SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

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

1717.11, OMB Control Number 2060-0313. 

1(b) Short Characterization/Abstract

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

the existing NESHAP for OSWRO (40 CFR part 63, subpart DD) as required by the Clean Air Act

(CAA). The NESHAP published at 40 CFR part 63, subpart DD were proposed on October 13, 

1994, and promulgated on July 1, 1996. The regulation applies to hazardous air pollutants (HAP) 

emissions from selected facilities involved in waste management and recovery operations that are 

not subject to Federal air standards under other subparts in 40 CFR part 63, if the facility is a major 

source of HAP emissions, as defined in general provisions to 40 CFR part 63. In addition, 40 CFR 

part 63, subpart DD cross-references control requirements to be applied to specific types of 

affected sources: tanks-level 1; containers; surface impoundments; individual drain systems; 

oil-water separators; organic water separators; and loading, transfer, and storage systems. This 

information is being collected to assure compliance with 40 CFR part 63, subpart DD. Organic 

HAP emissions are the pollutants regulated under this subpart.

In general, all NESHAP standards require initial notifications, performance tests, and 

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

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

NESHAP. Semi-annual summary reports are also required.

This final rulemaking amends title 40, chapter I, part 63 subpart DD revising the leak 

detection and repair (LDAR) requirements. In addition, the proposed amendments also add 

requirements to monitor each pressure relief device (PRD) that is designed to release to the 

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

duration of each pressure release and of notifying operators that a release has occurred. 
2

Information related to these new provisions is required to be submitted in the semi-annual reports 

required by the existing NESHAP. In addition, the EPA is finalizing requirements that require 

storage vessels of certain sizes and containing materials above certain vapor pressures to use Level 

2 controls (i.e., obtain a 95 percent organic HAP emissions reduction). Burden changes associated 

with these proposed amendments would result from new recordkeeping and reporting 

requirements associated with the LDAR and PRD monitoring requirements for all facilities subject 

to subpart DD. 

The Office of Management and Budget (OMB) approved the currently active ICR without

any “Terms of Clearance.” The overall change in burden found in this ICR reflect the provision 

changes, an update in the cost of labor, and corrections to the number of affected facilities found in 

EPA ICR number 1717.09.

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

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

size of the regulated universe are based on data from the National Emissions Inventory (NEI) 

database, available permit data and information collected in the 2013 OSWRO CAA section 114

survey. There are an estimated 56 major source facilities in the OSWRO source category. Based on 

available permit information, seven facilities are known to be exempt from most of the rule 

requirements due to the low HAP content of the off-site waste they receive. These facilities are not 

expected to be affected by the rule. Therefore, we estimate that there is an annual average of 49

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

expected to be constructed in the foreseeable future, so consequently it is estimated that no 

additional sources will become subject to the standard over the next three years.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 112 of the CAA, as amended, to establish standards of 

performance for each category or subcategory of major sources and area sources of HAP. These 

standards are applicable to new or existing sources of HAP and must require the maximum degree 

of emission reduction. In addition, section 114(a) of the CAA states that the Administrator may 

require any owner or operator subject to any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C) 

install, use, and maintain such monitoring equipment, and use such 
3

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.

2(b) Practical Utility/Users of the Data

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

applicable regulations which were promulgated in accordance with the CAA. In addition, the 

collected information is used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability 

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

compliance with the standard at all times. During the performance tests, a record of the operating 

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

compliance in place of a continuous emission monitor.

The notifications required in the standard are used to inform the Agency or delegated 

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

authority may then inspect the source to ensure that the pollution control devices are properly 

installed and operated, that leaks are being detected and repaired, and that the standards are being 

met. The performance test may also be observed.

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

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

determinations.

The information generated by the monitoring, recordkeeping and reporting requirements 

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

continues to operate the control equipment in compliance with the regulation.

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

3(a) Non-duplication
4

A search of the EPA’s existing standards and ongoing ICRs revealed no duplication of 

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

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

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

Federal standards. Therefore, no duplication exists.

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

This ICR is related to final amendments to 40 CFR part 63, subpart DD for the OSWRO 

source category. Comments were solicited on the proposal package and the proposed ICR, and no 

comments were received regarding the proposed ICR.

3(c) Consultations

Over the next three years, an average of 49 facilities per year will be subject to the standard, 

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

number of sources and the growth rate of OSWRO facilities subject to this standard during a 

previous renewal, we referenced the most recent ICR, and used other resources to obtain the most 

recent data available. We reviewed information available from the Online Tracking Information 

System (OTIS), which is the primary source of information regarding the number of existing 

sources. OTIS data was used in conjunction with industry consultation to verify the number of 

sources and the industry growth rate.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that facilities 

are continuing to meet the standards. Requirements for information gathering and recordkeeping 

are useful techniques to ensure that good operation and maintenance practices are applied and 

emission limitations are met. If the information required by these standards was collected less 

frequently, the proper operation and maintenance of control equipment and the possibility of 

detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements are consistent with the regulations 

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

These standards require the respondents to maintain all records, including reports and 

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

standards. EPA believes that the five-year records retention requirement is consistent with the Part 
5

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

The retention of records for five years allows EPA to establish the compliance history of a source, 

any pattern of non-compliance, and to determine the appropriate level of enforcement action. The 

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

Without the five-year record retention, the EPA would be prevented from pursuing the violators 

due to the destruction or nonexistence of essential records.

3(f) Confidentiality

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

be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B -

Confidentiality of Business Information (see 40 CFR 2; 41 FR 36902, September 1, 1976; 

amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, 

March 23, 1979).

3(g) Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents

The respondents to the recordkeeping and reporting requirements are OSWRO that store, 

treat, recycle, reprocess, or dispose of wastes containing organic chemical compounds. The United 

States Standard Industrial Classification (SIC) codes, which correspond to the North American 

Industry Classification System (NAICS) codes, could be found in the following table:

Off-site Waste and Recovery Operations 

(40 CFR part 63, subpart DD)

NAICS

Crude Petroleum and Natural Gas Extraction 211111

Water Supply and Irrigation Systems 221310

Highway, Street, and Bridge Construction 237310

Petroleum Refineries 324110

Other Basic Inorganic Chemical Manufacturing 325180

Cyclic Crude, Intermediate, and Gum and Wood 

Chemical Manufacturing 325194

All Other Basic Organic Chemical Manufacturing 325199

Plastics Material and Resin Manufacturing 325211
6

Off-site Waste and Recovery Operations 

(40 CFR part 63, subpart DD)

NAICS

Cement Manufacturing 327310

Alumina Refining and Primary Aluminum Production 331313

Photographic and Photocopying Equipment Manufacturing 333316

Aircraft Manufacturing 336411

Other Chemical and Allied Products Merchant Wholesalers 424690

Office Administrative Services 561110

Solid Waste Collection 562111

Hazardous Waste Treatment and Disposal 562211

Solid Waste Combustion and Incinerators 562213

Other Nonhazardous Waste Treatment and Disposal 562219

Materials Recovery Facilities 562920

National Security

a

928110

a One facility is operated by the U.S. Department of Defense. Small business size standards are not 

established for this sector. 

4(b) Information Requested

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

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

(i) Data Items

All data in this ICR that is recorded and/or reported is required by NESHAP for OSWRO

(40 CFR part 63, subpart DD).

A source must make the following notifications:

Notifications for 40 CFR part 63, subpart DD

Notification and application of construction/reconstruction 63.5(d)

Notification of initial startup 63.9(b)

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

Rescheduled initial performance test 63.7(b)(2)

Demonstration of continuous monitoring system 63.9(g)
7

Notifications for 40 CFR part 63, subpart DD

Compliance status 63.9(h)

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

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

Notification of tank floating roof inspection and seal gap 

measurements 63.697(c)

A source must make the following reports:

Reports for 40 CFR part 63, subpart DD

Initial performance test results 63.10(d)(2)

Excess emission reports 63.10(e)(3)

Initial pressure relief device description 63.697(a)(1)

Malfunction reports (included with semi-annual reports) 63.697(b)(3)

Semi-annual summary report 63.697(b)(4)-(6)

A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart DD

Reports and notifications 63.10(b)(1) and 

63.10(b)(2)(vi)-(xi)

Record of applicability 63.10(b)(3)

Records of sources with continuous monitoring systems 63.10(c)

Records of tank floating roof design, inspections, defects and 

repairs 63.696(d)

Records of tank fixed roof inspections, defects and repairs 63.696(e)

Records of tank enclosure measurements and calculations 63.696(f)

Records of anticipated and completed planned routine 

maintenance 63.696(g)

Control device malfunction records 63.696(h)

Records of releases from pressure relief devices 63.696(i)

Records of control device bypasses 63.696(j)

Records should be retained for 5 years. 63.10(b)(1)
8

Currently, sources are using monitoring equipment that automatically records parameter 

data. Although personnel at the source still need to evaluate the data, this type of monitoring 

equipment has significantly reduced the burden associated with monitoring and recordkeeping. 

However for this rule, we are only proposing electronic reporting of performance tests.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain and operate CMS.

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

calculations.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.

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

providing information.

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

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

Transmit, or otherwise disclose the information.

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

Management

5(a) Agency Activities

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

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and malfunction reports

required to be submitted by industry.

Audit facility records.

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

5(b) Collection Methodology and Management

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

determine whether the pollution control devices are properly installed and operated. Performance 

test reports are used by the Agency to discern a source’s initial capability to comply with the 

emission standard, and note the operating conditions under which compliance was achieved. Data 

and records maintained by the respondents are tabulated and published for use in compliance and 

enforcement programs. The semiannual reports are used for problem identification, as a check on 

source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into OTIS which is operated and maintained 

by EPA's Office of Compliance. OTIS is EPA’s database for the collection, maintenance, and 

retrieval of compliance data for approximately 125,000 industrial and government-owned 

facilities. EPA uses the OTIS for tracking air pollution compliance and enforcement by local and 

state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated 

Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for five

years.

5(c) Small Entity Flexibility

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 of Reporting and Recordkeeping 

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

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and 
10

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 49,118 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Technical $54.66 ($26.29 + 110%)

Managerial $115.96 ($55.81 + 110%)

Clerical $38.14 ($18.39 + 110%)

These labor rates are based on the May 2013 National Occupational Employment and Wage 

Estimates for the United States for Production Occupations 

(http://www.bls.gov/oes/current/oes_nat.htm#51-0000), occupational codes 51-8091 for chemical 

plant and system operators (technical), 11-1021 for general and operations managers (managerial) 

and 43-6010 for secretaries and administrative assistants (clerical).

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

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

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

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

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

maintain the monitor and other costs such as photocopying and postage.

As part of the amendments to the OSWRO NESHAP, facility owners or operators are 

required to monitor each PRD that is designed to release to the atmosphere using a device or 

system that is capable of identifying and recording the time and duration of each pressure release 

and of notifying operators that a release has occurred. For purposes of estimating the costs of this 

requirement, we assumed that operators would install electronic indicators on each PRD in organic 
11

HAP service that vents to the atmosphere. The cost of each monitoring system depends on the 

number of PRDs at the facilities. For OSWRO facilities, based on information received in the 2013 

ICR survey, there is an average of 13 PRDs at each plant. The cost for this system for the 49

affected facilities in the OSWRO source category is expected to be $1.9 million. For equipment 

leaks, facility owners or operators would also be required to follow the leak detection and repair 

(LDAR) requirements of 40 CFR part 63, subpart H, including connector monitoring requirements,

rather than 40 CFR part 63, subpart V under the amendments to the OSWRO NESHAP. The 

capital costs associated with this requirement are estimated to be $2.1 million. The rule requires

storage vessels of certain sizes and containing materials above certain vapor pressures to use Level 

2 controls. Compared to current requirements, the requirements lower the vapor pressure threshold 

at which control is required for tanks of certain sizes, making additional storage tanks subject to 

the use of Level 2 controls. In determining the impacts of the requirements, it was assumed that 

tanks would require ducting to a carbon adsorber as a control device. The capital costs associated 

with this requirement are estimated to be approximately $139,000.

Based on a previous ICR for the Pesticide Active Ingredient source category, which 

estimated the annual O&M costs to be $1,450 per source in 2011 dollars, inflating this number 

from 2011 dollars to 2013 dollars gives $1,505 per source. The total annual O&M cost for the 

OSWRO source category is approximately $74,000. For the PRD monitors, annualized costs are 

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

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

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

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

assumed equipment life of 15 years. In addition, for the LDAR and storage tank requirements, 

other annual monitoring and operating costs are included in the annual costs. The annualized costs

for the PRD, LDAR and storage vessels requirements is approximately $1.1 million. 

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

Capital/Startup and Operation and Maintenance (O&M) Costs
12

(A)

Cost Type

(B)

Capital/

Startup Cost 

for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/

Startup Cost 

(B X C) 

(E)

Annual Costs 

for One 

Respondent 

(F)

Number of 

Respondents 

(G)

Total 

Annual Cost

(E X F)

O&M $0 49 $0 $1,505 49 $73,745

LDAR $42,626 49 $2,088,689 $13,550 49 $663,955

PRD Monitoring 

Equipment $38,886 49 $1,905,410 $5,537 49 $271,313

Storage Tanks 

1

$139,497 - $139,497 $191,886 - $191,886

Total $4,133,596 $1,200,899

1Costs shown are the total costs for the estimated 14 additional tanks captured under the new threshold.

The total capital/startup costs for this ICR are $4,133,596. This is the total of column D in 

the above table. The total annual and operation and maintenance (O&M) costs for this ICR are 

$1,200,899 and is shown in column G.

6(c) Estimating Agency Burden and Cost

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

information. The EPA compliance and enforcement program includes activities such as: the 

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

emissions; and the publication and distribution of collected information.

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

$22,017.

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), 2013 General Schedule, 

which excludes locality rates of pay

(http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2013/general-schedule/201

3-gs-hourlyovertime-rates-by-grade-and-step/). The rates have been increased by 60 percent to 

account for the benefit packages available to government employees. Details upon which this 

estimate is based appear below in Table 2: Average Annual EPA Burden for the Proposed 

NESHAP for OSWRO (40 CFR part 63, subpart DD) (Revised).
13

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

The number of major source respondents was updated based on the NEI database, which 

was used during the analysis to determine the MACT. The EPA also used available permit data 

and information collected in the 2013 OSWRO ICR survey. The number of respondents is 

calculated using the following table which addresses the 3 years covered by this ICR. Over the 

three year period of this ICR, we expect 49 existing facilities to be respondents. 

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

YEAR

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

Number of 

New 

Respondents

Number 

Existing 

Respondents

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

Number of Existing 

Respondents That 

Are Also New 

Respondents

Number of 

Respondents 

(E=A+B+C-D)

1 0 49 0 0 49

2 0 49 0 0 49

3 0 49 0 0 49

Average 0 49 0 0 49

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 49.

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

Total Annual Responses

(A)

Information Collection Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of 

Existing 

Respondents That 

Keep Records But 

Do Not Submit 

Reports

(E)

Total 

Annual 

Responses

E=(BxC)

Initial notification (PRD) 49 0.33 0 16

Semiannual periodic report 49 2 0 98

Total Number of Annual Responses 114

The number of Total Annual Responses is 114.

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 
14

Agency are shown in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

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

49,118 labor hours at a cost of $2,745,132. See below Table 1: Annual Respondent Burden and 

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

CF93R Part 63, Subpart DD) (Revised).

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 489

labor hours at a cost of $22,017. See below Table 2: Average Annual EPA Burden for the 

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

6(f) Reasons for Change in Burden

The rulemaking amends title 40, chapter I, part 63 subpart DD to include revisions to the 

storage tank requirements, revisions to the LDAR requirements and requirements to monitor PRDs. 

The number of affected facilities under this subpart is not expected to increase. At this time, none 

of the amendments will affect area sources. The overall change in burden found in this ICR reflect 

the provision changes, an update in the cost of labor, an update to the number of affected facilities 

and corrections to errors found in EPA ICR number 1717.09. 

6(g) Burden Statement

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

estimated to average 431 hours per response. Burden means the total time, effort, or financial 

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

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

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

information, processing and maintaining information, and disclosing and providing information; 

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

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

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

information.

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

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

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

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this 

information.
Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements for the 

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

Burden Item

Person-hours 

per occurrence 

(A)

No. of 

occurrences 

per source 

per year (B)

Person-hour

s per source 

per year 

(C=AxB)

Respondent

s per year 

(D)

Technica

l personhours 

per year 

(E=CxD)

Managemen

t 

person-hour

s per year 

(Ex0.05)

Clerical 

person-hour

s per year 

(Ex0.1)

Cost,$

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

 A. Read instructions 4 1 4 49 196 9.8 19.6 $12,597 

 B. Required activities Included in 4C

 C. Create information Included in 4C

 D. Gather existing information Included in 4C

 E. Write report

 Initial notification report (d) 1 0.33 0.33 49 16.17 0.8085 1.617 $1,039 

 Semiannual summary report 8 2 16 49 784 39.2 78.4 $50,389 

REPORTING SUBTOTAL (Rounded) 1,146 $64,026 

4. Recordkeeping Requirements

 A. Read instructions 8 1 8 49 392 19.6 39.2 $25,195 

 B. Plan activities 40 1 40 0 0 0 0 $0 

 C. Implementation activities

 a. VOHAP concentration 

determination

 Commercial facilities (e) 2 260 520 25 13,000 650 1,300 $835,536 

 Other facilities (f) 2 12 24 25 600 30 60 $38,563 

 b. Vapor pressure 

determination

 Commercial facilities (e) 1 260 260 25 6,500 325 650 $417,768 
17

 Other facilities (f)1 12 12 25 300 15 30 $19,282 

 c. Control equipment visual 

inspection

 Large cover 0.25 10 2.5 49 1236 12 $7,873 

 Small cover 0.05 1000 50 49 2,450 123 245 $157,466 

 Closed vent system 0.55 2.5 49 1236 12 $7,873 

 d. Control equipment leak 

monitoring

 Cover vented to control 

device

155 49 245 12 25 $15,747 

 Closed vent system155 49 245 12 25 $15,747 

 e. Control devices

 Performance determination 401 400000 $0 

 Continuous monitoring 

system

85 40 49 1,960 98 196 $125,973 

 f. LDAR program

 Identify affected waste 

streams

401 400000 $0 

 Perform monitoring/repair 801 80 49 3,920 196 392 $251,946 

 g. PRD monitoring

 Identification of PRD devices8180000 $0 

 Perform monitoring/repair 161 16 49 784 39 78 $50,389 

 D. Develop record system

 Control equipment 161 160000 $0 

 LDAR program 401 400000 $0 

 PRD program818 49 392 20 39 $25,195 

 E. Time to enter information

 Cover designs 401 400000 $0 

 Control device design 401 400000 $0 

 Control equipment testing1110000 $0 

 Control equipment inspections111 49 4925 $3,149 

 Control equipment monitoring111 49 4925 $3,149 

 Control device CMS1 52 52 49 2,548 127 255 $163,765 
18

 LDAR program4 16 64 49 3,136 157 314 $201,557 

 PRD program2 16 32 49 1,568 78 157 $100,778 

 Off-site material 

determinations

1 52 52 49 2,548 127 255 $163,765 

 F. Time to train personnel 

 Waste determination methods 401 400000 $0 

 Control equipment inspect and 

monitor 40

1 400000 $0 

 LDAR program818 49 392 20 39 $25,195 

 PRD program818 49 392 20 39 $25,195 

 G. Time for audits N/A

RECORDKEEPING SUBTOTAL 

(Rounded) 47,972 $2,681,106 

TOTAL LABOR BURDEN AND COST 

(Rounded) 49,118 $2,745,132 
19

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

Burden Item

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

EPA 

person-hour

s per 

occurrence

No. of 

occurrence

s per plant 

per year

EPA 

person-hour

s per plant 

per year 

(C=AxB)

Plants 

per year

Technical 

person-hour

s per year 

(E=CxD)

Manageme

nt 

person-hour

s per year 

(Ex0.05)

Clerical 

person-hour

s per year 

(Ex0.1)

Cost,$ 

REPORT REVIEW

 New Plants

 Initial notification (PRD) (a) 2 0.33 0.67 49 33 2 3 $1,701 

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

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

 Performance test report 16 0 0 0 0 0 0 $0 

 Existing Plants

 Semiannual summary report 4 2 8 49 392 20 39 $20,315 

TOTAL ANNUAL EPA BURDEN AND COST 

(Rounded) 489 $22,017 

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