1156ss11

11

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal)

EPA ICR Number 1156.11, OMB Control Number 2060-0059

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Synthetic Fiber Production Facilities were proposed on November 23, 1982, and promulgated on April 5, 1984, and amended on October 17, 2000 (65 FR 61768). These standards apply to affected facilities at synthetic fiber production plants including each solvent-spun synthetic fiber process that produces more than 500 megagrams of fiber per year that commenced construction or reconstruction after November 23, 1982. The provisions of this subpart do not apply to any facility that uses the reaction spinning process to produce spandex fiber, or the viscose process to produce rayon fiber, or to facilities that commence modification but not reconstruction after November 23, 1982. Volatile organic compounds (VOCs) are the pollutants regulated under this subpart. This information is being collected to assure compliance with 40 CFR part 60, subpart HHH.

In general, all NSPS standards require initial notifications, performance tests and periodic reports. Owners or operators 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 notification, reports, and records are essential in determining compliance, and are required of all sources subject to NSPS.

Any owner/operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two 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.

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).

There are approximately 22 existing sources that are currently associated with the rule, and it is estimated that no new sources will become subject to the standard in the next three years.

The Office of Management and Budget (OMB) approved the current Information Collection Request (ICR) without any “Terms of Clearance.”

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal). The burden to the “Federal Government” is attributed entirely to work performed by federal employees or government contractors; this burden may be found below in Table 2: Average Annual EPA Burden - NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

. . . application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. Section 111(a)(l).

The Agency refers to this charge as selecting the best demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards every four years.

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, pollutant emissions from volatile organic compounds (VOCs) cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this source category at 40 CFR part 60, subpart HHH.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard 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 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 the standard 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, that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part 60, subpart HHH.

3(a) Non-duplication

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 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 (74 FR 38004) on July 30, 2009. No comments were received on the burden published in the Federal Register.

3(c) Consultations

Consultation with an industry representative (i.e., respondent) was conducted during a previous ICR renewal to determine if there is anyway for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it easier to comply. Our contact was: Mr. Robert Barker, American Fiber Manufacturers Association Incorporated (AFMA), (727) 772-1685.

During a previous renewal, the most recent ICR was referenced and the preparer of the active ICR was consulted. In addition, other resources were used to obtain the most recent data available. Available information from the following sources were reviewed: the United States Census Bureau, the AIRS Facility Subsystem (AFS), the primary source of information regarding the number of existing sources, and websites covering synthetic fiber production facilities. EPA's Office of Air Quality Planning and Standards, Information Transfer and Program Integration Division was also consulted.

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 that emission limitations are met. If the information required by these standards was collected less frequently, the likelihood of detecting poor operation and maintenance of control equipment and noncompliance would decrease.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB at 5 CFR part 1320, section 1320.5.

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 synthetic fiber production facilities. The United States Standard Industrial Classification (SIC) codes for the respondents affected by the standards, which corresponds to the North American Industry Classification System (NAICS) codes, are listed below for source category descriptions.

Standard (40 CFR part 60, subpart HHH)	SIC Codes	NAICS Codes
Manmade Organic Fibers, Except Cellulosic	2824	325222
Cellulosic Manmade Fibers	2823	3252211

4(b) Information Requested

None of these reporting or recordkeeping requirements violate any of the regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i) Data Items

In this ICR, all the data that is recorded or reported is required by NSPS for Synthetic Fiber Production Facilities (40 CFR part 60, subpart HHH).

A source must make the following reports:

Notifications	Standard Citation by Sections
Notification of construction/reconstruction	60.7(a)(1)
Notification of initial startup including compliance method	60.7(a)(3)
Notification of initial performance test	60.8(d), 60.604(a)
Performance test results	60.8(a), 60.604(a)(1)
Demonstration of continuous monitoring system	60.7(a)(5)
Physical or operational change	60.7(a)(4)
Quarterly reports of exceedances or semiannual report of no exceedances	60.604(a)(2)
Reports within 30 days whenever extruded fiber for the preceding twelve calendar months exceeds 551 tons, if exempt from standard under Section 60.600	60.604(b)

A source must make the following reports:

Recordkeeping
Record of startup, shutdown, and malfunctions	60.7(b)
Records are required to be retained for two years	60.7(f)

Electronic Reporting

Some of the respondents use monitoring equipment that automatically records parameter data. Although personnel at the affected facility must evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site.

Also, regulatory agencies in cooperation with the respondents continue to create reporting systems to transmit data electronically. However, electronic reporting systems are not widely used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate monitoring devices that continuously measure and record for each calendar month the amount of makeup solvent and solvent feed.

Perform performance test to determine and record monthly the VOC emissions per unit mass solvent feed from each affected facility for the current and preceding five consecutive calendar months, and using these values to calculate the 6-month average emissions by using the equations provided by the standard.

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.

Currently, sources are using automated monitoring equipment that provides parameter data. Although personnel at the sources need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping.

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

Observe initial performance tests and repeat performance tests if necessary.

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 AIRS Facility Subsystem (AFS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might 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. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.

Information contained in the reports is entered into the AFS which is operated and maintained by EPA's Office of Compliance. AFS is EPA’s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses the AFS 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 two 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. An estimate of the number of small entities affected could not be determined, based on review of available Federal Register notices and background documents for 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 requirements the minimum 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 Industry Burden - NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (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 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 1,859 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of this regulation, Agency knowledge and experience with the NSPS 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 $97.46 ($46.41 + 110%)

Technical $83.71 ($39.86 + 110%)

Clerical $42.55 ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 19, 2005, “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 during a previous renewal of this ICR.

(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 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 Respondent with O&M	(G) Total O&M, (E X F)
Flow indicator for solvent feed	$3,300	0	0	$7,500	22	$165,000

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

The total operation and maintenance (O&M) costs for this ICR are $165,000. This is the total of column G.

The total respondent costs in block 14 have been calculated as the addition of the capital/startup costs, and the annual operation and maintenance costs. 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 $165,000.

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 activities such as the examination of records maintained by the respondents, periodic inspection of sources of emission, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $5,237. This cost is based on the average hourly labor rate as follows:

Managerial $57.20 (GS-13, Step 5, $35.75 x 1.6)

Technical $42.45 (GS-12, Step 1, $26.53 x 1.6)

Clerical $22.96 (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2006 General Schedule” which excludes locality rates of pay. Details upon which this estimate is based appear in Table 2: Average Annual EPA Burden - NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (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 22 existing respondents 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 22 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	(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	22	0	0	22
2	0	22	0	0	22
3	0	22	0	0	22
Average	0	22	0	0	22

To avoid double-counting respondents column D is subtracted. As shown above, the average Number of Respondents over the three-year period of this ICR is 22.

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
Notification of construction/reconstruction	18	0	0	0
Notification of actual startup	18	0	0	0
Notification of initial performance test	18	0	0	0
Report of performance test	18	0	0	0
Report of repeat of performance test	3.6	0	0	0
Quarterly report of VOCs emission exceedances	22	0.50	0	11
Semiannual report of no exceedances	22	2	0	44
Notification of noncompliance	22	0	0	0
			Total	55

The number of Total Annual Responses is 55.

6(e) Bottom Line Burden Hours Burden 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 Hours Requested is 1,859. The total annual labor costs are $150,119. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost - NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 34 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $165,000. 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 the next three years is estimated to be 126 labor hours at a cost of $5,237. See Table 2. Annual Agency Burden and Cost, NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH).

6(f) Reasons for Change in Burden

There is no change in the labor hours or cost to the respondents in this ICR compared to the previous ICR. This is due to two considerations. First, the regulations have not changed over the past three years and are not anticipated to change over the next three years. Secondly, the growth rate for respondents is very low, negative, or non-existent. Therefore, the labor hours and cost figures in the previous ICR reflect the current burden to the respondents and are reiterated in this ICR.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 34 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–2009–0529. 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–2009–0529 and OMB Control Number 2060-0059 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 – NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (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) Cost, $ b
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Read instructions	1	1	1	0	0	0	0	$0
B. Required activities
Initial performance test	72	1	72	0	0	0	0	$0
Repeat performance test c	72	1	72	0	0	0	0	$0
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write report
New Sources
Notification of construction/ reconstruction d	2	1	2	0	0	0	0	$0
Notification of actual startup d	2	1	2	0	0	0	0	$0
Notification of initial performance test d	2	1	2	0	0	0	0	$0
Notification of demonstration of CMS d	2	1	2	0	0	0	0	$0
Report of initial performance test d	See 3B
Existing Sources
Quarterly report of VOCs emission exceedances e	8	0.50	4	22	88	4.4	8.8	$8,169.74
Semiannual report of no exceedances f	2	2	4	22	88	4.4	8.8	$8,169.74
Notification of noncompliance g	2	1	2	0	0	0	0	$0
Subtotal Reporting	Subtotal burden hours = 202 (rounded)							$16,339.48
4. Recordkeeping requirements
A. Read instructions	See 3A
B. Plan activities	See 4C
C. Implement activities	See 3B
D. Develop record system	See 4E
E. Time to enter information
Records of operating parameters h	0.25	250	62.5	22	1,375	68.75	137.5	$127,652.24
Records of monthly VOC emission i	0.25	12	3	22	66	3.3	6.6	$6,127.31
F. Time to train personnel	N/A
G. Time for audits	N/A
Subtotal Recordkeeping	Subtotal burden hours = 1,657 (rounded)							$133,779.55
Subtotals Labor Burden and cost					1,617	80.85	161.7	$150,119.03
TOTAL LABOR BURDEN AND COST (rounded)					1,859			$150,119

Assumptions:

^a We have assumed that the average number of respondents that will be subject to the rule will be 22. 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: $97.46 per hour for Executive, Administrative, and Managerial labor; $83.71 per hour for Technical labor, and $42.55 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 19, 2005, ”Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, ”Total compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.

^c We have assumed that 20 percent of initial performance tests will be repeated.

^d We have assumed that there will be no new sources over the three-year period of this ICR.

^e We have assumed that each respondent will submit one quarterly report every other year due to excess of volatile organic compounds (VOCs) emissions.

^f Semiannual reports are required of all respondents.

^g We have assumed that there are no existing solvent-spun synthetic fiber producing facility subject to the exemption under section 60,600(a) that has exceeded the annual requirement of 500 mg. Therefore, no existing solvent-spun synthetic fiber producing facility will submit a notification of exceeding the limits over the three-year period of the ICR.

^h We have assumed that respondents will enter information on records of operating parameters 250 days per year.

ⁱ Respondents are required to conduct monthly calculation of the 6 months VOC average emission which is considered a performance test. Respondents will have to determine this value by calculating the VOC emissions per unit of mass solvent feed from each affected facility for the current and proceeding five consecutive calendar months.

Table 2: Average Annual EPA Burden - NSPS for Synthetic Fiber Production Facilities (40 CFR Part 60, Subpart HHH) (Renewal)

Activity	(A) EPA person- hours per occurrence	(B) No. of occurrences per plant per year	(C) EPA person hours per plant per year (C=AxB)	(D) Plants 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) Cost, $ b
Required Activities
New Plant
Initial performance test	24	1	24	0	0	0	0	$0
Repeat performance test c	24	0.2	4.8	0	0	0	0	$0
Report review
New Plant
Notification of construction	2	1	2	0	0	0	0	$0
Notification of actual startup	0.5	1	0.5	0	0	0	0	$0
Notification of initial test	0.5	1.2	0.6	0	0	0	0	$0
Review test results	8	1.2	9.6	0	0	0	0	$0
Notification of demonstration of CMS	0.5	1	0.5	0	0	0	0	$0
Existing Plant
Quarterly report of VOCs emission exceedances d	2	0.50	1	22	22	1.1	2.2	$1,047.33
Semiannual report of no VOC emission exceedances e	2	2	4	22	88	4.4	8.8	$4,189.33
Notification of noncompliance	2	0	0	0	0	0	0	$0
Subtotals Labor Burden and cost					110	5.5	11	$5,236.66
TOTAL ANNUAL BURDEN AND COST (rounded)					126			$5,237

Assumptions:

^a We have assumed that the average number of respondents that will be subject to the rule will be 22. There will be no additional new source that will become subject to the rule over the three-year period of this ICR.

^b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $56.02 (GS-13, Step 5, $35.01 x 1.6), Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical rate of $22.50 (GS-6, Step 3, $14.06 x 1.6). These rates are from the Office of Personnel Management (OPM) ”2005 General Schedule“ which excludes locality rates of pay.

^c We have assumed that 20 percent of initial performance tests will be repeated.

^d We have assumed that each respondent will submit one quarterly report every other year due to excess of volatile organic compounds (VOCs) emissions.

. ^e Semiannual reports are required of all respondents.