**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY** 

**NESHAP for O ff** 

**- Site Waste and Recovery Operations**  **( Revised**  **) 1**  **. Identificatio**  **n of the Information Collection 1(a) Title**  **of the Information Collection** N ational Emission Standards for Hazardous Air Pollutants (NESHAP) for Off

- Site Waste and Recovery

Operations (OSWRO) (40 CFR part 63, s ubpart DD ) (Revised) , EPA I CR Number 1717.1 1 , OMB Control Number 2060

- 0 313

. **1(b) Short**  **Characterization/Abstract** The amendments to this information collection request ( IC R) are a result of the review of the existing NESHAP for OSWRO (40 CFR p art 63, s ubpart 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 pollutant s (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 i s 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 spe cific types of affected sources: tanks

- level 1; containers; surface impoundments; individual drain s ys tems; oil

- water separators; organic water separators; and loading, transfer, and storage s ys tems. 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 amend s 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 s ys tem 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

In formation related to these new provisions is required to be submitted in the semi

- annual reports required b y the existing NESHAP. Inaddition, 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 organi c 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 Offi ce of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.” The overall change in burden found in this I CR reflect the provision changes, an update in the cost of labor, and corrections to the number of affected facilities found in EPA I CR number 1717.0 9

. The period considered in this I CR and throughout this supporting statement is the first three ye ars following the promulgation of the amended OSWRO NESHAP. The estimates of the size of the regulated universe are ba sed on data from the National Emissions Inventory (NE I) database , available permit data and information collected in the 2013 OSWRO CAA section 114 survey
. There are an estimate d 5 6 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 e stimate that there is an annual average of 4 9 respondents that wi ll be subject to the regulation

. We do not know of any new facilities that are expected to be constructed in the foreseeable future , so consequentl y 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 categ ory 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

. Inaddition, 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 such3 audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. **2(b) Prac tical 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 i nitial capability to comply

with the emissio n standard. Continuous emission monitors are used to ensure compliance with the standard at all times. Durin g 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 properl y installed and operated, that leaks are being detected and repaired, and that the standards are being met

. The perform ance 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 I CR 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 exi sting standards and ongoing ICR s revealed no duplication of information gathering efforts. However, certain reports required b y s tate or local agencies may duplicate information required by this NESHAP

. In these cases , a cop y of the report submitted to the s tate or local agency

can be sent to the Administrator in lieu of the report required b y the F ederal standards

. Th erefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB** This I CR 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 ye ars, an average of 4 9 facilities per year will be subject to the standard, with no additional sources per year b ecoming 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. W e reviewed information available from the Online Tracking Information System (OTIS) , which is the primary source of information regarding the number of existing sources. OT IS data was used in conjunction with industry consultation to verify

the number of
s ources 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 rec ordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met

. If the information required by these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely

. **3(e) General Guidelines** These reporting or recordkeeping requirements 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 Provision s as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part5

70 permit program and the five

- ye ar 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 appropriat e level of enforcement action. The EPA has found that the most flagrant violators have violations extending beyond the five years. Without the five

- ye ar record retention, the EPA would be prevented from pursuing the violato rs due to the destruction or nonexistence of essential records. **3(f ) Confidentiality**  Any information submitted to the Agency for which a claim of confidentiality i s 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 b y 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 Respondent s and the Information Requested**  **4(a) Respondents** The respondents to the recordkeeping and reporting requirements are OSWRO that store, treat, recycle, reprocess, or disp ose of wastes containing organic chemical compounds. The United States Standard Industrial Classification (SI C) codes, which correspond to the North American Industry Classification System (NAICS) codes, could be found in the following table: **Off**
**- site Wast**  **e 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 3252116 **Off**
**- site Wast**  **e 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 Securitya 928110

a One facility

i s 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 I CR that is recorded and/or reported is required b y 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 con struction/reconstruction 63.5(d) Notific ation of initial startup 63.9(b) Notification of initial perf ormance 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** Complian ce status 63.9(h) Notification o f 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 63.6 97 ( 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 63.69 6(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 by passes 63.696(j) Records should be r etained for 5 ye ars. 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 onl y proposing electronic reporting of performance tests.

**(ii) Respondent Activities**

**Respondent Activi ties**  Read instructions. Install, calibrate, maintain and operate CMS

. Perform initial performance test and repeat performance tests if necessary . Perform anal ys es 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 Methodol ogy, and Information**  **Management 5(a)**  **Agency Activities** The EPA conducts the following activities in connection with the acquisition, anal ys is, 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, anal yz e and maintain data in the Online Tracking Information System (OTI S).9

**5(b) Collection Methodology and Management**  Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agenc y 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 enf orcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations. In formation contained in the reports is entered into OTI S which is operated and maintained by EPA's 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 OTI S 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 anal yz e the data. The records required b y this regulation must be retained by the owner/operator for five ye ars. **5(c) Small Entity Flexibility** 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 ty pe 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 Schedu le**  The specific frequency

f or 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, s ubpart 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 I CR

. 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 and10

major assumptions have been identified

. Responses to this inform ation 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 C ontrol 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 4 9,118 ( 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 I CR 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 201 3 National Occupational Employ ment 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 s ys tem operators (technical), 11

- 1021 for general and operations managers (managerial) and 43

- 6010 for secretaries and administrative a ssistants (clerical).

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

costs associated with the information collection activities in the subject standard are labor costs which are addressed elsewhere in this IC R and the costs associat ed 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 organic11

HAP service that vents to the atmosphere. The cost of each monitoring s ys tem 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 4 9 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 require s storage vessels of certain sizes and containing materials above certain vapor pressures to use Level 2 controls. Compared to current requirements, th e requirement s 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

. Indetermining 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 I CR 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 , 00 0. For the PRD monitors, annualized co sts are calculated b y multiplying the capital recovery factor by the capital cost. The capital recovery factor is 0.1 424 based on an interest rate of 7 percent and an assumed equipment life of 1 0 years. For the LDAR requirements, the capital recovery facto r 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 1 5 ye ars
. In addition, for the LDAR and storage tank requirements, other annual monitoring and operating costs are included in the annual costs . The annual ized cost s 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 4 9 $0 $1,505 4 9 $ 73,745 LDAR $ 4 2,626 4 9 $ 2, 0 88 , 689 $1 3, 550 4 9 $ 6 63,955 PRD Monitoring Equipment $38,886 4 9 $1, 905,410 $5,537 4 9 $ 271,3 13 Storage Tanks

1 $ 139,497

- $ 139,497 $ 191,886

- $ 191,886
Total $ 4, 1 33,596 $ 1, 200,899
1 C ost s shown are the total costs for the estimated 14 additional tanks captured under the new threshold. The total capital/startup costs for this IC R are $ 4,1 33,596

. This is the total of column D in the above table. The total annual and operation and maintenance (O&M) costs for this I CR 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 anal ys is 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 distrib ution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 2 2,017

. This cost is based on the average hourl y 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 - hourl yovertime

- 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 ye ars covered b y this I CR. Over the three ye ar period of this ICR, we expect 4 9 existing facilities to be respondents. The total number of annual responses per ye ar is calcul ated using the following table:

**YEAR (** **A )**  **( B**  **) (**  **C )**  **( D**  **) (E)** 

**Number of New**  **Respondents Number** 

**Existing Respondents**  **Number of Existing** 

**Respondents T**  **hat 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 4 9 0 0 4 9 2 0 4 9 0 0 4 9 3 0 4 9 0 0 4 9 Av erage 0 4 9 0 0 4 9
To avoid double

- counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three

- ye ar period of this I CR is 4 9

. The total number of annual responses per ye ar is calculated using the following table: **Total Annu al Responses**  **(A) Inform**  **ation 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) 4 9 0.33 0 1 6 Semiannual periodic report 4 9 2 0 9 8 Total Number of Annual Responses 1 14

The numb er of Total Annual Responses is 1 14

. **6(e) Bottom Line Burden Hou rs Burden Hours and Cost Tables**  The detailed bottom line burden hours and cost calculations for the respondents and the14

Agency are shown in Tables 1 and 2, respe ctivel y, and summarized below. **(i) Respondent Tally** The average annual respondent burden and cost over next three ye ars is estimated to be 4 9,118 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 CF 93 R Part 63, Subpart DD) (Revised)

.

**(ii) The Agency Tally** The average annual Agency burden and cost over next three ye ars is estimated to be 4 8 9 l abor hours at a cost of $2 2,017

. See below Table 2: Average Annual EPA Burden for the Proposed NESHAP for OSWRO (40 CFR part 63, s ubpart DD) (Revised)

. **6(f) Reasons for Change in Burden** The rulemaking amend s 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 I CR number 1717.09

. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 4 3 1 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 s ys tems 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 p reviously

a pplicable instructions and requirements; to train personnel to be able to respond to a coll ection 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 CF R 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, s ubpart**  **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 person**
  ** hours** **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 $417,76817 Other facilities (f) 1 12 12 25 300 15 30 $19,282 c. Control equipment visual inspection Large cover 0.25 10 2.5 49 123 6 12 $7,873 Small cover 0.05 1000 50 49 2,450 123 245 $157,466 Closed vent system 0.5 5 2.5 49 123 6 12 $7,873 d. Control equipment leak monitoring Cover vented to control device 1 5 5 49 245 12 25 $15,747 Closed vent system 1 5 5 49 245 12 25 $15,747 e. Control devices Performance determination 40 1 40 0 0 0 0 $0 Continuous monitoring system 8 5 40 49 1,960 98 196 $125,973 f. LDAR program Identify affected waste streams 40 1 40 0 0 0 0 $0 Perform monitoring/repair 80 1 80 49 3,920 196 392 $251,946 g. PRD monitoring Identification of PRD devices 8 1 8 0 0 0 0 $0 Perform monitoring/repair 16 1 16 49 784 39 78 $50,389 D. Develop record system Control equipment 16 1 16 0 0 0 0 $0 LDAR program 40 1 40 0 0 0 0 $0 PRD program 8 1 8 49 392 20 39 $25,195 E. Time to enter information Cover designs 40 1 40 0 0 0 0 $0 Control device design 40 1 40 0 0 0 0 $0 Control equipment testing 1 1 1 0 0 0 0 $0 Control equipment inspections 1 1 1 49 49 2 5 $3,149 Control equipment monitoring 1 1 1 49 49 2 5 $3,149 Control device CMS 1 52 52 49 2,548 127 255 $163,76518

LDAR program 4 16 64 49 3,136 157 314 $201,557 PRD program 2 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 40 1 40 0 0 0 0 $0 Control equipment inspect and monitor 40 1 40 0 0 0 0 $0 LDAR program 8 1 8 49 392 20 39 $25,195 PRD program 8 1 8 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, s**  **ubpart 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.