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 1717.07, 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, and promulgated on July 1, 

1996. These standards apply to hazardous air pollutant (HAP) emissions from selected facilities 

involved in waste management and recovery operations that are not subject to Federal air standards 

under other subparts in 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, 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.

Owners or operators of the affected facilities described must make one-time-only

notifications. Owners or operators 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. Semiannual reports of excess emissions, 

or reports certifying that no exceedances have occurred, are required. These notifications, reports, 

and records are essential in determining compliance; and, in general, are required of all sources 

subject to the NESHAP.

Any owner or 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 United States 

Environmental Protection Agency (EPA) regional office.

There is an annual average of 236 respondents that will be subject to the regulations. Due 

to the nature of the industry, it is estimated that no additional sources will become subject to the 

standard over the next three years. This information is based on discussions with EPA personnel 

knowledgeable about the off-site waste and recovery operations. The average annual cost to 
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industry over the next three years of this Information Collection Request (ICR) is estimated to be 

$14,681,368.

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 burden to the “Federal government” is attributed entirely to work performed 

by Federal employees or government contractors. This burden may be found below in Table 2: 

Average Annual EPA Burden - NESHAP for Off-Site and Waste 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 HAP and 

shall require the maximum degree of emission reduction. In addition, section 114(a) 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; 

(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 was promulgated for this source category at 40 

CFR part 63, subpart DD.

2(b) Practical Utility/Users of the Data

The control of emissions of pollutants from off-site waste and recovery operations requires 

not only the installation of properly designed equipment, but also the operation and maintenance of 

that equipment. Emissions of organic HAP from off-site waste and recovery operations are the 
3

result of operation of the affected facilities. The subject standards are achieved by the reduction of 

organic HAP emissions using control technology and/or leak detection and repair procedures.

The notifications required in the applicable regulations are used to inform the Agency or 

delegated authority when a source becomes subject to the requirements of the regulations. The 

reviewing authority may then inspect the source to check if the pollution control devices are 

properly installed and operated, that leaks are being detected and repaired, and that the regulations 

are being met. The semiannual reports are used for problem identification, as a check on source 

operation and maintenance, and for compliance determinations.

The information generated by the monitoring, recordkeeping and reporting requirement 

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

continue to operate the control equipment in compliance with the regulation. Adequate monitoring, 

recordkeeping, and reporting are necessary to ensure compliance with the applicable regulations, 

as required by the Clean Air Act. The information collected from recordkeeping and reporting

requirements is also used for targeting inspections, and is of sufficient quality to be used as 

evidence in court.

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 their 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, no duplication 

exists.

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 (74 FR 38004) on July 30, 2009. No comments were received on the burden 

published in the Federal Register.

3(c) Consultations

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

standard, with no additional sources per year becoming subject to the standard. We have also 

determined that approximately 33 percent of the respondents are reporting electronically. In 

estimating the affected number of sources and the growth rate of off-site waste and recovery

operations facilities subject to this standard during a previous renewal, we contacted the Solid 

Waste Association of North America (SWANA) Ms. Shannon Crawford, at (800) 467-9262, and 
4

Chartwell Information, Mr. Grant Ferrier, (619) 295-7685. For this renewal, we contacted 

Environmental Business International (formerly Chartwell Information), Mr. Grant Ferrier, (619) 

295-7685, who did not refute current estimates. 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 likelihood of detecting poor operation and maintenance of control equipment and 

noncompliance would decrease.

3(e) General Guidelines

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

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

These standards require affected facilities 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. 

Also, the retention of records for five years would allow EPA to establish the compliance history of 

a source and any pattern of compliance for purposes of determining the appropriate level of 

enforcement action. Historically, EPA has found that the most flagrant violators frequently have 

violations extending beyond the five years. EPA would be prevented from pursuing the worst 

violators due to the destruction or nonexistence of records if records were retained for less than five 

years.

3(f) Confidentiality

The required information has been determined not to be confidential. However, 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

None of the reporting or recordkeeping requirements contain sensitive questions.
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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, 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) 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

4(b) Information Requested

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

established by OMB at 5 CFR part 1320, section 1320.5.
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(i) Data Items

All data in this ICR that is recorded and/or reported is required by National Emission 

Standards for Hazardous Air Pollutants for Off-Site Waste and Recovery Operations (40 CFR part 

63, subpart DD).

A source must make the following reports:

Reports 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)

Physical and operational change 63.10

Notification of performance tests 63.7(b), and 

63.697(b)(1)

Performance test results 63.8(e)(5), and 

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:

Recordkeeping for 40 CFR part 63, subpart DD

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)
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Recordkeeping for 40 CFR part 63, subpart DD

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

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way, e.g., leaks and spills of mercury. 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. In addition, some regulatory agencies are setting 

up electronic reporting systems to allow sources to report electronically which is reducing the 

reporting burden. However, electronic reporting systems are still not widely used by the regulatory

agencies. It is estimated that approximately 33 percent of the respondents use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Determine the VOHAP concentration for off-site material at the point-of-delivery and for the 

treated off-site material streams at the point-of-treatment.

Determine the required HAP mass removal rate, actual HAP mass removal, HAP reduction 

efficiency and HAP bio-degradation efficiency.

Determine the maximum organic HAP vapor pressure of the off-site material in tanks and the 

process vent stream flow rate and total HAP concentration.

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.
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Respondent Activities

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

Transmit, or otherwise disclose the information.

Currently, sources are using monitoring equipment that provides parameter data in an 

automated way, e.g., HAP vapor pressure. 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

Observe initial performance tests and repeat performance tests if necessary.

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

startup, shutdown, malfunction plan, and quality control plan for CMS required to be submitted 

by industry.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority might inspect the source to 

determine whether the pollution control devices are properly installed and operational. 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 the AFS which is operated and 

maintained by the EPA Office of Compliance. AFS is the EPA database for the collection, 

maintenance, and retrieval of compliance and annual emission inventory data for more than 

100,000 industrial and government-owned facilities. EPA uses the AFS 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 or operator for five 

years.
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5(c) Small Entity Flexibility

A majority of the affected facilities are primarily small entities (e.g., small 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 approximately 18 percent of the total facilities are small businesses, or 42 of 236 

respondents.

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 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).

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 155,212 (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: 
10

Managerial $114.49 ($54.52 + 110%) 

Technical $98.20 ($46.76 + 110%)

Clerical $48.53 ($23.11 + 110%)

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

2009, “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 capital/startup costs are one-time costs when a facility becomes subject to the standard. 

Since this is based on no new sources over the next three years, capital/startup costs associated 

with this ICR during this period will be zero. In addition, there is no significant operation and 

maintenance costs associated with this ICR since sources are not required to install continuous 

monitoring systems. The only operational cost that sources will incur is associated with 

photocopying and postage which would be minimal based on a rate of $7.57 per response. There 

are approximately 708 responses per year (708 responses x $7.57 = $5,359.56), for a total annual 

operation and maintenance (O&M) cost of $5,360.

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 

$106,353. 

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), 2010 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 – 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

Based on our research for this ICR, there are approximately 236 existing sources currently
11

subject to the standard. It is estimated that no additional sources per year will become subject to 

the regulation in the next three years.

Number of respondents is calculated using the following table which addresses the three 

years covered by this ICR.

Number of Respondents

Year

(A)

Number of New 

Respondents

(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

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 236.

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

Respondent Universe and Number of Responses Per Year

Regulation 

Citation

(A)

Average 

Number of 

New

Respondents 

per Year

(B)

Number of 

Reports for 

New

Sources

(C)

Number of 

Existing 

Respondents

(D)

Number 

of Reports 

for 

Existing 

Sources

(F)

Number of 

Respondents 

That Keep 

Records But 

Do Not Submit 

Reports

(E)

Total Annual 

Responses =

(AxB)+(CxD)

+F

40 CFR part 

63, subpart 

DD

0 0 236 3 0 708

The number of total respondents is 236. This represents the number of existing sources 

plus the number of new sources averaged over the three-year period (i.e., the total of the number of 

new respondents over the three-year period divided by three years).

The number of Total Annual Responses is 708. This is the number in column E of the 

Respondent Universe and Number of Responses per Year table above.

The total annual labor costs are $14,681,368. Details regarding these estimates 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).
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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 (below), respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 155,212. Details regarding these estimates 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). Furthermore, the annual public 

reporting and recordkeeping burden for this collection of information is estimated to average 219 

hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $5,000 

(rounded). The cost calculations are detailed in Section 6(c)(ii), Estimating Capital/Startup and 

Operation and Maintenance Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 2,360 

labor hours at a cost of $106,353. See below Table 2: Average Annual EPA Burden – NESHAP 

for Off-Site Waste and Recovery Operations (40 CFR part 63, subpart DD) (Renewal).

6(f) Reasons for Change in Burden

There is no change in the calculation methodology for labor hours in this ICR compared to 

the previous ICR. This is due to two considerations: (1) the regulations have not changed over the 

past three years and are not anticipated to change over the next three years; and (2) the growth rate 

for the respondents is very low, negative or non-existent. There is, however, an apparent increase 

of 906 hours in respondent labor hours, due to a math error in the previous ICR. 

Also, there is an increase in both Respondent and Agency costs resulting from labor rate 

increases from 2003 to 2009. In this ICR, the labor burden and cost calculations in Tables 1 and 2 

of this ICR were expanded to include managerial and clerical labor rates, and the previous ICR 

only provided a technical labor rate for 2003. This ICR has been updated to present the most recent 

available labor rates for each of the three labor categories.

6(g) Burden Statement

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

estimated to average 219 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; 
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adjust the existing ways to comply with any previously applicable instructions and requirements; 

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

and review the collection of information; and transmit or otherwise disclose the information.

An agency may 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-2009-0534. 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., N.W., Washington, D.C. 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, N.W., Washington, D.C. 

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

EPA-HQ-OECA-2009-0534 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 - NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal)

 

A B C D E F G H I

Reporting/Recordkeeping Requirements

Hours/

Occurrence

Occurrences/

Year

Hours/Year

(C = A x B)

Respondents/

Year

Technical

Hours/Year

(C*D)

Managerial

Hours/Year

(E*0.05)

Clerical

Hours/Year

(E*0.10)

Total

Hours/Year

(H=E+F+G)

Total

Costs/Year a

1. Applications N/A

2. Survey and Studies N/A

Technology and Systems b 80 1 80 0 0 0 0 0 $0.00

4. Reporting Requirements

New Sources

A. Read Instructions b, c 4 1 4 0 0 0 0 0 $0.00

B. Required Activities Included in 5

C. Create Information Included in 5

D. Gather Existing Information b, d 8 1 8 0 0 0 0 0 $0.00

E. Write Reports

Initial Notification Report b, e 1 1 1 0 0 0 0 0 $0.00

Performance Test Notification Report b, e 1 1 1 0 0 0 0 0 $0.00

Compliance Status Notification b, e 2 1 2 0 0 0 0 0 $0.00

Performance Test Reports b, e 8 1 8 0 0 0 0 0 $0.00

Startup/Shutdown/Malfunction Reports 2 1 2 236 410.43 20.52 41.04 472.00 $44,646.07

Semi-Annual Summary Report f 4 2 8 236 1,641.74 82.09 164.17 1,888.00 $178,584.28

Reporting Subtotal 2,360 $223,230

5. Recordkeeping Requirements

A. Read Instructions b 8 1 8 0 0 0 0 0 $0.00

B. Plan Activities b 40 1 40 0 0 0 0 0 $0.00

C. Implementation Activities

Determination

Commercial Facilities g2 260 520 118 53,356.52 2,667.83 5,335.65 61,360.00 $5,803,989.04

Other Facilities h2 12 24 118 2,462.61 123.13 246.26 2,832.00 $267,876.42

b. Vapor Pressure Determination

Commercial Facilities g1 260 260 118 26,678.26 1,333.91 2,667.83 30,680.00 $2,901,994.52

Other Facilities h1 12 12 118 1,231.30 61.57 123.13 1,416.00 $133,938.21

c. Control Equipment Visual Inspection

Large Cover 0.25 10 2.5 236 513.04 25.65 51.30 590.00 $55,807.59

Small Cover 0.05 1000 50 236 10,260.87 513.04 1,026.09 11,800.00 $1,116,151.74

Closed Vent System 0.5 5 2.5 236 513.04 25.65 51.30 590.00 $55,807.59

d. Control Equipment Leak Monitoring

Cover Vented to Control Device 1 5 5 236 1,026.09 51.30 102.61 1,180.00 $111,615.17

Closed Vent System 1 5 5 236 1,026.09 51.30 102.61 1,180.00 $111,615.17

e. Control Devices

Performance Determination b 40 1 40 0 0 0 0 0 $0.00

Continuous Monitoring System 8 5 40 236 8,208.70 410.43 820.87 9,440.00 $892,921.39
15

A B C D E F G H I

Reporting/Recordkeeping Requirements

Hours/

Occurrence

Occurrences/

Year

Hours/Year

(C = A x B)

Respondents/

Year

Technical

Hours/Year

(C*D)

Managerial

Hours/Year

(E*0.05)

Clerical

Hours/Year

(E*0.10)

Total

Hours/Year

(H=E+F+G)

Total

Costs/Year a

f. LDAR Program

Identify Affected Waste Streams b 40 1 40 0 0 0 0 0 $0.00

Perform Monitoring/Repair i80 1 80 47 3,269.57 163.48 326.96 3,760.00 $355,655.13

D. Develop Record System b

Control Equipment 16 1 16 0 0 0 0 0 $0.00

LDAR Program 40 1 40 0 0 0 0 0 $0.00

E. Time to Enter Information

Cover Designs b 40 1 40 0 0 0 0 0 $0.00

Control Device Design b 40 1 40 0 0 0 0 0 $0.00

Control Equipment Testing b 1 1 1 0 0 0 0 0 $0.00

Control Equipment Inspections 1 1 1 236 205.22 10.26 20.52 236.00 $22,323.03

Control Equipment Monitoring 1 1 1 236 205.22 10.26 20.52 236.00 $22,323.03

Control Device CMS 1 52 52 236 10,671.30 533.57 1,067.13 12,272.00 $1,160,797.81

LDAR Program 4 16 64 47 2,615.65 130.78 261.57 3,008.00 $284,524.10

Off-Site Material Determinations 1 52 52 236 10,671.30 533.57 1,067.13 12,272.00 $1,160,797.81

F. Time to Train Personnel b

Waste Determination Methods 40 1 40 0 0 0 0 0 $0.00

Monitoring 40 1 40 0 0 0 0 0 $0.00

LDAR Program 40 1 40 0 0 0 0 0 $0.00

G. Time for Audits N/A

Recordkeeping Subtotal 152,852 $14,458,138

TOTAL ANNUAL BURDEN 155,212 $14,681,368

Assumptions:

a) This ICR uses the following labor rates: Managerial $114.49 ($54.52 + 110%); Technical $98.20 ($46.76 + 110%); and Clerical $48.53 ($23.11 + 110%). These rates are from the 

United States Department of Labor, Bureau of Labor Statistics, September 2009, “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. This ICR assumes that 

Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours.

b) This activity is performed once during the year following promulgation of the rule.

c) It is assumed that it will take four hours to read instructions.

d) It is assumed that it will take eight hours to gather existing information.

e) It is assumed that there will be no new sources.

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

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

h) 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.

i) It is assumed that 20 percent of 236 facilities will perform monitoring/repair.
16

Table 2: Average Annual EPA Burden - NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal)

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

Activity

EPA

Hours/

Occurrence

Occurrences/

Plant/Year

EPA

Hours/Year

(C=A*B)

Plants/

Year

Technical

Hours/Year

(C*D)

Managerial

Hours/Year

(E*0.05)

Clerical

Hours/Year

(E*0.10)

Total

Hours/Year

(H=E+F+G)

Total

Costs/Year a

Report Review

New Plants b, c

Initial Notification 2 1 2 0 0 0 0 0 $0

Performance Test Notification 1 1 1 0 0 0 0 0 $0

Compliance Status Notification 4 1 4 0 0 0 0 0 $0

Performance Test Report d 16 1 16 0 0 0 0 0 $0

Existing Plants

Startup/Shutdown Report e 2 1 2 236 410.43 20.52 41.04 472.00 $21,270.58

Semi-Annual Summary Report f 4 2 8 236 1,641.74 82.09 164.17 1,888.00 $85,082.31

Report Review Subtotal 2,360 $106,353

TOTAL ANNUAL BURDEN 2,360 $106,353

Assumptions:

a) This ICR uses the following labor rates: Managerial $62.27 (GS-13, Step 5, $38.92 + 60%); Technical $46.21 (GS-12, Step 1, $28.88 + 60%); and Clerical $25.01 (GS-6, Step 3, 

$15.63 + 60%). These rates are from the Office of Personnel Management (OPM), 2010 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. This ICR assumes that Clerical hours are 10 percent of Technical hours and Managerial hours 

are 5 percent of Technical hours.

b) 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.

c) It is assumed that there will be no new sources (respondents) over the 3-year period of this Information Collection Request. new or reconstructed turbines per year.

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

e) It is estimated that the number of facilities subject to the rule is 236.

f) It is assumed that two reports will be submitted by each of the 236 facilities on an annual basis.