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 con duct the mixing, milling, blending or extruding of industrial chemicals and that are area sources of hazardous air pollutants (HAP s ). 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 stand ards require initial notification report s, 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 own er/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 st ate 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 source s 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).

Th e Federal Governmen t ’s burden is attributed entirely to work performed by either F ederal 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, Subpart2

BBBBBBB) (R enewal).

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

- acti ve 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, produc tion 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 the se standard s 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 com ply with the emission standard s . Continuous emission monitors are used to3

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

de termine compliance in place of a continuous emission monitor.

The notifications required in the se standard s are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated

, leaks are being detected and repaired and the standard s are being met. The performance test may also be observed.

The require d semiannual reports a re 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 an d 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 t o 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 r equired 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 i ndustry experts and internal data sources to project the4

number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the se standard s , is the Integrated Compliance Information System (ICIS). ICIS is

EPA’s database for the collectio n, 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 p arties were provided an opportunity

to comment on the burden associated with the se standard s 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 operat ion 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

T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to

the standards. EPA believes that the five

- year records retention requirement is consistent with the Part 70 permit program and the fiv e

- year statute of limitations on which the permit program is

based. T he retention of records for five years allow s EPA to establish the compliance history of a

source
, any pattern of non

- compliance and to determine the appropriate level of enforcement

action. EPA has 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

nonexistenc e 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

T he reporting or r ecordkeeping requirements in the se standard s 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 ) cod e 325998

for All Other Miscellaneous Chemical Product and Preparation Manufacturing

.

4(b) Information Requested

(i) Data Items

I n 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:

Notification s
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 r espondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and 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 technolog y and systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

5. The Information Collected: Agency Activities, Collection Methodology, and Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information :

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry.

Audit facility records.

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

and ICIS

.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source ’ s initial capability to comply with the

emission standard s , and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compl iance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance8

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. IC IS is

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

- owned facilities. EPA uses ICIS for tracking ai r 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 re tained 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 pe rcent 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 requirement s 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 specif ic 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 headin gs 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 s ponsor, 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 r ecordkeeping and reporting requirement s is estimated to be 2,210 hours ( Total Labor Hours from Table 1

below ). T hese hours are based on Agency studies and background documen ts 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 $1 2 9

. 93 ($ 61.87 + 110%)

Technical $ 10 3

. 97 ($4 9

. 51 + 110%)

Clerical $ 5 1

. 79 ($2 4

. 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 c ollection activities in the subject standard s 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 inf ormation) and semiannual compliance reports. Photocopying and10

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 pos tage/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 o f 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 Co st

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

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

examination of records maint ained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $ 2,830

.

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

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% )

Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% )

Clerical $2 5. 25 (GS

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

These rates are from the Office of Personnel Management (OPM)

, 20 1 6 General Schedule

, which excludes locality rates of pay. The rates have been increased by 60 percent to account for11

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 existin g respondents will be subject to the se standard s

. It is estimated that no additional respondents per year will become subject. The overall average number of responden ts, 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.

C olumn 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 0 012

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 d uties 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) (R enewal).

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 ta sks 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 most

recently 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; dev elop, 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 co mment 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 I CR under

Docket ID Number EPA

- HQ

- OECA

- 201 2

- 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

i n 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 i s (202) 566

- 17 52

. Also, you can send comm ents 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

- 20 12

- 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 $24,054.2616

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 t hree

- years of this ICR.17

b. This ICR uses the following labor rates: Technical $103.97 ($49.51 + 110%); Manag erial $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 colu mn 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 ho urs 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 ex isting 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 guaran tees or engineering calculations to demonstrate compliance.

e. We assume that all existing facilities will use their existing continuous parameter monitoring equipment or alarms to demonst rate 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 f inal rule.

h We assume that compliance extensions will not be necessary.

i We have assumed that semiann ual 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 syst em inspections, calibration

and maintenance activity.

k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.18

Table 2: Average Annual EPA Burden and Cost

– NESHAP for Chemical Preparation Industry (40 CFR Part 6 3 , 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 $019

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 thre e

- years of this ICR. Facilities subject to the NESHAP rules are located in 13 States.

b. This cost is based on the average hour ly 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 Cleri cal 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 existin g 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 day s of the effective date of the

final rule.

h There are no new sources expected.

i We have assumed that the compliance extension s 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.