**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 I CR Number 1717.0 9 , OMB Control Number 2060

- 0313 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) fo r 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 appl y 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

. Inaddition, subpart DD cross

- references control require ments to be applied to specific types of affected sources: tankslevel

- 1; containers; surface impoundments; individual drain sy stems; oil

- water separators; organic water separators; and loading, transfer, and storage s ys tems. 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 peri odic 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 th e monitoring s ys tem 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 de legated authority , the reports are sent directl y 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 ye ars, an average of 236 respondents per ye ar will be subject to the standard s , and no additional respondents per year will become subject to the standard s
.2

The Office of Management and Budget ( OMB ) approved the currentl y active I CR 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 b y either F ederal employees or government contractors, and may be found below in Table 2: Average Annual EPA Burden and Co st

– 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 esta blish 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 em ission 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 reasonabl y 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 initial3

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 record ed and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard s are used to inform either the Agency or its delegated authority

when a source becomes subject to the requirements of the regulatio ns. The reviewing authority may then inspect the source to check if the pollution control devices are properl y 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 directl y to the appropriate EPA regional office. Otherwis e, the information is sent directl y 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 cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y 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 I CR was pub lished 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 b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and retrieval of all complianc e 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 I CR, we contacted : 1) the Solid Waste Association of North America (SWANA) , at (800) 467

- 926 2 ; 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 re ceived. **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 frequentl y, 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 b y OMB under 5 CFR part 1320, section 1320.5. These standards require the respondents to maintain all records, including rep orts and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- ye ar statute o f limitations on which the permit program is based. The retention of records for five ye ars 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 fo und that the most flagrant violators have violations extending beyond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records. **3(f) Confidentiality** Any information submitte d 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, 1 976; 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 sensitive5

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 c ompounds . The United States Standard Industrial Classification ( SI C ) code s for the respondents affected b y the standards and the corresponding North American Industry Classification System (NAI CS ) codes are listed in the table below

. **Standard ( 40 CFR**  **P art 63,**  **S ubpart 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 prototy pes) 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 3312216

**4(b) Information Requested**  **(i) Data Items**
In this ICR , all the data that is recorded or reported is required by the NESHAP for Off

Site Waste and Recovery Operations (40 CFR P art 63, S ubpart DD). A source must make the following reports:

**Notification s**  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 sy stem 63.9(g) Compliance status 63.9(h) Phy sical 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 sy stem 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 sy stem 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 ye ars. 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 th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems 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 s ys tem) . Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. **5. The Information Collected: Agency Activities, Collection Method ology, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analy sis, 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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S).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 properl y installed and operated. Performance test reports are used b y the Agency to discern a s ource’s initial capability to comply with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained b y 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.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's O ffice of Compliance. OT IS 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 OTI S for tracking air pollution compliance and enforcement b y 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 b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** A majority

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

- Site W aste and Recovery Operations NESHAP: Economic Impact Analysis, (EPA

- 452/R

- 96

- 011, June 1996), EPA specificall y 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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden und er the Paperwork Reduction Act. Where ver 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 requirement s 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 p rogram, the previously

approved ICR, and an y comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 2

. 4 9 ($5 8

. 3 3 + 110%) Technical $ 10 1

. 2 8 ($4 8

. 2 3 + 110%) Clerical $ 50

. 80 ($2 4

. 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 b y 1 10 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated with the information collection activities in the s ubject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. Th e capital/startup costs are one

- time costs when a facility becomes subject to the regulation. There are no capital/start up costs for this I CR s ince 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 s ys tems.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs**11

**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 I CR are $ 0 . This is the total o f column D in the above table. The total operation and maintenance (O&M) costs for this I CR 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 ye ars of the IC R 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 anal ys is of the reported information. EPA's overall complian ce and enforcement program includes activities such as the examination of records maint ained 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 hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 2 General Schedule , which excludes locality , rates of pay

. The rates have been increased b y 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 I CR, on average over the next three ye ars, approximately 236 existing respondents will be subject to the standard s . It is estimated that n o additional respondents per ye ar will become subject. The o verall 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 ye ars covered b y this ICR.
**Number of Respondents**

Year (A) Number of Ne w 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. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 236

. The total number of annual responses per ye ar 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 be13

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 , respectivel y, 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 recentl y approved ICR is due to a mathematical correction in labor hours and an increase in labor costs . Th is I CR uses rounded estimates of per

respondent technical h ours to calculate both industry and agency

burden. In addition, this I CR 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 b y 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 s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and14

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 o therwise 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 h as established a public docket for this I CR under Docket ID Number EPA

- HQ

- OECA

- 2013

- 033 6

. 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 sy stem , 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 holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation 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

- 20 13

- 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 H**  **ours per**  **Occurrence (B)** 

**No of o**  **ccurrences per**  **respondent per y**  **ear (C)** 

**Person h**  **ours per**  **respondent per year**  **(C= AxB)**  **(D)**

**Respondents per**  **y ear**  **(E)**

**Technical person**  **h ours**  **per y**  **ear (**  **E= C x D)**  **b (F)** 

**Managerial person**  **h ours**  **per y**  **ear (E x 0.05)**  **(G)**

**Clerical Person**  **h ours**  **per y ear**  **(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 , d 4 1 4 0 0 0 0 $ 0 B. Required Activities Included in 4 C. Create Information Included in 4 D. Gather Existing Information c , e 8 1 8 0 0 0 0 $ 0 E. Write Reports Initial Notification Report c , f 1 1 1 0 0 0 0 $ 0 Performance Test Notification Report c , f 1 1 1 0 0 0 0 $ 0 Compliance Status Notification c , f 2 1 2 0 0 0 0 $ 0 Performance Test Reports c , f 8 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 g 4 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 c 8 1 8 0 0 0 0 $ 0 B. Pla nned Activities c 40 1 40 0 0 0 0 $ 0 C. Implementation of Activities16

**Burden Items (A)**  **Person H**  **ours per**  **Occurrence (B)** 

**No of o**  **ccurrences per**  **respondent per y**  **ear (C)** 

**Person h**  **ours per**  **respondent per year**  **(C= AxB)**  **(D)**

**Respondents per**  **y ear**  **(E)**

**Technical person**  **h ours**  **per y**  **ear (**  **E= C x D)**  **b (F)** 

**Managerial person**  **h ours**  **per y**  **ear (E x 0.05)**  **(G)**

**Clerical Person**  **h ours**  **per y ear**  **(E x 0.1) (H)** 

**Total Costs**  **per year**  **$ (a)**

a. Determination Commercial Facilities h 2 260 520 118 61,360 3,068 6,136 $6,902,048.92 Other Facilities i 2 12 24 118 2 , 832 141.6 283.2 $318,556.10 b. Vapor Pressure Determination Commercial Facilities h 1 260 260 118 30,680 1,534 3,068 $3,451,024.46 Other Facilities i 1 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 c 40 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 I dentify Affected Waste Streams c 40 1 40 0 0 0 0 $ 0 Perform Monitoring/Repair j 80 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 $ 017

**Burden Items (A)**  **Person H**  **ours per**  **Occurrence (B)** 

**No of o**  **ccurrences per**  **respondent per y**  **ear (C)** 

**Person h**  **ours per**  **respondent per year**  **(C= AxB)**  **(D)**

**Respondents per**  **y ear**  **(E)**

**Technical person**  **h ours**  **per y**  **ear (**  **E= C x D)**  **b (F)** 

**Managerial person**  **h ours**  **per y**  **ear (E x 0.05)**  **(G)**

**Clerical Person**  **h ours**  **per y ear**  **(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 c 40 1 40 0 0 0 0 $ 0 C ontrol Equipment Testing c 1 1 1 0 0 0 0 $ 0 Control Equipment Inspections c 1 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 j 4 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**  **,81 2.92**  **$17,196,720.3 4**  **TOTAL ANNUAL BURDEN AND COST (rounded)**  **178,527 $17,462,184** 
**Assu mptions:** 
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 rate s are from column 1, “Total compensat ion.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by privat e industry. b We have assumed that there are approximately 236 respondents, with no additional new or reconstructed sources becomi ng 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 n otification 2 1 2 0 0 0 0 $ 0 Performance t est n otification 1 1 1 0 0 0 0 $ 0 Com pliance s tatus n otification 4 1 4 0 0 0 0 $ 0 Performance t est r eport e 16 1 16 0 0 0 0 $ 0 Existing Plants Startup/ s hutdown r eport f 2 1 2 236 472 23.6 47.2 $24,461.16 Semi annual s ummary r eport g 4 2 8 236 1,888 94.4 188.8 $97,844.66 **TOTAL ANNUAL BURDEN AND COST (rounded)**  **2,714 $122,**  **306**

**Assu mptions:**  (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 em ployees. b We have assumed that there are approximately 236 respondents, with no additional new or reconstructed sources becoming subjec t 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 su bmit report.