SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Off-Site Waste and Recovery Operations (Revised)

1. Identification of the Information Collection

1(a) Title of the Information Collection

National Emission Standards for Hazardous Air Pollutants (NESHAP) for Off-Site Waste 

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

1717.10, OMB Control Number 2060-0313. 

1(b) Short Characterization/Abstract

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

the existing NESHAP for OSWRO (40 CFR part 63, subpart 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 pollutants

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

that are not subject to Federal 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 

addition, 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 loading, 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 notifications, performance tests, and 

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

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

subject to NESHAP. Semi-annual summary reports are also required.

The proposed rulemaking would amend title 40, chapter 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 relief device (PRD) that releases to the atmosphere

using a device or system that is capable of identifying and recording the time and duration of 
2

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 pressures 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 in the cost of labor, and corrections to the number of affected 

facilities found in EPA ICR number 1717.09.

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

three years following the promulgation of the amended OSWRO NESHAP. The estimates of the 

size of the regulated 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 estimated 52 major source facilities 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 affected by the proposed rule. Therefore, we estimate that there is an annual 

average of 45 respondents that will be subject to the regulation. We do not know of any new 

facilities that are expected to be constructed 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 the 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; 
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(C) install, use, and maintain such monitoring equipment, and use 

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may 

reasonably require.

In the Administrator's judgment, HAP emissions from 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 category at 40 CFR 

part 63, subpart DD.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensure compliance with the 

applicable regulations which were promulgated in accordance with the 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 emission standard. Continuous emission monitors are used to 

ensure compliance with 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 performance test may also be observed.

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

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

determinations.
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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 existing standards and ongoing ICRs revealed no duplication of 

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

duplicate information required by this NESHAP. In these cases, a copy of the report submitted to 

the state or local agency can be sent to the Administrator in lieu of the report required by the 

Federal standards. Therefore, no duplication exists.

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

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 45 facilities per year will be subject to the 

standard, with no additional sources per year becoming subject to the standard. In estimating the 

affected number of sources 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 available. 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 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.
5

3(e) General Guidelines

These 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 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the 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. The EPA has found that the most flagrant violators have violations extending 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, chapter 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 Respondents 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 221310
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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 Securitya928110

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:
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Notifications for 40 CFR part 63, subpart DD

Notification and application of construction/reconstruction 63.5(d)

Notification of initial startup 63.9(b)

Notification of initial performance test 63.7(b) and 63.9(e)

Rescheduled initial performance test 63.7(b)(2)

Demonstration of continuous monitoring system 63.9(g)

Compliance status 63.9(h)

Notification of performance tests 63.7(b) and 63.697(b)(1)

Performance test results 63.8(e)(5) and 63.697(b)(2)

Notification of tank floating roof inspection and seal gap 

measurements

63.697(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

Reports 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, inspections, defects and 

repairs 63.696(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)
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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 retained 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 Activities

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 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.
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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 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 entered into OTIS which 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 retained 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

control equipment employed, the recordkeeping and reporting requirements are the same for both

small and large entities. The Agency considers these requirements the minimum needed to 

ensure compliance and, therefore, cannot reduce them further for small entities. 

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 
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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, subpart 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 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. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

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

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

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 2013 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 for 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 collection activities in the 

subject standard are 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 
11

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

ongoing costs to maintain the monitor and other costs such 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 releases 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 received in 

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

the 45 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, including connector 

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

$1.9 million. The proposed rule requires storage vessels of certain sizes and containing materials 

above certain vapor pressures to use Level 2 controls. Compared to current requirements, the

proposed requirements 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 impacts 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 requirements are the costs 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 were estimated at approximately $76,000

with an annual cost of approximately $21,000.

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 $68,000. For the PRD monitors, annualized costs are 

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

factor is 0.1424 based on an interest rate of 7 percent and an assumed equipment life of 10 years. 
12

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

tank requirements, the capital recovery factor is 0.1098 based on an interest rate of 7 percent and 

an assumed equipment life of 15 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 $67,725

LDAR $41,254 45 $1,856,430 $11,876 45 $534,420

PRD Monitoring 

Equipment $38,886 45 $1,749,870 $5,537 45 $249,165

Storage Tanks 

Duct Work1

$76,412 - $76,412 $20,797 - $20,797

Total $3,682,712 $872,107

1Costs 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 and distribution 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%)
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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-oversight/payleave/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, subpart 

DD) (Revised).

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

The number of major source respondents was updated based on the 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 45 existing facilities to be respondents. 

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

YEAR

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

Number of 

New 

Respondents

Number 

Existing 

Respondents

Number of Existing 

Respondents That 

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

Average 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 45.
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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 105

The number of Total Annual Responses is 105.

6(e) Bottom Line Burden Hours 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, respectively, and summarized below. 

(i) Respondent Tally

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

45,147 labor hours at a cost of $2,523,181. See below Table 1: Annual Respondent Burden and 

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

CF93R Part 63, Subpart DD) (Revised).

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 449

labor hours at a cost of $20,221. See below Table 2: Average Annual EPA Burden for the 

Proposed NESHAP for OSWRO (40 CFR part 63, subpart DD) (Revised).

6(f) Reasons for Change in Burden

The proposed rulemaking 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 to errors found in EPA ICR number 1717.09. 
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6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information 

is estimated to average 430 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 

otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a valid OMB Control Number. The OMB Control 

Numbers for EPA’s 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-2012-0360. 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 

content 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 viewing 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., Monday 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 the 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-2012-0360 
16

and OMB Control Number 2060-0313 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 of Reporting and Recordkeeping Requirements for the 

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

Burden Item

Personhours per 

occurrence 

(a)

No. of 

occurrences 

per source 

per year (b)

Personhours per 

source per 

year (C=AxB)

Respondents 

per year

Technical 

personhours 

per year 

(E=CxD)

Management 

person-hours 

per year 

(Ex0.05)

Clerical 

personhours 

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 determination
18

 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 1136 11 $7,231 

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

 Closed vent system 0.55 2.5 45 1136 11 $7,231 

 d. Control equipment leak monitoring

 Cover vented to control device155 45 225 11.25 22.5 $14,461 

 Closed vent system155 45 225 11.25 22.5 $14,461 

 e. Control devices

 Performance determination 401 400000 $0 

 Continuous monitoring system85 40 45 1,800 90 180 $115,690 

 f. LDAR program

 Identify affected waste streams 401 400000 $0 

 Perform monitoring/repair 801 80 45 3,600 180 360 $231,379 

 g. PRD monitoring

 Identification of PRD devices8180000 $0 

 Perform monitoring/repair 161 16 45 720 36 72 $46,276 

 D. Develop record system

 Control equipment 161 160000 $0 

 LDAR program 401 400000 $0 

 PRD program818 45 360 18 36 $23,138 

 E. Time to enter information

 Cover designs 401 400000 $0 

 Control device design 401 400000 $0 

 Control equipment testing1110000 $0 

 Control equipment inspections111 45 4525 $2,892 

 Control equipment monitoring111 45 4525 $2,892 

 Control device CMS1 52 52 45 2,340 117 234 $150,396 
19

 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 $2,523,181 
20

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

Burden Item

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

EPA personhours per 

occurrence

No. of 

occurrences 

per plant 

per year

EPA personhours per 

plant per 

year 

(C=AxB)

Plants 

per 

year

Technical 

personhours per 

year 

(E=CxD)

Management 

person-hours 

per year 

(Ex0.05)

Clerical 

personhours 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 $1,564

 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) 449 $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/salarieswages/2013/general-schedule/2013-gs-hourlyovertime-rates-by-grade-and-step/.

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