**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal)**  **1. Identification of the Information Collection 1(a) Title of the Information Collection**  N ESHAP for Semiconductor Manufacturing (40 CFR Part 63, S ubpart BBBBB) (Renewal), EPA I CR Number 2042.06 , OMB Control Number 2060

- 0519. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Semiconductor Manufacturing were proposed on May 8, 2002 , promulgated on May 22, 2003 , and amended on July

22, 2008

. These regulations apply to each new, reconstructed, or existing affected major source that emits or has the potential to emit, considering controls, in the aggregate, any single hazardous air pollutants (HAP) at a rate of 10 tons per year (tp y) or more or any combination of HAP at a rate of 25 tpy or more. Under the EPA’s “Once In Alway s In” p olicy (May 16, 1995 memorandum from John S. Seitz, director, O ffice of Air Quality Planning and Standards, titled “Potential to Emit for MACT Standards

– guidance on Timing Issues”) , a facility would be considered a major source if it was a major source on the compliance date of the relevant MACT standard

-- even if i t subsequently had a potential to emit that was below the regulatory

levels. The semiconductor NESHAP, unlike some other NESHAPs, does not have a provision for EPA to re

- evaluate the applicability of the se standard s
. Semiconductor manufacturing process units are used to manufacture p

- ty pe and n - ty pe semiconductors and active solid

- state devices from a wafer substrate, including research and development activities integrated into a semiconductor manufacturing process unit. A semiconduct or manufacturing process unit includes the equipment assembled and connected by ductwork or hard

- piping , including: furnaces and associated unit operations; associated wet and dry work benches; associated recovery devices; feed, intermediate, and product s torage tanks; product transfer racks and connected ducts and piping; pumps, compressors, agitators, pressure - relief devices, sampling connecting sy stems, open

- ended valves or lines, valves, connectors, and instrumentation sy stems; and control devices. 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 BBBBB. In general, all NESHAP standards require initial notifications , 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 sy stem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Any owner/operator subject to the provisions of this part shall maintain a file of these2

measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are sent to the deleg ated state or local authority

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

. S

. Environmental Protection Agency (EPA) regional office. The semiconductor facilities in the United States are owned and operated by the semiconductor manufacturing industry ( aka: the “Affected Public”). While some semiconductor facilities could be owned by either state, or local, or the Federal government , the existing major source facility

subject to this regulation is a privately

- owned, for

- profit businesses. The

“burden ” to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal) . The Federal Government “burden ” is attributed entirel y to work performed b y either F ederal emplo ye es or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal)

. Based on our consultations with industry representatives, there is an average of one affected facility at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site). Over the next three ye ars, we estimate there are 127 facilities, with either no new or reconstructed facilities becoming subject to the se standard s
. Of the 127 facilities, only one is considered a major source and this is solely due to the fact that this small factory was once under common o wnership with a larger business park complex that is a major source. The 126 other non - major sources only

read the rule requirements for the first year and have no additional burden during this I CR renewal period. The Office of Management and Budget (OMB) approved the currentl y active I CR 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 maintai n 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 (in3 accordance with such procedures or methods, at such locations, at such intervals, duri ng such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certification s in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, HAP emissions from semiconductor manufacturing facilities 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 BBBBB. **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 w ere promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standard s . Continuous emission monitors are used to ensure compliance with the se standard s at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in 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 properl y installed and operated , leaks are being detected and repaired , and the standard are being met. The performance test may also be observed. The required semiannual reports are used to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance d eterminations. **3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart BBBBB.

**3(a) Non**
**- duplication** 4

If the subject standards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Pub lic Notice Required Prior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR was published in the Federal Register ( 79 FR 30117) on May 27, 2014

. 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 the 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 standard, is Enforcement and Compliance History Online (ECHO), which is operated and maintained by EPA's Office of Compliance. ECHO is EPA’s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our consultations with the Agency ’s internal industry experts. Industry trade associations and other interested parties were provided an opportunity to comment on the burden associated with the standard as it was being developed. In developing this I CR, we contacted both the Semiconductor Industry Association , at (202) 446

- 1700 , and the Fab Owners Association , at (408) 725

- 7127. EPA received comments from the subject major fa cility and incorporated the comments into this ICR. The subject facility provided estimate for an additional O&M cost item, but felt that the respondent burden and cost estimates associated with the NESHAP and presented in Table 1 of this I CR are conservative. 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. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likel y. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations5

promulgated b y 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

- ye ar records retention requirement is consistent with the Part 70 permit program and the five

- ye ar statute o f limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non

- compliance and to determine the appropriate level of enforcement action. EPA has fo und that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **3(f) Confidentiality** Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 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 recordkeeping requirements in the standard do not include sensitive question s. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are semiconductor manufacturing facilities . The United States Standard Industrial Classification ( SI C ) code for the respondents affected b y the standards is SI C 3674 , which corresponds to the North American Industry Classification Sy stem (NAICS ) 334413 for Semiconductor and Related Device Manufacturing

. **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Semiconductor Manufacturing ( 40 CFR Part 63, Subpart BBBBB )

. A source must make the following reports:6
**Notification s**  Initial notification 63.9(b)(2)

- (3), 63.7189(b)

- (c) Notification of performance test 63.7(b)

- (c), 63.9(e), 63.7189(d) Notification of compliance status 63.9(h), 63.10(d)(2), 63.7189(e) Performance evaluation reports 63.8(e)(5), 63.7191(a)(e) Startup, shutdown, malfunction 63.6(e)(3), 63.7190(a)(2) Semiannual summary

report 63.7190 A source must keep the following records: **Recordkeeping** Initial notification or notification of compliance status 63.10(b)(2)(xiv), 63.7191(a)(1) Record of startup, shutdown, malfunctions 63.6(e)(3), 63.7191(a)(2) Records of performance tests and performance evaluations 63.10(b)(2)(viii), 63.7191(a)(3) Records are required to be retained for five years 63.10(b)(2) Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordke eping at a plant site.

**(ii) Respondent Activities Respondent Activities** 7 **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, Reference Method 320, 26, 26A test s , and repeat performance tests if necessary

. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems 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, analy sis, 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, anal yz e, and maintain data in Integrated Compliance Information System (I CI S) and ECHO. **5(b) Collection Methodology and Management**8

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are p roperl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comp ly with the emission standard and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance det erminations

. In formation contained in the reports is reported b y state and local governments in the IC IS 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 IC IS for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordke eping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown in below Table 1: Annual Respondent Burden and Cost

– N ESHAP for Semiconductor Manufacturing (40 CFR Part 63, S ubpart BBBBB) (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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, spec ific tasks and major assumptions have been identified. Responses to this information collection are mandatory

.9

The Agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently

- valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 41 hours ( Total Labor Hours from Table 1 below ). T hese h ours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program , the previousl y approved ICR, and any comments received. The one facility

that is a major source emph asized that the cost estimates in Table 1 are only the reporting and recordkeeping burden associated with this NESHAP, which is a fraction of the facility

compliance costs under the Clean Air Act . T he Table 1 burden is relativel y low because the NESHAP “pi ggy back” on the other compliance costs. The greater compliance costs relate to the time involved to ensure that emissions are within the permit limits whenever any change is made to the manufacturing process th at might affect HAP emissions. The semicond uctor fabrication process is complex, involving dozens of steps, and any changes to the process

– such as changing a photoresist or moving a chemical to a different tool

– requires extensive calculations to determine if a permit modification is required. In those cases where a permit modification is required, the preparation of the submission is both costly and takes about month to process with state regulatory authorities. Like the other 126 facilities in the semiconductor industry , the one facility th at is a considered a major source has a potential to emit below the NESHAP regulatory levels of a rate of 10 tons per ye ar of any single hazardous air pollutants (HAP) and below at a rate of 25 tons per year for any combination of HAP. This facility is co nsidered a major source solel y due to the fact that it was once under common ownership with a larger business park complex that is a major source. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $ 129

. 93 ($ 61.87 + 110%) Technical $ 103

. 97 ($ 49.51 + 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 b y 110 percent to account for the benefit packages available to those employed by private industry

.10
**(ii) Estimating Capital/Startup and Operation and Main tenance Costs**  The ty pe of industry

costs associated with the information collection activities in the subject standard 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 a nd Maintenance (O&M) Costs**  **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 1 (F)

Number of Respondents with O&M (G)

Total O&M, (E X F) 2

N/A N/A N/A N/A $ 5 50 1 $ 5 50 Total $ 5 50
1 We assume annual photocopy and postage cost will be $50 , and the consulting fees will be $500

. 2 Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. The total capital/startup costs for this I CR are $ 0. This is the total o f column D in the above table. The total operation and maintenance ( O&M) costs for this I CR are $ 5 5 0

. This is the total of column G. The average annual cost for capital/startup and /or operation and maintenance costs to industry over the next three years of the IC R is estimated to be $ 5 5 0

. These are recordkeeping costs. **6(c) Esti mating Agency Burden and Cost**  The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the res pondents, 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 $ 1,570

. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% )11 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 5 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
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Co st

– NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately one existing major source will be subject to the standard. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, is one per year. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR : **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w 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 1 0 0 1
2 0 1 0 0 1
3 0 1 0 0 1 Average 0 1 0 0 1 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 ye ar period of this ICR is one
. The total number of annual responses per ye ar is calculated using the following table:
**Total Annual Responses**12 **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

Initial notification 0 1 0 0 Notification of performance evaluation 0 1 0 0 Notification of compliance status 0 1 0 0 Performance evaluation reports 0 1 0 0 Startup, shutdown, malfunction report 0 4 0 0 Semiannual summary report 1 2 0 2 Total 2 The number of Total Annual Responses is 2

. The total annual labor costs are $ 4,160

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal)

. **6(e) Bottom Line Burden Hours and Cost Tables** The detailed bo ttom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 , respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 41 hours at a cost of $4,160

. Details regarding these estimates may

be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal)

. We assume that burdens for managerial tasks take 5% of the time required for technical t asks because the ty

pical 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 ty pical duties of clerical staff are to proofread the reports, make copies and mai ntain records. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 21 hours per response

. The total annual capital/startup and O&M costs to the regulated entity are $5 5 0

. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance13

(O&M) Costs. **(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 35 labor hours at a cost of $1,570 . See below Table 2: Average Annual EPA Burden and Cost

– NESHAP for Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB) (Renewal)

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

pical 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 ty pical duties of clerical staff are to proofread the reports, make copies and maintain records. **6(f) Reasons f**

**or Change in Burden** There is a small increase in the respondent burden from the most recently approved ICR due to an update in assumption and an adjustment in labor rates

. In this ICR, we assume the existing major source will read and re

- familiar with th e rule requirement annually . We have also updated all burden calculations using the latest labor rates from the Bureau of Labor Statistics. There is also a small increase in the O&M cost. Based on comments received from industry consultation, the major source facility subject to this regulation incurs an annual consulting fee. We have added this fee to the annual O&M cost. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 21 hours per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclo se or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 20 1 4

- 0089

. An electronic version of the public docket is available at http://www.regulations.gov/ , which may be used to obtain a copy

of the draft14

collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those do cuments in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docke t and Information Center in the EPA Docket Center (EPA/DC), WJC 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 holiday s. T he 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 comments to the Office of In formation 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 14

- 0089 and OMB Control Number 2060

- 0519 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 Semiconductor Manufacturing (40 CFR**  **Part 63, Subpart BBBBB) (Renewal** **)**

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **- hours**  **per year (E=CxD**  **) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per**  **year (Ex0.1)**  **(H)**

**Total Cost**  **Per year b**  1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Familiariz ation with rule requirement 4 1 4 1 4 0.2 0.4 $463 B. Process/review information d 4 2 8 1 8 0.4 0.8 $925.16 C. Write Report Initial notification c 2 1 2 0 0 0 0 $0 Notification of performance evaluation
c 2 1 2 0 0 0 0 $0 Notification of compliance status c 2 1 2 0 0 0 0 $0 Performance evaluation reports c 2 1 2 0 0 0 0 $0 Startup, shutdown, malfunction (SSM) report e 1 4 4 0 0 0 0 $0 Semiannual summary report f 4 2 8 1 8 0.4 0.8 $925.16 **Subtotal for Reporting Requirements 23**  **$2,312.91** 4. Recordkeeping requirements A. Familiarization with rule requirement See 3A B. Plan activities 8 1 8 1 8 0.4 0.8 $925.16 C. Implement activities Control devices16

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(C=AxB) (D)** 

**Respondents per year**  **a (E)** 

**Technical person**  **- hours**  **per year (E=CxD**  **) (F)** 

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per**  **year (Ex0.1)**  **(H)**

**Total Cost**  **Per year b**  Design analysis 15 1 15 0 0 0 0 $0 Performance evaluation 40 1 40 0 0 0 0 $0 Equipment inspection 1 52 52 0 0 0 0 $0 Monitoring activities 1 52 52 0 0 0 0 $0 Maintenance 2 52 104 0 0 0 0 $0 D. Develop record system Develop SSM plan 8 1 8 0 0 0 0 $0 Control equipment/maintenance plan 12 1 12 0 0 0 0 $0 E. Time to enter information Control equipment testing 1 1 1 0 0 0 0 $0 Control equipment inspection 0.5 52 26 0 0 0 0 $0 Control equipment monitoring 0.5 52 26 0 0 0 0 $0 F. Time to train personnel Control equipment inspection and Monitoring 40 1 40 0 0 0 0 $0 G. Store, file and maintain records g 2 2 4 1 4 0.2 0.4 $462.58 H. Retrieve records/reports h 2 2 4 1 4 0.2 0.4 $462.58 **Subtotal for Recordkeeping Requirements 1**  **9 $1,850.33** 
**TOTAL LABOR BURDEN AND COST i**  **41 $4,160**  **Capital and O&M Cost (see Section 6(b)(iii)): i**  **$ 5**  **50 TOTAL COST:**  **i , j**  **$4, 7**  **10**17

**Assu mptions:**  a We have assumed that there is approximately 127 existing sources currently subject to this rule (one major source and 126 non

- major sources). There will be no additional new source that will become subject to the rule over the three

- year period of this ICR. b This ICR uses the following labor rates: $129.93 per hour for Managerial labor; $103.97 per hour for Technical labor, and $5 1.79 per hour for Clerical labor. 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 p ercent to account for the benefit packages available to those employed by private industry.

c This is a one

- time only activity. d We have assumed that it will take the respondent 4 hours twice a year to process and review information.

e We have assumed that it will take each respondent 1 hour four times a year to w rite SSM report. f We have assumed that it will take the respondent 4 hours two times a year to complete the semiannual report. g We have assumed that the respondent will take 2 hours two times per year to store, file and maintain records. h We have assumed that the r espondent will take 2 hours two times per year to retrieve records/reports. i Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding. j The labor and cost estimates are only for activities unique to the reporting and record keeping requirements and do not include other compliance costs under the Clean Air Act which provide data for the reporting and record keeping costs.18

**Table 2: Average Annual EPA Burden and Cost**

**– NESHAP for Semiconductor Manufacturing (40 CFR P**  **art 63, Subpart BBBBB) (Renewal)** 

**Activity (A)**  **(B) (C)**  **(D) (E)**  **(F) (G)**  **(H) EPA person** 
**** **hours per occurrence**  **No. of**

**occurrences per plant per**  **year EPA** 

**person**   ** hours per** **plant per year**  **Plants**

**per year**  **a Technical** 

**person**   ** hours per** **year Managem**  **ent**

**person -**  **hours per year**  **Clerical**

**person**   ** hours** **per year Cost, $**  **b**

**(C=AxB) (E=CxD)**  **(Ex0.05) (Ex0.1)**  Revie w initial notification reports 8 1 8 0 0 0 0 $0 Revie w notification of compliance status 10 1 10 0 0 0 0 $0 Revie w semiannual summary reports c 15 2 30 1 30 1.5 3 $1,570.20 Revie w notification of performance test d 4 1 4 0 0 0 0 $0 Attend initial performance tests 120 1 120 0 0 0 0 $0 Revie w test results e 10 1 10 0 0 0 0 $0 **TOTAL ANNUAL BURDEN AND COST f**  **35 $1,570** 

**Assu mptions:**  a We have assumed that there is approximately one existing sources currently subject to this rule. There will be no additional ne w source that will become subject to the rule each year over the three

- year period of this ICR. b This cost is based on the foll owing labor rates w hich incorporate a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for Managerial (GS

- 13, Step 5, $39.81 x 1.6), $46.67 for Technical (GS

- 12, Step 1, $29.17 x 1.6), and $25.25 Clerical (GS

- 6, Step 3 , $15.78 x 1.6). These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.
c We have assumed that the respondent will take 15 hours two times a year to review the semiannual summary reports. d We have assumed that it will take each respondent 4 hours one time a year to review notification of performance tests.

e We have assumed that it will take each respondent 10 hours one time a year to review test results. f Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.