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

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

EPA ICR 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 (tpy) or more 

or any combination of HAP at a rate of 25 tpy or more. Under the EPA’s “Once In Always In” 

policy (May 16, 1995 memorandum from John S. Seitz, director, Office 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 it 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 these standards. 

Semiconductor manufacturing process units are used to manufacture p-type and 

n-type semiconductors and active solid-state devices from a wafer substrate, including 

research and development activities integrated into a semiconductor manufacturing process unit. 

A semiconductor 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 storage 

tanks; product transfer racks and connected ducts and piping; pumps, compressors, agitators, 

pressure-relief devices, sampling connecting systems, open-ended valves or lines, valves, 

connectors, and instrumentation systems; 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 system is 

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

and are required of all affected facilities subject to NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these 
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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 delegated state or local authority. 

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

Environmental Protection Agency (EPA) regional office.

The 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 entirely to work performed by either 

Federal employees 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 years, we estimate there are 127 facilities, with either no new or 

reconstructed facilities becoming subject to these standards. 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 ownership 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 ICR renewal period.

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

without any “Terms of Clearance.” 

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

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

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

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

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

of this Act to: 

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

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

such audit procedures, or methods; (D) sample such emissions (in 
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accordance with such procedures or methods, at such locations, at 

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

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

equipment parameters, production variables or other indirect data 

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

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

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

reasonably require.

In the Administrator's judgment, HAP emissions from 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 these standards ensure compliance with 

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

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

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

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

ensure compliance with these standards at all times. During the performance test a record of the 

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

determine compliance in place of a continuous emission monitor.

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

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

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

installed and operated, leaks are being detected and repaired, and the 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 

determinations.

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

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

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

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

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.

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

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

in the Federal Register (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 industry 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 ICR, 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 

facility 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 ICR 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 frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

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

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

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

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

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

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

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

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

nonexistence of essential records.

3(f) Confidentiality

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

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

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

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

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

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are semiconductor 

manufacturing facilities. The United States Standard Industrial Classification (SIC) code for the 

respondents affected by the standards is SIC 3674, which corresponds to the North American 

Industry Classification System (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 by the NESHAP for 

Semiconductor Manufacturing (40 CFR Part 63, Subpart BBBBB). 

A source must make the following reports:
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Notifications

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 recordkeeping at 

a plant site. 

(ii) Respondent Activities

Respondent Activities
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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 tests, 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 

systems for the purpose of collecting, validating, and verifying information.

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

maintaining information.

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

providing information.

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

Transmit, or otherwise disclose the information.

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

Information Management

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information:

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) and 

ECHO. 

5(b) Collection Methodology and Management
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Following notification of startup, the reviewing authority could inspect the source to 

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

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

with the emission standard 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 

determinations.

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

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

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

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

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

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

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

years.

5(c) Small Entity Flexibility

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 types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

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

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

Manufacturing (40 CFR Part 63, Subpart 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 ICR. The 

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

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

major assumptions have been identified. Responses to this information collection are mandatory.
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The Agency may not conduct or sponsor, and a person is not required to respond to, a 

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

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 41 hours (Total Labor Hours from Table 1 below). 

These hours are based on Agency studies and background documents from the development of 

the regulation, Agency knowledge and experience with the NESHAP program, the previously 

approved ICR, and any comments received.

The one facility that is a major source emphasized 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. The Table 1 burden is relatively low 

because the NESHAP “piggyback” 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 that might affect HAP emissions. The 

semiconductor 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 that is a 

considered a major source has a potential to emit below the NESHAP regulatory levels of a rate 

of 10 tons per year 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 considered a major source solely 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 ICR uses the following labor rates: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

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

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

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

the benefit packages available to those employed by private industry.
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(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type 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 and 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 $550 1 $550

Total $550

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 ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $550. 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 ICR is estimated to be $550. These are recordkeeping 

costs. 

6(c) Estimating Agency Burden and Cost

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

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

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

emissions, and the publication and distribution of collected information. 

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

$1,570. 

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

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 
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Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

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

These rates are from the Office of Personnel Management (OPM), 2015 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 Cost – 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 ICR, on average over the next three years, approximately

one existing major source will be subject to the standard. It is estimated that no additional 

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

in the table below, is one per year. 

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

years covered by this ICR: 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1

0 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. 

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

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

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

Total Annual Responses
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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 bottom line burden hours and cost calculations for the respondents and the 

Agency are shown in Tables 1 and 2, respectively, 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 

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

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

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

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

information is estimated to average 21 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $550. The cost 

calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 
13

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

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

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

6(f) Reasons for Change in Burden

There is 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 the 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 by persons to generate, maintain, retain, or disclose or provide information 

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

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

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

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

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

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

the information.

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

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

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

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

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

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

Docket ID Number EPA-HQ-OECA-2014-0089. An electronic version of the public docket is 

available at http://www.regulations.gov/, which may be used to obtain a copy of the draft 
14

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

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

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

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

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

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

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

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

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

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

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

Number EPA-HQ-OECA-2014-0089 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)

Management 

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. Familiarization 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 e1 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 devices
16

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)

Management 

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 

19

$1,850.33

TOTAL LABOR BURDEN AND COST i41 $4,160 

Capital and O&M Cost (see Section 6(b)(iii)): i$550

TOTAL COST: i, j $4,710 
17

Assumptions:

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 $51.79

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 percent 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 write 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 respondent 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 Part 63, Subpart 

BBBBB) (Renewal)

Activity

(A) (B) (C) (D) (E) (F) (G) (H)

EPA personhours per 

occurrence

No. of 

occurrences 

per plant per 

year

EPA 

personhours per 

plant per 

year

Plants 

per 

year 

a

Technical 

personhours per 

year

Management 

person-hours 

per year

Clerical 

personhours 

per year

Cost, $ b

(C=AxB) (E=CxD) (Ex0.05) (Ex0.1)

Review initial notification reports 8 1 8 0 0 0 0 $0 

Review notification of compliance status 10 1 10 0 0 0 0 $0 

Review semiannual summary reports c

15 2 30 1 30 1.5 3 $1,570.20 

Review 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 

Review test results e

10 1 10 0 0 0 0 $0 

TOTAL ANNUAL BURDEN AND COST f35 $1,570 

Assumptions:

a

 We have assumed that there is approximately one existing sources currently subject to this rule. There will be no additional new 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 following labor rates which 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.