**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 I CR 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 appl y 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 re constructio n 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 b y the owners/operator s 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 s ys tem 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 directl y 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 government s . The “burden ” to the Federal Government is attributed entirely to work performed by either F ederal emplo ye es 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 ye ars, approximately six respondents per ye ar will be subject to the se2

standard s . No additional respondents per ye ar will become subject to the se same standard s . The Office of Management and Budget (OMB) approved the currentl y active I CR without any

“Terms of Clearance.” **2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. Inaddition, S ec tion 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 reasonab l y require. In the Administrator's judgment, HAP emissions fro m POTWs either cause or contribute to air pollution that may

reasonabl y be anticipated to endanger public he alth 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 the se standard s ensure compliance with the applicable regulations which w ere 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 comp ly

with the emission standard s . 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.3

The notifications required in the se standard s 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 sourc e to check if the pollution control devices are properl y installed and operated , that leaks are being detected and repaired , and that the standard s are being met. The performance test may also be observed. The required semiannual reports are used to dete rmine 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 directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency . If a state or local agency has adopted its own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Pub**  **lic Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this I CR was published in the Federal Register (79 FR 30117) on 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 rep orted by industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Integrated Compliance Information Sy stem (I CI S). IC IS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industri al 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 th e Southern California Allian ce of Publicly

Owned Treatment Works , at (760) 479

- 4880.4

**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 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 do not violate any of the regulations promulgated b y 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 the se standards. EPA believes that the five

- ye ar records retention requirement is consistent with the Part 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 allow s 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, C ha pter 1, P art 2, S ubpart 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.5

**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 b y the standard is 221320 (Sewage Treatment Facilities), which corresponds to the United States Standard Industrial Classification code 4952 (Sewerage Sy stems)

. **4(b) Information Requested (i) Data Items**  In this ICR , all the data that is recorded or reported is required b y the NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV). A source must make the following notifications :
**Notification s**  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)6 **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 b y 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 asso ciated with monitoring and recordkeeping at a plant site. **(ii) Respondent Activities Respondent Activities**  Familiarization with regulatory requirements. Write the notifications and reports listed above.7 **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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing 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 in formation : **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, inc luding performance test reports and excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in Integrated Compliance Information System (I CI S) and Enforcement and Compliance History Online ( ECHO )

.

**5(b) Collection Methodology and Management** 8

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to comply with the emission standard , and note the operating conditions under which complianc e 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. In formation contained in the reports is reported b y state and local governments in the IC IS Air database , which is operated and maintained by EPA's Office of Compliance. IC IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for industrial and government

- owned facilities. EPA uses IC IS for tracking air pollution compliance and enforcement b y local 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 b y this regulation must be retained by the owner/op erator for five ye ars. **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 ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collectio n 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 I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of “burden ” under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

.9

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 record

keeping and reporting requirement s 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 th e 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: Managerial $ 129

. 93 ($ 61.87 + 110%) Technical $ 103

. 97 ($ 49.51 + 110%) Clerical $ 5 1

. 79 ($2 4

. 66 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/ Startup and Operation an**  **d Maintenance Costs** The only costs to the regulated industry resulting from information collection activities required b y the subject standard are labor costs. There are no capital/startup 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 anal ys is of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maint ained by the respondents, periodic 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 be10

$628

. This cost is based on the average hourl y labor rate a s follows:

Managerial $ 6 2. 90 (GS

- 13, Step 5, $ 3 9.31 + 60% ) Technical $ 4 6

. 67 (GS

- 12, Step 1, $ 2 9

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

- 6, Step 3, $ 15. 78 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 4 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 Cos t

– 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 I CR, on average over the next three ye ars, approximately six ex isting respondents will be subject to the standard. It is estimated that no additional re spondents per ye ar will become subject. The overall average number of respondents, as shown in the table below, i s six per year . The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR : **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w Respondents 1 (B)

Number of Existing Respondents (C)

Number of Existing Respondents that keep records but do not submit reports (D) Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 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

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR i s six.11

The total number of annual responses per ye ar is calculated using the following table: **Total Annual Responses** (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (E) Total Annual Responses E=(BxC)+D

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 i s 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.12 **(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 ty

pical tasks for managers are to review and approve reports. Clerical burden s are assumed to take 10% of the time required for technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records. Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to averag e 1 h ours per response . Th ere are n either annual capital/startup nor O&M costs to th is regulated entity

. **(ii) The Agency Tally** The average annual Agency burden and cost over the next three years is estimated to b e 14 labor hours at a cost o f $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 ty

pical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the ty pical duties of clerical staff are to proofread the reports, make copies and maintain records. **6(f) Reasons for Change in Burden**  There is an increase in the respondent burden from the most recentl y approved I CR. 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 recentl y approved ICR due to the use of updated labor rates. This I CR references labor rates from the Bureau of Labor Statistics to calculate respondent burden costs, and references labor rates f rom 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 averag e one hour per response. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop,13

acquire, install, and utilize technology and s ys tems for the purpose s of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and 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 I CR 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 th e docket, and to access those documents in the public docket that are available electronically

. When in the sy stem , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Frid ay , excluding legal holidays. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 17 52

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2014

- 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.14

**Table 1 : Annual Respondent Burden and Cost** 

**– NESHAP for Pub**  **licly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal)** 

**Burden item A**  **B C**  **D E**  **F G**  **H Person**  **** **hours per**  **occurrence Annual** 

**occurrences per**  **respondent Person**  ****

**hours per**  **respondent per year**  **(AxB) Respondents** 

**per year a**  **Technical**

**hours per year**  **(CxD) Managem**  **ent**

**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 c 0.5 1 1 6 3 0.2 0.3 346.94 B. Required activities Initial notific ation 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/A15

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 **Assu mptions:**  a EPA estimates an average of six existing sources will be subject to the standard. We do not expect any ne w sources wi ll become subject to the rule over the next three years.16

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.” T he 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) Managem**  **ent**

**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 c 2 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 System18

N/A

- Not Applicable SSM

- Startup, Malfunction, or Startup **Assu mptions:**  a EPA estimates an average of six existing sources will be subject to the standard. W e do not expect any ne w sources wi ll 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 fro m the Office of Personnel Management (OPM), 20 14 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the be nefit 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 acti vities 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 di gits. Figures may not add exactly due to rounding.