SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for O ff

- Site Waste and Recovery Operations ( Revised )

1

. Identificatio n of the Information Collection

1(a) Title of the Information Collection

N ational Emission Standards for Hazardous Air Pollutants (NESHAP) for Off

- Site Waste

and Recovery Operations (OSWRO) (40 CFR part 63, s ubpart DD ) ( Revised) , EPA ICR Number

1717.10 , OMB Control Number 2060

- 0 313

. 1(b) Short C haracterization/Abstract

The amendments to this information collection request ( ICR ) are a result of the review of

the existing NESHAP for OSWRO (40 CFR p art 63, s ubpart DD ) as required by the Clean Air

Act (CAA)

. The NESHAP published at 40 CFR part 63, subpart DD were proposed on October

13, 1994, and promulgated on July 1, 1996. The regulation applies to hazardous air pollutant s

(HAP) emissions from selected facilities involved in waste management and recovery operations

that are not subject to Fed eral air standards under other subparts in 40 CFR part 63, and

commencing construction, modification or reconstruction after the date of proposal if the facility

is a major source of HAP emissions, as defined in general provisions to 40 CFR part 63. In

add ition, 40 CFR part 63, subpart DD cross

- references control requirements to be applied to

specific types of affected sources: tanks

- level 1; containers; surface impoundments; individual

drain systems; oil

- water separators; organic water separators; and load ing, transfer, and storage

systems. This information is being collected to assure compliance with 40 CFR part 63, subpart

DD. Organic HAP emissions are the pollutants regulated under this subpart.

In general, all NESHAP standards require initial notificati ons, performance tests, and

periodic reports by the owners/operators of the affected facilities. These notifications, reports,

and records are essential in determining compliance, and are required of all affected facilities

subject to NESHAP. Semi

- annual s ummary reports are also required.

The proposed rulemaking would amend title 40, c hapter I, part 63 subpart DD revising

the leak detection and repair (LDAR) requirements. In addition, the proposed amendments also

add requirements to monitor each pressure re lief device (PRD) that releases to the atmosphere

using a device or system that is capable of identifying and recording the time and duration of2

each pressure release and of notifying operators that a release has occurred . Information related

to these new provisions is required to be submitted in the semi

- annual reports required by the

existing NESHAP. In addition, the EPA is proposing to require storage vessels of certain sizes

and containing materials above certain vapor pr essures to use Level 2 controls (i.e., obtain a 95

percent organic HAP emissions reduction). Burden changes associated with these proposed

amendments would result from new recordkeeping and reporting requirements associated with

the LDAR and PRD monitoring requirements for all facilities subject to subpart DD.

The Office of Management and Budget (OMB) approved the currently active ICR

without any “Terms of Clearance.” The overall change in burden found in this ICR reflect the

provision changes, an update i n the cost of labor, and corrections to the number of affected

facilities found in EPA ICR number 1717.0 9

. The period considered in this ICR and throughout this supporting statement is the first

three years following the promulgation of the amended OSWRO N ESHAP. The estimates of the

size of the r egulated universe are based on data from the National Emissions Inventory (NEI)

database , available permit data and information collected in the 2013 OSWRO ICR survey

.

There is an estimate d 5 2 major source facilitie s in the OSWRO source category . Based on

available permit information, seven facilities are known to be exempt from most of the rule

requirements due to the low HAP content of the off

- site waste they receive. These facilities are

not expected to be affecte d by the proposed rule. Therefore, we estimate that t here is an annual

average of 45 respondents that wi ll be subject to the regulation

. We do not know of any new

facilities that are expected to be construc ted in the foreseeable future

, so consequently it is

estimated that no additional sources will become subject to the standard over the next three

years.

2

. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 112 of the CAA , as amended, to establish standards of

performance for each category or subcategory of major sources and area sources of HAP

. These

standards are applicable to new or existing sources of HAP and must require the maximum

degree of emission reduction

. In addition, section 114(a) of t he CAA states that the

Administrator may require any owner or operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports;3

(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 par ameters, 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 r equire.

In the Administrator's judgment, HAP emissions from OSWRO facilities cause or

contribute to air pollution that may reasonably be anticipated to endanger public health or

welfare

. Therefore, the NESHAP standards were promulgated for this source cate gory at 40 CFR

part 63, subpart DD

. 2(b) Prac tical 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 CAA. In addition, the

collected information is 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 emissio n standard. Continuous emission monitors are used to

ensure compliance w ith the standard at all times. During the performance tests, 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 ensure that the pollution control devices are properly

installed and operated, that leaks are being detected and repaired, and that the standards are being

met

. The perform ance test may also be observed.

The required semi

- annual reports are used to determine periods of excess emissions,

i dentify problems at the facility, verify operation/maintenance procedures, and for compliance

determinations.4

The information generated by the monitoring, recordkeeping and reporting requirements

described in this ICR is used by the Agency to ensure that facilities affected by the NESHAP

continues to operate the control equipment in compliance with the regulation.

3

. Non

- duplication, Consultations, and Other Collection Criteria

3(a) Non

- duplication

A search of the EPA’ s exi sting standards and ongoing ICR s revealed no duplication of

information gathering efforts. However, certain reports required by s tate or local agencies may

duplicate information required by this NESHAP

. In these cases , a copy of the report submitted to

the s tate or local agency can be se nt to the Administrator in lieu of the report required by the

Federal standards

. Th erefore, no duplication exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

This ICR is related to proposed amendments to 40 CFR part 63, subpart DD for the

OSWRO source category

. Comments will be solicited on the proposal package and the proposed

ICR.

3(c) Consultations

Over the next three years, an average of 4 5 facilities per year will be subject to the

standard, with no additional sources per year b ecomin g subject to the standard . In estimating the

affected number of so urces and the growth rate of OSWRO facilities subject to this standard

during a previous renewal, we referenced the most recent ICR, and used other resources to obtain

the most recent data a vailable. We reviewed information available from the Online Tracking

Information System (OTIS)

, which is the primary source of information regarding the number of

existing sources. OTIS data was used in conjunction with industry consultation to verify the

number of sources and the industry growth rate.

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 gather ing 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 mainten ance of control equipment and the

possibility of detecting violations would be less likely.5

3(e) General Guidelines

T hese reporting or recordkeeping requirements are consistent with the regulations

established by OMB at 5 CFR part 1320, section 1320.5

. These standards require the respondents to maintain all records, including reports and

notifica tions for at least five years. This is consistent with the General Provision s as applied to

the standards. EPA believes that the five

- year records retention requ irement 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

- comp liance, and to determine the appropriat e level of enforcement

action. The EPA has found that the most flagrant violators have violations ex tending beyond the

five years. Without the five

- year record retention, the 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, ch apter 1, part 2,

subpart B

- Confidentiality of Business Information (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

None of the reporting or recordkeeping requirements contain sensitive questions

.

4

. The Respondent s and the Information Requested

4(a) Respondents

The respondents to the recordkeeping and reporting requirements are OSWRO that store,

treat, recycle, reprocess, or dispose of wastes containing organic chemical compounds. The

United States Standard Industrial Classification (SIC) codes, which correspond to the North

American Industry Classification System (NAICS) codes, could be found in the following table:

Off

- site Waste and Recovery Operations (40 CFR part 63, subpart DD) NAICS

Crude Petroleum and Natural Gas Extraction 211111

Water Supply and Irrigation Systems 2213106

Off

- site Waste and Recovery Operations (40 CFR part 63, subpart DD) NAICS

Highway, Street, and Bridge Construction 237310

Petroleum Refineries 324110

Other Basic Inorganic Chemical Manufacturing 325180

Cyclic Crude, Intermediate, and Gum and Wood Chemical Manufacturing 325194

All Other Basic Organic Chemical Manufacturing 325199

Plastics Material and Resin Manufacturing 325211

Cement Manufacturing 327310

Alumina Refining and Primary Aluminum Production 331313

Photographic and Photocopying Equipment Manufacturing 333316

Aircraft Manufacturing 336411

Other Chemical and Allied Products Merchant Wholesalers 424690

Office Administrative Services 561110

Solid Waste Collection 562111

Hazardous Waste Treatment and Disposal 562211

Solid Waste Combustion and Incinerators 562213

Other Nonhazardous Waste Treatment and Disposal 562219

Materials Recovery Facilities 562920

National Security a 928110

a One facility is operated by the U.S. Department of Defense. Small business size standards are

not established for this sector.

4(b) Information Requested

None of these reporting and recordkeeping requirements violate any of the regulations

established by OMB at 5 CFR part 1320, section 1320.5.

(i) Data Items

All data in this ICR that is recorded and/or reported is required by NESHAP for OSWRO

(40 CFR part 63, subpart DD).

A source must make the following notifications :7

Notifications for 40 CFR part 63, subpart DD

Notification and application of con struction/reconstruction 63.5(d)

Notific ation of initial startup 63.9(b)

Notification of initial perf ormance test 63.7(b) and 63.9(e)

Rescheduled ini tial performance test 63.7(b)(2)

Demonstration of cont inuous monitoring system 63.9(g)

Complian ce status 63.9(h)

Notification o f performance tests 63.7(b) and 63.697(b)(1)

Performa nce test results 63.8(e)(5) and 63.697(b)(2)

Notification of tank floating roof inspection and seal gap

measurements 63.6 97 ( c )

A source must make the following reports:

Reports for 40 CFR part 63, subpart DD

Initial performance test results 63.10(d)(2)

Excess emission reports 63.10(e)(3)

Initial pressure relief device description 63.697(a)(1)

Malfunction reports (included with semi

- annual reports) 63.697(b)(3)

Semi

- annual summary report 63.697(b)(4)

- (6)

A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart DD

R eports and notifications 63.10(b) (1) and 63.10(b)(2)(vi)

- (xi)

Record of applicability 63.10(b)(3)

Records of sources with continuous monitoring systems 63.10(c)

Records of tank floating roof design, i nspections, defects and repairs 63.69 6(d)

Records of tank fixed roof inspections, defects and repairs 63.696(e)

Records of tank enclosure measurements and calculations 63.696(f)

Records of anticipated and completed planned routine

maintenance 63.696(g)8

Control device malfunction records 63.696(h)

Records of releases from pressure relief devices 63.696(i)

Records of control device bypasses 63.696(j)

Records should be r etained for 5 years. 63.10(b)(1)

Currently, sources are using monitoring equipment that automatically records parameter

data. Although personnel at the source still need to evaluate the data, this type of monitoring

equipment has significantly reduced the burden associated with monitoring and recordkeeping.

However for this rule, we are only proposing electronic reporting of performance tests.

(ii) Respondent A ctivities

Respondent Activities

Read instructions.

Install, calibrate, maintain and operate CMS

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

and calculations.

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.

Adjust existing ways to comply with any previously applicable instructions and requirements.

Transmit, or otherwise disclose the information.

5

. The Information Collected: Agency Activities, Collection Methodol ogy, and Info rmation

Management

5(a) Agency Activities

The EPA conducts the following activities in connection with the acquisition, analysis,

storage, and distribution of the required information.9

Agency Activities

Observe initial performance tests and repeat performance tests if necessary. Review notifications and reports, including performance test reports, and malfunction reports required to be submitted by industry. Audit facility records. Input, analyze and maintain data in the Online Tracking Information System (OTIS).

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 standard, and note the operating conditions under which compliance was achieved.

Data and records maintained by the respondents are tabulated and publ ished 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 entered into OTIS w hich is operated and

maintained by EPA's Office of Compliance. OTIS 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 OTIS 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 retai ned by the owner/operator for five

years.

5(c) Small Entity Flexibility

The impact on small entities was taken into consideration during the development of the

regulation. Due to technical considerations involving the process operations and the type of

c ontrol 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 ent ities

. 5(d) Collection Schedule

The specific frequency for each information collection activity within this request is10

shown below in Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping

Requirements for the Proposed NESHAP for OSWRO (40 CFR part 63, s ubpart DD) (Revised)

.

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 indust ry 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

. Wherever appropriate, specific tasks and

major assumptions hav e been identified

. Responses to this inform ation 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 C ontrol Number.

6(a) Estimat ing Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping

and reporting requirements is estimated to be 45, 147 ( Total Labor Hours from Table 1)

. These

hours are based on Agency studies and background doc uments from the development of the

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6( b) E stimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Technical $54.66 ($26. 29 + 110%)

Managerial $115.96 ($55. 81 + 110%)

Clerical $38.14 ($18. 39 + 110%)

These labor rates are based on the May 201 3 National Occupational Employment and Wage

Estimates for the United States for Production Occupations

( http://www.bls.gov/oes/current/oes_nat.htm#51

- 0000 ) , occupational codes 51

- 8091 for

chemical plant and system operators (technical), 11

- 1021 f or general and operations managers

(managerial) and 43

- 6010 for secretaries and administrative assistants (clerical).

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

The type of industry costs associated with the information collect ion activities in the

subject standard are labor costs which are addressed elsewhere in this ICR and the costs

associat ed with continuous monitoring. The capital/startup costs are one

- time costs when a11

facility becomes subject to the regu lation. The annual operation and maintenance costs are the

ongoing costs to maintain the monitor and other costs su ch as photocopying and postage.

As part of the proposed amendments to the OSWRO NESHAP, facility owners or

operators are required to monitor each PRD that rele ases to the atmosphere using a device or

system that is capable of identifying and recording the time and duration of each pressure release

and of notifying operators that a release has occurred. For purposes of estimating the costs of this

requirement, we assumed that operators would install electronic indicators on each PRD in

organic HAP service that vents to the atmosphere. The cost of each monitoring system depends

on the number of PRDs at the facilities. For OSWRO facilities, based on information rece ived in

the 2013 ICR survey, there is an average of 13 PRDs at each plant. The cost for this system for

the 4 5 affected facilities in the OSWRO source category is expected to be $ 1

. 75 million

. For

equipment leaks, facility owners or operators would also be required to follow the leak detection

and repair (LDAR) requirements of 40 CFR part 63, subpart H, rather than 40 CFR part 63

, subpart V under the proposed amendments to the OSWRO NESHAP, inc luding connector

monitoring requirements. The capital costs associated with this requirement are estimated to be

$1. 9 million. The proposed rule require s storage vessels of certain sizes and containing materials

above certain vapor pressures to use Level 2 controls. Compared to current requirements, t h e

proposed requirement s lower the vapor pressure threshold at which control is required for tanks

of certain sizes

, making additional storage tanks subject to the use of Level 2 controls

. In

determining the im pacts of the proposed requirements, it was assumed that tanks requiring

control will be routed to an existing control device. Consequently, the only costs associated with

the proposed requirement s are the cost s of additional duct work for the estimated 21 additional

tanks that would be controlled with Level 2 controls under the proposed new threshold. The

capital costs associated with the additional duct work w ere estimated at approximately $ 76, 000

with an annual cost of approximately $ 2 1,000

.

Based on a previous ICR for the Pesticide Active Ingredient source category, which

estimated the annual O&M costs to be $1,450 per source in 2011 dollars, inflating this number

from 2011 dollars to 2013 dollars gives $1,505 per source. The total annual O&M cost for the

OSWRO source category is approximately $6 8

, 00 0. For the PRD monitors, a nnualized costs are

calculated by multiplying the capital recovery factor by the capital cost. The capital recovery

factor is 0.1 424 based on an interest rate of 7 percent and an assumed equipment life of 1 0 years.12

For the proposed LDAR requirements, the capital recovery factor is also 0.1424, and for storage

tank requirements, t he capital recovery factor is 0. 1098 based on an interest rate of 7 percent and

an assumed equipment life of 1 5 years

. In addition, for the LDAR and storage tank requirements,

other annual monitoring and operating costs are included in the annual costs . The total annual

cost for the proposed PRD, LDAR and storage vessels requirements is approximately $ 804 ,000.

(iii) Capital/Startup and Operation and Maintenance (O&M) Costs

Capital/Startup and Operation and Maintenance (O&M) Costs

(A) Cost Type (B)

Capital/
Startup Cost

for One Respondent (C)

Number of

New Respondents (D)

Total Capital/ Startup Cost (B X C) (E)

Annual Costs

for One Respondent (F)

Number of Respondents (G)

Total

Annual

Cost (E X F)

O&M $0 45 $0 $1,505 45 $6 7,725

LDAR $41,254 45 $1,8 56

, 430 $11,876 45 $5 34,420

PRD Monitoring Equipment $38,886 45 $1,7 49,870 $5,537 45 $2 49,165

Storage Tanks

Duct Work 1 $76,412

- $76,412 $20,797

- $20,797

Total $3, 682,712 $ 872,107

1 C ost s shown are the total costs for the estimated 21 additional tanks captured under the proposed new threshold.

The total capital/startup costs for this ICR are $ 3

, 682,712

. This is the total of column D

in the above table. The total annual and operation and maintenance (O&M) costs for this ICR are

$ 872

, 107 and is shown in column G.

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 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 a nd distrib ution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be

$ 20

, 221

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

Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%)

Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%)13

These rates are from the Office of Personnel Management (OPM), 2013 General

Schedule, which excludes locality rates of pay (http://www.opm.gov/policy

- data

- oversig ht/pay

leave/salaries

- wages/2013/general

- schedule/2013

- gs

- hourlyovertime

- rates

- by

- grade

- and

- step/)

. 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 for the Proposed NESHAP for OSWRO (40 CFR part 63, s ubpart

DD) (Revised)

. 6(d) Estimating the Respondent Universe and Total Burden and Costs

The number of major source respondents was updated based on t he NEI database, which

was used during the analysis to determine the MACT . The EPA also used available permit data

and information collected in the 2013 OSWRO ICR survey

. The number of respondents is

calculated using the following table which addresses the 3 years covered by this ICR. Over the

three year period of this ICR, we expect 4 5 existing facilities to be respondents.

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

YEAR ( A ) ( B ) ( C ) ( D ) (E)

Number of

New Respondents Number

Existing Respondents Number of Existing

Respondents T hat Keep Records But
Do Not Submit Reports Number of

Existing Respondents That

Are Also New Respondents Number of

Respondents (E=A+B+C

- D)

1 0 45 0 0 45

2 0 45 0 0 45

3 0 45 0 0 45

Av erage 0 45 0 0 45

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 4 5

.14

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)

Initial notification (PRD) 45 0.33 0 15

Semiannual periodic report 45 2 0 90

Total Number of Annual Responses 10 5

The numb er of Total Annual Responses is 10 5

. 6(e) Bottom Line Burden Hou rs 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, respe ctively, and summarized below.

(i) Respondent Tally

The average annual respondent burden and cost over next three years is estimated to be

45, 147 l abor hours at a cost of $2,5 23,181

. See below Table 1: Annual Respondent Burden and

Cost of Reporting and Recordkeeping Requirements for the Proposed NESHAP for OSWRO (40

CF 93 R Part 63, Subpart DD) (Revised)

.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 4 49

l abor hou rs at a cost of $20, 221

. See below Table 2: Average Annual EPA Burden for the

Proposed NESHAP for OSWRO (40 CFR part 63, s ubpart DD) (Revised)

. 6(f) Reasons for Change in Burden

The proposed rul emaking would amend title 40, chapter I, part 63 subpart DD to include

revisions to the storage tank requirements , revisions to the LDAR requirements and requirements

to monitor PRDs. The number of affected facilities under this subpart is not expected to increase.

At this time, none of the proposed amendments will affect area sources. The overall change in

burden found in this ICR reflect the provision changes, an update in the cost of labor, an update

to the number of affected facilities and corrections t o errors found in EPA ICR number 1717.09

.15

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of info rmation

is estimated to average 4 30 hours per response

. Burden means the total time, effort, or financial

resources expended by persons to generate, maintain, retain, disclose or provide information to

or for a Federal agency

. This includes the time needed to review instructions; to 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; to adjust the existing ways to comply with any previously applicable instructions

and requirements; to train personnel to be able to respond to a collection of information; to

search data sources; to complete and review the collection of information; and to transmit or

othe rwise 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 ’ s regulations are listed at 40 CF R 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

- 2012

- 0 360. An electronic v ersion 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

c ontent of the docket, and to access those documents in the public docket that are available

electronically. When in the system, select “search” than key in the docket ID number identified

in this document. The documents are also available for public view ing at the Enforcement and

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West,

Room 3334, 1301 Constitution Avenue, N.W., Washington, DC. The EPA Docket Center Public

Reading Room is open from 8:30 a.m. to 4:30 p.m., Mond ay through Friday, excluding legal

holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone

number for the Enforcement and Compliance Docket and Information Center Docket is (202)

566

- 1752

. Also, you can send comments to t he Office of Information and Regulatory Affairs,

Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention:

Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OAR

- 2012

- 0 36016

and OMB Control Number 2060

- 0313 i n 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 of Reporting and Recordkeeping Requirements for the
Proposed NESHAP for OSWRO (40 CFR part 63, s ubpart DD ) ( Revised )

Burden Item Person

hours per

occurrence (a) No. of

occurrences

per source per year (b) Person

hours per

source per year (C=AxB) Respondent s

per year Technical

person

hours

per year (E=CxD) Management

person

- hours

per year (Ex0.05) Clerical

person

hours

per year (Ex0.1) Cost,$ (c) (D)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read instructions 4 1 4 45 180 9 18 $11,569

B. Required activities Included in

4C

C. Create information Included in

4C

D. Gather existing information Included in

4C

E. Write report

Initial notification report (d) 1 0.33 0.33 45 14.85 0.7425 1.485 $954

Semiannual summary report 8 2 16 45 720 36 72 $46,276

REPORTING SUBTOTAL (Rounded) 1,052 $58,799

4. Recordkeeping Requirements

A. Read instructions 8 1 8 45 360 18 36 $23,138

B. Plan activities 40 1 40 0 0 0 0 $0

C. Implementation activities

a. VOHAP concentration determination

Commercial facilities (e) 2 260 520 23 11,960 598 1,196 $768,693

Other facilities (f) 2 12 24 23 552 28 55 $35,478

b. Vapor pressure determination18

Commercial facilities (e) 1 260 260 23 5,980 299 598 $384,347

Other facilities (f) 1 12 12 23 276 14 28 $17,739

c. Control equipment visual inspection

Large cover 0.25 10 2.5 45 113 6 11 $7,231

Small cover 0.05 1000 50 45 2,250 113 225 $144,612

Closed vent system 0.5 5 2.5 45 113 6 11 $7,231

d. Control equipment leak monitoring

Cover vented to control device 1 5 5 45 225 11.25 22.5 $14,461

Closed vent system 1 5 5 45 225 11.25 22.5 $14,461

e. Control devices

Performance determination 40 1 40 0 0 0 0 $0

Continuous monitoring system 8 5 40 45 1,800 90 180 $115,690

f. LDAR program

Identify affected waste streams 40 1 40 0 0 0 0 $0

Perform monitoring/repair 80 1 80 45 3,600 180 360 $231,379

g. PRD monitoring

Identification of PRD devices 8 1 8 0 0 0 0 $0

Perform monitoring/repair 16 1 16 45 720 36 72 $46,276

D. Develop record system

Control equipment 16 1 16 0 0 0 0 $0

LDAR program 40 1 40 0 0 0 0 $0

PRD program 8 1 8 45 360 18 36 $23,138

E. Time to enter information

Cover designs 40 1 40 0 0 0 0 $0

Control device design 40 1 40 0 0 0 0 $0

Control equipment testing 1 1 1 0 0 0 0 $0

Control equipment inspections 1 1 1 45 45 2 5 $2,892

Control equipment monitoring 1 1 1 45 45 2 5 $2,892

Control device CMS 1 52 52 45 2,340 117 234 $150,39619

LDAR program 4 16 64 45 2,880 144 288 $185,103

PRD program 2 16 32 45 1,440 72 144 $92,552

Off

- site material determinations 1 52 52 45 2,340 117 234 $150,396

F. Time to train personnel

Waste determination methods 40 1 40 0 0 0 0 $0

Control equipment inspect and monitor 40 1 40 0 0 0 0 $0

LDAR program 8 1 8 45 360 18 36 $23,138

PRD program 8 1 8 45 360 18 36 $23,138

G. Time for audits N/A

RECORDKEEPING SUBTOTAL (Rounded) 44,094 $2,464,381

TOTAL LABOR BURDEN AND COST (Rounded) 45,147 $2,523,18120

Table 2: Average Annual EPA Burden for the Proposed NESHAP for OSWRO (40 CFR part 63, s ubpart DD ) (Revised)

Burden Item (A) (B) (C) (D) (E) (F) (G) (H)

EPA person

hours per

occurrence No. of

occurrences per plant

per year EPA person

hours per plant per

year (C=AxB) Plants

per

year Technical

person

hours per

year (E=CxD) Management

person

- hours

per year (Ex0.05) Clerical

person

hours per year (Ex0.1) Cost,$

(a)

REPORT REVIEW

New Plants

Initial notification (PRD) (b) 2 0.33 0.67 45 30.2 1.5 3.02 $1,5 64

Performance test notification 1 0 0 0 0 0 0 $0

Compliance status notification 4 0 0 0 0 0 0 $0

Performance test report 16 0 0 0 0 0 0 $0

Existing Plants

Semiannual summary report 4 2 8 45 360 18 36 $ 18,657
TOTAL ANNUAL EPA BURDEN AND COST (Rounded) 4 49 $20, 221 (a) Agency labor rates are from the Office of Personnel Management (OPM) 2013 General Schedule which excludes locality rates of pay. Salary Table 2013

- GS.

Labor rates are inflated to reflect average locality pay increase from base rates. Available at http://www.opm.gov/policy

- data

- oversight/pay

- leave/salaries

wages/2013/general

- schedule/2013

- gs

- hourlyovertime

- rates

- by

- grade

- and

- step/.

(b) Assumes 1 PRD initial notification in the 3 years.