1969ss07

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (Renewal), EPA ICR Number 1969.07, OMB Control Number 2060-0533.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) were proposed on April 4, 2002, and promulgated on July 14, 2006. These regulations apply to both existing facilities and new facilities that manufacture a miscellaneous organic chemical and that are located at, or are part of, major sources of hazardous air pollutant (HAP) emissions. New facilities include those that commenced construction, modification or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart FFFF.

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 containing these documents, and retain the file for at least five years following the generation date of such maintenance reports and records. All reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.

The ‘burden’ to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (Renewal). The Federal Government’s ‘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 Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (Renewal). There are approximately 201 miscellaneous organic chemical manufacturing facilities, which are owned and operated by the miscellaneous organic chemical manufacturing industry. None of the 201 facilities in the United States are owned by either state, local, tribal or the Federal government. They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond to EPA inquiries.

Based on our consultations with industry representatives, there are an average of 201 affected facilities at each plant site and each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 201 respondents per year will be subject to these standards, and 1 additional respondent per year will become subject to these same standards. This estimate is based on the Agency’s evaluation of the source category for the rule’s risk and technology review.

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 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 miscellaneous organic chemical manufacturing either cause or contribute to air pollution that may reasonably be anticipated to endanger the public health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 63, Subpart FFFF.

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 the standard at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to 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 that these same standards 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 FFFF.

3(a) Non-duplication

If the subject standard(s) 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 83 FR 24785 on May 31, 2019. No comments were received on the burden published in the Federal Register for this renewal.

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 these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 201 respondents will be subject to these standards over the three-year period covered by this ICR, and one new additional respondent per year will become subject to these same standards.

Industry trade associations and other interested parties were provided an opportunity to comment on the ‘burden’ associated with these standards as they were being developed. In developing this ICR, we contacted both the National Association of Chemical Distributors (NACD), at (703) 527-6223, and the American Chemistry Council (ACC), at (703) 741-5165.

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as for those submitted in response to the first Federal Register notice. In this case, no comments were received.

3(d) Effects of Less-Frequent Collection

Less-frequent information collection would decrease the margin of assurance that facilities are continuing to meet these 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 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 these 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 these standards 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 miscellaneous organic chemical manufacturers. The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standards and the corresponding North American Industry Classification System (NAICS) codes are listed in the table below:

Standard (40 CFR Part 63, Subpart FFFF)	SIC Codes	NAICS Codes
Resin, Synthetic Rubber, and Artificial Synthetic Fibers and Filaments Manufacturing	2821, 2822, 2823, 2824	3252
Pharmaceutical and Medicine Manufacturing	2833, 283, 2835, 2836	3254
Soap, Cleaning Compound, and Toilet Preparation Manufacturing	28,41, 2842, 2843, 2844	3256
Paint, Coating, and Adhesive Manufacturing	2851, 2891	3255
Basic Chemical Manufacturing (Does not include 325131-Inorganic Dye and Pigment Manufacturing or 325181- Alkalis and Chlorine Manufacturing)	2861, 2865, 2869	3251
Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing	2873, 2874, 2875, 2879	3253
Other Chemical Product and Preparation Manufacturing	2892, 2893	3259

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported is required by the NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF).

A source must make the following reports:

Notifications / Reports
Initial notification	§63.5, §63.9(b), §63.2515(a)-(c)
Initial performance test, test plan, and emission profile	§63.7(b)-(c), §63.9(e), §63.2515(a), (c)
Notification of CMS performance evaluation	§63.8(e)(2), §63.9(g)
Notification of compliance status (including performance test results)	§63.9(h), §63.10(d)(2), §63.2520(d)
Notification of process change	§63.2515(f) §63.2520(e)(10)
Notification of construction/reconstruction	§63.5
Notification of actual startup	§63.10(d)(5)(i)
Performance test notification	§63.7(b)(1)
Notification of physical/operational change	§63.8(c)(3)
Emissions averaging plan	§63.2500(c)
Pre-compliance report	§63.2520(c)
Semiannual compliance report	§63.10(e)(3), §63.2520(b), (d)

A source must keep the following records:

Recordkeeping
Record retention	§63.10(b)(1)
Documentation supporting initial notification and notification of compliance status	§63.10(b)(2)(xiv)
Startup, shutdown, and malfunction plan	§63.6(e)(3)
Record related to startup, shutdown, and malfunction	§63.6(e)(3)(iii)-(iv)
Records of performance tests and CMS performance evaluations	§63.10(b)(2)(viii)
Records for equipment leaks	§63.1038(b)-(c)
Daily schedule or log of each operating scenario	§63.2525(c)
Records for batch processes	§63.2525(e)
Planned routine maintenance records for storage tank control devices	§63.2505(b)(9)
Maintenance wastewater plan	§63.2525(a)(9)Table 7 to Subpart FFFF
Records for safety device openings	63.2525(a)(10)
Results of each CMS calibration, validation check, and inspection	63.2475(c)(6)-(8), (d)(4)-(5), (e(4)-(7), (f)(3)-(4), 63.2525(a)(11)
Records for emissions averaging	63.2500(d)
Records for each CMS	63.8(d)(3), 63.8(f)(6)(i), 63.10(b)(2)(vi)-(xi), 63.2525(b)

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

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid supply pressure for control device.

Perform initial performance test and repeat performance tests if necessary.

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 collecting, validating, and verifying information.

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

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

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

Transmit, or otherwise disclose the information.

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

5(a) Agency Activities

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

Agency Activities

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

Audit facility records.

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

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standards 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 below in Table 1: Annual Respondent Burden and Cost – NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (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.

The Agency may neither conduct nor 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 327,000 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.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $147.40 ($70.19+ 110%)

Technical $117.92 ($56.15 + 110%)

Clerical $57.02 ($27.15 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

The type of industry costs associated with the information collection activities in the subject standards 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 these regulations. The annual operation and maintenance costs are the ongoing costs to maintain the monitors 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	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
Monitoring equipment	$17,174 1	1	$17,174	NA	NA	$0
File cabinet	$235 2	1	$235	NA	NA	$0
Material, supply, and equipment maintenance	NA	NA	$0	$21,209 3	202	$4,284,218
Photocopying and postage	NA	NA	$0	$46 4	202	$9,292
Total			$17,400			$4,290,000

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

¹ The capital costs for the monitoring equipment were estimated based on the following assumptions: (1) the monitoring equipment cost per process vent is $12,150, which includes the cost for thermocouple, wire, and data acquisition system (DAS); (2) the monitoring equipment cost for each facility with wastewater systems is $20,100, which includes the cost for steam flow meter, liquid flow meter, thermocouple, wire, and DAS; (3) the monitoring equipment cost for each storage tank with separate emission controls is $780, which includes the cost for thermocouple and wire to connect to the DAS for process vents; and (4) two new facilities will purchase this equipment for process vents, wastewater systems, and storage tanks in each of the three years covered by this ICR. The monitoring equipment costs were applied to the impacted process vents, wastewater systems, and storage tanks to determine an average capital cost per facility for monitoring equipment. In this way, the average capital cost per facility was estimated to be $17,174.

² The capital costs associated with file cabinets for storing collected data and reports include the purchase of one standard four-drawer file cabinet for each facility (assume $235 per file cabinet).

³ The O&M cost associated with the monitoring equipment is $15,875 for process vents, $20,510 for wastewater systems, and $5,825 for storage tanks. The O&M costs were applied to the impacted process vents, wastewater systems, and storage tanks to determine an average O&M cost of $21,209 per facility for monitoring equipment.

⁴ O&M costs associated with the paperwork requirement such as photocopying and postage are estimated to be approximately $46 per facility.

The total capital/startup costs for this ICR are $17,400. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $4,290,000. This is the total of column G.

The average annual cost for capital/startup and operation and maintenance costs to industry over the next three years of the ICR is estimated to be $4,310,000.

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 such activities 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 $308,000.

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

Managerial $65.71 (GS-13, Step 5, $41.07 + 60%)

Technical $48.75 (GS-12, Step 1, $30.47 + 60%)

Clerical $26.38 (GS-6, Step 3, $16.49 + 60%)

These rates are from the Office of Personnel Management (OPM), 2018 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (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 201 existing respondents will be subject to these standards. It is estimated that one additional respondent per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 202 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	1	200	0	0	201
2	1	201	0	0	202
3	1	202	0	0	203
Average	1	201	0	0	202

¹ New respondents include sources with constructed, reconstructed and modified affected facilities. In this standard existing respondents submit initial notifications.

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 202.

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

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Initial performance test process vents	1	1	0	1
Initial performance test wastewater	1	1	0	1
Initial CMS performance evaluation	0	1	0	0
Repeat performance test	1	1	0	1
Notification of construction/ reconstruction	1	1	0	1
Notification of actual startup	1	1	0	1
Initial notification	1	1	0	1
Emission Averaging plan	0	1	0	0
Pre-compliance report	1	1	0	1
Notification of performance test	1	1	0	1
Notification of initial CMS performance evaluation	0	1	0	0
Notification of compliance status
a. With performance test	1	1	0	1
b. Without performance test	0	1	0	0
Notification of physical/operational change	20.2	1	0	20.2
Semiannual summary reports
a. No deviations	181.8	2	0	363.6
b. Deviations	20.2	2	0	40.4
c. SS&M report	202	2	0	404
d. Leak detention and repair (LDAR) report	202	2	0	404
e. Emission averaging report	20.1	2	0	40.2
			Total	1,281

The number of Total Annual Responses is 1,281.

The total annual labor costs are $37,300,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown below in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 327,000 hours (rounded). Details regarding these estimates may be found below in Table 1. Annual Respondent Burden and Cost – NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (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 255 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $4,310,000. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 6,500 labor hours at a cost of $308,000; see below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (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 an adjustment decrease in the total estimated burden as currently identified in the OMB Inventory of Approved Burdens; this decrease is not due to any program changes. The decrease in burden is due to more accurate estimates of existing sources based on information gathered by EPA and confirmed by the industry. The decrease in the number of respondents also results in a decrease in responses and operation and maintenance costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 255 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either 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 neither conduct nor 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-2015-0191. An electronic version of the public docket is available at http://www.regulations.gov/, which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the docket ID number identified 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), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the 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-2015-0191 and OMB Control Number 2060-0533 in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.

Table 1: Annual Respondent Burden and Cost – NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (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 yeara	(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. Surveys and studies	N/A
3. Reporting requirements
a. Familiarization with the regulartory requirement	1	1	1	202	202	10.10	20.20		$26,460.38
b. Required activities
i. Initial performance test – process vents c	480	1	480	1	480	24	48		$62,876.16
ii. Initial performance test – wastewater c	160	1	160	1	160	8	16		$20,958.72
iii. Initial CMS performance evaluation d	10	1	10	0	0	0	0		$0
iv. Repeat performance test	20	1	20	1	20	1	2		$2,619.84
c. Create information	See 3E
d. Gather existing information	See 3E
e. Write report
i. Notification of construction/reconstruction	2	1	2	1	2	0.10	0.20		$261.98
ii. Notification of actual startup	2	1	2	1	2	0.10	0.20		$261.98
iii. Initial notification	2	1	2	1	2	0.10	0.20		$261.98
iv. Emissions averaging plan e	40	1	40	0	0	0	0		$0
v. Pre-compliance report f	40	1	40	1	20	1	2		$2,619.84
vi. Performance test notification g	2	1	2	1	2	0.10	0.20		$261.98
vii. Notification of initial CMS performance evaluation	2	1	2	0	0	0	0		$0
viii. Notification of compliance status
a. With performance test g	80	1	80	1	80	4	8		$10,479.36
b. Without performance test h	120	1	120	0	0	0	0		$0
ix. Notification of physical/operational change i	8	1	8	20.2	161.6	8.08	16.16		$21,168.31
x. Semiannual summary report
a. No deviations j	8	2	16	181.8	2,908.8	145.44	290.88		$381,029.53
b. Deviations j	24	2	48	20.2	969.6	48.48	96.96		$127,009.84
c. SS&M report k	8	2	16	202	3,232	161.60	323.20		$423,366.14
d. LDAR report l	404	2	808	202	163,216	8,160.80	16,321.60		$21,379,990.27
e. Emission averaging report m	20	2	40	20.1	804	40.20	80.40		$105,317.57
Subtotal for Reporting Requirements					198,101				$22,564,943.90
4 Recordkeeping requirements
a. Familiarize with the regulatory requirements	See 3E
b. Plan activities	N/A
c. Implement activities	N/A
d. Develop record system n	40	1	40	1	40	2	4		$5,239.68
e. Develop SS&M plan o	100	1	100	1	100	5	10		$13,099.20
f. Develop QA/QC plan for CMS p	40	1	40	0	0	0	0		$0
g. Time to train personnel q	40	1	40	1	40	2	4		$5,239.68
h. Time to retrain/refresh personnel r	16	1	16	201	3,216	160.80	321.60		$421,270.27
i. Time to enter information
i. Records of SS&M	1.5	52	78	202	15,756	787.80	1,575.60		$2,063,909.95
ii. Records of CMS data s
a. Record of continuously monitored parameters	1	365	365	202	73,730	3,686.50	7,373.00		$9,658,040.16
b. Compile data	24	2	48	202	9,696	484.80	969.60		$1,270,098.43
c. Enter/verify information for semiannual report	16	2	32	202	6,464	323.20	646.40		$846,732.29
j. Calibration of CMS t	16	1	16	202	3,232	161.60	323.20		$423,366.14
Subtotal for Recordkeeping Requirements					129,115				$14,706,996
Total Annual Labor Burden and Costs (rounded) u					327,000				$37,300,000
Capital and O&M Cost (rounded): u									$4,310,000
Grand Total (rounded): u									$41,600,000
a We have assumed that there are 201 existing facilities subject to the rule, and that one new major source per year will become subject. Therefore, the average number of respondents that are subject to this rule is 202.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, 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 will occur only in the first year after a facility becomes subject to the rule.
d Person-hours per occurrence are based on the performance specification costs to certify CMS ($500) divided by the composite hourly labor rate. No performance evaluations are required for the parameter monitoring systems included in the rule. Assumes no facilities will use the alternative standard, which required CEMS and performance evaluations.
e We have assumed that 10 percent of existing facilities will comply with emissions averaging requirements and have previously submitted an averaging plan; new facilities are not allowed to use emissions averaging.
f Assumes 1 new facility will submit a pre-compliance report.
g We have assumed that 1 new facility will comply by conducting a performance test(s). The notification of compliance status includes the report of the performance test(s).
h We have assumed that no new facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations.
i We have assumed that 10 percent of facilities will implement process changes.
j We have assumed that 90 percent of facilities will have no deviations, only 10 percent will have deviations.
k We assume that all facilities will report actions taken during startup, shutdown, or malfunction that are consistent with the SS&M plan.
l Assumes 404 hours for completion of the LDAR report.
m We have assumed that 10 percent of existing facilities will comply with emissions averaging requirements; new facilities are not allowed to use emissions averaging.
n We have assumed that it will take 40 hours for each respondent to develop a record system for recording parameter monitoring information.
o We have assumed that it will take 80 hours for each respondent to draft the startup, shutdown, and malfunction plan and another 20 hours of review/revisions, for a total of 100 hours.
p We have assumed that it will take 40 hours to develop and review the QA/QC plan for the CMS. No QA/QC plan is required for the parameter monitoring systems included in the rule. We have assumed that no facility will use the alternative standard, which requires CEMS and QA/QC plans.
q We have assumed that it will take 40 hours to train personnel.
r We have assumed it will take 20 days (16 hours) to provide refresher training for personnel.
s The record of continuously monitored parameters includes: process vent, storage tank, and wastewater monitoring and inspections.
t We have assumed that calibration of CMS will require 8 hours per year for each monitor. We are assuming a total of 2 CMS for each facility, for a total requirement of 16 hours per year per facility.
uTotals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR Part 63, Subpart FFFF) (Renewal)

Activity	(A) EPA person hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per respondent per year (C=AxB)	(D) Plants per yeara	(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. Review notification of construction/reconstruction	2	1	2	1	2	0.10	0.20	$109.35
2. Review notification of actual startup	1	1	1	1	1	0.05	0.10	$54.67
3. Review initial notification	2	1	2	1	2	0.10	0.20	$109.35
4. Review emissions averaging plan c	20	1	20	0	0	0	0	$0
5. Review pre-compliance report d	4	1	4	1	4	0.20	0.40	$218.69
6. Review notification of initial performance test	2	1	2	1	2	0.10	0.20	$109.35
7. Review notification of initial CMS demonstration	2	1	2	0	0	0	0	$0
8. Review notification of compliance status report
i. With performance test e	40	1	40	1	40	2	4	$2,186.94
ii. Without performance test f	40	1	40	0	0	0	0	$0
9. Review notification physical/operational changeg	8	1	8	20.2	161.6	8.08	16.16	$8,835.24
10. Review semiannual summary report
i. No deviations h	2	2	4	181.8	727.2	36.36	72.72	$39,758.57
ii. Deviations h	8	2	16	20.2	323.2	16.16	32.32	$17,670.48
iii. SS&M report i	2	2	4	202	808	40.40	80.80	$44,176.19
iv. LDAR report j	8	2	16	202	3,232	161.60	323.20	$176,704.75
v. Emission averaging report c	8	2	16	20.1	321.6	16.08	32.16	$17,583.00
Total Annual Labor Burden and Costs (rounded)k					6,500			$308,000
a We have assumed that there are 201 existing facilities subject to the rule, and that one new major source per year will become subject. Therefore, the average number of respondents that are subject to this rule is 202.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $65.71 (GS-13, Step 5, $41.07 + 60%) for Managerial rate, $48.75 (GS-12, Step 1, $30.47 + 60%) for Technical rate, and $26.38 (GS-6, Step 3, $16.49 + 60%) for Clerical rate. These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c We have assumed that 10 percent of existing facilities will comply with emissions averaging requirements and have previously submitted an averaging plan; new facilities are not allowed to use emissions averaging.
d We have one new facility will submit a pre-compliance report.
e We have assumed that one new facility will comply by conducting a performance test(s). The notification of compliance status includes the report of the performance test(s).
f We have assumed that no new facilities will comply by submitting engineering calculations, design calculations, etc. with no performance tests. The notification of compliance status includes those calculations.
g We have assumed that 10 percent of facilities will implement process changes.
h We have assumed that 90 percent of facilities will have no deviations, 10 percent will have deviations.
i We have assumed that all facilities will report actions taken during startup, shutdown, or malfunction that are consistent with the SS&M plan.
j We have assumed that all facilities will report the specified information for processes subject to the equipment leak standards.
k Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.