1871ss11

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal), EPA ICR Number 1871.11, OMB Control Number 2060-0420.

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production were proposed on October 14, 2998; and promulgated on June 29, 1999; and amended on: November 22, 1999; November 2, 2001; June 7, 2002; July 12, 2002; and October 8, 2014. These regulations apply to new and existing facilities of the following four categories: Polycarbonates (PC) Production, Acrylic and Modacrylic Fibers (AMF) Production, Acetal Resins (AR) Production, and Hydrogen Fluoride (HF) Production. New facilities include those that either 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 of these measurements and retain this file for at least five years following the date of such measurements, maintenance reports, and records. All reports required to be submitted electronically are submitted through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI), where the delegated state or local authority can review them. If there is no such delegated authority, the EPA regional office can review them. All other reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the EPA regional offices. 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. 

The “Affected Public” are owners or operators of facilities that produce polycarbonates, acrylic and modacrylic fibers, acetal resins, and hydrogen fluoride. The “burden” to the Affected Public may be found at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (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 at the end of this document in Table 2: Average Annual EPA Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal). None of the facilities in the United States are owned by either state, local, tribal entities 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.

The PC industry consists of facilities that produce polycarbonates, a process that involves a polymerization reaction using either a solution or suspension process in either a batch or continuous mode. All production of polycarbonates in the United States is currently based on the polymerization reaction of bisphenols with phosgene in the presence of catalysts, solvents (mainly methylene chloride) and other additives.

The AMF industry consists of facilities that produce acrylic and modacrylic fibers, which are manufactured synthetic fibers in which the fiber-forming substance is any long-chain synthetic polymer containing acrylonitrile units.

The AR industry consists of facilities that produce homopolymers and/or copolymers of alternating oxymethylene units. Acetal resins are also known as polyoxymethylenes, polyacetals, and aldehyde resins.

The HF industry consists of facilities that produce and recover hydrogen fluoride by reacting calcium fluoride with sulfuric acid. In this subpart, hydrogen fluoride production is not a process that produces gaseous hydrogen fluoride for direct reaction with hydrated aluminum to form aluminum fluoride (i.e., the hydrogen fluoride is not recovered as an intermediate or final product prior to reacting with the hydrated aluminum).

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

Over the next three years, approximately 3 PC production facilities, 1 AMF production facility, 2 AR production facilities and 1 HF production facility 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 PC, AMF, AR and HF sources either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the GMACT were promulgated for this source category 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 the emission standards. Continuous emission monitors are used to ensure compliance with these standards at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

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

Additionally, the EPA is requiring electronic reporting for certain notifications or reports. The EPA is requiring that owners or operators of affected sources would submit electronic copies of initial notifications required in 40 CFR 63.9(b), notifications of compliance status required in 40 CFR 63.9(h), performance test reports, a Flare Management Plan required in 40 CFR 63.1103(e)(4)(iii), and semiannual reports through the EPA's Central Data Exchange (CDX), using the Compliance and Emissions Data Reporting Interface (CEDRI).

CEDRI includes the Electronic Reporting Tool (ERT) software, which is used by facilities to generate electronic reports of performance tests. The EPA is also requiring that 40 CFR Part 63, Subpart YY performance test reports be submitted through the EPA’s ERT.

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

For reports required to be submitted electronically, the information is sent through the EPA's CDX, using CEDRI, where the appropriate EPA regional office can review it, as well as for state and local agencies that have been delegated authority. If a state or local agency has adopted under its own authority its own standards for reporting or data collection, adherence to those non-Federal requirements does not constitute duplication. 

For all other reports, 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 either the delegated state or local agency. If a state or local agency has adopted its own 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 these 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 (86 FR 19256) on April 13, 2021. No comments were received on the burden published in the Federal Register for this renewal.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 7 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 that thes standards have been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted DuPont, at (302) 773-0900, SABIC, at (713) 430-2300, and the American Chemistry Council at 202-249-6714.

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

3(d) Effects of Less-Frequent Collection

Less-frequent information collection would decrease the margin of assurance that facilities are continuing to meet these standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less-frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.

3(e) General Guidelines

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

These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to these standards. The EPA believes that the five-year records retention requirement is consistent with both 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. The 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 either 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 owners and operators of PC, AMF, AR, and HF production facilities. 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 below for the source categories:

Standard (40 CFR Part 63, Subpart YY)	SIC Codes	NAICS Codes
Polycarbonates (PC) Production (Synthetic Rubber Manufacturing)	2822	325212
Acrylic and Modacrylic Fibers (AMF) Production (Organic Fibers - Noncellulosic, and Artificial and Synthetic Fibers and Filaments Manufacturing)	2824	325220
Acetal Resins (AR) Production (Plastic Materials and Resins)	2821	325211
Hydrogen Fluoride (HF) Production (Industrial Inorganic Chemicals, and Other Basic Inorganic Chemical Manufacturing)	2819	325180

4(b) Information Requested

(i) Data Items

In this ICR, all the data that are recorded or reported is required by the NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal).

A source must make the following reports:

Notifications
Application for approval of construction/reconstruction	§63.5(d), §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) §63.1066(a)
Notification of initial applicability	§63.1110(a), §63.1110(c)
Notification of compliance status	§63.1110(d) §63.1110(a), §63.999(b), §63.1039(a)
Notification of performance test and performance evaluation results	§63.1110(a), §63.1110(d), §63.987(c), §63.988(b), §63.997(a) §63.999(a)
Rescheduled initial performance test	§63.999(a)(1)(i)
Develop startup, shutdown, malfunction plan and periodic reports	§63.10(d)(5)(i), §63.1110(a), §63.1111
Operating parameter value and rationale selection	§63.1110(a), §63.1111
Excess emissions and continuous parameter monitoring systems (CPMS) performance reports	§63.1110(a)
Notification of changes in information (reclassification to area source status or to revert to major source status) (electronic submission)	§63.9(b), 63.9(j)

Reports
Periodic reports (Semiannual or according to the schedule for Title V) with information on excess emissions and on the implementation of leak detection and repair standard provisions	§63.999(c), §63.1110(e), §63.1108(a), §63.1109, §63.1039(b) §63.1066(b)
Startup, shutdown and malfunction reports (for AR and HF only)	§63.1110(a), §63.1111
Performance test reports (electronic submission)	§§63.1110(a)(9)

A source must keep the following records:

Recordkeeping
Maintain records of startup, shutdown, malfunctions periods when excess emissions have occurred during the reporting period (AR and HF only)	§63.1109(a), §63.998(d)
Records of verification of DOT tank certification or Method 27 of appendix A to 40 CFR Part 60 testing (HF Only)	§63.1105(i)
Records of maintenance	§63.1109(a)
Maintain records of performance test and performance evaluation results	§63.1109(a), §63.998(a)
Maintain records of all reports and notifications	§63.998(a), §63.1109(a)
Maintain record of applicability	§63.998(a), §63.1109(a)
Records of CPMS operation adjustments, calibration checks, and maintenance	§63.998(c), §63.1109(a)
Records of nonflare 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 implementation of leak detection and repair (LDAR) standards provision	§63.1107, §63.998(d), §§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)

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.

The rule was amended to include electronic reporting provisions on January 22, 2016, March 17, 2020, and November 19, 2020. Respondents are required to use the EPA’s Electronic Reporting Tool (ERT) to develop performance test reports and submit them through the EPA’s Compliance and Emissions Data Reporting Interface (CEDRI), which can be accessed through the EPA’s Central Data Exchange (CDX) (https://cdx.epa.gov/). The ERT is an application, rather than a form, and the requirement to use the ERT is applicable to numerous subparts. The splash screen of the ERT contains a link to the Paperwork Reduction Act (PRA) requirements, such as the OMB Control Number, expiration date, and burden estimate for this and other subparts. Respondents are also required to submit electronic copies of notifications and certain reports through EPA’s CEDRI. The notification is an upload of their currently required notification in portable document format (PDF) file. For purposes of this ICR, it is assumed that there will be no additional burden associated with the proposed requirement for respondents to submit the notifications and reports electronically.

Electronic copies of records may also be maintained in order to satisfy federal recordkeeping requirements. For additional information on the Paperwork Reduction Act requirements for CEDRI and ERT for this rule, see: https://www.epa.gov/electronic-reporting-air-emissions/paperwork-reduction-act-pra-cedri-and-ert.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

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

Perform initial performance test, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and systems for collecting, validating, and verifying information.

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

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

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

Transmit, or otherwise disclose the information.

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

5(a) Agency Activities

The 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 these 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 these 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. The EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices, and EPA headquarters. The 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

There are no small entities (i.e., small businesses) affected by this regulation. However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of these regulations. 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 at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (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 record-keeping and reporting requirements is estimated to be 2,910 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of these regulations, 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 $153.55 ($73.12 + 110%)

Technical $122.20 ($58.19 + 110%)

Clerical $61.51 ($29.29 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2021, “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(s) 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) Continuous Monitoring Device	(B) Capital/Startup Cost for One Respondent	(C) Number of New Respondents	(D) Total Capital/Startup Cost, (B X C)	(E) Annual O&M Costs for One Respondent	(F) Number of Respondents with O&M	(G) Total O&M, (E X F)
PC (O&M)	$0	0	$0	$1,505	3	$4,515
PC (PRD)	$12,649	0	$0	$1,804	3	$5,412
PC (LDAR)	$3,899	0	$0	$541	3	$1,623
AMF (O&M)	$0	0	$0	$1,505	1	$1,505
AMF (PRD)	$37,063	0	$0	$5,277	1	$5,277
AMF (LDAR)	$1,428	0	$0	$223	1	$223
AR1,2	$0	0	$0	$192	2	$384
				$7,500	2	$15,000
HF1,3	$0	0	$0	$192	1	$192
				$9,776	1	$9,776
Total (rounded)4		0	$0			$43,900

¹ We have assumed that each source will respond 5 times per year to comply with the rule at a total cost of $192 per source to cover costs. This estimate is based on the assumption that it takes 0.5 hours to conduct these tasks at a clerical labor rate of $61.51 per hour for a total labor cost of $30.76 per response. First-class postage is estimated at $7.63 per response.

² Based on our consultation with affected entities, we estimate that $7,500 per year are required on LDAR monitoring for the AR MACT.

³ Based on our consultation with affected entities, we estimate that 80 technical hours per year are required to maintain and calibrate the scrubber, monitor, and related instruments for the HF MACT unit ($122.20/hr x 80 hr = $9,776).

⁴ 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 $43,900. 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 $43,900. 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. The EPA's overall compliance and enforcement program includes such activities as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $4,830.

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

Managerial $69.04 (GS-13, Step 5, $43.15 + 60%)

Technical $51.23 (GS-12, Step 1, $32.02 + 60%)

Clerical $27.73 (GS-6, Step 3, $17.33 + 60%)

These rates are from the Office of Personnel Management (OPM), 2021 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear at the end of this document in Table 2: Average Annual EPA Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (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 7 existing respondents will be subject to these standards (3 in the PC source category, 1 in the AMF source category, 1 in the HF source category and 2 in the AR source category). It is estimated that no additional respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 7 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	7	0	0	7
2	0	7	0	0	7
3	0	7	0	0	7
Average	0	7	0	0	7

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 7.

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 requirements for PC Production	0	1	N/A	0
Initial requirements for AMF Production	0	1	N/A	0
Initial requirements for AR Production	0	1	N/A	0
Initial requirements for HF Production	0	1	N/A	0
SSM reports for AR Production	2	1	N/A	2
SSM reports for HF Production	1	1	N/A	1
Periodic reports for PC Production	3	2	N/A	6
Periodic reports for AMF Production	1	2	N/A	2
Periodic reports for AR Production	2	2	N/A	4
Periodic reports for HF Production	1	2	N/A	2
LDAR reports for PC Production	3	2	N/A	6
LDAR reports for AMF Production	1	2	N/A	2
LDAR reports for AR Production	2	2	N/A	4
LDAR reports for HF Production	1	2	N/A	2
			Total	31

The number of Total Annual Responses is 31.

The total annual labor costs are $344,000. Details regarding these estimates may be found at the end of this document in Table 1: Annual Respondent Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (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 at the end of this document, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 2,910 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 Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (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 94 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $43,900. 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 97 labor hours at a cost of $4,830; see below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (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 no change in burden from the most-recently approved ICR as currently identified in the OMB Inventory of Approved Burdens. This is due to two considerations: 1) the regulations have not changed over the past three years and are not anticipated to change over the next three yearsp and 2) the growth rate for this industry is very low or non-existent, so there is no significant change in the overall burden. Since there are no changes in the regulatory requirements and there is no significant industry growth, there are also no significant changes in the capital/startup or operation and maintenance (O&M) costs. There is a slight increase in costs, which is wholly due to the use of updated labor rates. This ICR uses labor rates from the most- recent Bureau of Labor Statistics report (March 2021) to calculate respondent burden costs and to update O&M costs.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 94 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.

An agency may neither conduct nor sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OAR-2021-0094. 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. Due to COVID-19 precautions, entry to the Reading Room is available by appointment only. Please contact personnel in the Reading Room to schedule an appointment. 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-OAR-2021-0094 and OMB Control Number 2060-0420 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 Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal)

Burden Item	(A) Person-hours per occurrencea	(B) No. of occurrences per source per yearb	(C) Person-hours per source per year (C=AxB)	(D) Respondents per yearc	(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,$d
1. Applications	N/A
2. Survey and Studies	N/A
3. Reporting Requirements
A. Familiarize with Rule Requirements e	See 4A
B. Required Activities for PC, AMF, AR, HF e	See 4C
C. Create Information for PC, AMF, AR, HF e	See 4C
D. Gather Information for PC, AMF, AR, HF e	See 4C
E. Write report
Initial notification requirements for pressure relief devices
Polycarbonates (PC)	4	1	4	0	0	0	0	$0
Acrylic and Modacrylic Fibers (AMF)	4	1	4	0	0	0	0	$0
General initial notification requirementse, f
Polycarbonates (PC)	52	1	52	0	0	0	0	$0
Acrylic and Modacrylic Fibers (AMF)	52	1	52	0	0	0	0	$0
Acetal Resins (AR)	52	1	52	0	0	0	0	$0
Hydrogen Fluoride (HF)	52	1	52	0	0	0	0	$0
Startup, shutdown and malfunction reportsg
Polycarbonates (PC)	N/A
Acrylic and Modacrylic Fibers (AMF)	N/A
Acetal Resins (AR)	2	1	2	2	4	0.2	0.4	$544.11
Hydrogen Fluoride (HF)	2	1	2	1	2	0.1	0.2	$272.06
Periodic reports h
Polycarbonates (PC)	13.5	2	27	3	108	5.4	10.8	$14,691.08
Acrylic and Modacrylic Fibers (AMF)	15.5	2	31	1	31	1.55	3.1	$4,216.88
Acetal Resins (AR)	8	2	16	2	32	1.6	3.2	$4,352.91
Hydrogen Fluoride (HF)	8	2	16	1	16	0.8	1.6	$2,176.46
Leak detection and repair reportingi
Polycarbonates (PC)	12	2	24	3	72	3.6	7.2	$9,794.05
Acrylic and Modacrylic Fibers (AMF)	12	2	24	1	24	1.2	2.4	$3,264.68
Acetal Resins (AR)	8	2	16	2	32	1.6	3.2	$4,352.91
Hydrogen Fluoride (HF)	8	2	16	1	16	0.8	1.6	$2,176.46
REPORTING SUBTOTAL (Rounded)					388			$45,842
4. Recordkeeping Requirements
A. Familiarize with Rule Requirements
Polycarbonates (PC)	4	1	4	3	12	0.6	1.2	$1,632.34
Acrylic and Modacrylic Fibers (AMF)	4	1	4	1	4	0.2	0.4	$544.11
Acetal Resins (AR)	4	1	4	2	8	0.4	0.8	$1,088.23
Hydrogen Fluoride (HF)	4	1	4	1	4	0.2	0.4	$544.11
B. Plan activities
Polycarbonates (PC)	40	1	40	3	120	6	12	$16,323.42
Acrylic and Modacrylic Fibers (AMF)	40	1	40	1	40	2	4	$5,441.14
Acetal Resins (AR) e	40	1	40	0	0	0	0	$0
Hydrogen Fluoride (HF) e	40	1	40	0	0	0	0	$0
C. Implementation activities
Material determinations e	N/A
Control equipment inspections
a. Tanks
Polycarbonates (PC)	N/A
Acrylic and Modacrylic Fibers (AMF)	2	12	24	1	24	1.2	2.4	$3,264.68
Acetal Resins (AR)	2	12	24	2	48	2.4	4.8	$6,529.37
Hydrogen Fluoride (HF)	N/A
b. Closed-vent systems
Polycarbonates (PC)	2	2	4	3	12	0.6	1.2	$1,632.34
Acrylic and Modacrylic Fibers (AMF)	2	2	4	1	4	0.2	0.4	$544.11
Acetal Resins (AR)	2	2	4	2	8	0.4	0.8	$1,088.23
Hydrogen Fluoride (HF)	2	2	4	1	4	0.2	0.4	$544.11
Control equipment leak monitoring
a. Cover vented to control device
Polycarbonates (PC)	1	2	2	3	6	0.3	0.6	$816.17
Acrylic and Modacrylic Fibers (AMF)	1	2	2	1	2	0.1	0.2	$272.06
Acetal Resins (AR)	1	2	2	2	4	0.2	0.4	$544.11
Hydrogen Fluoride (HF)	1	2	2	1	2	0.1	0.2	$272.06
a. Closed vent system
Polycarbonates (PC)	1	2	2	3	6	0.3	0.6	$816.17
Acrylic and Modacrylic Fibers (AMF)	1	2	2	1	2	0.1	0.2	$272.06
Acetal Resins (AR)	1	2	2	2	4	0.2	0.4	$544.11
Hydrogen Fluoride (HF)	1	2	2	1	2	0.1	0.2	$272.06
Control devices
a. Initial requirements design analysis, performance test
Polycarbonates (PC) e	80	1	80	0	0	0	0	$0
Acrylic and Modacrylic Fibers (AMF)	80	1	80	0	0	0	0	$0
Acetal Resins (AR) e	80	1	80	0	0	0	0	$0
Hydrogen Fluoride (HF) e	80	1	80	0	0	0	0	$0
b. Operate and maintain CMS
Polycarbonates (PC)	8	12	96	3	288	14.4	28.8	$39,176.21
Acrylic and Modacrylic Fibers (AMF)	8	12	96	1	96	4.8	9.6	$13,058.74
Acetal Resins (AR)	8	12	96	2	192	9.6	19.2	$26,117.47
Hydrogen Fluoride (HF)	8	12	96	1	96	4.8	9.6	$13,058.74
Pressure relief devices
Polycarbonates (PC)	2	1	2	3	6	0.3	0.6	$816.17
Acrylic and Modacrylic Fibers (AMF)	2	1	2	1	2	0.1	0.2	$272.06
Leak detection and repair program
a. Initial requirements: Identify all affected streams
Polycarbonates (PC)	2	1	2	0	0	0	0	$0
Acrylic and Modacrylic Fibers (AMF)	2	1	2	0	0	0	0	$0
General Burden e
Polycarbonates (PC)	20	1	20	0	0	0	0	$0
Acrylic and Modacrylic Fibers (AMF)	20	1	20	0	0	0	0	$0
Acetal Resins (AR)	20	1	20	0	0	0	0	$0
Hydrogen Fluoride (HF)	20	1	20	0	0	0	0	$0
b. Perform monitoring/repairs
Polycarbonates (PC) j
Acrylic and Modacrylic Fibers (AMF) j
Acetal Resins (AR)	16	12	192	2	384	19.2	38.4	$52,234.94
Hydrogen Fluoride (HF) k	0.1	1092	109.2	1	109.2	5.46	10.92	$14,854.31
Container vapor tightness certification	N/A
D. Develop Record System
Develop startup, shutdown, malfunction plane, g
Polycarbonates (PC)	N/A
Acrylic and Modacrylic Fibers (AMF)	N/A
Acetal Resins (AR)	20	1	20	0	0	0	0	$0
Hydrogen Fluoride (HF)	20	1	20	0	0	0	0	$0
Control equipment
General Burden e
Polycarbonates (PC)	16	1	16	0	0	0	0	$0
Acrylic and Modacrylic Fibers (AMF)	16	1	16	0	0	0	0	$0
Spinning Lines (AMF)	2	1	2	0	0	0	0	$0
Acetal Resins (AR)	16	1	16	0	0	0	0	$0
Hydrogen Fluoride (HF)	16	1	16	0	0	0	0	$0
Pressure relief devices e
Polycarbonates (PC)	2	1	2	0	0	0	0	$0
Acrylic and Modacrylic Fibers (AMF)	2	1	2	0	0	0	0	$0
Leak detection and repair program e
Polycarbonates (PC)	44	1	44	0	0	0	0	$0
Acrylic and Modacrylic Fibers (AMF)	44	1	44	0	0	0	0	$0
Acetal Resins (AR)	40	1	40	0	0	0	0	$0
Hydrogen Fluoride (HF)	40	1	40	0	0	0	0	$0
E. Record All Information Required by Standards
Initial requirements e
Polycarbonates (PC)	17	1	17	0	0	0	0	$0
Acrylic and Modacrylic Fibers (AMF)	17	1	17	0	0	0	0	$0
Acetal Resins (AR)	17	1	17	0	0	0	0	$0
Hydrogen Fluoride (HF)	17	1	17	0	0	0	0	$0
Control equipment inspections
Polycarbonates (PC)	1	2	2	3	6	0.3	0.6	$816.17
Acrylic and Modacrylic Fibers (AMF)	1	2	2	1	2	0.1	0.2	$272.06
Acetal Resins (AR)	1	2	2	2	4	0.2	0.4	$544.11
Hydrogen Fluoride (HF)	1	2	2	1	2	0.1	0.2	$272.06
Control equipment monitoring l
Polycarbonates (PC)	1	52	52	3	156	7.8	15.6	$21,220.45
Acrylic and Modacrylic Fibers (AMF)	1	52	52	1	52	2.6	5.2	$7,073.48
Acetal Resins (AR)	1	52	52	2	104	5.2	10.4	$14,146.96
Hydrogen Fluoride (HF)	1	52	52	1	52	2.6	5.2	$7,073.48
Control device CMS
Polycarbonates (PC)	1	12	12	3	36	1.8	3.6	$4,897.03
Acrylic and Modacrylic Fibers (AMF)	1	12	12	1	12	0.6	1.2	$1,632.34
Acetal Resins (AR)	1	12	12	2	24	1.2	2.4	$3,264.68
Hydrogen Fluoride (HF)	1	12	12	1	12	0.6	1.2	$1,632.34
Pressure relief devices
Polycarbonates (PC)	2	1	2	3	6	0.3	0.6	$816.17
Acrylic and Modacrylic Fibers (AMF)	2	1	2	1	2	0.1	0.2	$272.06
Leak detection and repair program
Polycarbonates (PC)	20	1	20	3	60	3	6	$8,161.71
Acrylic and Modacrylic Fibers (AMF)	20	1	20	1	20	1	2	$2,720.57
Acetal Resins (AR)	16	1	16	2	32	1.6	3.2	$4,352.91
Hydrogen Fluoride (HF)	16	1	16	1	16	0.8	1.6	$2,176.46
F. Time to Train Personnel
Material determination methods	N/A
Control equipment inspection and monitoring m
Polycarbonates (PC)	8	1	8	3	24	1.2	2.4	$3,264.68
Acrylic and Modacrylic Fibers (AMF)	8	1	8	1	8	0.4	0.8	$1,088.23
Acetal Resins (AR)	8	1	8	2	16	0.8	1.6	$2,176.46
Hydrogen Fluoride (HF)	8	1	8	1	8	0.4	0.8	$1,088.23
Leak detection and repair program h, m
Polycarbonates (PC)	10	1	10	3	30	1.5	3	$4,080.86
Acrylic and Modacrylic Fibers (AMF)	10	1	10	1	10	0.5	1	$1,360.29
Acetal Resins (AR)	2	1	2	2	4	0.2	0.4	$544.11
Hydrogen Fluoride (HF)	2	1	2	1	2	0.1	0.2	$272.06
Container leak tight method	N/A
RECORDKEEPING SUBTOTAL					2,518			$297,794
TOTAL LABOR BURDEN AND COST (Rounded)n					2,910			$344,000
TOTAL CAPITAL AND O&M COST (Rounded)n								$43,900
GRAND TOTAL (Rounded)n								$388,000

Assumptions:

N/A = Not Applicable.

^a Estimate of burden for each activity, technical hours only.

^b Estimate based on average facilities.

^c We have assumed that there are 7 existing sources (3 PC, 1 AMF, 2 AR, and 1 HF) and that no additional new sources will become subject to the rule over the next three years.

^d Costs are rounded and based on the following hourly rates: Technical at $122.20, Management at $153.55, and Clerical at $61.51. These labor rates are based on the United States Department of Labor, Bureau of Labor Statistics, March 2021, “Table 2. Civilian Workers, by occupational and industry group".

^e Since there are no new respondents estimated, these requirements do not apply.

f Initial notification requirements include: initial notifications, initial compliance determination, and initial performance tests.

^g All major sources except for those in the PC and AMF subcategories must submit startup, shutdown, malfunction reports semiannually when actions are taken in the event of a startup, shutdown, or malfunction that are consistent with the source’s SSM plans. Sources can submit this information with the periodic reports.

^h The rules requires that all sources submit periodic reports (semiannually or according to the schedule for Title V).

ⁱ The standards for equipment leak requires the submittal of an initial report and semiannual reports of leak detection and repair (LDAR) and any changes to the processes, monitoring frequency and initiation of a quality improvement program. These estimates assume sources are submitting the required periodic LDAR information with the semiannual reports. Since there are no new respondents estimated, the requirements for a one-time initial report do not apply.

^j Costs for performing monitoring and repairs for the polycarbonates (PC) and acrylic and modacrylic fibers (AMF) categories are accounted for in operation and maintenance costs (i.e. the LDAR program is contracted out instead of conducted in house) (see section 6(b)(iii)).

^k Visual inspections are required once per shift with a total of three shifts per day, at seven days per week, for 52 weeks per year. (3x7x52) for a total of 1,092 inspections per year.

^l We have assumed that control equipment monitoring should be done on a weekly basis.

^m We have assumed that there will be some labor hours associated with rule analysis and training per year.

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

Table 2: Average Annual EPA Burden and Cost – NESHAP for Source Categories: Generic Maximum Achievable Control Technology Standards for Acetal Resin; Acrylic and Modacrylic Fiber; Hydrogen Fluoride and Polycarbonate Production (40 CFR Part 63, Subpart YY) (Renewal)

Burden Item	(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) Agency Cost, $b
REPORT REVIEW
1. Initial Requirements
a. Initial notification c	2	1	2	0	0	0	0	$0
b. Performance test c, d	2	1	2	0	0	0	0	$0
c. Compliance status e	4	1	4	0	0	0	0	$0
d. Performance test reports c, d	4	1	4	0	0	0	0	$0
2. Periodic Requirements
a. Periodic reports	3	2	6	7	42	2.1	4.2	$2,413.11
b. Leak detection and repair reports c, f	3	2	6	7	42	2.1	4.2	$2,413.11
c. Startup, shutdown, malfunction reports c, g	2	1	2	0	0	0	0	$0
TOTAL (Rounded)h						97		$4,830

Assumptions

^a We have assumed that there are 7 existing sources (3 PC, 1 AMF, 2 AR, and 1 HF) and that no additional new sources will become subject to the rule over the next three years.

^b This cost is based on the following hourly labor rates times a 1.6 benefits multiplication factor to account for government overhead expenses: $69.04 for Managerial (GS-13, Step 5), $51.23 for Technical (GS-12, Step 1) and $27.73 Clerical (GS-6, Step 3). These rates are from the Office of Personnel Management (OPM) “2021 General Schedule”, which excludes locality rates of pay.

^c We have assumed there will be no new sources over the next three years of this ICR. Since there are no new respondents estimated, these requirements do not apply.

^d We have assumed that the Agency will not have additional burden from sources conducting performance tests due to a process change that may or may not result in the source meeting additional requirements.

^e Since there are no new respondents estimated, these requirements do not apply.

^f The equipment leak standards require the submittal of an initial report and semiannual report of leak detection and repair (LDAR) program experiencing any changes to the processes, monitoring frequency and initiation of a quality improvement program. We have assumed that sources are submitting the required LDAR information with the periodic reports.

^g All major sources except for those in the PC and AMF subcategories must submit startup, shutdown, malfunction reports semiannually when actions are taken in the event of a startup, shutdown, or malfunction that are consistent with the source’s SSM plans. Since there are no new respondents estimated, the requirements to develop a startup, shutdown and malfunction (SSM) plan do not apply. These estimates assume that sources are submitting their information on SSM with the periodic report which is submitted on a semiannual basis.

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