SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Chemical Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Chemical Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) 

(Renewal), EPA ICR Number 2356.04, OMB Control Number 2060-0636.

1(b) Short Characterization/Abstract

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

Preparations Industry were proposed on August 5, 2009, and promulgated on December 30, 

2009. These regulations apply to existing and new chemical preparation facilities that conduct 

the mixing, milling, blending or extruding of industrial chemicals and that are area sources of 

hazardous air pollutants (HAPs). Area sources are classified as sources that emit less than 10 

tons per year of a single HAP or less than 25 tons per year of any combination of HAPs. New 

facilities include those that commenced construction or reconstruction after the date of proposal.

This information is being collected to assure compliance with 40 CFR Part 63, Subpart 

BBBBBBB.

In general, all NESHAP standards require initial notification reports, performance tests, 

and periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the

operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file containing 

these documents, and retain the file for at least five years following the generation date of such 

maintenance reports and records. All reports are sent to the delegated state or local authority. 

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

Environmental Protection Agency (EPA) regional office.

The “Affected Public” includes owners and operators of chemical preparation facilities 

that are area sources and that conduct the mixing, milling, blending or extruding of industrial 

chemicals, though not to be confused with non-industrial mixing or blending that occurs at a 

pharmacy, in a laboratory, or in similar non-industrial circumstances. The “burden” to the 

Affected Public may be found below in Table 1: Annual Respondent Burden and Cost –

NESHAP for Chemical Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) (Renewal).

The Federal Government’s burden is attributed entirely to work performed by either Federal 

employees or government contractors and can be found below in Table 2: Average Annual EPA 

Burden and Cost – NESHAP for Chemical Preparations Industry (40 CFR Part 63, Subpart 
2

BBBBBBB) (Renewal). 

Over the next three years, approximately 26 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard.

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

without any “Terms of Clearance”. 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. In addition, section 

114(a) states that the Administrator may require any owner/operator subject to any requirement 

of this Act to: 

(A) Establish and maintain such records; (B) make such reports; 

(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may 

reasonably require.

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

either cause or contribute to air pollution that may reasonably be anticipated to endanger public 

health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 

CFR Part 63, Subpart BBBBBBB.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards ensure compliance with 

the applicable regulations which were promulgated in accordance with the Clean Air Act. The 

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

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standards. Continuous emission monitors are used to 
3

ensure compliance with the standard at all times. During the performance test, a record of the 

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

determine compliance in place of a continuous emission monitor.

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

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

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

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

The performance test may also be observed.

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

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

determinations.

The information obtained under the initial compliance demonstration, monitoring, 

recordkeeping, and reporting will be used by our enforcement personnel to: (1) identify existing 

and new HAP emission points subject to the NESHAP; (2) ensure that GACT is being properly 

applied; and (3) ensure that vent collection systems and control devices are being properly 

operated and maintained on a continuous basis to reduce HAP emissions from mixers, mixing 

and blending tanks, mills, and extruders.

3. Non-duplication, Consultations, and Other Collection Criteria

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

BBBBBBB.

3(a) Non-duplication

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

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

or local agency. If a state or local agency has adopted its own similar standards to implement the 

Federal standards, a copy of the report submitted to the state or local agency can be sent to the 

Administrator in lieu of the report required by the Federal standards. Therefore, duplication does 

not exist.

3(b) Public Notice Required Prior to ICR Submission to OMB

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

in the Federal Register (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 
4

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 these standards, is the Integrated Compliance Information System (ICIS). ICIS is 

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

and government-owned facilities. The growth rate for the industry is based on our consultations 

with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity 

to comment on the burden associated with these standards as they were being developed. In 

developing this ICR, we contacted both the American Coatings Association, at (202) 719-3703,

and the PPG Industries, at (412) 492-5476.

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

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

case, no comments were received.

3(d) Effects of Less-Frequent Collection

Less-frequent information collection would decrease the margin of assurance that 

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

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

applied and emission limitations are met. If the information required by these standards was 

collected less-frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five-year records retention requirement is consistent with the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish the compliance history of a 

source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 
5

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in these standards 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 chemical 

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

respondents affected by the standards is SIC 2899 (Chemical and Chemical Preparations, NEC),

which corresponds to the North American Industry Classification System (NAICS) code 325998

for All Other Miscellaneous Chemical Product and Preparation Manufacturing.

4(b) Information Requested

(i) Data Items

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

Chemical Preparations Industry (40 CFR Part 63, Subpart BBBBBBB).

A source must make the following reports:

Notifications

Initial notification of applicability 63.11585(b)(1)

Notification of intent to construct or reconstruct 63.5(d)(1), 63.9(b)(5)

Notification of commencement of construction or reconstruction 63.5(d)(1)

Notification of anticipated and actual startup 63.9(b)(5)

Request for compliance extension 63.9(c)

Notification of initial performance tests 63.11585(b)(2)

Notification of compliance status 63.11585(b)(3)

Reports

Initial compliance report and test data 63.11585(b)(3), (6)
6

Reports

Results of initial management practices 63.11585(b)(5)

Semiannual compliance reports 63.11585(c)

A source must keep the following records:

Recordkeeping

All notification and reports 63.11585(d)(1)(i)

Records of initial compliance demonstration 63.11585(d)(1)(iii)

Records of continuous parameter monitoring 63.11585(d)(1) (v)

Records of calibration and maintenance to continuous parameter 

monitoring equipment

63.11585(d)(1)(iv), 

(vi)

Records of vent collection system and control device inspection 63.11585(d)(1)(vi)

Records of site-specific monitoring plan 63.11585(d)(1)(vii)

Records of particulate control device manufacturing specifications and 

recommendations

63.11585(d)(1)(viii)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for control device.

Perform initial performance test, and repeat performance tests if necessary.

Demonstrate compliance using prior emissions test, performance guarantee information, or 

engineering calculations.

Write the notifications and reports listed above.
7

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

and ICIS. 

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. Performance 

test reports are used by the Agency to discern a source’s initial capability to comply with the 

emission standards, and note the operating conditions under which compliance was achieved.

Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual reports are used for problem 

identification, as a check on source operation and maintenance, and for compliance 
8

determinations.

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

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

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

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

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

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five

years.

5(c) Small Entity Flexibility

Approximately 38 percent of the area source facilities are small entities (i.e., small 

businesses). Due to the high percentage of companies that are small businesses, it is likely 

that some small businesses are affected by this NESHAP. However, it has been determined that 

the standard will not have a significant impact on small businesses. It is estimated that no 

companies will incur compliance costs, which include the cost of monitoring, inspection, 

recordkeeping and reporting costs, in excess of 1 percent of sales. Additionally, we have limited 

the initial compliance demonstration, monitoring, recordkeeping, and reporting requirements for 

all facilities, including those owned by small businesses, to the minimum necessary to ensure 

compliance. 

Due to technical considerations involving the process operations and the types 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, therefore, cannot reduce them further for small entities. To the extent 

that larger businesses can use economies of scale to reduce their burden, the overall burden will 

be reduced.

5(d) Collection Schedule

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

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

Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

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

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.
9

The Agency may not conduct or sponsor, and a person is not required to respond to, 

a collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated to be 2,210 hours (Total Labor Hours from Table 1

below). 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-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

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

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

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

the benefit packages available to those employed by private industry.

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

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

subject standards 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

EPA assumes all affected sources will use existing continuous parameter monitoring 

equipment or alarms to demonstrate continuous compliance. Therefore, no new equipment would 

be required to comply with the recordkeeping and reporting requirements of the NESHAP and 

that no capital costs would be incurred. 

The annual operation and maintenance (O&M) costs include the cost of photocopying 

and mailing reports for initial compliance demonstrations (engineering calculations or 

performance guarantee information) and semiannual compliance reports. Photocopying and 
10

postage costs are incurred when reports required by the NESHAP are submitted to regulatory 

agencies. These costs were estimated to be $7.50 per report ($0.10/page, 15 pages/report, and 

$0.50 postage/report). 

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New 

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents

with O&M

(G)

Total O&M,

(E X F)

Photocopy 

and 

postage

NA NA NA $15 1 26 $390

Note: Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding. 1

Photocopy and postage cost for semiannual reports ($7.50/report x 2 report/yr) = $15/yr 

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $390. This is the total 

of column G. 

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

industry over the next three years of the ICR is estimated to be $390. These are recordkeeping 

costs.

6(c) Estimating Agency Burden and Cost

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

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$2,830.

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

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

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

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

These rates are from the Office of Personnel Management (OPM), 2016 General Schedule,

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 
11

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Chemical 

Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) (Renewal).

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

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

26 existing respondents will be subject to these standards. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 26 per year.

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

years covered by this ICR:

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New 

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 26 0 0 26

2 0 26 0 0 26

3 0 26 0 0 26

Average 0 26 0 0 26

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

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

average Number of Respondents over the three year period of this ICR is 26. 

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total Annual Responses

E=(BxC)+D

Notification of applicability 0 1 0 0
12

Total Annual Responses

Notification of construction / 

reconstruction

0 1 0 0

Notification of startup 0 1 0 0

Notification of initial 

performance tests

0 1 0 0

Notification of compliance status 0 1 0 0

Semiannual reports 26 2 0 52

Total 52

The number of Total Annual Responses is 52.

The total annual labor costs are $223,000. Details regarding these estimates may be found 

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

Industry (40 CFR Part 63, Subpart BBBBBBB) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

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

(i) Respondent Tally

The total annual labor hours are 2,210 hours. Details regarding these estimates may be 

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

Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) (Renewal).

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

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

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

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

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

information is estimated to average 43 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $390. The cost 

calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.
13

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 62

labor hours at a cost of $2,830. See below in Table 2: Average Annual EPA Burden and Cost –

NESHAP for Chemical Preparations Industry (40 CFR Part 63, Subpart BBBBBBB) (Renewal). 

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

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

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

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

6(f) Reasons for Change in Burden

There is an adjustment increase in respondent labor hours in this ICR from the mostrecently approved ICR. This is due to assuming all existing sources will have to re-familiarize 

with the regulatory requirements each year. 

6(g) Burden Statement

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

is estimated to average 43 hours per response. “Burden” means the total time, effort, or financial 

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

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 

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

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

the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

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

Docket ID Number EPA-HQ-OECA-2012-0642. An electronic version of the public docket is 

available at http://www.regulations.gov/, which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

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

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, 
14

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

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

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

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

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

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

Number EPA-HQ-OECA-2012-0642 and OMB Control Number 2060-0636 in any 

correspondence. 

Part B of the Supporting Statement

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

information.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for Chemical Preparations Industry (40 CFR Part 63, Subpart 

BBBBBBB) (Renewal)

Burden Items

(A) 

Respondent 

Hours per 

Occurrence

(B) 

Number of 

Occurrences 

per 

Respondent 

per Year

(C) 

Hours per 

Respondent 

per Year 

(A x B)

(D) Number 

of 

Respondents 

per Year a

(E) 

Technical 

Hours per 

Year 

(C x D)

(F) 

Management 

Hours per 

Year 

(E x 0.05)a

(G) 

Clerical 

Hours 

per Year 

(Ex0.1)a

(H) Total 

Labor Costs 

per Year, $b

1. Familiarization with the regulatory requirements 4 1 4 26 104 5.2 10.4 $12,027 

2. Required activities

 a. Initial performance tests c, d 8 1 8 0 0 0 0 $0 

b. Engineering calculations or performance 

guarantees d, e 8 1 8 0 0 0 0 $0 

c. Continuous parameter monitoring e, f 8 1 8 0 0 0 0 $0 

3. Reporting requirements

 a. Initial notification that existing facilities are 

subject to the standard c, g 4 1 4 0 0 0 0 $0 

 b. Notification of new area sources h

(1) Notification of intent to 

construct/reconstruct 4 1 4 0 0 0 0 $0 

(2) Notification to commence 

construct/reconstruct 4 1 4 0 0 0 0 $0 

(3) Notification of startup 4 1 4 0 0 0 0 $0 

c. Request for compliance extension h 4 1 4 0 0 0 0 $0 

 d. Notification of initial performance test c, d 2 1 2 0 0 0 0 $0 

e. Notification of compliance status c 4 1 4 0 0 0 0 $0 

f. Gather information for semiannual reports 4 2 8 26 208 10.4 20.8 $24,054.26 

g. Semiannual compliance reports i 4 2 8 26 208 10.4 20.8 $24,054.26 
16

Burden Items

(A) 

Respondent 

Hours per 

Occurrence

(B) 

Number of 

Occurrences 

per 

Respondent 

per Year

(C) 

Hours per 

Respondent 

per Year 

(A x B)

(D) Number 

of 

Respondents 

per Year a

(E) 

Technical 

Hours per 

Year 

(C x D)

(F) 

Management 

Hours per 

Year 

(E x 0.05)a

(G) 

Clerical 

Hours 

per Year 

(Ex0.1)a

(H) Total 

Labor Costs 

per Year, $b

Subtotal for Reporting Requirements 598 $60,135.66 

4. Recordkeeping Requirements

 a. Develop a record system c 4 1 4 0 0 0 0 $0 

 b. Develop a monitoring plan c 4 1 4 0 0 0 0 $0 

 c. Implement activities $0 

(1) Record performance tests 1 1 1 0 0 0 0 $0 

(2) Record periods of target HAP service 

and deviations 0.5 52 26 26 676 33.8 67.6 $78,176.36 

(3) Continuous parameter monitoring 

system inspections, calibration and 

maintenance j

1 12 12 26 312 15.6 31.2 $36,081.40 

(4) Vent collection systems and control 

inspections 1 12 12 26 312 15.6 31.2 $36,081.40 

 d. Store, file and maintain records 4 1 4 26 104 5.2 10.4 $12,027.13 

5. Time to train personnel 4 1 4 0 0 0 0 $0 

6. Prepare for and participate in audits 0 0 0 0 0 0 0 $0 

Subtotal for Recordkeeping Requirements 1,615 $162,366.28 

TOTAL ANNUAL BURDEN and COST 

(rounded) k 2,210 $223,000 

Capital and O&M Cost (see Section 6(b)(iii)): k $390

TOTAL COST: k $223,000

Assumptions:

a. We have assumed that there are approximately 26 respondents subject to the rule, with no new sources expected over the next three-years of this ICR.
17

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

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

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

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

hours.

c. We assume that this is a one-time only activity for new facilities.

d. One-time activity for new and existing facility after promulgation of final rule. Assume that performance tests are not required for any of the existing 

facilities to demonstrate compliance with the emission limits. We assume that 50 percent of the industry will have existing performance tests that demonstrate 

compliance with the emission limits, and the other 50 percent will use performance guarantees or engineering calculations to demonstrate compliance.

e. We assume that all existing facilities will use their existing continuous parameter monitoring equipment or alarms to demonstrate continuous compliance. 

f. There is no additional burden for new monitoring equipment because additional add-on control devices are not expected to be needed to demonstrate 

compliance with the emission limits and facilities are already equipped with equipment to monitor existing control device parameters.

g. Existing facilities must submit notification that they are subject to the standard within 120 days of the effective date of final rule.

h

 We assume that compliance extensions will not be necessary.

i We have assumed that semiannual compliance reports will take each respondent 4 hours twice per year to prepare.

j We have assumed that each respondent will take 1 hour 12 times per year to implement the continuous parameter monitoring system inspections, calibration 

and maintenance activity.

k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.
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Table 2: Average Annual EPA Burden and Cost – NESHAP for Chemical Preparation Industry (40 CFR Part 63, Subpart 

BBBBBBB) (Renewal)

Burden Items

(A) EPA 

Hours per 

Occurrence

(B) 

Occurrences 

per Plant per 

Year

(C) EPA 

Hours per 

Plant per 

Year (AxB)

(D) Plants 

per Year a

(E) 

Technical 

EPA Hours 

per Year 

(CxD)

(F) 

Managerial 

Hours per 

Year 

(Ex0.05)

(G) 

Clerical 

Hours per 

Year 

(Ex0.1)

(H) Cost 

per year, 

$b

1. Familiarization with the regulatory requirements 2 1 2 1 2 0.1 0.2 $104.68 

2. Required activities

 a. Initial performance tests c, d, e 8 1 8 0 0 0 0 $0 

 b. Review initial performance test reports, 

 performance guarantees, engineering 4 1 4 0 0 0 0 $0 

 c. Enter and update information into agency 

 recordkeeping system 1 1 1 0 0 0 0 $0 

3. Excess emissions – enforcement activities f N/A

4. Notification requirements

 a. Review initial notification that existing facilities are 

 subject to the standard c, g 1 1 1 0 0 0 0 $0 

b. Notifications for new area sources h

(1) Review notification of intent to 

construct/reconstruct 4 1 4 0 0 0 0 $0 

(2) Review notification of commencement of 

construction/reconstruction 2 1 2 0 0 0 0 $0 

(3) Review notification of startup 2 1 2 0 0 0 0 $0 

c. Review request for compliance extension i 2 1 2 0 0 0 0 $0 

d. Review notification of initial performance tests c, d, 

e 1 1 1 0 0 0 0 $0 

 e. Review notification of compliance status c, j 4 1 4 0 0 0 0 $0 
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Burden Items

(A) EPA 

Hours per 

Occurrence

(B) 

Occurrences 

per Plant per 

Year

(C) EPA 

Hours per 

Plant per 

Year (AxB)

(D) Plants 

per Year a

(E) 

Technical 

EPA Hours 

per Year 

(CxD)

(F) 

Managerial 

Hours per 

Year 

(Ex0.05)

(G) 

Clerical 

Hours per 

Year 

(Ex0.1)

(H) Cost 

per year, 

$b

5. Reporting requirements – review semiannual 

compliance reports k 4 1 4 13 52 2.6 5.2 $2,721.68 

TOTAL ANNUAL BURDEN and COST (rounded) l 62 $2,830 

Assumptions:

a. We have assumed that there are approximately 26 respondents subject to the rule, with no new sources expected over the next three-years of this ICR. 

Facilities subject to the NESHAP rules are located in 13 States.

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

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

percent of Technical hours. These rates are from the OPM, 2016 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 assume that this is a one-time only cost.

d. We assume that EPA technical personnel will observe all performance tests conducted by new sources.

e. We have assumed that not emission tests will need to be performed. Facilities will utilize existing performance tests, performance guarantees, or engineering 

calculations to demonstrate initial compliance

f. We have assumed that there would be no enforcement activities for the 3-year period covered by this ICR.

g. We assume that existing area source facilities must submit notification that they are subject to and the standard within 120 days of the effective date of the 

final rule.

h

 There are no new sources expected.

i We have assumed that the compliance extensions will not be necessary.

j Assume that EPA technical personnel will review all of the initial compliance status notifications for new sources.

k

 We assume that EPA technical personnel will review 25 percent of the semiannual compliance reports for 26 sources, Number of occurrence = (26 x2 

reports) x25% = 13 reports.

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