**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) ( Renewal) , EPA I CR Number 1541.11 , OMB Control Number 2060

- 0183

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP ) for Benzene Waste Operations were proposed on September 14, 1989 , promulgated on March 7, 1990 , and amended on December 4, 2003

. These regulations apply to existing and new facilities that generate waste containing b enzene, such as chemical manufacturing plants, coke by

- product recovery plants, petroleum refineries, and those owners and operators of hazardous waste treatment, storage, and disposal facilities (TSDF) that receive wastes from the above facilities. 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 61, Subpart FF

. In general, all NESHAP standards require initial notification report s, performance tests, and periodic reports b y the owners/o perators 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 sy stem 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 two 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. All of the benzene waste facilities in the United States are owned and operated by private, for

- profit businesses (the “Affected Public”). None of the se facilities in the United States are owned b y either state, or local, or tribal entities or by the Federal government. The “burden ” to the Affected Public may

be found belo w in Table 1: Annual Respondent Burden and Cost

– NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal)

. The Federal Government “burden ” is attributed entirel y to work performed b y either F ederal emplo ye es or government contractors and can be found below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal). Based on our consultations with industry representatives, there is an average of one2

affected facility 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, approximately 270 respondents per ye ar will be subject to the se standard s , and no additional respondents per year will become subject to the standard. Of the 270 sources, we estimate 135 sources have a total annual benzene (TAB) waste quantity greater than 10 MG/yr. The Office of Management and Budget ( OMB ) approved the currentl y active I CR without any “ Terms of Clearance. ”
**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, durin g 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, benzene emissions from benzene waste operations either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/ or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 6 1 , Subpart FF

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the se standard s ensure compliance with the applicable regulations which were 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 se standard s 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 se standard s are used to in form 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 properl y installed and operated , leaks are being detected and repaired , and the standard are being met. The performance test may also be observed. The required annual 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 an d reporting are required under 40 CFR Part 6 1 , Subpart FF

. **3(a) Non**
**- duplication**  If the subject standards have not been d elegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, 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 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 I CR was published in the Federal Register ( 79 FR 30117 ) on Mary 27, 2014 . No comments were received on the burden published in the Federal Register

. **3(c) Consultations** The Agency

has consulted industry

experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry , in compliance with the recordkeepi ng and reporting provisions in the standard is the Integrated Compliance Information Sy stem (I CI S) , which is operated and maintained by EPA’s Office of Compliance. IC I S is EPA’s database for the collection, maintenance, and retrieval of all compliance dat a. 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. In developing4

this I CR , we contacted Sage Environmental Consulting , at (866) 234

- 57 68 , and the American Fuel & Petrochemical Manufacturers (AFPM) , at (202) 457

- 0480

. 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. **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 tec hniques 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 p ossibility

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. **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 se standard s do not include sensitive questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are facilities with benzene waste operations . The United States Standard Industrial Classification ( SI C ) code s for the respondents affected by the standards , and their corresponding North American Industry Classification System (NAI CS ) codes are listed below : **Standard ( 40 CFR Part 61,**  **Subpart FF )**  **SIC Codes NAICS Codes** 5

Chemical Products Manufacturing 2812, 2813, 2816, 2819, 2821, 2822, 2823, 2824, 2833, 2834, 2835, 2836, 2841, 2842, 2843, 2844, 2851, 2861, 2865, 2869, 2873, 2874, 2875, 2879, 2891, 2892, 2893, 2895, 2899, 3087, 3861, 3952, 3999, 7389 325

Plastic Product Manufacturing 2671 , 2673, 3069, 3081, 3082, 3083, 3084, 3085, 3086, 3088, 3089, 3996, 3999 3261
Petroleum Refineries 2911 32411 Integrated Iron and Steel Mills 3312, 3399 331111 Remediation Services 1799, 4959 56291 All Other Miscellaneous Waste Management Services 4959, 7699 562998 Administration of Air and Water Resource and Solid Waste Management Programs 9511 92411

**4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF)

. A source must make the following reports:

**Notification s**  **/Reports** Notification and application of construction or modification. 61.07 Notification of anticipated date of initial startup. 61.09(a)(1) Notification of actual startup. 61.09(a)(2) Source reporting and request for waiver of compliance 61.10 Emission test and waiver of emission tests for flares and some waste incinerators 61.13 Initial performance test results 61.13(f) Initial performance test 61.13(c) Demonstration of continuous monitoring sy stem 61.354(c)6
**Notification s**  **/Reports** Notification of phys ical or operational change which may increase the emission rate. 61.15 Report that summarizes the regulatory status of each waste stream that contain benzene 61.357(a) Initial certification of necessary equipment and inspection tests 61.357(d)(1) Annual certification of benzene waste streams, benzene concentration, and benzene quantity determination 61.357(b), (c), (d)(2) Notification of election to comply with alternative requirements and certification of benzene waste streams, benzene concentration, and benzene quantity

determination 61.357(d)(4

- 5) Quarterl y reports certifying required inspections 61.357(d)(6) Quarterl y reports when monitored parameters are exceeded 61.357(d)(7) Initial and quarterl y reports of inspections during which detectable emissions or a problem is identified 61.357(d)(8) Notification of election to comply with standard 61.357(e) Initial and quarterl y reports identifying all seal gap measurements that are outside limits 61.357(g)

A source must keep the following records: **Recordkeeping** Monitoring requirements 61.14 Monitoring of operation of treatment process or wastewater treatment 61.354 (a), (b) Monitoring of alternative op erational or process parameters 61.354(e) Monitoring of affected facilities 61.343

- 349 Startup, shutdowns, malfunctions, periods where the continuous monitoring sy stem is inoperative 61

. 356 (i), (j) Emission t est results and other data needed to determine emissions 61.13(g) Records of off

- site shipment of waste 61.356(c) Records of control equipment engineering design 61.356(d) Records of engineering calculations, operating conditions, and performance tests 61.356(e) Records of detectable emissions from closed vent sy stems and control 61.356(f)7 **Recordkeeping** devices Records of location, date and corrective actions for problems found during visual inspections 61.356(g) Records for each test of no detectable emissions 61. 356(h) Operational records for each control device, treatment process, and wastewater treatment sy stem 61.356(i), (j) Records are required to be retained for two ye ars and they must be retained at the facility 61.356(a) Measurements and determinations of annual waste quantity , water content, and benzene concentration 61.356(b)
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. **(ii) Respondent Activities Respondent Activities**  Familiarization with the regulatory requirements. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for control device. Perform initial performance test, Reference Method 21 test, and repeat performance tests if necessary
. Write the notificati ons 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. D evelop, 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 and8 **Respondent Activities** providing information. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.

**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, 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 Enforcement and Compliance History Online (ECHO) and I CI S. **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 source ’ s initial capab ility to compl y 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 annual repor ts are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is reported b y state and local governments in the IC IS Air database, which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y local an d state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated a

uthorities can edit, store, retrieve and anal yz e the data. The records required b y this regulation must be retained by the owner/operator for two9

ye ars. **5(c) Sm**  **all Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). However, 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 ty pes 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 sp ecific frequency

for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF ) (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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or s ponsor, 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 recordk eeping and reporting requirement s is estimated to be 19, 2 00 hours ( 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 NES HAP program, the previously

- approved I CR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 9

. 93 ($ 61.87 + 110%) Technical $ 10 3

. 97 ($4 9

. 51 + 110%)10 Clerical $ 5 1

. 79 ($2 4

. 66 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 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 only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. There are no capital/startup and/ or operation and maintenance costs

.

**(iii) Capital/Startup vs. Operation and Main tenance (O&M) Costs**  The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup and/ or operation and maintenance costs. **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 compliance and enforcement program includes activities such as the examination of records maint ained by the respondents, periodic inspectio n 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 $ 70,700

. This cost is based on the average hourl y labor rate as follows:
M anagerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9

. 31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

. 17 + 60% ) Clerical $2 5. 25 (GS

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 5 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 Benzene Wa ste Operations (40 CFR Part 61, Subpart FF ) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 270 existing respondents will be subject to the se standard s . It is estimated that no additional respondent per year will become subject. The overall average number of respondents, as shown11

in the table below, is 270 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**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

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 0 270 0 0 270 2 0 270 0 0 270 3 0 270 0 0 270 Average 0 270 0 0 270 1 New respondents include sources with constructed, reconstructed and modified affected facilities. Based on consultation with industry representative, EPA believes there wa s at least one facility that wa s currently undergoing permitting for construction during the previous ICR renewal period wh ile several others have suspended operation

. Therefore, EPA estimated that there is no net increase in the number of respondents. 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 270

. 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

Annual report 270 1 0 270 Quarterly emission report 135 4 0 540 Notification of offsite facility 14 12 0 16812 **Total Annual Responses** Total 978 The number of Total Annual Responses is 978

. The total annual labor costs are $1,930,000

. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (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 below in Tables 1 and 2, respectively , and summarized below. **(i) Respondent Tally** The total annual labor hours are 19, 2 00 hours at a cost of $1,930,000

. Details regarding these estimates may

be found below in Table 1: Annual Respondent Burden an d Cost

- NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal)

. We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty

pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 20 hours per response

. The total annual capital/startup and O&M costs to this regulated entity are $0

. 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 1,550 labor hours at a cost of $70,700 . See below Table 2: Average Annual EPA Burden and Cost

- NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF ) (Renewal). We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the ty

pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records.13

**6(f) Reasons for Change in Burden** There is an adjustment increase in the respondent burden from the most recently approved ICR . The increase is primaril y attributed to correcting an entry error in the number of respondents that record monthly benzene waste concentration data under Table 1, labor item 4(c)(ii). In addition, we have rounded all total values to 3 significant figures. There is also an adjustment increase in the number of responses due to a correction. The previous I CR did not account for quarterly emission reports and notifications of offsite facilities in calculating the number of responses. **6(g) Burden Statement** The annual publ ic reporting and recordkeeping burden for this collection of information is estimated to average 20 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 in formation, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and re view 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 C ontrol 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 t his I CR under Docket ID Number EPA

- HQ

- OECA

- 201 4

- 0046

. 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), WJC 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

- 2014

- 0046 and OMB Control Number 2060

- 0183 in any14

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 Benzene Waste Operations (40 CFR Part 61, Subpart FF)**  **(Renewal)**

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours**  **per respondent**  **per year (AxB)**  **(D)**

**Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year (CxD)**  **(F)**

**Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **hours per year**  **(Ex0.1) (H)** 

**Total Cost Per year**  **b**
1. Applications N/A 2. Surveys and studies N/A 3. Reporting requirements
a. Familiarize with rule requirement See 3C b. Required activities See 3C c. Create information i. Determine quantity of benzene in waste l 2 1 2 0 0 0 0 $0 ii. Initial waste determination l 2 1 2 0 0 0 0 $0 iii. Treatment performance evaluation l 2 1 2 0 0 0 0 $0 iv. Annual waste determination c, d 2 1 2 270 540 27 54 $62,448.57 v. Monthly treated waste analysis e, f 1 12 12 14 168 8.4 17 $19,428.44 vi. Treatment/control device monitoring See 4C vii. Initial visual inspection l 2 1 2 0 0 0 0 $0 viii. Quarterly visual inspection g 2 4 8 135 1,080 54 108 $124,897.14 ix. Annual method 21 monitoring h 6 1 6 135 810 40.5 81 $93,672.86 d. Gather existing information See 3E e. Write report New source Notification of construction /reconstruction N/A Notification of anticipated/actual startup N/A16

Notification/report of performance test N/A Existing sources Initial report N/A Quarterly emission report 4 4 16 135 2,160 108 216 $249,794.28 Annual report 1 1 1 270 270 13.5 27 $31,224.29 Notification of offsite facility i 2 12 24 14 336 16.8 33.6 $38,856.89 **Subtotal for Reporting Requirements 6,169**  **$620,322.46** 4. Recordkeeping requirements
a. Familiarize with rule requirement See 3A b. Plan activities See 4C c. Implement activities i. Filing and maintain records j 78 1 78 135 10,530 526.5 1,053 $1,217,747.12 ii. Concentration data (annual benzene quantity determination) k 0.5 12 6 1 21 726 36.3 72.6 $83,958.63 iii. Conc entration data 0.5 12 6 14 84 4.2 8.4 $9,714.22 iv. Waste quantity data l 1 1 1 0 0 0 0 $0 d. Develop record system See 4C e. Time to enter information See 4C f. Train Personnel N/A g. Audits N/A **Subtotal for Recordkeeping Requirements 13,041**  **$1,3 11**  **, 419** **. 97**  **TOTAL LABOR BURDEN AND COST (rounded)**  **m 19,**  **2 00**  **$1,930,000 Capital and O&M Cost (see Section 6(b)(iii)):**  **m $0**  **TOTAL COST: m**  **$1,930,000**

**Assu mptions:**  a We have assumed that the average number of respondents that will be subject to this rule will be 270. There will be no additional new sources that will become subject to the rule over the three

- year period of the ICR. It is estimated that 135 sources that have a total annual benzene (TAB) quantity waste between 1 Mg/yr17

and 10 Mg/yr must file an annual report. It is also estimated that 135 sources that have a TAB greater than 10 Mg/yr and hav e com plied with the control requirements must file quarterly r eports. b This ICR uses the following labor rates: $129.93 per hour for Executive, Administrative, and Managerial labor; $103.97 per h our for Technical labor, and $51.79 per hour for Clerical labor. These rates are from the United States Department o f Labor, Bureau of Labor Statistics, June 2014, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110 p ercent to account for the benefit packages available to those employed by private industry.
c We have assumed that it will take each respondent two hours once per year to create the annual waste determination. d We have assumed that all facilities above 1 Mg/yr must evaluate waste streams annually TAB report. e We have assumed that it will take one hour each month for each respondents to create the monthly treated waste analysis information (0.5 hours for collection activities for all samples and 0.5 hours per sample for analysis for a total of 1 hour per sample). f We have assumed that 90 percent of 135 sources (121) will monitor process parameters, and the remaining 10 percent (14) must conduct monthly sampling. g We have assumed that 135 facilities that are expected to be greater than 10 Mg per year must comply with the quarterly visual inspection requirements. h We have assumed that 135 respondents will each take six hours once per year to comply with the annual method 21 monitoring requirements. i We have assumed that 10 percent of facilities (14) will choose to ship their waste offsite once a month for treatment. j We have assumed that 135 respondents will take 78 hours once per year to comply with the re cord requirements. k. We have assumed that 1 21 respondents will take 30 minutes twelve times per year to repeat the benzene quantity determination. l We have assumed that this is a onetime only activity.

m Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.18

**Table 2: Average Annual EPA Burden and Cost**

**– NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF)**  **(Renewal)**

**Burden item (A)**  **Person hours per**  **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person hours per**  **respondent per year**  **(AxB) (D)**  **Respondents per year**  **a (E)** 

**Technical person**  **** **hours per year**  **(CxD) (F)**  **Managem ent**  **person hours per year**  **(Ex0.05) (G)** 

**Clerical person hours**  **per year (Ex0.1)**  **(H)**

**Total Cost Per year**  **b**
Initial performance tests N/A Report Review N/A New Plant Notification of construction c 2 1 2 0 0 0 0 $0 Notification of anticipated startup N/A Notification of actual startup N/A Initial report N/A Notification of performance test N/A Existing Plants Quarterly reports d 2 4 8 135 1,080 54 108 $56,527.20 Annual recertification 1 1 1 270 270 13.5 27 $14,131.80 **TOTAL ANNUAL BURDEN AND COST f**  **1,550 $70,700** 

**Assu mptions:** 
a We have assumed that the average number of respondents that will be subject to this rule will be 270 and there will be no add itional new sources that will become subject to the rule over the three

- year period of the ICR. It is estimated that 135 sources that have a total annual benzene (TAB) quantity waste between 1 Mg/yr and 10 Mg/yr must file an annual report. It is also estimated that 135 sources that have a TAB greater than 10 Mg/yr and have complied with the control requirements must file quarterly reports. b This cost is based on the following labor rates w hich incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.90 for Managerial (GS

- 13, Step 5, $39.31 x 1.6), $46.67 for Technical (GS

- 12, Step 1, $29 .17 x 1.6), and $25.25 Clerical (GS

- 6, Step 3, $15.78 x 1.6). These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.19

c We have assumed that this is a one

- time activity for each new fac ility. d We have assumed that 135 respondents will review quarterly reports.

e It is assumed that all respondents will take one hour each per year to review annual recertification. f Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.