## Information Collection Request for Requirements for Control

Technology Determinations from Major Sources in Accordance

with Clean Air Act Section 112(j)

Supporting Statement1



## PART A OF THE SUPPORTING STATEMENT
1. IDENTIFICATI ON OF THE INFORMATION COLLECTION (a) Title and Number of the Information Collection ICR: In formation 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 I CR # 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 p ollutants (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 ye ar [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 source s 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

- by

case 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 (Poly vinyl Chloride and Copoly mers Production (“PVC”), Brick and Structural Clay Products Manufacturing ("Brick"), Clay Ceramics Manufacturing (“Clay Ceramics”), and the Industri al, Commercial and Institutional Boilers and Process Heaters (“Boilers”)) have re

- established the need for appl yi ng the rule implementing section 112(j) of the CAA. EPA is proposing revisions to the section 112(j) rule to clarify

the application of sectio n 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 I CR 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/Local2

decisions. As discussed further below, only activities related to the regulatory requirement to submit permit applications are activities fo r which an estimate of burden need be calculated. This I CR 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 $ 1 9 , 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 sectio n 112 and therefore covered b y this I CR, 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 b y 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 wa ste, 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 chan ge. 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 amen ded by Public L aw 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 information3

gathered is necessarily

source - specific, the case

- by

- case determinations cann ot 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. Mo st 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 I CR, 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 I CR. 3(c) Consultations Several industry

representatives commented on a p revious version of the IC R (#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 I CR ( #1648.07 )

. These commenters w ere Pillsbury , Winthrop Shaw, Pittman representing the American Forest & Paper Association, the American Petroleum Institute, the National Oilseed Processors Association, and the Sy nthetic Organic Chemical Manufacturers Association; the Alliance of Automob ile 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) regulation4

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. An y confidential information submitted to EPA will be safeguarded according to policies in 40 CFR, Chapter 1, Part 2, Subpart B

-- Confide ntiality of Business Information. 3(g) Sensitive Questions This section is not applicable. This I CR does not contain any sensitive questions relating to sexual behavior or attitudes, religious beliefs, or other matters usuall y 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: pol yvin ylchloride and copol ym ers production, brick and structural clay product s 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 Sy stem (NAICS) codes f or poly vinyl chloride and copoly mers 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 institutio nal 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 do es not contain recordkeepin g 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 perm it will review the information provided in the permit applications. EPA will provide oversight to the process.5

The permit application for a MACT determination requires the following information: (1) The name and address (phy sical 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 ty pes 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 l imited to those emission points and hazardous air pollutants which would be subject to control under the proposed standard. (7) An y existing Federal, State, or local limitations or requirements governing emissions of hazardous air pollutants from those emi ssion 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) An y additional emission data or other information specificall y requested by the permitting authority. For man y 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 applications6

- 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 Table s 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 Tab les 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 th is regulation will have the responsibili ty

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 perm it 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 ty pe of survey

. 5(c) Small Entity Flexibility7

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 I CR does not require survey s. E ach 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 I CR requires th e 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 Supportin g 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 relativel y low for this activity

. For the section 112(j) regul ation , 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 pol yvinyl chloride and cop ol ym ers production, brick and structural clay

products manufacturing, and clay ceramics manufacturing facilities (see Table 2a); and about 1 1 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 essentiall y 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 Manufactu ring Sector (NAICS 31 thru 33), loaded using an overhead factor of 110%, and indexed to June 2009 using the8

Employ ment 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 Employ ment Statistics Survey

Web site (http://www.bls.gov/oes/2008/may /naics2_31

- 33.htm) and reflect the latest values available (May 2008). The Employ

ment 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 re quired b y 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/L ocal agencies are divided into the activities that w ould take place for the application process as described in section 4(b)(i) of this Supporting Statement. Wage rates for State/Local emplo yees were retrieved from the Bureau of Labor Statistics (http://www.bls.gov/news.release/pdf/ecec.pdf , “ Table 4. Emplo yer costs per hour worked for employee compensation and costs as a percent of total compensation: State and local government workers, b y 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 cons titutes overhead. The addition of benefits and overhead to the hourly rate produces a pay

rate that reflects the true cost to employ a State, L ocal, 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 Managem ent $33.02 $15.65 $6.60 $55.27 Technical $32.64 $15.32 $6.53 $54.49 Clerical $16.80 $1 0.50 $3.36 $30.66 Tables 3a and 3b provide a breakdown of labor hours and associated costs for9

State/L ocal/Tribal agencies. There are a total of 112 State/L ocal agencies that have a Title V permitting program, and these State/L ocal agencies would re view 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 IC R Handbook, wage rates for EPA employees are based upon the Federal government pay

scale. We calculated the hourly rates for EPA employees us ing 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 l evels for management, technical, and clerical personnel. We divided the annual pay rate by 2080, the amount of working hours during a calendar ye ar, 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 hourl y 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 Managem ent 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 on10

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 cos ts. 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, In diana, Illinois, Kentucky, Lo uisiana, 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

- ye ar period of this I CR, the estimated average annual respondent burden (sources) and cost associated with the se ction 11 2(j) regulation are 63,863 hours and $ 5,573,129 respectivel y. 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 contain s the total estimated burden and cost breakdown associated with the section 112(j) regulation. Table 6 provide s a summary

of the estimated bottom line burden hours and costs associated with th e section 112(j) regulation. (ii) The Agency tally Over the 3

- ye ar period of this I CR , the average annual Federal Government cost is $ 30 , 079 for 539 hours for the se ction 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; 1 9 , 807 hours and $ 1,015,725 for State/L ocal/Tribal agencies; and 539 hours and $ 30 , 079 for the EPA. Table 5 present s the annual burden for respondents, State/L ocal agencies, and the EPA over the next 3 years. Burden means the t otal time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize techno logy and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with an y previously

applicable instructions and req uirements; 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 perso n 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 in formation 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 I CR under Docket ID No. EPA

- HQ

- OAR

- 200 9

- 0746 , which is available for online viewing at http://www.regulations.gov , or in person viewing at the Air and Radiation Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 130 1 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 holiday s. 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 sy stem, select “search,” then key in one of the Docket ID Numbers identified above. Also, you can send comments to the O ffice of In formation and Regulatory Affairs, Office of Management and Budget, 725 17 th Street, NW, Washington, DC 20503, Attention Desk Officer for EPA. Please include the relevant Docket ID Number ( EPA

- HQ

- OAR

- 2009

- 0746 ) in an y correspondence.



## Part B of the Supporting Statement This section is not applicable because statistical methods are not used in the data12

collection associated with the section 112(j) regulation.13 

### TABLES14

Table 1. Source Categories for whi ch M AC T 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 15,64915

Table 2a. Summary of A ctivities, Labor Hours, and A dministrative Costs for Respondents (polyvinyl chloride and copolymers production, brick and structural clay products manufacturing, and clay ceramics manufacturing) Ac tivity Ma nagement 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 requirem ents 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 m aintain 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 m aintain perm it 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 $1 00/hr.16

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

(industrial, commercial, and institutional boilers and process heaters) Ac tivity 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 perm it 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 Ag encies (polyvinyl chloride and copolymers production, brick and structural clay products manufacturing, and clay ceramics manufacturing facilities) Ac tivity Ma nagement 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 perm it 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. Analy ze 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

T able 3b. Summary of Activities, Labor Hours, and Administrative Costs for S/L/T Ag encies (industrial, commercial, and institutional boilers and process heaters)

Ac tivity 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 com pleteness 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)
Ac tivity Ma nagement 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 A ctivities, Labor Hours, and A dministrative Costs for the EPA

(industrial, commercial, and institutional boilers and process heaters)
Ac tivity Ma nagement Te chnical 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 perm itting 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 onl y 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 An nual A

verage 5,254 83,670 $6,588,853 (a) Number of Respondents consists of all existing sources and State and local agencies affected b y the section 112(j) program