1983ss08

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Carbon Black, Ethylene, Cyanide and Spandex (40 CFR Part 63, Subpart YY) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Carbon Black, Ethylene, Cyanide and Spandex (40 CFR Part 63, Subpart YY) (Renewal), EPA ICR Number 1983.08, OMB Control Number 2060-0489.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Generic Maximum Achievable Control Technology (GMACT) Standards published at (40 CFR Part 63, Subpart YY) were promulgated on July 12, 2002 (67 FR 46257), and amended on April 13, 2005 (70 FR 19266). These regulations apply to existing and new carbon black (CB), cyanide (CY), ethylene (ET), and spandex (SP) facilities that would be subject to the major source provisions specified under the GMACT NESHAP. New facilities include those that commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 63, Subpart YY.

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. In the event that there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.

The “burden” to the Affected Public may be found below in Table 1: Annual Respondent Burden and Cost - NESHAP for Carbon Black, Ethylene, Cyanide, and Spandex (40 CFR Part 63, Subpart YY) (Renewal). The “burden” to the Federal Government is attributed entirely to work performed by either Federal employees or government contractors and may be found below in Table 2: Annual Agency Burden and Cost - NESHAP for Carbon Black, Ethylene, Cyanide, and Spandex (40 CFR Part 63, Subpart YY) (Renewal). There are approximately 61 facilities that are subject to 40 CFR 63 Subpart YY, consisting of 18 carbon black (CB) production facilities, 26 ethylene (ET) production facilities, 14 cyanide (CY) production facilities, and 3 spandex (SP) production facilities, all which are owned and operated by their respective industries. None of the 61 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 is an average of one affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 61 respondents per year will be subject to these standards, and no additional respondents per year will become subject to these same standards.

The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance”.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner/operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in 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, hazardous air pollutant (HAP) emissions from CB production, CY chemicals manufacturing, ET production, and SP production source categories either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were promulgated for these source categories at 40 CFR Part 63, Subpart YY.

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 these emission standards. Continuous emission monitors are used to ensure compliance with these same standards at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

The notifications required in these standards are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated, leaks are being detected and repaired, and that the 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 YY.

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, 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 (82 FR 29552) on June 29, 2017. 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 the standard, 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 61 respondents will be subject to these standards over the three-year period covered by this ICR.

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 and these standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted both the Continental Carbon Company, at (800) 231-4594, and Syngenta Corporation, at (336) 632-6000.

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as those submitted in response to the first Federal Register notice. 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 CB, CY, ET, and SP production facilities. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards and their corresponding North American Industry Classification System (NAICS) codes are listed below:

Standard (40 CFR Part 63, Subpart YY)	SIC Codes	NAICS Codes
Carbon Black Manufacturing (CB)	2895	325180
All Other Basic Inorganic Chemical Manufacturing / All Other Basic Organic Chemical Manufacturing (CY)	2819/2869	325180/325199
Petrochemical Manufacturing (ET)	2865/2869	325110
Noncellulosic Organic Fiber Manufacturing (SP)	2824	325220

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Carbon Black, Ethylene, Cyanide and Spandex (40 CFR Part 63, Subpart YY).

A source must make the following reports:

Notifications
Notification and application of construction or reconstruction.	§63.5 §63.1110(a)
Notification of anticipated date of initial startup.	§63.5
Notification of actual date of initial startup (if not submitted under 63.5)	§63.1110(a), §63.1110(b)
Initial Notification	§63.1110(a), §63.1110(c)
Notification of performance evaluation and performance test dates	§63.1110(a)
Operating parameter value and rationale selection	§63.1110(a), §63.1111

Reports
Initial Compliance Status Report	§63.1110(a), §63.1110(d)
Performance test and performance evaluation results	§63.1110(a)(9), §63.987(c), §63.988(b), §63.997(a)
Semiannual reports	§63.1090, §63.1110(e)
Startup, shutdown, and malfunction (SSM) reports	§63.1110(a), §63.1111
Excess emissions and CPMS performance summary report	§63.1110(a)

A source must keep the following records:

Recordkeeping
Records of verification of DOT tank certification or Method 27 of appendix A to 40 CFR Part 60 testing	§63.1105(i)
Records of maintenance	§63.1109(a), §§63.1090(b)-(e)
Records of startup, shutdown and malfunction and actions taken	§63.998(d)
Records of continuous monitoring and compliance	§63.998(b), §63.998(c)
Records of non-flare control and recovery device regulated source monitoring	§63.998(c)
Records of closed vent systems	§63.998(d)
Records of storage vessel and transfer racks	§63.998(d)
Records of equipment leaks	§63.998(d)
Records of monitored parameters out of range	§63.998(d)
Records of malfunctioning or inoperative CPMS	§63.998(c)
Records of CPMS operation, adjustments, calibration checks, and maintenance	§63.998(c)
Records of performance test and performance evaluation results	§63.998(a)
Records of initial and compliance status notifications	§63.998(a)
General and specific equipment leak records	§§63.1038(b)-(c)
Records of vessel dimensions and capacity	§63.1065(a)
Records of floating roof inspection results for storage vessels (tanks)	§63.1065(b)
Records of floating roof landing	§63.1065(c)
Records of monitoring data required by 63.1086 on leak detection	§63.1089(a)
Records of leak repair, including the method or procedure and date of repair	§§63.1089(b)-(d)

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. Additionally, performance tests are reported in an electronic format using the Electronic Reporting Tool (ERT). The data will be extracted from the ERT files and can be viewed through EPA’s Central Data Exchange. At this time, it is estimated that approximately 100 percent of the respondents use electronic reporting for performance tests.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for the appropriate 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 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 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

The 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 Source Categories: Generic Maximum Achievable Control Technology Standards for Carbon Black, Ethylene, Cyanide and Spandex (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 41,800 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 $149.35 ($71.12 + 110%)

Technical $112.98 ($53.80 + 110%)

Clerical $54.81 ($26.10 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “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 standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor(s) 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) Source Category with CMS 1	(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)
CB	N/A	0	$0	$9,545	18	$171,800
CY	N/A	0	$0	$9,545	14	$133,600
ET	N/A	0	$0	$734	26	$19,084
SP	N/A	0	$0	$8,811	3	$26,433
TOTAL2	-	0	$0	-	61	$351,000

1. Continuous monitoring system

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

The total capital/startup costs for this ICR are $0. This is the total of column D in the above table.

The total operation and maintenance (O&M) costs for this ICR are $351,000.

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 $351,000. These are the recordkeeping costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. EPA’s overall compliance and enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $166,000.

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

Managerial $64.80 (GS-13, Step 5, $40.50 + 60%)

Technical $48.08 (GS-12, Step 1, $30.05 + 60%)

Clerical $26.02 (GS-6, Step 3, $16.26 + 60%)

These rates are from the Office of Personnel Management (OPM), 2017 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Carbon Black, Ethylene, Cyanide and Spandex (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 61 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 61 per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR.

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	0	61	0	0	61
2	0	61	0	0	61
3	0	61	0	0	61
Average	0	61	0	0	61

¹ New respondents include sources with constructed, reconstructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three-year period of this ICR is 61.

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 notification	0	1	0	0
Notification of construction or reconstruction	0	1	0	0
Notification of anticipated startup	0	1	0	0
Notification of actual startup	0	1	0	0
Notification of performance evaluation and performance test dates	0	1.1	0	0
Operating parameter and rationale selection	0	1	0	0
Notification of compliance status and initial compliance status report	0	1	0	0
Performance test results	0	1.1	0	0
Semiannual and periodic report	61	2	0	122
Excess emissions and continuous monitoring system performance report and summary report	61	2	0	122
Immediate SSM report	3	1	0	3
			Total	247

The number of Total Annual Responses is 247.

The total annual labor costs are $4,580,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Carbon Black, Ethylene, Cyanide and Spandex (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

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

(i) Respondent Tally

The total annual labor hours are 41,800 hours. Details regarding these estimates may be found below in Table 1. Annual Respondent Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Carbon Black, Ethylene, Cyanide and Spandex (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 169 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $351,000. 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 3,540 labor hours at a cost of $166,000; see below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Carbon Black, Ethylene, Cyanide and Spandex (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 increase of 61 hours in the total estimated respondent burden compared with the ICR currently approved by OMB. The adjustment increase in burden from the most recently approved ICR is the addition of burden hours to account for the time spent by existing facilities to re-familiarize themselves annually with the rule requirements. There is also a small increase in the total O&M cost due to rounding.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 169 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 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-2014-0082. 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), WJC West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1527. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2014-0082 and OMB Control Number 2060-0489 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 Carbon Black, Ethylene, Cyanide, and Spandex (40 CFR Part 63, Subpart YY) (Renewal)

REPORTING / RECORDKEEPING REQUIREMENT	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent (C=AxB)	(D) Respondents per year a	(E) Technical person-hours (E=CxD)	(F) Managerial person-hours (Ex0.05)	(G) Clerical person-hours (Ex0.10)	(H) Cost, $b
1. APPLICATIONS	N/A
2. SURVEY AND STUDIES	N/A
3. REPORTING REQUIREMENTS
a. Familiarization with Regulatory Requirements	1	1	1	61	61	3.05	6.1	$7,681.64
b. Required Activities
Initial Performance Tests	57	1	57	0	0	0	0	$0
Repeat of Performance Tests c	57	0.1	5.7	0	0	0	0	$0
Startup, Shutdown and Malfunction Plan	40	1	40	61	2,440	122	244	$307,265.54
c. Create Information	See 3b
d. Gather Existing Information	See 3b
e. Write Report
Initial Notification of Applicability	2	1	2	0	0	0	0	$0
Notification of Construction/ Reconstruction	2	1	2	0	0	0	0	$0
Notification of anticipated startup	2	1	2	0	0	0	0	$0
Notification of Actual Startup	2	1	2	0	0	0	0	$0
Notification of Performance Test Dates	2	1.1	2.2	0	0	0	0	$0
Notification of Operating Parameter Value and Rationale Selection	2	1	2	0	0	0	0	$0
Notification of Compliance Status	2	1	2	0	0	0	0	$0
Report of Initial Performance Test Results	8	1.1	8.8	0	0	0	0	$0
Reporting Results of Continuous Monitoring System Performance Report and Summary Report	See 3b
Periodic and Semiannual Reports	8	2	16	61	976	48.8	97.6	$122,906.22
Excess Emissions and Continuous Monitoring System Performance Report and Summary Report d	8	2	16	61	976	48.8	97.6	$122,906.22
Immediate Startup, Shutdown, Malfunction Reports e	4	1	4	3	12	0.6	1.2	$1,511.14
Request for Waiver of Reporting and Recordkeeping	4	1	4	0	0	0	0	$0
Reporting Subtotal					5,135			$562,270.75
4. RECORDKEEPING REQUIREMENTS
a. Familiarization with Regulatory Requirements	See 3b
b. Plan Activities	See 3b
c. Implement Activities	See 3b
d. Develop Record System	N/A
e. Time to Enter Information
Records of SS&M	1.5	52	78	61	4,758	237.9	475.8	$599,167.80
Records of CMS	1	365	365	61	22,265	1,113.25	2,226.5	$2,803,798.05
Collect and compile data	24	2	48	61	2,928	146.4	292.8	$368,718.65
Enter / verify information for semiannual reports	16	2	32	61	1,952	97.6	195.2	$245,812.43
f. Train Personnel	N/A
g. Audits	N/A
Recordkeeping Subtotal					36,688			$4,017,496.94
TOTAL LABOR BURDEN AND COSTS (rounded)f					41,800			$4,580,000
TOTAL CAPITAL AND O&M COST (rounded)f								$351,000
GRAND TOTAL (rounded)f								$4,930,000

Assumptions:

^a We have assumed that there are approximately 61 respondents, consisting of 18 manufacturing carbon black, 14 manufacturing cyanide, 26 manufacturing ethylene, and 3 manufacturing spandex, with no additional new or reconstructed sources becoming subject to the rule over the next three years.

^b This ICR uses the following labor rates: $112.98 (technical), $149.35 (managerial), and $54.81 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

^c We have assumed that the rate of failed performance tests is 10%.

^d Includes periodic startup, shutdown and malfunction report.

^e We have assumed that only 5% (3) respondents per year will need to submit an immediate SSM report.

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

Table 2: Annual Agency Burden and Cost - NESHAP for Carbon Black, Ethylene, Cyanide, and Spandex (40 CFR Part 63, Subpart YY) (Renewal)

REPORTING/RECORDKEEPING REQUIREMENT	(A) Person-hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person-hours per respondent (C=AxB)	(D) Respondents per yeara	(E) Technical person-hours (E=CxD)	(F) Managerial person-hours (Ex0.05)	(G) Clerical person-hours (Ex0.10)	(H) Cost, $b
INITIAL PERFORMANCE TESTS
New or Modified Facility	5	1	5	0	0	0	0	$0
Repeat of Performance Tests	5	0.1	0.5	0	0	0	0	$0
REPORT REVIEW
Notification of Applicability	2	1	2	0	0	0	0	$0
Notification of Construction/Reconstruction	2	1	2	0	0	0	0	$0
Notification of Anticipated Startup	2	1	2	0	0	0	0	$0
Notification of Actual Startup	2	1	2	0	0	0	0	$0
Request for Extension of Compliance	2	1	2	0	0	0	0	$0
Notification of Special Compliance Requirements	2	1	2	0	0	0	0	$0
Notification of Performance Test Dates	2	1.1	2.2	0	0	0	0	$0
Notification of Operating Parameter Value and Rationale Selection	2	1	2	0	0	0	0	$0
Notification of Compliance Status	2	1	2	0	0	0	0	$0
Review Report of Initial Performance Test	5	1.1	5.5	0	0	0	0	$0
Review Reporting Results of Continuous Monitoring System Performance Report and Summary Report	Included in Review of Performance Test Report
Review Periodic & Semiannual Reports	5	2	10	61	610	30.5	61	$32,892.42
Review Excess Emission Report and Continuous Monitoring System Performance Report and Summary Report c	20	2	40	61	2,440	122	244	$131,569.68
Review Immediate Startup, Shutdown, Malfunction Report	8	1	8	3	24	1.2	2.4	$1,294.13
Review Request for Waiver of Reporting and Recordkeeping	2	1	2	0	0	0	0	$0
Subtotal					3,074	153.7	307.4	$165,756.23
TOTAL ANNUAL BURDEN AND COST (rounded)c					3,540			$166,000

Assumptions:

^a We have assumed that there are approximately 61 respondents, consisting of 18 manufacturing carbon black, 14 manufacturing cyanide, 26 manufacturing ethylene, and 3 manufacturing spandex, with no additional new or reconstructed sources becoming subject to the rule over the next three years.

^b This ICR uses the following labor rates: $48.08 (technical), $64.80 (managerial), and $26.02 (clerical). These rates are from the Office of Personnel Management (OPM), 2017 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.

^c Includes review of periodic startup, shutdown and malfunction report.

^d We have assumed that only 5% (3) respondents per year will need to submit an immediate SSM report.

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