Information Collection Request for Requirements for Control 

Technology Determinations from Major Sources in Accordance 

with Clean Air Act Section 112(j)

Supporting Statement
1

PART A OF THE SUPPORTING STATEMENT

1. IDENTIFICATION OF THE INFORMATION COLLECTION

(a) Title and Number of the Information Collection

ICR: Information Collection Request for Requirements for Control Technology

Determinations from Major Sources in Accordance with Clean Air Act Section 112(j).

OMB Control Number: 2060-0266, EPA ICR # 1648.07.

(b) Short Characterization

Section 112 of the Clean Air Act (CAA) requires EPA to establish National Emissions 

Standards for Hazardous Air Pollutants (NESHAP) for both major and area sources of hazardous 

air pollutants (HAP) that are listed for regulation under CAA section 112(c). An area sources is 

a stationary source that is not a major source (i.e., an area source does not emit and does not have 

the potential to emit more than 10 tons per year [tpy] of any single HAP and more than 25 tpy of 

any combination of HAP). Section 112(j) of the CAA requires that if EPA fails to promulgate a 

standard for a category or subcategory of major sources within 18 months after its scheduled date 

of promulgation, then sources must submit a title V permit application beginning on that date. 

States (with approved title V operating permit programs) or EPA will issue permits containing 

maximum achievable control technology (MACT) emission limitations determined on a case-bycase basis to be equivalent to what would have been promulgated by EPA pursuant to CAA 

section 112(d). 

EPA has promulgated regulations implementing section 112(j) for all of the listed 

categories and the previous OMB clearance for the section 112(j) regulation was allowed to 

lapse. However, recent vacaturs of several MACT standards (Polyvinyl Chloride and 

Copolymers Production (“PVC”), Brick and Structural Clay Products Manufacturing ("Brick"), 

Clay Ceramics Manufacturing (“Clay Ceramics”), and the Industrial, Commercial and 

Institutional Boilers and Process Heaters (“Boilers”)) have re-established the need for applying 

the rule implementing section 112(j) of the CAA. EPA is proposing revisions to the section 

112(j) rule to clarify the application of section 112(j) in the case of complete standards vacaturs 

and to clarify and streamline the permit application and review process for the vacatur situation. 

The purpose of this ICR is to reinstate the OMB clearance for the revised section 112(j) 

regulation. 

This ICR supports the regulation to implement section 112(j) (40 CFR part 63, subpart B, 

§§63.50-56). It addresses the information collection burden (hours and costs) to industry

respondents subject to these provisions; State and Local agencies that review applications 

submitted under these provisions; and the EPA oversight review of a percentage of State/Local 
2

decisions. As discussed further below, only activities related to the regulatory requirement to 

submit permit applications are activities for which an estimate of burden need be calculated. 

This ICR includes about 149 major sources and 15,500 boilers at major sources (see 

Table 1) contained in the four source categories for which MACT standards have been vacated 

by the United States Court of Appeals for the District of Columbia Circuit. The average 

administrative cost per major source of these activities is estimated to be $3,148, and the average 

administrative cost per boiler of these activities is estimated to be $1,048. Total estimated

administrative costs may be up to $19,856,799 for all sources (including state and federal costs) 

in all four source categories over the next 3 years. 

Further, the burden estimate is conservative, because we assume 15,500 boilers are 

subject to section 112 and therefore covered by this ICR, based on the number of initial 

notifications received following promulgation of the boiler MACT. However, this assumption 

likely represents an overestimate of the number of such sources. EPA's major source boiler 

MACT was vacated by the DC Circuit Court of Appeals, along with a separate rule defining a 

“commercial or industrial solid waste incineration unit” for purposes of Section 129 of the Act 

(the definitional rule). NRDC V. EPA, 489 F.3d. 1250 (D.C. Cir. 2007). In the definitional rule 

case, the court held that Section 129’s directive to regulate “any facility which combusts any

solid waste material from commercial or industrial establishments” does not permit the exclusion 

of facilities that combust solid waste, but recover thermal energy for a useful purpose The court 

then concluded that the flaws in EPA’s definitional rule would necessitate revision of the major 

source boiler MACT rule as well, because the scope of facilities subject to the MACT would 

change. Therefore the court also vacated the boiler MACT. Once EPA revises both the 

definitional rule and the boiler MACT, it is likely that the number of sources subject to the boiler 

MACT will be smaller than those that would have been subject to the MACT the court vacated.

2. NEED FOR AND USE OF THE COLLECTION

(a) Need/Authority for the Collection

Section 112(j) of the Clean Air Act as amended in 1990 contains the need and authority

for this information collection. [42 U.S.C. 7401 (et. seq.) as amended by Public Law 101-549]

(b) Use/Users of the Data

The information collected in the permit applications will be used for the purposes of 

permit approval, compliance determination, and the selection of particular control technology on 

a case-by-case basis. The Federal or State administrator of the operating permits program will 

use the information for the case-by-case emission limit determinations. Because the information 
3

gathered is necessarily source-specific, the case-by-case determinations cannot be made without 

it.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Nonduplication

The information collection activities required under the section 112(j) regulation are not 

routinely collected elsewhere by EPA. However, in this situation, the permitting authority may

likely have collected much, if not all, of the information items previously in support of other 

applications in the course of implementing or preparing to implement the MACT standards that 

have been vacated. Most permitting authorities, though, will likely accept references to 

previously submitted information in lieu of significant duplication, in accordance with 

§63.53(b)(1). 

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

Since this is a reinstatement of a previously approved ICR, it will be treated as if it were a 

new collection. Comments will be solicited on the proposal amendments to the section 112(j) 

rule and this ICR.

3(c) Consultations

Several industry representatives commented on a previous version of the ICR (#1648.06), 

the availability of which was announced in the Federal Register on April 17, 2008 (73 Federal 

Register 20920). The relevant comments that were reviewed have been considered in this ICR 

(#1648.07). These commenters were Pillsbury, Winthrop Shaw, Pittman representing the 

American Forest & Paper Association, the American Petroleum Institute, the National Oilseed 

Processors Association, and the Synthetic Organic Chemical Manufacturers Association; the 

Alliance of Automobile Manufacturers; the Council of Industrial Boiler Owners; the National 

Association of Clean Air Agencies; the Brick Industry Association; the Vinyl Institute; and the 

Occidental Chemical Corporation (see Docket No. EPA-HQ-OAR-2002-0038). 

3(d) Effects of Less Frequent Collection

Each applicant would submit the required information only once (a permit application) 

over the term of this ICR. There is no less frequent collection.

3(e) General Guidelines

The recordkeeping and reporting requirements contained in the section 112(j) regulation 
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do not violate any of the Paperwork Reduction Act guidelines contained in 5 CFR 1320.6.

3(f) Confidentiality

Any information submitted to a permitting authority with a claim of confidentiality will 

be safeguarded according to that agency’s policies set forth prior to approval of the agency’s 

operating permit program by EPA. Any confidential information submitted to EPA will be 

safeguarded according to policies in 40 CFR, Chapter 1, Part 2, Subpart B -- Confidentiality of 

Business Information.

3(g) Sensitive Questions

This section is not applicable. This ICR does not contain any sensitive questions relating 

to sexual behavior or attitudes, religious beliefs, or other matters usually considered private.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS Codes

Respondents include owners/operators of major sources of HAP in the following source 

categories: polyvinyl chloride and copolymers production, brick and structural clay products 

manufacturing, clay ceramics manufacturing, and industrial, commercial, and institutional 

boilers and process heaters (Table 1). A major source is one that has the potential to emit 

considering controls, in the aggregate, 10 tons per year or more of any HAP or 25 tons per year 

or more of any combination of HAP. The boilers source category cuts across a wide variety of 

industries, including both manufacturing and nonmanufacturing sources. The North American 

Industry Classification System (NAICS) codes for polyvinyl chloride and copolymers 

production, brick and structural clay products manufacturing, and clay ceramics manufacturing 

facilities are 325211, 327121, 327122, and 327123; and the three-digit NAICS codes for 

industrial, commercial, and institutional boilers and process heaters are 211, 221, 316, 321, 322, 

324, 325, 326, 331, 332, 336, 339, 611 and 622. 

 

4(b) Information Requested

(i) Data items, including recordkeeping requirements 

Section 112(j) regulation does not contain recordkeeping requirements. However, we 

have included an estimate for burden associated with filing the permit applications and permits.

The section 112(j) regulation requires a title V permit application or revision. State and 

local agencies that develop the permit will review the information provided in the permit 

applications. EPA will provide oversight to the process.
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The permit application for a MACT determination requires the following information:

(1) The name and address (physical location) of the major source.

(2) A brief description of the major source and an identification of the relevant source 

category.

(3) An identification of the types of emission points belonging to the relevant source 

category.

(4) An identification of any affected sources for which a section 112(g) MACT 

determination has been made.

(5) For a new affected source, the anticipated date of startup of operation.

(6) Each emission point or group of emission points at the affected source which is part 

of a category or subcategory for which a permit application is required, and each of the 

hazardous air pollutants emitted at those emission points. When the Administrator has 

proposed a standard pursuant to section 112(d) of the Act for a category or subcategory, 

such information may be limited to those emission points and hazardous air pollutants 

which would be subject to control under the proposed standard.

(7) Any existing Federal, State, or local limitations or requirements governing emissions 

of hazardous air pollutants from those emission points which are part of a category or 

subcategory for which a permit application is required.

(8) For each identified emission point or group of affected emission points, an 

identification of control technology in place.

(9) Any additional emission data or other information specifically requested by the 

permitting authority.

For many sources the permitting authority already has much of this information, gathered 

through previous title V permit submittals. A source may work with its permitting authority to 

determine what additional or revised information is necessary for a complete application 

submittal.

(ii) Respondent Activities

Activities (see Tables 2a and 2b) that the owner or operator must perform include:

- Develop and submit permit applications 

- File and maintain the permit applications 
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- Utilize legal and consulting resources, as desired

- File and maintain permit.

5. THE INFORMATION COLLECTED -- AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

This section addresses the activities of State and Local agencies, as the permitting 

authority, and EPA, in an oversight capacity. The permitting authority, typically the State or 

Local air agency, will perform the following activities (see Tables 3a and 3b):

- Review permit applications and deny or approve them

- File and maintain permit applications

- Interact with EPA as appropriate

- File and maintain permit.

Acting in an oversight capacity, EPA will perform the following activities (see Tables 4a 

and 4b):

- Review permit applications

- Interact with the permitting authority

- File and maintain permit.

5(b) Collection Methodology and Management

The owners or operators of the sources affected by this regulation will have the 

responsibility of submitting permit applications to the permitting authority. It is the 

responsibility of the permitting authority to provide information necessary for EPA oversight 

review.

Qualified staff who work for the permitting authority will perform the permit application 

reviews and check the quality of data submitted by the applicant on a case-by-case basis. The 

permitting authority’s employees will handle confidential information submitted by the applicant 

according to the permitting authority’s confidential information handling procedures.

The section 112(j) regulation does not require the request of information through any 

type of survey.

5(c) Small Entity Flexibility
7

Minimizing the information collection burden for all sizes of organizations is a 

continuing effort on EPA’s part. EPA has reduced the information required by requiring only

basic information needed by the permitting authority to make a case-by-case MACT 

determination.

5(d) Collection Schedule

This ICR does not require surveys. Each source affected by the section 112(j) regulation 

is required to submit a permit application which the permitting authority must then review.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

This ICR requires the calculation of the amount of burden hours associated with each 

activity for each respondent. In the section 112(j) permitting process for major sources, each 

respondent must submit the permit application as specified in section 4(b)(i) of this Supporting 

Statement. Much of the information required in the permit application will have already been 

submitted to the permitting authority in previous permit submittals; we expect the burden to be 

relatively low for this activity.

For the section 112(j) regulation, burden for the respondents is administrative costs 

(preparing and submitting the permit applications). 

We estimate the burden associated with the preparation and submittal of permit 

applications to be about 35 hours for polyvinyl chloride and copolymers production, brick and 

structural clay products manufacturing, and clay ceramics manufacturing facilities (see Table 

2a); and about 11 hours for each industrial, commercial, and institutional boiler and process 

heater (see Table 2b).

We have separated the burden estimates for boilers from the other sources. Unlike the 

other sources, boilers consist of a single emission point and many facilities contain essentially 

identical boilers, making permit application preparation for each boiler much less burdensome 

than preparing a permit application for the other sources, which consist of various different 

emission points.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

Wage rates were based on May 2008 raw labor rates for the Manufacturing Sector (NAICS 

31 thru 33), loaded using an overhead factor of 110%, and indexed to June 2009 using the 
8

Employment Cost Index. The resulting rates are $121.08 for management personnel, $82.39 for 

technical personnel, and $31.41 for clerical personnel. These values were taken from the Bureau of 

Labor Statistics Occupational Employment Statistics Survey Web site 

(http://www.bls.gov/oes/2008/may/naics2_31-33.htm) and reflect the latest values available 

(May 2008). The Employment Cost Index is located at: 

http://www.bls.gov/news.release/eci.t02.htm. Tables 2 and 2a provide a breakdown of labor 

hours and associated costs per occurrence for each activity in each part of the application process 

for existing and new sources.

(ii) Estimating Capital and Operation and Maintenance (O&M) Costs

We do not expect sources to expend additional capital and O&M costs to gather 

information required by the permit applications. 

(iii) Annualizing Capital Costs

Not applicable.

6(c) Estimating State/Local Agency Burden and Cost

Similar to sections 6(a) and 6(b), the activities for State/Local agencies are divided into 

the activities that would take place for the application process as described in section 4(b)(i) of 

this Supporting Statement. Wage rates for State/Local employees were retrieved from the 

Bureau of Labor Statistics (http://www.bls.gov/news.release/pdf/ecec.pdf, “Table 4. Employer 

costs per hour worked for employee compensation and costs as a percent of total compensation: 

State and local government workers, by occupational and industry group, June 2009”) and are as 

follows: $33.02 per hour for management labor, $32.64 per hour for technical labor, and $16.80 

per hour for clerical labor. We added in the value of total benefits in BLS Table 4. We chose 20 

percent of the base rate as the percentage of salary that constitutes overhead. The addition of 

benefits and overhead to the hourly rate produces a pay rate that reflects the true cost to employ a 

State, Local, or Tribal agency worker. Following is a summary of the computed hourly wages 

for State, Local, and Tribal agency employees. 

Hourly Labor Rates for State, Local and Tribal Respondents

Labor Type Hourly Rate Benefits Overhead

(20 % Salary)

Adjusted Hourly 

Rate

Management $33.02 $15.65 $6.60 $55.27

Technical $32.64 $15.32 $6.53 $54.49

Clerical $16.80 $10.50 $3.36 $30.66

Tables 3a and 3b provide a breakdown of labor hours and associated costs for 
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State/Local/Tribal agencies. 

There are a total of 112 State/Local agencies that have a Title V permitting program, and 

these State/Local agencies would review the section 112(j) applications within the first year and 

issue permits within 27 months after promulgation of these amendments.

6(d) Estimating Agency Burden and Cost

Under the section 112(j) regulation, EPA would serve in an oversight capacity and audit 

approximately 10 percent of all applications processed by State/Local agencies. As 

recommended in the ICR Handbook, wage rates for EPA employees are based upon the Federal 

government pay scale. We calculated the hourly rates for EPA employees using information on 

annual salaries from the Internet site for the Office of Personnel Management. 

(http://www.opm.gov/oca/09tables/pdf/RUS.pdf; January 2009). We used the appropriate pay

grade levels for management, technical, and clerical personnel. We divided the annual pay rate 

by 2080, the amount of working hours during a calendar year, to get the hourly wage rate. We 

then multiplied this rate by 1.6 to produce a pay rate that reflects the true cost to the Federal 

government to employ a worker. The value of 1.6 incorporates the addition of benefits at 40 % 

of salary and the addition of overhead at 20% of salary to the hourly rate. Following is a 

summary of the computed wages for EPA personnel.

Hourly Labor Rates for EPA

Labor Type Pay 

Grade

Annual 

Salary

Hourly 

Rate

Benefits

(40 % Salary)

Overhead

(20 % Salary)

Adjusted 

Hourly Rate

Management GS-15 $111,760 $53.73 $21.49 $10.75 $85.97

Technical GS-12 $67,613 $32.51 $13.00 $6.50 $52.01

Clerical GS-6 $34,300 $16.49 $6.60 $3.30 $26.39

Tables 4a and 4b provide a breakdown in the amount of hours associated with each 

activity and the total burden hours and cost per occurrence.

6(e) Estimating the Respondent Universe

The estimated number of major sources subject to the section 112(j) regulation in the 

proposed ICR is based on latest estimates from the EPA rule writers for each of the affect source 

categories. 

After the vacatur of the boiler NESHAP, the Agency began collecting data from EPA 

regional offices and delegated state authorities to revise its estimate of boilers and process 

heaters that may be impacted under a revised standard. Since the last boiler and process heater 

data gathering effort, many sources have shut down, others have selected to operate with a limit on 
10

their HAP emissions in order to avoid being subject to the boiler and process heater NESHAP, and 

some units have switched out older solid fuel units for newer equipment due to increased insurance 

and maintenance costs. Therefore, the Agency will base its boiler respondent pool on a revised list 

of initial notifications, Title V permits, and state applicability lists. Since the proposal of this ICR, 

data from Alaska, Alabama, Colorado, Delaware, Florida, Georgia, Indiana, Illinois, Kentucky, 

Louisiana, Michigan, New Jersey, New York, North Carolina, Ohio, Tennessee, Utah, and 

Wisconsin has been compiled and reviewed, and the Agency estimates that 15,500 existing boilers 

will be subject to this ICR. The estimated number of potentially affected sources is shown in 

Table 1.

6(f) Bottom Line Burden Hours and Cost

(i) Respondent tally

Over the 3-year period of this ICR, the estimated average annual respondent burden 

(sources) and cost associated with the section 112(j) regulation are 63,863 hours and $5,573,129

respectively. State/Local agencies will experience 19,807 burden hours and $1,015,725. 

Approximately 2/3 of the burden will occur within the first hear after promulgation of the 

amendments, consisting of permit application submittal and initial review. Table 5 contains the 

total estimated burden and cost breakdown associated with the section 112(j) regulation. Table 6 

provides a summary of the estimated bottom line burden hours and costs associated with the 

section 112(j) regulation.

(ii) The Agency tally

Over the 3-year period of this ICR, the average annual Federal Government cost is 

$30,079 for 539 hours for the section 112(j) regulation. The bottom line Agency burden hours 

and costs presented in Table 5.

(iii) Variations in the annual bottom line

This section does not apply since no significant variation is anticipated.

6(g) Reasons for Change in Burden

We are requesting an increase in burden of 84,208 hours due to reinstatement of the 

previously approved collection. 

6(h) Burden Statement

This estimate includes all activities associated with the respondents or government 

agencies. Overall, the section 112(j) program will have the following average annual burden: 
11

63,863 hours and $5,573,129 for respondents; 19,807 hours and $1,015,725 for 

State/Local/Tribal agencies; and 539 hours and $30,079 for the EPA. Table 5 presents the 

annual burden for respondents, State/Local agencies, and the EPA over the next 3 years.

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 currently valid OMB control number. The OMB 

control numbers for EPA’s regulations in 40 CFR part 63 are listed in 40 CFR part 9.

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

burden estimates, and any suggestions for minimizing respondent burden, including through the 

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

Docket ID No. EPA-HQ-OAR-2009-0746, which is available for online viewing at 

http://www.regulations.gov, or in person viewing at the Air and Radiation Docket and 

Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The 

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

Air Docket is (202) 566-1742. An electronic version of the public docket is available at 

http://www.regulations.gov. This site can be used to submit or view public comments, access the 

index listing of the contents of the public docket, and to access those documents in the public 

docket that are available electronically. When in the system, select “search,” then key in one of 

the Docket ID Numbers identified above. 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 relevant Docket ID 

Number (EPA-HQ-OAR-2009-0746) in any correspondence. 

Part B of the Supporting Statement

This section is not applicable because statistical methods are not used in the data 
12

collection associated with the section 112(j) regulation.
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TABLES
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Table 1. Source Categories for which MACT Standards Have Been Vacated

Source Category Total estimated number of 

sources

Polyvinyl chloride and copolymers production (Part 63, Subpart J) 19

Brick and structural clay products manufacturing (Part 63, Subpart JJJJJ) 122

Clay ceramics manufacturing (Part 63, Subpart KKKKK) 8

Industrial, Commercial, and Institutional Boilers and Process Heaters (Part 63, Subpart 

DDDDD)

15,500

Total 15,649
15

 Table 2a. Summary of Activities, Labor Hours, and Administrative Costs for Respondents 

(polyvinyl chloride and copolymers production, brick and structural clay products 

manufacturing, and clay ceramics manufacturing)

Activity

Management Technical Clerical Total

Wage Rate ($/hr) $121.08 $82.39 $31.41

A. Read applicable regulations to 

determine source applicability 0.5 1.0 0.0 1.5

Cost of A per occurrence $60.54 $82.39 $0.00 $142.93

B. Collect information to required by

63.53(a) and (b)(2) 0.0 5.0 0.0 5.0

Cost of B per occurrence $0.00 $411.95 $0.00 $411.95

C. Process, compile, and review 

application for accuracy and 

appropriateness 2.0 12.0 2.0 16.0

Cost of C per occurrence $242.16 $988.68 $62.82 $1,293.66

D. Fulfill any state or local requirements as 

set forth by 63.53(b)(2)(iii) 1.0 4.0 0.0 5.0

Cost of D per occurrence $121.08 $329.56 $0.00 $450.64

E. Store, file, and maintain application 

information 0.5 1.0 1.0 2.5

Cost of E per occurrence $60.54 $82.39 $31.41 $174.34

F. Store, file, and maintain permit 0.5 1.0 1.0 2.5

Cost of F per occurrence $60.54 $82.39 $31.41 $174.34

G. Legal and consultant resources (1) 5.0

Cost of G per occurrence $500.00

Total Hours per Occurrence (hr/occ) 4.5 24.0 4.0 37.5

Total Cost per Occurrence ($/occ) $544.86 $1,977.36 $125.64 $3,147.86

Labor Hours per Occurrence (hr/occ)

(1) These are external consultations, assumed to be billed at $100/hr.
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 Table 2b. Summary of Activities, Labor Hours, and Administrative Costs for Respondents 

(industrial, commercial, and institutional boilers and process heaters)

Activity

Management Technical Clerical Total

Wage Rate ($/hr) $121.08 $82.39 $31.41

A. Read applicable regulations to 

determine source applicability 0.50 1.0 0.0 1.5

Cost of A per occurrence $60.54 $82.39 $0.00 $142.93

B. Collect information to required by 

63.53(a) and (b)(2) 0.0 1.0 0.0 1.0

Cost of B per occurrence $0.00 $82.39 $0.00 $82.39

C. Process, compile, and review 

application for accuracy and 

appropriatenes 0.5 3.0 0.5 4.0

Cost of C per occurrence $60.54 $247.17 $15.71 $323.42

D. Fulfill any state or local requirements as 

set forth by 63.53(b)(2)(iii) 0.25 1.0 0.0 1.25

Cost of D per occurrence $30.27 $82.39 $0.00 $112.66

E. Store, file, and maintain application 

information 0.25 0.25 0.25 0.75

Cost of E per occurrence $30.27 $20.60 $7.85 $58.72

F. Store, file, and maintain permit 0.33 0.33 0.33 1.0

Cost of F per occurrence $40.36 $27.46 $10.47 $78.29

G. Legal and consultant resources (1) 2.5

Cost of G per occurrence $250.00

Total Hours per Occurrence (hr/occ) 1.8 6.6 1.1 12.0

Total Cost per Occurrence ($/occ) $221.98 $542.40 $34.03 $1,048.41

Labor Hours per Occurrence (hr/occ)

(1) These are external consultations, assumed to be billed at $100/hr.
17

 Table 3a. Summary of Activities, Labor Hours, and Administrative Costs for S/L/T 

Agencies (polyvinyl chloride and copolymers production, brick and structural clay 

products manufacturing, and clay ceramics manufacturing facilities)

Activity

Management Technical Clerical Total

Wage Rate ($/hr) 55.27 54.49 30.66

A. Answer respondents questions about 

submitting applications 0.0 0.2 0.0 0.2

Cost of A per occurrence $0.00 $10.90 $0.00 $10.90

B. Review permit application for 

techincal completeness and file 0.1 5.0 0.1 5.2

Cost of B per occurrence $5.53 $272.45 $3.07 $281.04

C. Analyze requests for confidentiality

and provide protection 0.0 1.0 0.0 1.0

Cost of C per occurrence $0.00 $54.49 $0.00 $54.49

D. Approve or disapprove application 

and notify respondents of decision 0.5 2.0 1.0 3.5

Cost of D per occurrence $27.64 $108.98 $30.66 $167.28

E. Store, file, and maintain permit 0.5 0.5 1.0 2.0

Cost of E per occurrence $27.64 $27.25 $30.66 $85.54

F. Interaction with EPA 0.5 1.5 0.0 2.0

Cost of F per occurrence $27.64 $81.74 $0.00 $109.37

Total Hours per Occurrence (hr/occ) 1.6 10.2 2.1 13.9

Total Cost per Occurrence ($/occ) $88.43 $555.80 $64.39 $708.62

Labor Hours per Occurrence (hr/occ)
18

 Table 3b. Summary of Activities, Labor Hours, and Administrative Costs for S/L/T 

Agencies (industrial, commercial, and institutional boilers and process heaters)

Activity

Management Technical Clerical Total

Wage Rate ($/hr) 55.27 54.49 30.66

A. Answer respondents questions about 

submitting applications 0.0 0.1 0.0 0.1

Cost of A per occurrence $0.00 $5.45 $0.00 $5.45

B. Review permit applications for 

techincal completeness and file 0.1 0.3 0.1 0.5

Cost of B per occurrence $5.53 $16.35 $3.07 $24.94

C. Analyze requests for confidentiality 

and provide protection 0.0 0.5 0.0 0.5

Cost of C per occurrence $0.00 $27.25 $0.00 $27.25

D. Approve or disapprove application 

and notify respondents of decision 0.25 1.0 0.25 1.5

Cost of D per occurrence $13.82 $54.49 $7.67 $75.97

E. Store, file, and maintain permit 0.17 0.17 0.17 0.5

Cost of E per occurrence $9.21 $9.08 $5.11 $23.40

F. Interaction with EPA 0.1 0.5 0.0 0.6

Cost of F per occurrence $5.53 $27.25 $0.00 $32.77

Total Hours per Occurrence (hr/occ) 0.5 2.4 0.4 3.7

Total Cost per Occurrence ($/occ) $24.87 $130.78 $10.73 $189.78

Labor Hours per Occurrence (hr/occ)
19

 Table 4a. Summary of Activities, Labor Hours, and Administrative Costs for the EPA

(polyvinyl chloride and copolymers production, brick and structural clay products 

manufacturing, and clay ceramics manufacturing facilities)

Activity Management Technical Clerical Total

Wage Rate ($/hr) $85.97 $52.01 $26.39

A. Audit and review application 0.1 0.2 0.1 0.4

Cost of A per Occurrence $8.60 $10.40 $2.64 $21.64

B. Interact with the permitting authority 0.5 1.5 0.0 2.0

Cost of B per Occurrence $42.99 $78.02 $0.00 $121.00

C. Store, file, and maintain permit 0.5 0.5 1.0 2.0

Cost of C per Occurrence $42.99 $26.01 $26.39 $95.38

Total Hours per Occurrence (hr/occ) 1.1 2.2 1.1 4.4

Total Cost per Occurrence ($/occ) $94.57 $114.42 $29.03 $238.02

Labor Hours per Occurrence (hr/occ)
20

 Table 4b. Summary of Activities, Labor Hours, and Administrative Costs for the EPA

(industrial, commercial, and institutional boilers and process heaters)

Activity Management Technical Clerical Total

Wage Rate ($/hr) $85.97 $52.01 $26.39

A. Audit and review application 0.1 0.1 0.1 0.3

Cost of A per Occurrence $8.60 $5.20 $2.64 $16.44

B. Interact with the permitting authority 0.05 0.15 0.0 0.2

Cost of B per Occurrence $4.30 $7.80 $0.00 $12.10

C. Store, file, and maintain permit 0.17 0.17 0.2 0.5

Cost of C per Occurrence $14.33 $8.67 $4.40 $27.40

Total Hours per Occurrence (hr/occ) 0.3 0.4 0.3 1.0

Total Cost per Occurrence ($/occ) $27.22 $21.67 $7.04 $55.93

Labor Hours per Occurrence (hr/occ)
21

Table 5. Administrative Burden and Cost Estimates for Respondents, State and Local Agencies, and the EPA

Number of 

112(j) 

Occurrences

Total 

Respondent 

Burden Hours

Total Respondent 

Costs

Total 

State/Local 

Burden Hours

Total 

State/Local 

Costs

Total EPA 

Burden Hours 

(a)

Total EPA 

Costs (a)

Total Burden 

Hours

112(j) 

Administrative 

Costs

(hr) (hr) (hr) (hr)

Polyvinyl 

Chloride and 

Copolymers; 

Brick and Clay; 

and Ceramics 

Manufacturing 

Facilities 149 5,588 $469,031 2,071 $105,584 66 $3,546 7,724 $578,162

Boilers 15,500 186,000 $16,250,355 57,350 $2,941,590 1,550 $86,692 244,900 $19,278,637

3- Year Total 15,649 191,588 $16,719,386 59,421 $3,047,174 1,616 $90,238 252,624 $19,856,799

Annual Average 5,216 63,863 $5,573,129 19,807 $1,015,725 539 $30,079 84,208 $6,618,933

(a) EPA only review 10% of permit applications.
22

Table 6. Bottom Line Burden and Cost Estimate for the Section 112(j) Program

Number of 

Respondents (a)

Total Hours 

Requested Total Costs

(hr)

3-Year Total 15,761 251,009 $19,766,560

Annual Average 5,254 83,670 $6,588,853

(a) Number of Respondents consists of all existing sources and State and local agencies 

affected by the section 112(j) program