item 

Plant Hours 

per 

Occurrence 

(A) 

Number of 

Occurrences 

per Plant 

(B) 

res— 

Hours 

(C = A X B) 

Number of 

Plants 

a 

(D)a 

lechnical 

Personnel 

Hours 

(E=CxD) 

Management 

Personnel 

Hours 

(F=Ex0.05) 

Clerical 

Personnel 

Hours 

(G=Ex0.1) 

Total Labor 

Costs 

b 

(H) 

flAM 

Costs 

(I) 

Total 

Costs 

(J=H+I) 

Footnotes 

1. Applications 

2. Survey and Studies 

3. Acquire and Install recordkeeping technology and systems 

4. Read and understand rule requirements 

A. Facilities with 2 groups of operations 

B. Facilities with 3 groups of operations 

C. Facilities with 4 groups of operations 

D. Facilities with 5 groups of operations 

E. Facilities with 6 groups of operations 

F. Facilities with 7 groups of operations 

5. Required activities for sources with add-on control devices 

A. Initial add-on control device performance test and report 

B. Establish operating parameters 

C Prepare startup, shutdown, and malfunction plan 

D. Prepare operation and maintenance plan 

E. Continuous parameter monitoring 

1) Initial costs 

2) Annual costs 

6. Employee Training Requirements 

A. Development of operator training course 

B. Time to train personnel 

1) Small facilities (100 or fewer employees) 

2) Medium facilities (more thanlOO to 2S0 employees) 

3) Large facilities (more than 2S0 employees) 

C Records of operator completing training course 

7. Required actlvles for recordkeeping systems 

A. Develop recordkeeping system (spreadsheets) 

1) Develop system for low HAP resins 

2) Develop system for work practices 

3) Develop system for add-on control devices 

B. Enter Information Into recordkeeping system 

1) Enter Information on low HAP resins 

2) Enter Information on work practices 

3) Enter Information on add-on control devices 

8. Create Information 

8. Gather Information 

10 Notification requirements 

A. Inttlal notification that existing sources are subject to the standard 

B. Notifications for new major sources 

1) Notification of start of construction 

2) Notification of anticipated startup date 

3) Notification of actual startup date 

C Request for compliance extention 

D. Notification of special compliance requirements 

E Notification of performance tests 

F. Notification of compliance status 

11 Recordkeeping requirements 

A. Read Instructions 

B. Plan and develop record system 

C Record Information 

D. Records for area sources not subject to the standard 

n/a 

n/a 

10 

11 

12 

13 

14 

15 

320 

Included in 5A 

20 

40 

0 

0 

4 

1 

2 

10 

n/a 

n/a 

Included in 7B 

Included In 7B 

n/a 

2 

2 

2 

n/a 

n/a 

2 

4 

Included In 4. 

Included In 7A. 

Included In 7B. 

n/a 

10 

11 

12 

13 

14 

15 

0 

0 

10 

9 

0 

0 

0 

0 

120 

117 

0 

0 

0.0 

0.0 

6.0 

5.9 

0.0 

0.0 

0.0 

0.0 

12.0 

11.7 

0.0 

0.0 

$0 

$0 

$6,143 

$5,989 

$0 

$0 

320 10,880 1,088.0 $556,953 $13,600 

180.8 361.6 $185,105 $4,520 

$0 

$0 

$0 

$6,143 

$5,989 

$0 

$0 

$570,553 

20 

40 

0 

0 

34 

34 

0 

0 

680 

1,360 

0 

0 

34.0 

68.0 

0.0 

0.0 

68.0 

136.0 

0.0 

0.0 

$34,810 

$69,619 

$0 

$0 

$850 

$1,700 

$0 

$0 

$35,660 

$71,319 

$0 

$0 

$189,625 

2 

4 

8 

2 

4 

1 

2 

10 

0 

0 

372 

47 

33 

452 

322 

452 

34 

322 

452 

34 

744 

188 

264 

904 

1,288 

452 

68 

3,220 

0 

0 

37.2 

9.4 

13.2 

45.2 

64.4 

22.6 

3.4 

161.0 

0.0 

0.0 

74.4 

18.8 

26.4 

90.4 

128.8 

45.2 

6.8 

322.0 

0.0 

0.0 

$38,086 

$9,624 

$13,514 

$46,276 

$65,933 

$23,138 

$3,481 

$164,833 

$0 

$0 

$930 

$235 

$330 

$1,130 

$1,610 

$565 

$85 

$4,025 

$0 

$0 

$39,016 

$9,859 

$13,844 

$47,406 

$67,543 

$23,703 

$3,566 

$168,858 

$0 

$0 

f 

e 

d 

f 

e 

d 

2 

2 

2 

2 

4 

19 

19 

19 

34 

452 

38 

38 

38 

68 

1,808 

1.9 

1.9 

1.9 

3.4 

90.4 

3.8 

3.8 

3.8 

6.8 

180.8 

$1,945 

$1,945 

$1,945 

$3,481 

$92,552 

$335 

$335 

$335 

$344 

$5,709 

$2,280 

$2,280 

$2,280 

$3,825 

$98,261 

2-7 
TABLE 3. RESPONDENT COSTS IN YEAR 3 (CONTINUED). 

12 Reporting requirements 

A. Semiannual compliance reports for all sources 

1) No exceedances 8 

2) With exceedances 16 

B. Additional reports for sources with add-on control devices 

1) Control device performance test report Included In 5A. 

2} Operating range for monitored parameters "included In 5A. 

3) Startup, shutdown, malfunction reports 2 

8 

16 

361.6 

90.4 

2,893 

1,446 

144.6 

72.3 

289.3 

144.6 

$148,084 

$74,042 

$6,375 

$2,497 

$154,459 

$76,539 

9. h 

9. i 

d 

$3,481 $3,825 

TOTAL NUMBER OF PLANTS 

TOTAL BURDEN ANNUAL COSTS 

TOTAL ANNUAL HOURS 

452 

1,515 3,030 

$1,550,980 

34,843 

FOOTNOTES 

a Based on 19 new facilities beginning operation in Year 3 and 433 existing facilities demonstrating compliance In Year 3. 

b Costs are based on the following houdy rates (the costs are loaded rates): Technical $45.04, Management $66.73, and clerical $28.14. 

c Applies only to the 19 new facilities beginning operation in Year 3. 

d Applies only to new facilities (2) and existing facilities (32) using an add-on control device. 

e Applies to all new and existing facilities required to demonstrate compliance In Year 3. 

f Applies only to facilities with open molding and/or centrifugal casting operations. 

g Assumes that one semiannual report will be required In the first year of operation for the 19 new facilities and the 433 existing facilities. 

h Assumes 80 percent of the 452 facilities prepare a semiannual compliance report indicating no exceedances. 

i Assumes 20 percent of the 452 facilities prepare a semiannual compliance report Indicating an exceedance. 

2-8 

TI 

CO 
Costs for Existing Facilities and Facilities that Started Up in Years 1 and 2 

TABLE 3. RESPONDENT COSTS IN YEAR 3 (Continued). 

Burden Item 

Hlant Hours 

per 

Occurrence 

(A) 

Number of 

Occurrences 

per Plant 

(B) 

Plant 

Hours 

(C = A X B) 

Number of 

Plants 

a 

(D)a 

Technical 

Personnel 

Hours 

(E=CxD) 

Management 

Personnel 

Hours 

(F=Ex0.05) 

Clerical 

Personnel 

Hours 

(G=Ex0.1) 

Total Labor 

Costs 

b 

(H) 

—OT 

Costs 

(I) 

Toial 

Costs 

(J=H+I) 

Footnotes 

1. Applications 

2. Survey and Studies 

3. Acquire and Install recordkeeping technology and systems 

4. Read and understand rule requirements 

A. Facilities with 2 groups of operations 

B. Facilities with 3 groups of operations 

C. Facilities with 4 groups of operations 

0. Facilities with 5 groups of operations 

E. Facilities with 6 groups of operations 

F. Facilities with 7 groups of operations 

5. Required activities for sources with add-on control devices 

A. Initial add-on control device performance test and report 

B. Establish operating parameters 

C Prepare startup, shutdown, and malfunction plan 

D. Prepare operation and maintenance plan 

E. Continuous parameter monitoring 

1) Initial costs 

2) Annual costs 

6. Employee Training Requirements 

A. Development of operator training course 

B. Time to train personnel 

1) Small facilities (100 or fewer employees) 

2) Medium facilities (more thanlOO to 250 employees) 

3) Large facilities (more than 250 employees) 

C Records of operator completing training course 

7. Required actlvles for recordkeeping systems 

A. Develop recordkeeping system (spreadsheets) 

1) Develop system for low HAP resins 

2) Develop system for work practices 

3) Develop system for add-on control devices 

B. Enter Information Into recordkeeping system 

1) Enter Information on low HAP resins 

2) Enter Information on work practices 

3) Enter Information on add-on control devices 

8. Create Infonnation 

9. Gather Information 

10 Notification requirements 

A. Initial notification that existing sources are subject to the standard 

B. Notifications for new major sources 

1) Notification of start of construction 

2) Notification of anticipated startup date 

3) Notification of actual startup date 

C Request for compliance extention 

D. Notification of special compliance requirements 

E. Notification of performance tests 

F. Notification of compliance status 

11 Recordkeeping requirements 

A. Read Instructions 

B. Plan and develop record system 

C Record Information 

D. Records for area sources not subject to the standard 

n/a 

n/a 

Included In 5A 

0 

0 

0 

0 

0 

0 

0 

10 

n/a 

n/a 

Included in 7B 

Included in 7B 

n/a 

0 

0 

0 

n/a 

n/a 

0 

0 

Included in 4. 

Included tn 7A. 

Included In 7B. 

n/a 

1 0 

1 0 

1 15 

1 18 

1 0 

1 1 

0 

0 

15 

18 

0 

1 

0.0 

0.0 

0.8 

0.9 

0.0 

0.1 

0.0 

0.0 

1.5 

1.8 

0.0 

0.1 

$0 

$0 

$768 

$921 

so 

$51 

$0 

$0 

so 

so 

so 

$768 

$921 

SO 

$51 

$0 

0 

0 

0 

0 

3 

3 

0 

0 

0 

0 

0 

0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

$0 

$0 

$0 

$0 

$0 

$0 

so 

$0 

so 

SO 

$0 

$0 

0 

0 

0 

2 

0 

0 

0 

10 

0 

0 

28 

4 

2 

34 

2 

34 

3 

2 

34 

3 

0 

0 

0 

68 

0 

0 

0 

20 

0 

0 

0.0 

0.0 

0.0 

3.4 

0.0 

0.0 

0.0 

1.0 

0.0 

0.0 

0.0 

0.0 

0.0 

6.8 

0.0 

0.0 

0.0 

2.0 

0.0 

0.0 

$0 

so 

$0 

$3,481 

$0 

$0 

$0 

$1,024 

$0 

$0 

$0 

so 

so 

$85 

$0 

$0 

$0 

$25 

$0 

$0 

$0 

$0 

$0 

$3,566 

SO 

$0 

$0 

$1,049 

SO 

$0 

$0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

0.0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

so 

$0 

$0 

$0 

$0 

$0 

2-9 
TABLE 3. RESPONDENT COSTS IN YEAR 3 (Continued). 

12 Reporting requirements 

A. Semiannual compliance reports for all sources 

1) No exceedances 8 

2) With exceedances 16 

B. Additional reports for sources with add-on control devices 

1) Control device performance test report Included In 5A. 

2) Operating range for monitored parameters Included In 5A. 

3) Startup, shutdown, malfunction reports 2 

16 

32 

27.2 

6.8 

435 

218 

21.8 

10.9 

43.5 

21.8 

$22,278 

$11,139 

$751 

$324 

$23,029 

$11,463 

$307 $30 

TOTAL NUMBER OF PLANTS 

TOTAL BURDEN ANNUAL COSTS 

TOTAL ANNUAL HOURS 781 

$39,970 

898 

$41,185 

FOOTNOTES 

a Based on the 34 facilities that began operation In Year 1 and Year 2. 

b Costs are based on the following hourly rates (the costs are loaded rates): Technical $45.04, Management $66.73, and clerical $28.14. 

c Applies only to facilities with an add-on control device. 

d Applies only to facilities with open molding and/or centrifugal casting operations. 

e Assumes 80 percent of the 34 facilities prepare a semiannual compliance report indicating no exceedances. 

f Assumes 20 percent of the 34 facilities prepare a semiannual compliance report Indicating an exceedance. 

Total Year 3 Costs 

TOTAL NUMBER OF PLANTS 

TOTAL BURDEN ANNUAL COSTS 

TOTAL ANNUAL HOURS 

45i5 

31.079 1,554 3,108 

486 

$1,638,019 

35,741 

2-10 
TABLE 4. SUMMARY AND AVERAGE RESPONDENT BURDEN FOR YEARS 1-3 

Year Technical Hours Management Hours Clerical Hours Total Hours 

Total Annual 

Labor Costs 

Total Annual 

O&M Costs 

Total Annual 

Costs 

Yearl 

Year 2 

Year 3 

6,419 

1,950 

31,079 

321 

97 

1,554 

642 

195 

3,108 

7,382 

2,242 

35,741 

$328,606 

$99,805 

$1,590,950 

$1,887 

$2,839 

$47,069 

$330,493 

$102,644 

$1,638,019 

Average Burden 15,122 $673,120 $17,265 $690,385 

2-11 
P.35 

Attachment 3 

TABLES 5, 6, 7, AND 8 

Table 5: Annual Federal Government Burden and Cost of 

Recordkeeping and Reporting Requirements for 

the Standard of Performance for National 

Emission Standards for Hazardous Air 

Pollutants for RPC Manufacturing--40 CFR Part 

63, Subpart WWWW - Year 1 

Table 6: Annual Federal Government Burden and Cost of 

Recordkeeping and Reporting Requirements for 

the Standard of Performance for National 

Emission Standards for Hazardous Air 

Pollutants for RPC Manufacturing--40 CFR Part 

63, Subpart WWWW - Year 2 

Table 7: Annual Federal Government Burden and Cost of 

Recordkeeping and Reporting Requirements for 

the Standard of Performance for National 

Emission Standards for Hazardous Air 

Pollutants for RPC Manufacturing--40 CFR Part 

63, Subpart WWWW - Year 3 

Table 8: Annual Federal Government Burden and Cost of 

Recordkeeping and Reporting Requirements for 

the Standard of Performance for National 

Emission Standards for Hazardous Air 

Pollutants for RPC Manufacturing--40 CFR Part 

63, Subpart WWWW - Years 1 through 3 and 

Average 
TABLE 5. AGENCY REPORTING AND RECORDKEEPING BURDEN FOR YEAR 1 

Burden Item EPA hours per ","L5[ ° EPA hours per Occurrences 

occurrence % C TM 8 facility 

Technical 

hours 

Management Clerical hours 

(A) (B) (C - A X B) (D) (E = CxO) (F= Ex 0.05) (6=E«0.1 ) 

Costs 

b 

(H) 

$95,518 

$6,888 

$1,561 

$1,102 

Footnotes 

1. Litigation 

2. Read and understand rule requirements 

3. Enter and updateinformatlon Into agency recordkeeping system 

4. Required activities tor sources with add-on control devices 

A. Observe initial add-on control device performance test 

B. Observe repeat performance test 

C. Review operating parameters 

D. Review continuous parameter monitoring 

5. Exceedance Enforcement Activities and Inspections 

6. Notification requirements 

A. Review Initial notification that existing sources are subject to the standard 

B. Notifications for new major sources 

1) Review notification of Intent to construct a new major source and review application to com 

2) Review notification of start of construction 

3) Review notification of anticipated startup date 

4) Review notification of actual startup date 

C. Review request for compliance extention 

D. Review notification of special compliance requirements 

E. Review notification of Initial performance tests and review test plan 

F. Review notification of compliance status 

G. Records for area sources not subject to the standard 

H. Review of NESHAP waiver application 

7. Reporting requirements 

A. Review semiannual compliance report 

1) Semiannual compliance reports with no exceedances 

2) Semiannual compliance reports with exceedances 

B. Additional reports for sources with add-on control devices 

1) Review of control device performance test report and operating range 

2) Review startup, shutdown, malfunction reports 

2080 

15 

2 

24 

n/a 

2 

2 

8 

12 

2 

2 

2 

n/a 

n/a 

20 

2 

n/a 

n/a 

16 

4 

2080 

15 

2 

24 

16 

4 

1 

10 

17 

13.6 

3.4 

2080 

150 

34 

24 

27.2 

13.6 

16 

4 

104 

7.5 

1.7 

1.36 

0.68 

0.8 

0.2 

208 

15 

3.4 

2 

2 

8 

1 

1 

3.4 

2 

2 

27.2 

0.1 

0.1 

1.36 

0.2 

0.2 

2.72 

$92 

$92 

$1,249 

2.72 

1.36 

1.6 

0.4 

$0 

12 

2 

2 

2 

20 

2 

17 

17 

17 

17 

1 

17 

204 

34 

34 

34 

20 

34 

10.2 

1.7 

1.7 

1.7 

1 

1.7 

20.4 

3.4 

3.4 

3.4 

2 

3.4 

$9,368 

$1,561 

$1,561 

$1,561 

$918 

$1,561 

$1,249 

$625 

$735 

$184 

Q.h 

g.i 

TOTAL BURDEN AND COST (SALARY) 

TOTAL ANNUAL HOURS 

2,740 137 $125,826 

FOOTNOTES 

a Based on 17 new facilities beginning operation in Year 1. 

b Costs are based on the following hourly rates (the costs are loaded rates): Technical $40.32, Management $66.56, and clerical $22.74. 

c One time only costs. Number ol occurrences is 45 states that have RPC major sources and 10 region offices. 

d Applies to the 17 new facilities beginning operation in Year 1. 

e Applies to the one new facility assumed to have an add-on control device. 

f Assumes 20 percent of the 17 facilities will have an exceedance. 

g Assumes that one semi-annual report win be required the first year of operation. 

h Assumes 80 percent of the 17 facilities will have no exceedances. 

3-1 
TABLE 6. AGENCY REPORTING AND RECORDKEEPING BURDEN FOR YEAR 2 

Burden Item EPA hours per "^ 8 ° L EPA hours per 

occurrence """^ s pe r facility 

Occurrences Technical hours Management Clerical hours 

(A) (B) (C = A X B) 

5 

(D) 

" O -

0 

34 

(E = C x D) 

5 

(F = Ex0.05) (G = Ex0.1) 

Costs 

b 

(H) 

Footnotes 

1. Litigation 

2. Read and understand rule requirements 

3. Enter and updateinformation into agency recordkeeping system 

4. Required activities for sources with add-on control devices 

A. Observe initial add-on control device performance test 

B. Observe repeat performance test 

C. Review operating parameters 

D. Review continuous parameter monitoring 

5. Exceedance Enforcement Activities and Inspections 

6. Notification requirements 

A. Review initial notification that existing sources are subject to the standard 

B. Notifications for new major sources 

1) Review notification of intent to construct a new major source and review application to construct 

2) Review notification ot start of construction 

3) Review notification of anticipated startup date 

4) Review notification of actual startup date 

C Review request for compliance extention 

D. Review notification of special compliance requirements 

E. Review notification of initial performance tests and review test plan -

F. Review notification ot compliance status 

G. Records lor area sources not subject to the standard 

H. Review of NESHAP waiver application 

7. Reporting requirements 

A. Review semiannual compliance report 

1) Semiannual compliance reports with no exceedances 

2) Semiannual compliance reports with exceedances 

B. Additional reports for sources with add-on control devices 

1) Review of control device performance test report and operating range 

2) Review startup, shutdown, malfunction reports 

2660 

0 

4 

24 

n/a 

2 

2 

8 

12 

2 

2 

2 

n/a 

n/a 

20 

2 

n/a 

n/a 

16 

4 

16 

4 

20.4 

5.1 

0 

136 

81.6 

40.8 

32 

0 

6.8 

4.08 

2.04 

1.6 

0.4 

0 

13.6 

4.8 

8.16 

4.08 

3.2 

0.8 

$0 

$6,245 

$2,204 

2 

2 

8 

2 

2 

6.8 

4 

4 

54.4 

0.2 

0.2 

2.72 

0.4 

0.4 

-5.44 

$184 

$184 

$2,498 

$0 

12 

2 

2 

2 

20 

2 

17 

17 

17 

17 

2 

17 

204 

34 

34 

34 

40 

34 

10.2 

1.7 

1.7 

1.7 

2 

1.7 

20.4 

3.4 

3.4 

3.4 

4 

3.4 

$9,368 

$1,561 

$1,561 

$1,561 

$1,837 

$1,561 

$3,747 

$1,874 

$1,470 

$367 

TOTAL BURDEN AND COST (SALARY) 

TOTAL ANNUAL HOURS 

789 39 $36,223 

FOOTNOTES 

a Based in 17 new facilities beginning operation in Year 2 and the 17 facilities that began operation in Year 1. 

b Costs are based on the following hourly rates (the costs are loaded rates): Technical $40.32, Management $66.56, and clerical $22.74. 

c Based on 2 of the 17 new facilities having an add-on control device. 

d Assumes that 20 percent of the 34 facilities will have an exceedance. 

e Based on the 17 facilities that begin operation in Year 2 submitting one semiannual report, the 17 facilities that began operation in Year 1 submitting two semiannual reports, and 80 percent of these reports indicate no exceedances. 

f Based on the 17 facilities that begin operation in Year 2 submitting one semiannual report, the 17 facilities that began operation in Year 1 submitting two semiannual reports, and 20 percent of these reports indicate an exceedance. 

3-2 
TABLE 7. AGENCY REPORTING AND RECORDKEEPING BURDEN FOR YEAR 3 

Number of 

occurrences 

per facility 

(B) 

Burden Item 

EPA hours per 

occurrence 

<*2 

EPA hours per Occurrences 

facility a 

(C = A X B) J2_ 

Technical 

hours 

(E = C x D) 

Management 

(F = E x 0.05) 

Clerical hours 

(G = E x 0.1) 

Costs 

b 

(H) 

Footnotes 

1. Litigation 

2. Read and understand rule requirements 

3. Enter and updatelnformation into agency recordkeeping system 

4. Required activities for sources with add-on control devices 

A. Observe Initial add-on control device performance test 

B. Observe repeat performance test 

C. Review operating parameters 

D. Review continuous parameter monitoring 

5. Exceedance Enforcement Activities and Inspections 

6. Notification requirements 

A. Review initial notification that existing sources are subject to the standard 

B. Notifications for new major sources 

1) Review notification of intent to construct a new major source and review application to const 

2) Review notification of start of construction 

3) Review notification of anticipated startup date 

4) Review notification of actual startup date 

C. Review request for compliance extention 

D. Review notification of special compliance requirements 

E. Review notification of Initial performance tests and review test plan 

F. Review notification of compliance status 

G. Records for area sources not subject to the standard 

H. Review of NESHAP waiver application 

7. Reporting requirements 

A. Review semiannual compliance report 

1) Semiannual compliance reports with no exceedances 

2) Semiannual compliance reports with exceedances 

B. Additional reports for sources with add-on control devices 

1) Review of control device performance test report and operating range 

2) Review startup, shutdown, malfunction reports 

TOTAL BURDEN AND COST (SALARY) 

TOTAL ANNUAL HOURS 

15 

2 

24 

n/a 

2 

2 

8 

1 

0 

486 

17 

34 

34 

97.2 

0 

0 

972 

408 

68 

68 

777.6 

0 

48.6 

20.4 

3.4 

3.4 

38.88 

0 

97.2 

40.8 

6.8 

6.8 

77.76 

$0 

$0 

$44,636 

$18,736 

$3,123 

$3,123 

$35,709 

$0 

12 

2 

2 

2 

n/a 

n/a 

16 

2 

n/a 

n/a 

2 

4 

12 

4 

1 

1 

1 

1 

1 

1 

2 

4 

1 

1 

12 

2 

2 

2 

16 

2 

4 

16 

12 

4 

19 

19 

19 

19 

34 

452 

208 

52 

34 

34 

228 

38 

38 

38 

544 

904 

# 

832 

832 

408 

136 

6,292 

11.4 

1.9 

1.9 

1.9 

27.2 

45.2 

41.6 

41.6 

20.4 

6.8 

315 

22.8 

3.8 

3.8 

3.8 

54.4 

90.4 

83.2 

83.2 

40.8 

13.6 

629 

$10,470 

$1,745 

$1,745 

$1,745 

$24,982 

$41,513 

$38,207 

$38,207 

$18,736 

$6,245 

$288,923 

d 

g 

h 

i 

d 

FOOTNOTES 

a Based on 19 new facilities beginning operation in Year 3 and 433 existing sources complying in Year 3 plus the 17 lacilities that began operation in Year 1 and the 17 facilities that began operation in Year 2. 

b Costs are based on the following hourly rates (the costs are loaded rates): Technical $40.32, Management $66.56, and clerical $22.74. 

c Based on 2 of the 19 new facilities and 32 of the 433 existing facilities having an add-on control device. 

d Assumes fifty percent of the performance tests are observed by Agency personnel 

e Assumes 20 percent of the 486 facilities will have an exceedance. 

f Applies to the 19 new facilities beginning operation in Year 3. 

g Based on the 19 facilities that begin operation in Year 3 and the 433 existing sources submitting one semiannual report, the 34 facilities that began operation in Year 1 and Year 2 submitting two semiannual reports, and 80 percent of these reports indicate no exceedances 

h Based on the 19 facilities that begin operation in Year 3 and the 433 existing sources submitting one semiannual report, the 34 facilities that began operation in Year 1 and Year 2 submitting two semiannual reports, and 20 percent of these reports indicate an exceedance. 

co 

oo 
TABLE 8. SUMMARY AND AVERAGE OF AGENCY REPORTING AND RECORDKEEPING BURDEN FOR YEARS 1 THROUGH 3. 

Agency Burden Summary 

Yearl 

Year 2 

Year 3 

Technical Hours 

2,740 

789 

6,292 

Management Hours 

137 

39 

315 

Clerical Hours 

274 

79 

629 

Average Burden 

Total Hours 

3,151 

907 

7,235 

11,293 

Total Costs 

$125,826 

$36,223 

$288,923 

$450,972 

3-4