1969ss09

1969ss09.pdf

NESHAP for Miscellaneous Organic Chemical Manufacturing (40 CFR part 63, subpart FFFF) (Final Rule)

OMB: 2060-0533

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SUPPORTING STATEMENT
ENVIRONMENTAL PROTECTION AGENCY
Risk and Technology Review of the National Emission Standards for Hazardous Air
Pollutants for Miscellaneous Organic Chemical Manufacturing
1.

IDENTIFICATION OF THE INFORMATION COLLECTION
1(a) Title of the Information Collection

Risk and Technology Review of the National Emission Standards for Hazardous Air
Pollutants for Miscellaneous Organic Chemical Manufacturing (40 CFR part 63, subpart FFFF),
EPA ICR Number 1969.09, OMB Control Number 2060-0533.
1(b) Short Characterization/Abstract
This supporting statement addresses information collection activities that will be imposed
by amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for
Miscellaneous Organic Chemical Manufacturing (MON), 40 CFR part 63, subpart FFFF. The
current MON was promulgated on July 14, 2006.
As part of the residual risk and technology reviews for the NESHAP, the Environmental
Protection Agency (EPA) is revising requirements for equipment leaks and heat exchange
systems, and also adding requirements to specifically address ethylene oxide emissions from
storage tanks, process vents, and equipment leaks. The EPA is also finalizing amendments to
correct and clarify regulatory provisions related to emissions during periods of startup,
shutdown, and malfunction (SSM); add requirements for electronic reporting of performance test
results and reports, performance evaluation reports, and compliance reports; add operational
requirements for flares used to control emissions from miscellaneous organic chemical
manufacturing process units that produce olefins or polyolefins and for flares controlling
ethylene oxide emissions, including operational and monitoring requirements to allow the use of
pressure-assisted multi-point flares; add work practice standards and monitoring requirements for
pressure relief device (PRD) releases; add requirements for storage tank degassing; and add
requirements and clarifications for vent control bypasses, including bypass lines, in situ sampling
systems, maintenance activities, and certain gaseous streams routed to a fuel gas system. This
information collection request documents the recordkeeping and reporting requirements and
burden imposed only by these amendments.
In general, all NESHAP standards require initial notifications, performance tests, and
periodic reports by the owners/operators of the affected facilities. These notifications, reports,
and records are essential in determining compliance and are required of all affected facilities
subject to NESHAP. This information collection request (ICR) includes the burden for all
activities that will be conducted in the first three years following promulgation of the
amendments to the MON. These activities include reading the rule, installing and maintaining
monitors, and completing the recordkeeping and reporting requirements.

Any owner/operator subject to the provisions of this part shall maintain a file of these
notifications, reports, and records, and retain the file for at least five years. All reports are sent to
the delegated state or local authority. In the event there is no such delegated authority, the reports
are sent directly to the EPA regional office. The use of the term "Designated Administrator"
throughout this document refers to the U.S. EPA or a delegated authority such as a state agency.
The term "Administrator" alone refers to the U.S. EPA Administrator.
Over the next three years, 201 MON facilities will be subject to this standard, and the
total labor, capital, and operations and maintenance costs imposed by the amendments will be
approximately $3.6 million per year for the first 3 years after the amendments are finalized. The
burden to the respondents from each facility is shown in Tables 1 through 4 in Attachment 1.
The total average annual cost to the Designated Administrator during the 3 years of the
ICR is estimated to be $112,000 per year. This burden includes labor costs for the Federal EPA
and state and local authorities to implement the requirements in the NESHAP after the
amendments are finalized. This burden is shown in Tables 5 through 8 of Attachment 2.
2.

Need for and Use of the Collection
2(a) Need/Authority for the Collection

The EPA is charged under CAA Section 112, as amended, to establish standards of
performance for each category or subcategory of major sources and area sources of hazardous air
pollutants (HAP). These standards are applicable to new or existing sources of HAP and require
the maximum degree of emission reduction. In addition, CAA 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 facilities cause or contribute to air pollution that may reasonably be anticipated to
endanger public health or welfare. Therefore, the NESHAP were promulgated for major sources
in this source category at 40 CFR part 63, subparts FFFF.

2(b) Practical Utility/Users of the Data
The recordkeeping and reporting information will be used by Designated Administrators
to 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 standard. Continuous emission monitors, along with the
other required monitors, are used to ensure compliance with the standards at all times.
The required notifications are used to inform the Designated Administrator when a source
becomes subject to the requirement of the regulations. The reviewing authority may then inspect
the source to ensure that monitors are properly installed and operated and the standards are being
met.
The required semiannual reports and records are used to determine periods of excess
emissions, identify problems at the facility, verify operation and maintenance procedures, and
determine compliance.
3.

Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting will be required under 40 CFR part 63,
subpart FFFF.
3(a) Nonduplication
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, no duplication
exists.
3(b) Public notice prior to ICR submission to OMB
A public notice and solicitation of public comment on this collection was provided in the
Federal Register notice of the proposed rulemaking published for the MON. No public comments
pertaining to this ICR were received.
3(c) Consultations
The public was provided the opportunity to review and comment on the burden estimated
in this Information Collection Request during the comment period for the proposed rulemaking.

3(d) Effects of Less Frequent Data Collection
The MON requires continuous monitoring and semiannual compliance reports. These
periodic reports are essential to enforcement of the standards and detection of violations. The
ongoing recordkeeping requirements also ensure that monitoring equipment is properly
maintained and enhances the reliability of the data that is gathered for this collection.
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.
The MON requires owners or operators of facilities to keep and maintain records for a
period of five years. The title V permit programs also require records to be retained for
five years. These records must be kept on file for use, if needed, by the regulating authority to
ensure that the plant personnel are operating and maintaining control equipment properly.
3(f) Confidentiality
All information submitted to the Agency for which a claim of confidentiality is made will
be safeguarded according to the Agency policies set forth in 40 CFR 2, subpart B -Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976,
amended by 43 FR 39999, September 28, 1978; 43 FR 42251, September 28, 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/NAICS 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

28,41, 2842, 2843,

3256

Soap, Cleaning Compound, and Toilet

Standard (40 CFR Part 63, Subpart FFFF)
Preparation Manufacturing

SIC Codes
2844

NAICS Codes

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

2892, 2893

3259

Other Chemical Product and Preparation
Manufacturing
4(b) Information Requested
(i) Data Items

In this ICR, all data that are recorded or reported is required by the MON (40 CFR, part
63, subpart FFFF). The tables below reflect the final amendments.
A source must make the following reports:
Notifications/Reports
Notification of performance test and results
Notification of compliance status (for flares, PRDs, process vents,
storage tanks, and equipment leaks)
Periodic reports (for flares, PRDs, process vents, storage tanks,
equipment leaks, heat exchangers, bypass lines, and maintenance vents)

63.2520(f)
63.2520(d)
63.2520(e)

A source must keep the following records:
Recordkeeping
Each notification and report
Performance tests
Records (for storage tank degassing, flares, PRDs,
process vents, storage tanks, heat exchangers, bypass
lines, and maintenance vents)

Table 12 to Subpart FFFF of Part
63 (63.10 in General Provisions)
Table 12 to Subpart FFFF of Part
63 (63.10 in General Provisions)
63.2470(f), 63.2525(m)-(r)

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
Read instructions.
Acquire, install, and operate monitoring devices for flares, PRDs, heat exchangers, and storage
tanks (scrubbers).
Develop a flare management plan and maintenance vent opening procedures.
Conduct performance tests, if applicable.
Adjust the existing ways to comply with any previously applicable instruction and
requirements.
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 Enforcement and Compliance History Online (ECHO)
and Integrated Compliance Information System (ICIS).

5(b) Collection Methodology and Management
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
Upon promulgation of the amendments, owners or operators of MON facilities have up to
three years to comply with the reporting and recordkeeping requirements associated with the
amendments for heat exchange systems, flares, PRDs, bypass lines, storage tank degassing, and
maintenance vents. Most facilities are expected to use the full three years to comply with the
general MON requirements, but it was assumed that one-third of the facilities would begin
complying in year 2 and the remaining facilities in year 3. MON facilities with ethylene oxide
emission sources (storage tanks, process vents, and equipment leaks) must be in compliance
within two years of the rule’s promulgation for these ethylene oxide emission sources and it was
assumed that all would comply in year 2. Revised monitoring for MON equipment leaks begins
within one year of the rule’s promulgation. It is anticipated facilities will read the rule and
perform certain one-time activities (e.g., develop a flare management plan) in year 1. The
specific frequency for each information collection activity within this request is shown in Tables
1 through 3 of Attachment 1.

ESTIMATING THE BURDEN AND COST OF THE COLLECTION

Tables 1 through 4 of Attachment 1 present an itemization of the burden on the
respondents subject to this NESHAP for the recordkeeping and reporting requirements in the
first three years following promulgation of the amendments to the MON. Tables 5 through 8 of
Attachment 2 present a summary of the burden on the Federal EPA and state and local
authorities in the first three years following promulgation of the amendments to the MON.
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 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 12,220 hours. The average annual recordkeeping
hours are 4,660 and the reporting requirement hours are 7,560, both of which are shown in Table
4 of Attachment 1. These hours are based on review of background documents in development of
the amendments to this NESHAP, Agency knowledge and experience with the NESHAP
program, and related ICRs.
6(b) Estimating Respondent Costs
The information collection activities for sources subject to these requirements are
presented in Tables 1 through 4 of Attachment 1. The total cost for each respondent activity
includes labor costs, capital/startup costs, and operating and maintenance (O&M) costs.
(i) Estimating Labor Costs
This ICR uses the following labor rates:
Managerial
Technical
Clerical

$143.56 ($68.36 + 110%)
$104.90 ($49.95 + 110%)
$43.39 ($20.66 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics,
May 2016, “National Industry-Specific Occupational Employment and Wage Estimates, NAICS
325000 - Chemical Manufacturing.” The rates are from column 8, mean hourly wage. The rates
have been increased by 110 percent to account for the benefit packages available to those
employed by private industry.
(ii) Estimating Capital/Start-up and Operation and Maintenance Costs

In addition to the labor costs mentioned above, industry costs associated with the
information collection activities in the MON include capital/start-up costs and operation and
maintenance costs associated with continuous monitoring. The capital/startup costs are one-time
costs when a facility becomes subject to the regulation and include the installation of monitors.
The annual operation and maintenance costs are the ongoing costs to maintain the monitors and
complete performance evaluations, as well as other costs such as photocopying and postage.
(iii) Capital/Startup and Operation and Maintenance (O&M) Costs
Below are the estimated capital and startup costs and O&M costs for the respondents
subject to the MON for the first three years after promulgation of the amendments. Note, capital
and O&M costs are not applicable for the amendments to equipment leaks, maintenance vents,
and bypass lines.
Capital/Startup and O&M Costs (2016$)

(A)
Unit Type

Flare Monitors
PRD Monitor
Heat Exchangers - El Paso
Method
Ethylene Oxide Process
Vents & Storage Tanks Scrubber Monitor
Ethylene Oxide Process
Vents & Storage Tanks Scrubber Testing
TOTAL

(C)
(E)
(D)
(B)
Number of
Annual Cost
(F)
Total
Capital/Startup Respondents
(O&M and
Capital/
Number
of
Costs for One
with
Capital) for
Startup Cost
Respondentsa
Respondent Capital/Startup
One
(B X C)
Costs
Respondent
$810,761
21
$17,025,981 $160,133
28
$63,150
201
$12,693,150
$8,349
268

(G)
Total Annual
Cost (Over
3-Yr Period)
(E X F)
$4,483,724
$2,237,532

$7,379

201

$1,483,179

$1,705

268

$456,940

$23,200

$92,800

$4,900

$39,200

$52,665

$210,661

$31,505,771

$7,217,396

a. Within a given year, there are a maximum of 201 respondents per information collection activity, however the values in
column F reflect the sum of these respondents for years 2 and 3.

The total capital/startup costs for this ICR are $31.5 million; this is the total of column D.
The total annual costs for this ICR are $7.22 million; this is the total of column G. This
includes O&M and annualized capital costs.
6(c) Estimating Agency Burden and Cost
The costs to the Agency are those costs associated with analysis of the reported
information. The Agency’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
$112,000.
This cost is based on the average hourly labor rates as follows:
Managerial
Technical
Clerical

$64.16 (GS-13, Step 5, $40.10+ 60%)
$47.62 (GS-12, Step 1, $29.76+ 60%)
$25.76 (GS-6, Step 3, $16.10 + 60%)

These rates are from the Office of Personnel Management (OPM), 2016 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 on the line item estimates used
to calculate these burdens are presented in Tables 5 through 8 of Attachment 2.
6(d) Estimating the Respondent Universe and Total Burden and Costs
The total number of respondents is also referred to as the respondent universe. Based on
research conducted for the residual risk and technology reviews of the MON, 201 facilities (of
which, 8 facilities have ethylene oxide emission sources) are currently operating and subject to
the standards. It was assumed that one-third of the facilities would begin complying with the
amendments for heat exchange systems, flares, PRDs, bypass lines, and maintenance vents in
year 2 and the remaining two-thirds of the facilities would begin complying in year 3. All 8
facilities with ethylene oxide emission sources would begin complying with the amendments for
storage tanks, process vents, and equipment leaks in year 2.
The total number of annual responses is calculated using the following table:
Total Annual Responses
(A)

(B)

(C)

(D)

Information Collection
Activity

Number of
Respondents

Number of
Responses

Number of Existing
Respondents That
Keep Records But Do
Not Submit Reports

21
201

1
1

0
0

21
201

28
268
268
268
268

2
2
2
2
2

0
0
0
0
0

56
536
536
536
536

Notification of Compliance Status
Flares
PRDs
Ethylene Oxide Process
Vents & Storage Tanks
Equipment Leaks
Periodic Reports
Flares
PRDs
Maintenance Vents
Bypass Lines
HEX El Paso Method

(E)
Total Annual
Responses
(Over 3-Yr
Period)
E=(BxC)+D

Ethylene Oxide Process
Vents & Storage Tanks
Ethylene Oxide
Equipment Leaks
TOTAL

32
2,482

The number of total annual responses is 2,482 over the first three years after finalizing the
amendments.
6(e) Bottom Line Burden Hours and Cost Tables
(i) The Respondent Tally
The total annual labor hours for respondents are 36,656 at a cost of $3.64 million.
Furthermore, the annual public reporting and recordkeeping burden for this collection of
information is estimated to average 15 hours per response. Details regarding these estimates may
be found in Tables 1 through 4 of Attachment 1.
The total annual capital/startup and O&M costs to the regulated entity are $7.22 million.
The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and
Maintenance Costs.
(ii) The Agency Tally
The average annual burden over the first three years for the Agency is estimated to be
2,393 hours at a cost of $112,000. The Agency burden hours and costs are presented in Tables 5
through 8 of Attachment 2.
6(f) Reasons for change in burden
There is no change in the labor hours or cost in this ICR as it presents the burden based
on the amendments to the MON and is considered new burden.
6(g) Burden Statement
The annual public reporting and recordkeeping burden for this collection of information
is estimated to be 15 hours per response. Burden means total time, effort, or financial resources
expended by persons to generate, maintain, retain, or disclose or provide information to or for a
Federal agency. This includes the time needed to review instructions; develop, acquire, install,
and utilize technology and systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and providing information;
adjust the existing ways to comply with any previously applicable instructions and requirements;
train personnel to be able to respond to a collection of information; search data sources; complete
and review the collection of information; and transmit or otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB control number. The OMB
Control Numbers for EPA regulations are listed in 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, the EPA has established a public docket for this ICR
under Docket ID Number EPA-HQ-OAR-2018-0746. 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) 566-1927. 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-OAR-2018-0746 and OMB Control Number 2060-0533 in any
correspondence.

PART B OF THE SUPPORTING STATEMENT
This section is not applicable because statistical methods are not used in data collection
associated with this regulation.

ATTACHMENT 1
TABLES 1, 2, 3, and 4

Tables 1 - 3: Annual Respondent Burden and Cost of Recordkeeping and Reporting
Requirements for the MON RTR – Years 1-3
Table 4:

Summary of Annual Respondent Burden and Cost of Recordkeeping and
Reporting Requirements for the MON RTR

Burden Item
1. Applications
2. Surveys and Studies
3. Reporting Requirements
A. Read Rule
B. Required Activities
1. Flare Monitors
a. Capital Cost
b. Annualized Cost
2. PRD Monitor
a. Capital Cost
b. Annualized Cost
3. HEX El Paso Method
a. Capital Cost
b. Annualized Cost
4. Ethylene Oxide Process Vents &
Storage Tanks - Scrubber Monitor
a. Capital Cost
b. Annualized Cost
5. Ethylene Oxide Process Vents &
Storage Tanks - Scrubber Testing
a. Initial Testing
b. Re-Testing
C. Create Information
D. Gather Information
E. Report Preparation
1. Notification of Compliance Status
a. Flares
b. PRDs
c. Ethylene Oxide Process Vents &
Tanks
d. Ethylene Oxide Eq. Leaks
2. Periodic Report
a. Flares
b. PRDs
c. Maintenance Vents
d. Bypass Lines
e. HEX El Paso Method
f. Ethylene Oxide Process Vents
g. Ethylene Oxide Eq. Leaks
Reporting Subtotal

(A)
Respondent
Hours per
Occurrence
(Technical
hours)
NA
NA

(B)
Non-Labor
Costs Per
Occurrence

(D)
Technical
Hours per
Respondent
Per Year
(A X C)

0
0

$810,761
$160,133

0
0

(J)
Total Labor
Costs Per
Year

(K)
Total NonLabor Costs
Per Year
(B x C x E)

(L)
Total
Number of
Responses
per Year
(C X E)

Footnotes

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the MON RTR - Year 1

5,548

$561,596

0
0

$0
$0

0
0

$0
$0

0
0

$0
$0

0
0

$0
$0

0
0

(E)
Number of
Respondents
Per Year

(F)
Technical
Hours per
Year
(D X E)

(G)
Clerical
Hours per
Year
(F X 0.1)

(H)
Management
(I)
Hours per
Total Hours
Year
per Year
(F X .05)
(F + G + H)

201

4,824

482

241

1
1

0
0

$63,150
$8,349

1
1

0
0

$7,379
$1,705

1
1

0
0

$23,200
$4,900

1
1

0
0

b,f

c,f

c,f
0
0
Inc. in 3B
Inc. in 3E

$52,665
$19,151

1
1

0
0

$0
$0

0
0

5
15

$0
$0

1
1

5
15

0
0

$0
$0

0
0

f
f

5
10
4
4
3
4
4

$0
$0
$0
$0
$0
$0
$0

2
2
2
2
2
2
2

10
20
8
8
6
8
8

0
0
0
0
0
0
0

0
0
0
0
0
0
0
4,824

0
0
0
0
0
0
0
482

0
0
0
0
0
0
0
241

0
0
0
0
0
0
0
5,548

$0
$0
$0
$0
$0
$0
$0
$561,596

$0
$0
$0
$0
$0
$0
$0
$0

0
0
0
0
0
0
0
0

f
f
f
d,f
f
c
c

Burden Item
4. Recordkeeping Requirements
A. Read Instructions
B. Implement Activities
C. Develop Record System
D. Record information
1. Flares
2. PRDs
3. HEX El Paso Method
4. Maintenance Vents
5. Bypass Lines
6. Ethylene Oxide Process Vents &
Tanks
7. Flare Management Plan
8. Tank Degassing
E. Personnel Training
F. Time for Audits
Recordkeeping Subtotal
TOTAL

(A)
Respondent
Hours per
Occurrence
(Technical
hours)

(B)
Non-Labor
Costs Per
Occurrence

(D)
Technical
Hours per
Respondent
Per Year
(A X C)

0.4
10
0
1
0

$0
$0
$0
$0
$0

365
1
1
1
1

75
3
16
NA

$0
$0
$0

(J)
Total Labor
Costs Per
Year

(K)
Total NonLabor Costs
Per Year
(B x C x E)

(L)
Total
Number of
Responses
per Year
(C X E)

Footnotes

Table 1 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the MON RTR - Year 1

0
0
0
0
0

$0
$0
$0
$0
$0

0
0
0
0
0

f
f
e
f
d

158
0
322

79
0
161

1,811
0
3,698

$183,357
$0
$374,397

$0
$0
$0

0
0
0

4,791

479

240

5,510

$557,754

9,615

962

481

11,057

$1,119,350

Total Hours
11,057

Labor
$1,119,350

Non-Labor
$0

Total
$1,119,350

(E)
Number of
Respondents
Per Year

(F)
Technical
Hours per
Year
(D X E)

(G)
Clerical
Hours per
Year
(F X 0.1)

(H)
Management
(I)
Hours per
Total Hours
Year
per Year
(F X .05)
(F + G + H)

146
10
0
1
0

0
0
0
0
0

1
1
1

75
3
16

21
0
201

1,575
0
3,216

Inc. in 3.A
NA
NA

Summary of Respondent Burden
Initial Capital and Startup
Annualized Capital/Start-up and O & M

$561,596
$0

Footnotes:
(a) This is a one-time cost (e.g., to read rule or develop plan).
(b) Includes costs for the following monitoring equipment: H2 analyzer, calorimeter, flare gas flow monitor, steam controls/flow monitor, and air controls/flow monitor.
(c) Only applicable to facilities with ethylene oxide emissions. Assumed facilities would begin complying in year 2. Note, there are not new monitoring or recordkeeping costs for ethylene oxide equipment leaks (there are only
reporting costs), as these activities are already conducted under the original MON requirements.
(d) Assumed that bypass lines were not used during the 3-year period, so costs for bypass lines would not be incurred.
(e) Assumed recordkeeping hours are comparable to previously required water methods, and assigned 0 additional hours to implement the El Paso Method.
(f) Assumed that one-third of the facilities would begin complying in year 2 and the remaining two-thirds of the facilities in year 3.

(A)
Respondent
Hours per
Occurrence
(Technical
hours)
NA
NA

(B)
Non-Labor
Costs Per
Occurrence

(D)
Technical
Hours per
Respondent
Per Year
(A X C)

0
0

$810,761
$160,133

0
0

(J)
Total Labor
Costs Per
Year

(K)
Total NonLabor Costs
Per Year
(B x C x E)

(L)
Total
Number of
Responses
per Year
(C X E)

Footnotes

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the MON RTR - Year 2

0
0

$0
$0

$5,675,327
$1,120,931

0
0

$0
$0

$4,231,050
$559,383

0
0

$0
$0

$494,393
$114,235

0
0

$0
$0

$92,800
$19,600

0
0

(E)
Number of
Respondents
Per Year

(F)
Technical
Hours per
Year
(D X E)

(G)
Clerical
Hours per
Year
(F X 0.1)

(H)
Management
(I)
Hours per
Total Hours
Year
per Year
(F X .05)
(F + G + H)

1
1

0
0

7
7

0
0

$63,150
$8,349

1
1

0
0

67
67

0
0

$7,379
$1,705

1
1

0
0

67
67

0
0

$23,200
$4,900

1
1

0
0

4
4

b,f

c,f

c,f
0
0
Inc. in 3B
Inc. in 3E

$52,665
$19,151

1
1

0
0

4
0

0
0

$0
$0

$210,661
$0

0
0

5
15

$0
$0

1
1

5
15

7
67

35
1005

4
101

2
50

40
1156

$4,075
$116,999

$0
$0

7
67

f
f

$1,863

$3,725

5
10
4
4
3
4
4

$0
$0
$0
$0
$0
$0
$0

2
2
2
2
2
2
2

10
20
8
8
6
8
8

7
67
67
67
67
4
8

70
1340
536
536
402
32
64
4,068

7
134
54
54
40
3
6
407

4
67
27
27
20
2
3
203

81
1541
616
616
462
37
74
4,678

$8,149
$155,999
$62,400
$62,400
$46,800
$3,725
$7,451
$473,586

$0
$0
$0
$0
$0
$0
$0
$1,814,149

14
134
134
134
134
8
16
660

f
f
f
d,f
f
c
c

(A)
Respondent
Hours per
Occurrence
(Technical
hours)

(B)
Non-Labor
Costs Per
Occurrence

(D)
Technical
Hours per
Respondent
Per Year
(A X C)

0.4
10
0
1
0

$0
$0
$0
$0
$0

365
1
1
1
1

75
3
16
NA

$0
$0
$0

(J)
Total Labor
Costs Per
Year

(K)
Total NonLabor Costs
Per Year
(B x C x E)

(L)
Total
Number of
Responses
per Year
(C X E)

Footnotes

Table 2 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the MON RTR - Year 2

1,175
771
0
77
0

$118,978
$77,999
$0
$7,800
$0

$0
$0
$0
$0
$0

0
0
0
0
0

f
f
e
f
d

$931

0
0
0

$0
$0
$0

0
0
0

177

2,032

$205,708

584

292

6,710

$679,294

$1,814,149

660

Total Hours
6,710

Labor
$679,294

Non-Labor
$1,814,149

Total
$2,493,443

(E)
Number of
Respondents
Per Year

(F)
Technical
Hours per
Year
(D X E)

(G)
Clerical
Hours per
Year
(F X 0.1)

(H)
Management
(I)
Hours per
Total Hours
Year
per Year
(F X .05)
(F + G + H)

146
10
0
1
0

7
67
67
67
67

1,022
670
0
67
0

102
67
0
7
0

51
34
0
3
0

3
1
1

225
3
16

0
0

0
0
0

1,767
5,835

Inc. in 3.A
NA
NA

Summary of Respondent Burden
Initial Capital and Startup
Annualized Capital/Start-up and O & M

$10,704,231
$1,814,149

(A)
Respondent
Hours per
Occurrence
(Technical
hours)
NA
NA

(B)
Non-Labor
Costs Per
Occurrence

(D)
Technical
Hours per
Respondent
Per Year
(A X C)

0
0

$810,761
$160,133

0
0

(J)
Total Labor
Costs Per
Year

(K)
Total NonLabor Costs
Per Year
(B x C x E)

(L)
Total
Number of
Responses
per Year
(C X E)

Footnotes

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the MON RTR - Year 3

0
0

$0
$0

$11,350,654
$3,362,793

0
0

$0
$0

$8,462,100
$1,678,149

0
0

$0
$0

$988,786
$342,705

0
0

$0
$0

$0
$19,600

0
0

(E)
Number of
Respondents
Per Year

(F)
Technical
Hours per
Year
(D X E)

(G)
Clerical
Hours per
Year
(F X 0.1)

(H)
Management
(I)
Hours per
Total Hours
Year
per Year
(F X .05)
(F + G + H)

1
1

0
0

14
21

0
0

$63,150
$8,349

1
1

0
0

134
201

0
0

$7,379
$1,705

1
1

0
0

134
201

0
0

$23,200
$4,900

1
1

0
0

0
4

b,f

c,f

c,f
0
0
Inc. in 3B
Inc. in 3E

$52,665
$19,151

1
1

0
0

$0
$0

0
0

5
15

$0
$0

1
1

5
15

14
134

70
2010

7
201

4
101

81
2312

$8,149
$233,998

$0
$0

14
134

f
f

5
10
4
4
3
4
4

$0
$0
$0
$0
$0
$0
$0

2
2
2
2
2
2
2

10
20
8
8
6
8
8

21
201
201
201
201
4
8

210
4020
1608
1608
1206
32
64
10,828

21
402
161
161
121
3
6
1,083

11
201
80
80
60
2
3
541

242
4623
1849
1849
1387
37
74
12,452

$24,448
$467,996
$187,199
$187,199
$140,399
$3,725
$7,451
$1,260,564

$0
$0
$0
$0
$0
$0
$0
$5,403,247

42
402
402
402
402
8
16
1,822

f
f
f
d,f
f
c
c

(A)
Respondent
Hours per
Occurrence
(Technical
hours)

(B)
Non-Labor
Costs Per
Occurrence

(D)
Technical
Hours per
Respondent
Per Year
(A X C)

0.4
10
0
1
0

$0
$0
$0
$0
$0

365
1
1
1
1

75
3
16
NA

$0
$0
$0

(J)
Total Labor
Costs Per
Year

(K)
Total NonLabor Costs
Per Year
(B x C x E)

(L)
Total
Number of
Responses
per Year
(C X E)

Footnotes

Table 3 - Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for the MON RTR - Year 3

3,526
2,312
0
231
0

$356,935
$233,998
$0
$23,400
$0

$0
$0
$0
$0
$0

0
0
0
0
0

f
f
e
f
d

$931

0
31
0

0
16
0

0
359
0

$0
$36,322
$0

$0
$0
$0

0
0
0

5,597

560

280

6,437

$651,586

16,425

1,643

821

18,889

$1,912,150

$5,403,247

1822

Total Hours
18,889

Labor
$1,912,150

Non-Labor
$5,403,247

Total
$7,315,397

(E)
Number of
Respondents
Per Year

(F)
Technical
Hours per
Year
(D X E)

(G)
Clerical
Hours per
Year
(F X 0.1)

(H)
Management
(I)
Hours per
Total Hours
Year
per Year
(F X .05)
(F + G + H)

146
10
0
1
0

21
201
201
201
201

3,066
2,010
0
201
0

307
201
0
20
0

153
101
0
10
0

3
1
1

225
3
16

0
104

0
312
0

Inc. in 3.A
NA
NA

Summary of Respondent Burden
Initial Capital and Startup
Annualized Capital/Start-up and O & M

$20,801,540
$5,403,247

Table 4 - Summary of Annual Respondent Burden and Cost of Recordkeeping and Reporting Requirements for
the MON RTR
Year

Technical Hours Clerical Hours

Management
Hours

Total Labor
Hours

Labor Costs

Non-Labor (Annualized
Capital/Startup and O&M)
Costs

Total Costs

1
2
3

9,615
5,835
16,425

962
584
1,643

481
292
821

11,057
6,710
18,889

$1,119,350
$679,294
$1,912,150

$0
$1,814,149
$5,403,247

$1,119,350
$2,493,443
$7,315,397

Total
Average

31,875
10,625

3,188
1,063

1,594
531

36,656
12,219

$3,710,794
$1,236,931

$7,217,396
$2,405,799

$10,928,190
$3,642,730

Year

Number of
Respondents

Number of
Responses

Reporting
Hours

Recordkeeping
Hours

Total Hours

Hours per Response

Hours Per
Respondent

1
2
3

201
201
201

0
660
1,822

5,548
4,678
12,452

5,510
2,032
6,437

11,057
6,710
18,889

#DIV/0!
10
10

2,764
1,678
4,722

Total
Average

31
31

2,482
827

22,678
7,559

13,978
4,659

36,656
12,219

15
15

9,164
3,055

ATTACHMENT 2
TABLES 5, 6, 7, and 8

Tables 5 - 7: Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements
for the MON RTR - Year 1-3
Table 8:

Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting
Requirements for the MON RTR

Table 5 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the MON RTR - Year 1
(B)

Number of
Occurrences
Per Year

Technical
Hours Per
Occurrence

(C)

(D)
(E)
(F)
(G)
Management
Clerical
Tech Hours
Hours Per
Hours Per Total Hours
Per Year
Year
Year
Per Year Total Cost
(C=A x B)
(D = C x 0.05) (E = C x 0.1)
(C+D+E)
Per Year
not applicable
1080
54
108
1242
$57,672

Burden Item
1. Applications
2. Read and Understand Rule Requirements
45
24
3. Required Activities
A. Observe stack tests
0
16
0
B. Excess emissions -- Enforcement Activities
0
24
0
C. Create Information
D. Gather Information
E. Report Reviews
1. Review notification of compliance status
a. Flares
0
2
0
b. PRDs
0
2
0
c. Process Vents & Tanks
0
2
0
d. Eq. Leaks
0
2
0
2. Review periodic reports
a. Flares
0
2
0
b. PRDs
0
2
0
c. Maintenance Vents
0
2
0
d. Bypass Lines
0
2
0
e. HEX El Paso Method
0
2
0
f. Process Vents & Tanks
0
2
0
g. Eq. Leaks
0
2
0
3. Review flare management plan
21
5
105
F. Prepare annual summary report
1
10
10
4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =
TOTAL
1195

0
0
not applicable
not applicable

0
0
0
0
0
0
0
0
0
0
0
5
1
$0
60

0
0

$0
$0

0
0
0
0

$0
$0
$0
$0

0
0
0
0
0
0
0
121
12

$0
$0
$0
$0
$0
$0
$0
$5,607
$534
$0
$63,813

0
0
0
0
0
0
0
11
1
per trip
120

Footnotes:
a Number of occurrences is the number of states and EPA Regions with affected sources (35 states + 10 EPA regions = 45 respondents).

1374

Footnotes

(A)

Table 6 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the MON RTR - Year 2
(B)

Number of
Occurrences
Per Year

Technical
Hours Per
Occurrence

(C)

(D)
(E)
(F)
(G)
Management
Clerical
Tech Hours
Hours Per
Hours Per Total Hours
Per Year
Year
Year
Per Year Total Cost
(C=A x B)
(D = C x 0.05) (E = C x 0.1)
(C+D+E)
Per Year
not applicable
0
0
0
0
$0

Burden Item
1. Applications
2. Read and Understand Rule Requirements
0
24
3. Required Activities
A. Observe stack tests
4
16
64
B. Excess emissions -- Enforcement Activities
0
24
0
C. Create Information
D. Gather Information
E. Report Reviews
1. Review notification of compliance status
a. Flares
7
2
14
b. PRDs
67
2
134
c. Process Vents & Tanks
4
2
8
d. Eq. Leaks
8
2
16
2. Review periodic reports
a. Flares
14
2
28
b. PRDs
134
2
268
c. Maintenance Vents
134
2
268
d. Bypass Lines
134
2
268
e. HEX El Paso Method
134
2
268
f. Process Vents & Tanks
8
2
16
g. Eq. Leaks
16
2
32
3. Review flare management plan
0
5
0
F. Prepare annual summary report
1
10
10
4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =
TOTAL
1394

3
0
not applicable
not applicable

6
0

74
0

$3,418
$0

1
13
1
2

16
154
9
18

$748
$7,156
$427
$854

3
27
27
27
27
2
3
0
1
per trip
139

32
308
308
308
308
18
37
0
12

$1,495
$14,311
$14,311
$14,311
$14,311
$854
$1,709
$0
$534
$3,525
$77,965

1
7
0
1
1
13
13
13
13
1
2
0
1
$881
70

Footnotes:
a Number of occurrences is the number of states and EPA Regions with affected sources (35 states + 10 EPA regions = 45 respondents).

1603

Footnotes

(A)

Table 7 - Annual Agency Burden and Cost of Recordkeeping and Reporting Requirements for the MON RTR - Year 3
(B)

(C)

Number of
Occurrences
Per Year

Technical
Hours Per
Occurrence

Tech Hours
Per Year
(C=A x B)

1. Applications
2. Read and Understand Rule Requirements
0
24
0
3. Required Activities
A. Observe stack tests
0
16
0
B. Excess emissions -- Enforcement Activities
0
24
0
C. Create Information
D. Gather Information
E. Report Reviews
1. Review notification of compliance status
a. Flares
14
2
28
b. PRDs
134
2
268
c. Process Vents & Tanks
0
2
0
d. Eq. Leaks
0
2
0
2. Review periodic reports
a. Flares
42
2
84
b. PRDs
402
2
804
c. Maintenance Vents
402
2
804
d. Bypass Lines
402
2
804
e. HEX El Paso Method
402
2
804
f. Process Vents & Tanks
8
2
16
g. Eq. Leaks
16
2
32
3. Review flare management plan
0
5
0
F. Prepare annual summary report
1
10
10
4. Travel expenses: (1 person * 30 hours per year / 8 hours per day * $75 per diem) + ($600 per round trip) =
TOTAL
3654

(D)
(E)
(F)
Management
Clerical
Hours Per
Hours Per Total Hours
Year
Year
Per Year
(D = C x 0.05) (E = C x 0.1)
(C+D+E)
not applicable
0
0
0

(G)

Total Cost
Per Year
$0

0
0
not applicable
not applicable

0
0

$0
$0

1
13
0
0

3
27
0
0

32
308
0
0

$1,495
$14,311
$0
$0

4
40
40
40
40
1
2
0
1
$0
183

8
80
80
80
80
2
3
0
1
per trip
365

97
925
925
925
925
18
37
0
12

$4,486
$42,934
$42,934
$42,934
$42,934
$854
$1,709
$0
$534
$0
$195,124

Footnotes:
a Number of occurrences is the number of states and EPA Regions with affected sources (35 states + 10 EPA regions = 45 respondents).

4202

Footnotes

Burden Item

(A)

Table 8 - Summary of Annual Agency Burden and Cost of Recordkeeping and Reporting
Requirements for the MON RTR
Year

Technical
Hours

Management Hours

Clerical Hours

Total Hours

Labor Costs

Non-Labor
Costs

Total Costs

1
2
3

1,195
1,394
3,654

60
70
183

120
139
365

1,374
1,603
4,202

$63,813
$77,965
$195,124

$0
$0
$0

$63,813
$77,965
$195,124

Total
Average

6,243
2,081

312
104

624
208

7,179
2,393

$336,901
$112,300

$0
$0

$336,901
$112,300

File Type	application/pdf
File Modified	2022-11-30
File Created	2020-05-14