SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) 

(Renewal), EPA ICR Number 1717.09, OMB Control Number 2060-0313

1(b) Short Characterization/Abstract

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

Waste and Recovery Operations were: proposed on October 13, 1994; promulgated on July 1, 

1996; and last amended on June 23, 2003. These regulations apply to existing facilities and new 

facilities with organic hazardous air pollutant (HAP) emissions that are involved in waste 

management and recovery operations, and that are not subject to Federal air standards under 

other subparts in part 63. In addition, subpart DD cross-references control requirements to be 

applied to specific types of affected sources: tankslevel-1; containers; surface impoundments; 

individual drain systems; oil-water separators; organic water separators; and loading, transfer, 

and storage systems. New facilities include those that commenced construction or reconstruction 

after the date of proposal. This information is being collected to assure compliance with 40 CFR 

part 63, subpart DD.

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 the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U.S.

Environmental Protection Agency (EPA) regional office.

 Based on our consultations with industry representatives, there is an average of one 

affected facilities at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

Over the next three years, an average of 236 respondents per year will be subject to the 

standards, and no additional respondents per year will become subject to the standards. 
2

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

without any “Terms of Clearance.”

The burden to the “Affected Public” may be found below in Table 1: Annual Respondent 

Burden and Cost – NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, 

Subpart DD) (Renewal). The Federal Government “burden” is attributed entirely to work 

performed by either Federal employees or government contractors, and may be found below in 

Table 2: Average Annual EPA Burden and Cost – NESHAP for Off-Site Waste and Recovery

Operations (40 CFR Part 63, Subpart DD) (Renewal). 

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, HAP emissions from off-site waste and recovery

operations cause or contribute to air pollution that may reasonably be anticipated to endanger 

public health or welfare. Therefore, the NESHAP 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 where 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 
3

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test a record of the 

operating parameters under which compliance was achieved may be recorded and used to 

determine compliance in place of a continuous emission monitor. 

The notifications required in the standards are used to inform either the Agency or its

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, and/or leaks are being detected and repaired, and the standard is

being met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

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

determinations.

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

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart

DD.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency 

can be sent to the Administrator in lieu of the report required by the Federal standards. 

Therefore, duplication does not exist.

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

An announcement of a public comment period for the renewal of this ICR was published 

in the Federal Register (78 FR 33409) on June 4, 2013. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts. 
4

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 

has been reviewed previously to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted: 1) the Solid Waste Association of North 

America (SWANA), at (800) 467-9262; and 2) Safety-Kleen, at (800) 323-5040.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet 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.

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 

the standards. EPA believes that the five-year records retention requirement is consistent the 

Part 70 permit program and the five-year statute of limitations on which the permit program is 

based. The retention of records for five years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 
5

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are off-site waste and 

recovery operations that store, treat, recycle, reprocess, or dispose of wastes containing organic 

chemical compounds. 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 in the table below. 

Standard (40 CFR Part 63, Subpart DD) SIC Codes NAICS Codes

Petrochemical Manufacturing 2869 325110

All Other Basic Inorganic Chemical Manufacturing 2869 325188

Cyclic Crude and Intermediate Manufacturing 2689 325192

Ethyl Alcohol Manufacturing 2689 325193

All Other Basic Organic Chemical Manufacturing 2689 325199

Industrial Gas Manufacturing 2689 325120

All Other Miscellaneous Chemical Product and 

Preparation Manufacturing 2689 325998

Plastic Materials and Resin Manufacturing 2821 325211

Explosives Manufacturing 2892 325920

Carbon Black Manufacturing 2816 325182

Inorganic Dye and Pigment Manufacturing 2816 325131

Semiconductor and Related Device Manufacturing 3674 334413

Petroleum Refineries 2911 324110

Aircraft Manufacturing 3721 336411

Aircraft (research and development not producing 

prototypes) 3721 541710

Other General Government Support 9199 921190

All Other Petroleum and Coal Products Manufacturing 3312 324199

Iron and Steel Mills 3312 331111

Rolled Steel Shape Manufacturing 3312 331221

 
6

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for OffSite Waste and Recovery Operations (40 CFR Part 63, Subpart DD). 

A source must make the following reports:

Notifications

Notification and application of construction/reconstruction 63.5(d)

Notification of initial startup 63.9(b)

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

Rescheduled initial performance test 63.7(b)(2)

Demonstration of continuous monitoring system 63.9(g)

Compliance status 63.9(h)

Physical and operational change 63.10

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

Performance test results 63.8(e)(5), 

63.697(b)(2)

Startup, shutdown, malfunction reports 63.697(b)(3)

Notification of tank floating roof inspection 63.686(b)(3)

Notification of oil/water separator floating roof inspection 63.687(d)(6)

Notification to tank refill 63.697(d)(1)

Notification of seal gap measurements 63.697(d)(2)

Reports

Initial performance test results 63.10(d)(2)

Opacity or visible emissions 63.10(d)(3)

Periodic startup, shutdown, malfunction reports 63.10(d)(5)(i)

Source status report 63.10(e)(3)

Excess emission reports 63.695(e)

Semiannual summary report 63.697(b)(4)

A source must keep the following records:
7

Recordkeeping

Startup, shutdown, malfunctions, periods where the continuous 

monitoring system is inoperative. 63.10(b)(2)

All reports and notifications. 63.10(b)

Record of applicability. 63.10(b)(3)

Records of sources with continuous monitoring systems. 63.10(c)

Records of startup, shutdown, and malfunctions, and pollution control 

system maintenance. 63.696(b)(1)

Records of applicability determinations. 63.696(b)(3)

Documentation of extension of tank emptying schedule. 63.696(c)

Records of results of seal gap measurements and description of repairs. 63.686(d)(3)

Record of sampling plan for determining volatile organic hazardous air 

pollutant (VOHAP) concentration at point of treatment 63.694(c)

Record of sampling plan for determining maximum HAP vapor 

pressure in tanks. 63.694(j)(2)(1)

Record of maximum HAP vapor pressure determinations for covered 

tanks 63.686(c)(5)

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

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. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 33 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

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

supply pressure for control device.
8

Respondent Activities

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

Write the notifications and reports listed above.

Enter information required to be recorded above.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

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

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring system). 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. 

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

Information Management

5(a) Agency Activities 

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

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 
9

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

A majority of the respondents are large entities (i.e., large businesses). According to the 

Off-Site Waste and Recovery Operations NESHAP: Economic Impact Analysis, (EPA-452/R-96-

011, June 1996), EPA specifically identified 388 firms that own 621 potentially affected 

facilities. These 388 firms include 110 small businesses that own 112 facilities; therefore, this 

ICR assumes that approximately 18 percent of the total facilities (42 of 236 respondents) are 

small businesses. 

The impact on small entities (i.e., small businesses) was taken into consideration during 

the development of the regulation. Due to technical considerations involving the process 

operations and the types of control equipment employed, the recordkeeping and reporting 

requirements are the same for both small and large entities. The Agency considers these to be 

the minimum requirements needed to ensure compliance and, therefore, cannot reduce them 

further for small entities. To the extent that larger businesses can use economies of scale to 

reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost – NESHAP for Off-Site Waste 

and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal). 
10

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 178,527 hours (see Total Labor Hours from Table 

1 below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NESHAP program, 

the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $122.49 ($58.33+ 110%) 

Technical $101.28 ($48.23 + 110%)

Clerical $50.80 ($24.19 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, 

September 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are 

from column 1, “Total compensation.” The rates have been increased by 110 percent to account 

for the benefit packages available to those employed by private industry.

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

The type of industry costs associated with the information collection activities in the 

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

associated with continuous monitoring. The capital/startup costs are one-time costs when a 

facility becomes subject to the regulation. There are no capital/startup costs for this ICR since 

no new sources are projected over the next three years. The annual operation and maintenance 

costs are the ongoing costs of photocopying and postage. There is no significant operation and 

maintenance costs since sources are not required to install continuous monitoring systems. 

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs
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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 1

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

N/A $0 0 $0 $22.71 256 $5,813.76

1

 We assume photocopying and postage cost of $7.57 per response and 3 responses per respondent, for a total of 

$22.71 per respondent. 

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 $5,814 (rounded). 

This is the total of column G. 

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 $5,814. These are the costs of 

recordkeeping. 

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

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

$122,306. 

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%)

These rates are from the Office of Personnel Management (OPM), 2012 General Schedule,

which excludes locality, rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Off-Site 

Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal).

6(d) Estimating the Respondent Universe and Total Burden and Costs
12

Based on our research for this ICR, on average over the next three years, approximately

236 existing respondents will be subject to the standards. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 236 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

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 0 236 0 0 236

2 0 236 0 0 236

3 0 236 0 0 236

Average 0 236 0 0 236

1

New respondent 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 236. 

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

Startup/Shutdown Report 236 1 0 236

Semiannual Report 236 2 0 472

Total 708

The number of Total Annual Responses is 708. 

The total annual labor costs are $17,462,184. Details regarding these estimates may be 
13

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Off-Site Waste 

and Recovery Operations (40 CFR Part 63, Subpart DD) (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, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 178,527 hours at a cost of $17,462,184. Details 

regarding these estimates may be found in Table 1: Annual Respondent Burden and Cost –

NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) 

(Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 252 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $5,814. 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 

2,714 labor hours at a cost of $122,306. See below Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) 

(Renewal).

6(f) Reasons for Change in Burden

The increase in burden from the most recently approved ICR is due to a mathematical 

correction in labor hours and an increase in labor costs. This ICR uses rounded estimates of perrespondent technical hours to calculate both industry and agency burden. In addition, this ICR 

uses updated labor rates from the Bureau of Labor Statistics to calculate burden costs.

6(g) Burden Statement

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

is estimated to average 252 hours per response. Burden means the total time, effort, or financial 

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

to or for a Federal agency. This includes the time needed to review instructions; develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable instructions and 
14

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

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

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

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

Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2013-0336. An electronic version of the public docket is 

available at http://www.regulations.gov/, which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

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

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

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

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

Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public 

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

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2013-0336 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.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, 

 Subpart DD) (Renewal) 

Burden Items

(A)

Person

Hours per

Occurrence

(B)

No of

occurrences

per 

respondent

per year

(C) 

Person 

hours per 

respondent

per year 

(C=AxB)

(D) 

Respondents 

per year

(E) 

Technical

person

hours per 

year 

(E=C x D)b

(F) 

Managerial

person

hours per

year 

(E x 0.05)

(G) 

Clerical

Person hours

per year

(E x 0.1)

(H)

Total

Costs per 

year $ (a)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

New Sources

A. Read Instructions c ,d4 1 4 0 0 0 0 $0

B. Required Activities Included in 4

C. Create Information Included in 4

D. Gather Existing Information c, e8 1 8 0 0 0 0 $0

E. Write Reports

Initial Notification Report c, f1 1 1 0 0 0 0 $0

Performance Test Notification Report c, f1 1 1 0 0 0 0 $0

Compliance Status Notification c, f2 1 2 0 0 0 0 $0

Performance Test Reports c, f8 1 8 0 0 0 0 $0

Startup/Shutdown/Malfunction Report 2 1 2 236 472 23.6 47.2 $53,092.68

Semiannual Summary Report g4 2 8 236 1,888 94.4 188.8 $212,370.74

Subtotal for Reporting Requirements 2,714 $265,463.42

4. Recordkeeping Requirements

A. Read Instructions c8 1 8 0 0 0 0 $0

B. Planned Activities c40 1 40 0 0 0 0 $0

C. Implementation of Activities
16

Burden Items

(A)

Person

Hours per

Occurrence

(B)

No of

occurrences

per 

respondent

per year

(C) 

Person 

hours per 

respondent

per year 

(C=AxB)

(D) 

Respondents 

per year

(E) 

Technical

person

hours per 

year 

(E=C x D)b

(F) 

Managerial

person

hours per

year 

(E x 0.05)

(G) 

Clerical

Person hours

per year

(E x 0.1)

(H)

Total

Costs per 

year $ (a)

 a. Determination

 Commercial Facilities h2 260 520 118 61,360 3,068 6,136 $6,902,048.92

 Other Facilities i2 12 24 118 2,832 141.6 283.2 $318,556.10

 b. Vapor Pressure Determination

 Commercial Facilities h1 260 260 118 30,680 1,534 3,068 $3,451,024.46

 Other Facilities i1 12 12 118 1,416 70.8 141.6 $159,278.05

 c. Control Equipment Leak Monitoring

 Large Cover 0.25 10 2.5 236 590 29.5 59 $66,365.86

 Small Cover 0.05 1000 50 236 11,800 590 1,180 $1,327,317.10

 Closed Vent System 0.5 5 2.5 236 590 29.5 59 $66,365.86

 d. Control Equipment Leak Monitoring

 Cover Vented to Control Device 1 5 5 236 1,180 59 118 $132,731.71

 Closed Vent System 1 5 5 236 1,180 59 118 $132,731.71

 e. Control Devices

 Performance Determination c40 1 40 0 0 0 0 $0

 Continuous Monitoring System 8 5 40 236 9,440 472 944 $1,061,853.68

 f. LDAR Program

 Identify Affected Waste Streams c40 1 40 0 0 0 0 $0

 Perform Monitoring/Repair j80 1 80 47.2 3,776 188.8 377.6 $424,741.47

D. Develop Record System c

 Control Equipment 16 1 16 0 0 0 0 $0

 LDAR Program 40 1 40 0 0 0 0 $0
17

Burden Items

(A)

Person

Hours per

Occurrence

(B)

No of

occurrences

per 

respondent

per year

(C) 

Person 

hours per 

respondent

per year 

(C=AxB)

(D) 

Respondents 

per year

(E) 

Technical

person

hours per 

year 

(E=C x D)b

(F) 

Managerial

person

hours per

year 

(E x 0.05)

(G) 

Clerical

Person hours

per year

(E x 0.1)

(H)

Total

Costs per 

year $ (a)

E. Time to Enter Information

 Cover Designs 40 1 40 0 0 0 0 $0

 Control Device Design c40 1 40 0 0 0 0 $0

 Control Equipment Testing c1 1 1 0 0 0 0 $0

 Control Equipment Inspections c1 1 1 236 236 11.8 23.6 $26,546.34

 Control Equipment Monitoring 1 1 1 236 236 11.8 23.6 $26,546.34

 Control Device CMS 1 52 52 236 12,272 613.6 1,227.2 $1,380,409.78

 LDAR Program j4 16 64 47.2 3,020.8 151.04 302.08 $339,793.18

 Off-site Material Determinations 1 52 52 236 12,272 613.6 1,227.2 $1,380,409.78

F. Time to Train Personnel c

 Waste Determination Methods 40 1 40 0 0 0 0 $0

 Monitoring 40 1 40 0 0 0 0 $0

 LDAR Program 40 1 40 0 0 0 0 $0

G. Time for Audits N/A

Subtotal for Recordkeeping Requirements 175,812.92 $17,196,720.34

TOTAL ANNUAL BURDEN AND COST (rounded) 178,527 $17,462,184

Assumptions:

a This ICR uses the following labor rates: Managerial $122.49 ; Technical $101.28; and Clerical $50.80. These rates are from the United States Department of 

Labor, Bureau of Labor Statistics, September 2012, “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.

b

 We have assumed that there are approximately 236 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next 

three years.

c This activity is performed once during the year following promulgation of the rule.
18

d

 It is assumed that it will take 4 hours to read instructions.

e

 It is assumed that it will take 8 hours to gather existing information.

f It is assumed that there will be no new sources.

g

 The burden of one annual summary report was included in the burden estimate for the semiannual report.

h

 It is assumed that 50 percent of the facilities, the owner or operator manages, for a fee, off-site materials received from other generators.

i It is assumed that 50 percent of the owners or operators accept the off-site material at another location and ship it to the facility for storage, treatment, or 

disposal.

j It is assumed that 20 percent of the facilities will perform monitoring/repair (for LDAR program).
19

Table 2: Average Annual EPA Burden and Cost – NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, 

Subpart DD) (Renewal)

Activity

(A) 

EPA 

Hours/ 

Occurrence

(B) 

Occurrences/ 

Plant/ Year

(C) 

EPA 

Hours/ 

Year 

(AxB)

(D) 

Plants/ 

Year b

(E) 

Technical 

Hours/ 

Year 

(C x D)

(F) 

Managerial 

Hours/ 

Year 

(E x 0.05)

(G) 

Clerical 

Hours/ 

Year 

(E x 0.1)

(H) 

Costs, $ a

Report Review

New Plants c, d

Initial notification 2 1 2 0 0 0 0 $0

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

Compliance status notification 4 1 4 0 0 0 0 $0

Performance test report e16 1 16 0 0 0 0 $0

Existing Plants

Startup/shutdown report f 2 1 2 236 472 23.6 47.2 $24,461.16

Semiannual summary report g4 2 8 236 1,888 94.4 188.8 $97,844.66

TOTAL ANNUAL BURDEN AND COST (rounded) 2,714 $122,306

Assumptions:

(a) This ICR uses the following labor rates: Managerial $62.27; Technical $46.21; and Clerical $25.01. These rates are from the Office of Personnel Management (OPM), 

2012 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government 

employees. 

b

 We have assumed that there are approximately 236 respondents, with no additional new or reconstructed sources becoming subject to the rule over the next three years

c There will be no travel expenses associated with this ICR since we have assumed that no new sources will become subject to this rule over the three year period of this 

ICR.

d

 It is assumed that there will be no new sources over the three year period of this ICR.

e It is assumed that it will take 16 hours to review each performance test report.

f It is assumed that it will take 2 hours once per year for each plant to review report.

g

 It is assumed that each facility will take 4 hours twice a year to submit report.