SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) 

(Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) 

(Renewal), EPA ICR Number 1891.07, OMB Control Number 2060-0428. 

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Publicly

Owned Treatment Works (40 CFR Part 63, Subpart VVV) were proposed on December 1, 1998, 

promulgated on October 26, 1999, and most-recently amended on December 22, 2008. These 

regulations apply to both existing and new publicly owned treatment works (POTWs) located 

at a major source of hazardous air pollutants (HAPs), or to industrial POTWs that are either area 

or major sources. New facilities include those that either commenced construction or reconstruction after the date of proposal. This information is being collected to assure compliance 

with 40 CFR Part 63, Subpart VVV.

In general, all NESHAP standards require initial notification reports, performance tests, 

and periodic reports by the owners/operators of the affected facilities. They are also required 

to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in 

the operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to the NESHAP.

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U.S.

Environmental Protection Agency (EPA) regional office.

The term “Affected Public” applies to owners and operators of POTWs and their 

“burden” may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for 

Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal). All of the 

facilities are owned and operated by either state, local, or tribal governments. The “burden” to 

the Federal Government is attributed entirely to work performed by either Federal employees or 

government contractors, and may be found below in Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV)

(Renewal).

Over the next three years, approximately six respondents per year will be subject to these
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standards. No additional respondents per year will become subject to these same standards.

The Office of Management and Budget (OMB) approved the currently active ICR 

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, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, HAP emissions from POTWs 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 63, Subpart 

VVV.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards 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 initial 

capability to comply with the emission standards. Continuous emission monitors are used to 

ensure compliance with the standard at all times. During the performance test, a record of the 

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

determine compliance in place of a continuous emission monitor.
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The notifications required in these standards are used to inform either the Agency or 

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

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

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

are being met. The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

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

determinations.

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

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subpart 

VVV.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated 

state or local agency. If a state or local agency has adopted its own similar standards to 

implement the Federal standards, a copy of the report submitted to the state or local agency can 

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

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 ICR was published 

in the Federal Register (79 FR 30117) on May 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 recordkeeping and reporting 

provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities.

Industry trade associations and other interested parties were provided with an opportunity

to comment on the burden associated with the standard when it was being developed and further 

amended, and the standard has been previously reviewed to determine the minimum information 

needed for compliance purposes. For the current renewal, EPA contacted both the National 

Association of Clean Water Agencies, at (202) 833-9106, and the Southern California Alliance 

of Publicly Owned Treatment Works, at (760) 479-4880.
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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 do not violate any of the regulations 

promulgated by OMB under 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 

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

the Part 70 permit program and the five-year statute of limitations on which the permit program 

is based. 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. EPA has found that the most flagrant violators have violations extending 

beyond five years. In addition, EPA would be prevented from pursuing the violators due to 

either 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 (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 standard do not include sensitive 

questions.
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4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are owners and 

operators of POTWs. The North American Industry Classification System code for the 

respondents affected by the standard is 221320 (Sewage Treatment Facilities), which 

corresponds to the United States Standard Industrial Classification code 4952 (Sewerage 

Systems).

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV).

A source must make the following notifications:

Notifications

Initial notification 63.9(b), 63.1591(b)

Request for extension of compliance 63.9(c)

Notification of special compliance requirements 63.9(d)

Notification of initial performance tests 63.7(b), 63.9(e),

63.1590(f)

Additional notification requirements for sources with CMS 63.9(g)

Notification of compliance status 63.9(h)

Notification of adjustments to time periods for submitting

required communications

63.9(i)

Notification of changes to information provided 63.9(j)

A source must make the following reports:

Reports

Initial performance test report 63.10(d)(2), 

63.1590(f)

Inspection and monitoring plan 63.1588(c)

Startup, shutdown, malfunction plan 63.6(e)(3)
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Reports

Startup, shutdown, malfunction report 63.10(d)(5), 

63.1590(f)

Semiannual report 63.1590(f)

Excess emissions report 63.10(e)(3), 63.10(e)

Initial report on compliance approach 63.1590(g)

A source must keep the following records:

Recordkeeping

Record of annual inspections 63.1589 (a)(1)

Records of defects detected 63.1589(a)(2)

Records of defect repair delays 63.1589(a)(3)

Records of control devices covered by other NESHAPS 63.1590(a)(4)

Records of methods used to calculate annual HAP emissions 63.1589(b)(1)

Record of methods and data used to determine if POTW meets

fraction emitted standard 63.1589(b)(2)

Records of methods and data that demonstrates POTW is in

continuous compliance 63.1589(b)(3)

Maintain records of five years 63.10(b)(1)

Records of startups, shutdowns, and malfunctions 63.10(b)(2)

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 regulatory requirements.

Write the notifications and reports listed above.
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Respondent Activities

Prepare required plans and perform initial performance test, if required.

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.

Adjust the existing ways to comply with any previously applicable instructions and 

requirements.

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

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, 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 excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in Integrated Compliance Information System (ICIS) and 

Enforcement and Compliance History Online (ECHO). 

5(b) Collection Methodology and Management
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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 reported by state and local governments in the 

ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is 

EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

and government-owned facilities. EPA uses ICIS 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 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 types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown below in Table 1: Annual Respondent Burden and Cost – NESHAP for Publicly Owned 

Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal).

6. Estimating the Burden and Cost of the Collection

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

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

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

concept of “burden” under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.
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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 17 (Total Labor Hours from Table 1

below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NESHAP 

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: 

Managerial $129.93 ($61.87 + 110%) 

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 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 by 110 percent to account for 

the benefit packages available to those employed by private industry.

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

The only costs to the regulated industry resulting from information collection activities 

required by the subject standard are labor costs. There are no capital/startup or operation and 

maintenance (O&M) costs.

(iii) Capital/Startup vs. Operation and Maintenance (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 or O&M costs.

6(c) Estimating Agency Burden and Cost

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

information. EPA's overall 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 
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$628. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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 Publicly

Owned Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

six existing respondents will be subject to the standard. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is six per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR: 

Number of Respondents

Respondents That Submit Reports Respondents That Do 

Not Submit Any Reports

Year

(A)

Number of New 

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 6 0 0 6

2 0 6 0 0 6

3 0 6 0 0 6 

Average 0 6 0 0 6

1

New respondents include sources with constructed, reconstructed, and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three-year period of this ICR is six.
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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)+D

Initial notification 0 1 0 0

Notification of compliance status 0 1 0 0

Request for extension of 

compliance

0 1 0 0

Notification of special

compliance requirements

0 1 0 0

Notification of initial 

performance test

0 1 0 0

Additional notification 

requirements for sources with 

CMS

0 1 0 0

Notification of adjustments to 

time periods

0 1 0 0

Notification of changes to 

information provided

0 1 0 0

Initial performance test report 0 1 0 0

Inspection and monitoring plan 0 1 0 0

Semiannual report 6 2 0 12

SSM report 0 1 0 0

Excess emissions report 0 1 0 0

Initial report on compliance 

approach

0 1 0 0

Total 12

CMS - Continuous Monitoring System

SSM - Startup, Shutdown, and Malfunction

The number of Total Annual Responses is 12.

The total annual labor costs are $1,730 (rounded). Details regarding these estimates may

be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Publicly Owned 

Treatment Works (40 CFR Part 63, Subpart VVV) (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. 
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(i) Respondent Tally

The total annual labor hours are 17 hours at a cost of $1,730 (rounded). Details regarding 

these estimates may be found below in Table 1: Annual Respondent Burden and Cost –

NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal). 

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

tasks because the typical 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 typical 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 1 hours per response.

There are neither annual capital/startup nor O&M costs to this regulated entity.

(ii) The Agency Tally

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

14 labor hours at a cost of $628. See below Table 2: Average Annual EPA Burden and Cost –

NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal).

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

tasks because the typical 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 typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an increase in the respondent burden from the most recently approved ICR. This 

increase is not due to any program changes. EPA revised the burden calculations to assume that 

all respondents incur a rule familiarization burden annually. Previously, EPA assumed that only

new sources would incur this burden. This change resulted in the burden increase in this ICR.

There is also an increase in respondent and Agency burden costs from the most recently 

approved ICR due to the use of updated labor rates. This ICR references labor rates from the 

Bureau of Labor Statistics to calculate respondent burden costs, and references labor rates from 

OPM to calculate Agency burden costs.

6(g) Burden Statement

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

is estimated to average one hour per response. Burden means the total time, effort, or financial 

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

to or for a Federal agency. This includes the time needed to review instructions; develop, 
13

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

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

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

the information.

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

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

Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA-HQ-OECA-2014-0071. An electronic version of the public docket is 

available at http://www.regulations.gov, which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), 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 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

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

Number EPA-HQ-OECA-2014-0071 and OMB Control Number 2060-0428 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart 

VVV) (Renewal)

Burden item

A B C D E F G H

Personhours

per 

occurrence

Annual 

occurrences

per 

respondent

Personhours

per 

respondent

per year 

(AxB)

Respondents

per year a

Technical 

hours per

year 

(CxD)

Management 

hours per 

year (Ex0.05)

Clerical 

hours

per year

(Ex0.10)

Annual 

cost

($) b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

A. Familiarization with rule requirements c0.5 1 1 6 3 0.2 0.3 346.94

B. Required activities

Initial notification 2 1 2 0 0 0 0 0

Notification of compliance status d N/A

C. Create information See 3B

D. Gather existing information See 3B

E. Write reports

Request for extension of compliance 2 1 2 0 0 0 0 0

Notification of special compliance requirements 2 1 2 0 0 0 0 0

Notification of initial performance test d N/A

Additional notification requirements for source 

with CMS

2 1 2 0 0 0 0 0

Notification of adjustments to time periods 2 1 2 0 0 0 0 0

Notification of changes to information provided 2 1 2 0 0 0 0 0

Initial performance test report d N/A

Inspection and monitoring plan d N/A

SSM plan d N/A

Semiannual report 1 2 2 6 12 0.6 1.2 1,387.75

SSM report d N/A
15

Excess emissions report 2 1 2 0 0 0 0 0

Initial report on compliance approach 2 1 2 0 0 0 0 0

Reporting Subtotal 17 1,735

4. Recordkeeping

A. Familiarization with rule requirements See 3A

B. Plan activities See 3E

C. Implement activities See 3E

D. Develop record system See 3E

E. Time to enter information

Records of annual inspections d N/A

Records of inspections, defects, and repair 

delays d

N/A

Methods and data used to determine compliance 

and emissions d

N/A

F. Time to transmit or disclose information N/A

G. Time to train personnel N/A

H. Time for audits N/A

Recordkeeping Subtotal 0 0

TOTAL ANNUAL BURDEN AND COST 

(ROUNDED) e

17 1,730

TOTAL ANNUAL CAPITAL AND O&M COST 

(SEE SECTION 6(b)(iii))

0

GRAND TOTAL (LABOR, CAPITAL, AND O&M) 

e

1,730

CMS - Continuous Monitoring System

N/A - Not Applicable

SSM - Startup, Malfunction, or Startup

Assumptions:

a EPA estimates an average of six existing sources will be subject to the standard. We do not expect any new sources will become subject to the rule over the 

next three years.
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b This ICR uses the following labor rates: $103.97 (technical), $129.93 (managerial), and $51.79 (clerical). 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.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

c This burden represents the time existing respondents spend re-familiarizing themselves with rule requirements. For new sources, we assume 4 hours per 

occurrence is required. 

d Only new sources are subject to rule emission limits, control requirements, and related performance testing, plan development, and reporting activities. Since 

no new sources are expected, these activities are not applicable. These requirements and activities do not apply to existing sources, which demonstrate 

compliance with the rule by operating treatment and control devices that meet all requirements specified in the appropriate industrial NESHAP(s).

e Totals have been rounded to three significant digits. Figures may not add exactly due to rounding. 
17

Table 2: Average Annual EPA Burden and Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart 

VVV) (Renewal)

Burden item

A B C D E F G H

EPA

person-hours

per 

occurrence

Annual 

occurrences

per respondent

EPA

person-hours

per respondent

per year 

(AxB)

Respondents

per year a

Technical 

hours

per year

(CxD)

Management

hours 

per year

(Ex0.05)

Clerical 

hours

per year

(Ex0.10)

Annual 

cost

($) b

Initial performance test c N/A

Repeat initial performance test c N/A

Report review

Initial notification 2 1 2 0 0 0 0 0

Notification of compliance status c2 1 2 0 0 0 0 0

Request for extension of compliance 0.5 1 1 0 0 0 0 0

Notification of special compliance 

requirements

2 1 2 0 0 0 0 0

Notification of initial performance test 

c

2 1 2 0 0 0 0 0

Additional notification requirements 

for sources with CMS

2 1 2 0 0 0 0 0

Notification of adjustments to time 

periods

2 1 2 0 0 0 0 0

Notification of changes to information 

provided

2 1 2 0 0 0 0 0

Initial performance test report c N/A

Inspection and monitoring plan c N/A

Semiannual report 1 2 2 6 12 0.6 1.2 628.08

SSM report c N/A

Excess emissions report N/A

Initial report on compliance approach 2 1 2 0 0 0 0 0

TOTAL ANNUAL BURDEN AND COST (ROUNDED) d 14 628

CMS - Continuous Monitoring System
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N/A - Not Applicable

SSM - Startup, Malfunction, or Startup

Assumptions:

a

 EPA estimates an average of six existing sources will be subject to the standard. We do not expect any new sources will become subject to the rule over the next 

three years.

b

 This ICR uses the following labor rates: $46.67 (technical), $62.90 (managerial), and $25.25 (clerical). These rates are from the Office of Personnel 

Management (OPM), 2014 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.

c

 Only new sources are subject to rule emission limits, control requirements, and related performance testing, plan development, and reporting activities. Since no 

new sources are expected, these activities are not applicable. These requirements and activities do not apply to existing sources, which demonstrate compliance 

with the rule by operating treatment and control devices that meet all requirements specified in the appropriate industrial NESHAP(s).

d

 Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.