SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG) (Renewal), 

EPA ICR Number 2062.05, OMB Control Number 2060-0534

1(b) Short Characterization/Abstract

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

Remediation were proposed on July 30, 2001, and promulgated on October 8, 2003. The most 

recent amendments to these regulations were proposed on May 1, 2006, and promulgated on 

November 29, 2006. These regulations apply to site remediation activities that use certain types 

of equipment to clean up materials containing organics that potentially could be released to the 

atmosphere as a hazardous air pollutant (HAP). These site remediation activities can potentially

be conducted at any facility where materials containing organic HAP currently are or have been 

stored, processed, treated, or otherwise managed at the facility. The types of businesses most 

likely to be subject to the rule include, but are not limited to, organic liquid storage terminals, 

petroleum refineries, chemical manufacturing facilities, and manufacturing facilities using 

organic materials. This information is being collected to assure compliance with 40 CFR part 

63, subpart GGGGG.

In general, all NESHAP standards require initial notifications, 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 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.

 Based on our consultations with industry representatives, there is an average of one 

affected facility at each site and that each site has only one respondent (i.e., the owner/operator 

of the plant site).

Over the next three years, an average of 286 respondents per year will be subject to the 

standard, and no additional respondents per year will become subject to the standard. Of the 286 

respondents, we estimate 243 respondents from the private sector (85 percent), 14 respondents 
2

from the state, local, or tribal governments (5 percent), and 29 respondents from the Federal 

government (10 percent). 

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

without any “Terms of Clearance.”

The “Affected Public” is owners and operators of facilities that conduct site remediation 

activities, and includes respondents from the private sector, state, local and tribal government, as 

well as the Federal Government. The burden to the “Affected Public” may be found below in

Table 1: Annual Respondent Burden and Cost – NESHAP for Site Remediation (40 CFR Part 63, 

Subpart GGGGG) (Renewal). 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 Site Remediation (40 CFR 

Part 63, Subpart GGGGG) (Renewal). 

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 site remediation activities cause or 

contribute to air pollution that may reasonably be anticipated to endanger public health or 

welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR part 63,

subpart GGGGG.
3

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard(s) ensure compliance with 

the applicable regulations which where 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 standard. 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. 

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 check if the pollution control devices are properly 

installed and operated, leaks are being detected and repaired, and the standard 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. 

To minimize the burden, much of the information the EPA needs to determine 

compliance is recorded and retained on-site at the facility. Such information will be reviewed by 

the enforcement personnel during an inspection and will not need to be reported routinely to the 

EPA. The Agency requires respondents to report a minimal amount of information to 

demonstrate compliance. However, when a deviation occurs, additional information must be 

reported that describes the cause of the deviation, steps taken to correct the problem, and time 

required to return to compliance.

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

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart

GGGGG.

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.
4

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 (77 FR 63813) on October 17, 2012. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is the Online Tracking Information System (OTIS) which is 

operated and maintained by EPA's Office of Compliance. OTIS is EPA’s database for the 

collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is 

based on our consultations with the Agency’s internal industry experts. 

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

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes. In developing this ICR, we contacted: 1) the American Chemistry Council (ACC), 

at (202) 249-7000; and 2) Regenesis, at (949) 366-8000.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received.

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 

the 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 
5

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 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.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

Unlike a specific industry sector or type of business, the respondents potentially affected 

by this ICR cannot be easily or definitively identified. Potentially, the site remediation NESHAP 

may be applicable to any type of business or facility at which a site remediation is conducted to 

clean up media contaminated with organic HAP, and the remediation activities performed and 

the magnitude of the cleanup meets the applicability criteria specified in the rule. A site 

remediation that is subject to this rule potentially may be conducted at any type of privately 

owned or government-owned facility at which contamination has occurred due to past events or 

current activities at the facility. Site remediation performed at sites where the facility has 

permanently closed, the owner has gone out of business, or the facility has been abandoned and 

there is no owner (in this latter case, a government agency takes responsibility for the cleanup) 

are not subject to this NESHAP in most cases.

The regulated sources under this NESHAP (i.e., the site remediation activities) are not the 

predominant activity, process, operation, or service conducted at the facility. A comprehensive 

list of Standard Industrial Classification (SIC) codes and North American Industry Classification 

System (NAICS) codes cannot be compiled for the respondents who will potentially be regulated 

by this action due to the nature of activities regulated by the source category. The NAICS code 

indicates a primary product produced or service provided at the facility rather than the presence 

of a site remediation performed to support the predominant function of the facility. Some 

representative NAICS codes for facilities where site remediation activities have been, or are 

currently being, conducted at some (but not all) facilities under a given code include: 325211, 

325192, 325188, 32411, 49311, 49319, 48611, 42269, and 42271. However, these codes are not 

necessarily comprehensive as to the types of facilities at which site remediation subject to the 
6

rule may be required in the future.

4(b) Information Requested

(i) Data Items

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

Remediation (40 CFR Part 63, Subpart GGGGG). 

A source must make the following reports:

Notifications/Reports

Initial notification 63.7950(a), (c)

Notification of performance tests 63.7950(a), (d)

Notification of compliance status 63.7950(a), (e)

Performance test results 63.7950(a), (e)

Notification of alternative standard selection (if applicable) 63.7950(f)

Semiannual compliance reports 63.7951(a), (b)

Startup, shutdown, malfunction reports 63.7951(a), (b), (c)

Part 70 monitoring report 63.7951(d)

A source must keep the following records:

Recordkeeping

Copies of each notification and report submitted to comply with 

subpart as listed above 63.7952(a)(1)

Records related to startups, shutdowns, and malfunctions 63.7952(a)(2)

Records of performance tests 63.7952(a)(3)

Records of initial and subsequent determinations for affected sources 

exempted from control requirements 63.7952(a)(4)

Records of control device operating parameter continuous monitoring 

system (CMS) deviations, calibrations, and maintenance 63.7952(b)

Records to show continuous compliance with each emissions 

limitation, work practice standard, and operation and maintenance 

requirement

63.7952(c), (d)
7

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. 

Also, regulatory agencies in cooperation with the respondents continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not 

widely used. At this time, it is estimated that approximately 10 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for VOHAP. 

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

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.

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring system). 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.
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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

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Conduct initial compliance determination. 

Audit facility records.

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

5(b) Collection Methodology and Management

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

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

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

with the emission standard. Data and records maintained by the respondents are tabulated and 

published for use in compliance and enforcement programs. The semiannual reports are used for 

problem identification, as a check on source operation and maintenance, and for compliance 

determinations.

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

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

maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

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

years.

5(c) Small Entity Flexibility

The rule places no requirement on any facility to initiate site remediation activities. The 

EPA anticipates that parties that undertake site remediation generally do so voluntarily and that 

the impact of this rule on those parties will not be significant. Further, because states and other 

parties decide whether to undertake site remediation activities, predicting how many, or what 
9

types of small entities will undertake such activities, is extremely difficult, if not impossible. 

Nonetheless, the rule is structured to avoid impacts on small businesses. 

The rule specifically excludes from its scope remediation conducted at gasoline stations, 

farm sites, and residential sites. Moreover, the rule applies only to remediation sites located at a 

facility that is a major source under the CAA and at which is collocated one or more nonremediation activities listed as a Maximum Achievable Control Technology (MACT) major 

source category, pursuant to CAA section 112(c). Such sources tend to be large businesses. 

The rule also contains applicability emission thresholds that are likely to exclude site 

remediation conducted at many small businesses. For example, the rule exempts sources where 

the total annual quantity of HAP contained in all extracted remediation material at the facility is 

less than 1 megagram per year. For these reasons, the rule does not impose a significant burden 

on a substantial number of small entities.

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NESHAP for Site Remediation 

(40 CFR Part 63, Subpart GGGGG) (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. Wherever appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, any

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 140,338 hours (Total Labor Hours from Table 1

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

development of the regulation, Agency knowledge and experience with the 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: 
10

Managerial $121.44 ($57.83 + 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 

2012, “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 type of industry costs associated with the information collection activities in the 

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

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

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

ongoing costs to maintain the monitors and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

Parametric 

system $10,000 0 $0 $2,000 286 $572,000

Leak 

detection $1,500 0 $0 $1,000 10 $10,000

Total $0 $582,000

There are no capital/startup costs for this ICR. This is the total of column D in the above 

table. 

The total operation and maintenance (O&M) costs for this ICR are $582,000. This is the 

total of column G, which is the total cost for all 286 respondents. The cost estimate includes 

$494,496 from the private sector (243 respondents), $28,490 from the state, local, or tribal 

governments, (14 respondents), and $59,014 from the Federal government (29 respondents). 

The average annual cost for capital/startup and operation and maintenance costs 

to industry over the next three years of the ICR is estimated to be $582,000. These are 

recordkeeping costs. 
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6(c) Estimating Agency Burden and Cost

The 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. Note the burden (both 

labor costs and O&M) to the Federal government respondents have been previously summarized 

in section 6(b). 

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

$365,375. 

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2012 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 Site 

Remediation (40 CFR Part 63, Subpart GGGGG) (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

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

respondents per year will become subject; therefore, the overall average number of respondents, 

as shown in the table below, is 286 per year. 

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

years covered by this ICR. 

Number of Respondents

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 0 286 0 0 286

2 0 286 0 0 286
12

Number of Respondents

3 0 286 0 0 286

Average 286 286

1

New respondent 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 286 (243 respondents 

from the private sector, 14 respondents from the state, local, or tribal governments, and 29 

respondents from the Federal government) . 

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

Semiannual reports 286 2 0 572

Total 572

The number of Total Annual Responses is 572. 

The total annual labor costs are $13,720,488. Details regarding these estimates may be 

found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Site Remediation 

(40 CFR Part 63, Subpart GGGGG) (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 in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 140,338 hours at a cost of $13,720,488. Details 

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

Cost – NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG) (Renewal).

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 245 hours per response.
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The total annual capital/startup and O&M costs to the regulated entity are $582,000. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally

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

7,322 labor hours at a cost of $365,375. See below Table 2: Average Annual EPA Burden and 

Cost – NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG) (Renewal).

6(f) Reasons for Change in Burden

There is an adjustment increase in labor hours and costs from the most recent ICR. This 

is not due to any program changes. The increase in labor hours is due to a change in the burden 

calculation methodology. The previous ICR did not account for managerial and clerical hours 

for some burden activities. This ICR assumes that managerial and clerical hours are 5 percent 

and 10 percent of technical hours for each burden activity, respectively. The increase in costs is 

due to an increase in labor rates, as well as the methodology change described above. 

6(g) Burden Statement

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

is estimated to average 245 hours 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, 

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–2012–0695. 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 
14

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA 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–2012–0695 and OMB Control Number 2060-0534 in any

correspondence. 

Part B of the Supporting Statement

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

information.
15

Table 1: Annual Respondent Burden and Cost – NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG) (Renewal)

Burden Item

(A) 

Person 

hours per 

occurrence

(B) 

Number of 

occurrences 

per year

(C) 

Person hrs 

per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

person

hrs per 

year 

(E=CxD)

(F) 

Management 

person 

hrs per year 

(F=Ex0.05)

(G) 

Clerical 

person hrs 

per year 

(G=Ex0.1)

(H)

Total Cost 

per year ($) b

Private Sector

1. Applications NA

2. Surveys and Studies NA

3. Parametric 40 1 40 0 0 0 0 0

Monitoring System

4. Reporting requirements

- Read instructions 16 1 16 0 0 0 0 0

- Conduct performance test 120 1 120 0 0 0 0 0

- Initial notification 0 1 0 0 0 0 0 0

- Performance test notification 0 1 0 0 0 0 0 0

- Initial compliance determination 40 1 40 0 0 0 0 0

- Performance test report 80 1 80 0 0 0 0 0

- Semiannual report d40 2 80 243 19,440 972 1,944 $2,164,702.32

- SSM report 8 0 0 0 0 0 0 0

Subtotal Reporting for Private Sector 22,356 $2,164,702.32

5. Recordkeeping requirements

- Read instructions 40 1 40 0 0 0 0 0

- Plan activities 100 1 100 0 0 0 0 0

- Prepare SSM plan 80 1 80 0 0 0 0 0

- Prepare documentation for exempted sources 80 1 80 22.1 1,768 88.4 176.8 $196,872.10

- In-situ process vents parametric monitoring c0.5 365 182.5 22.1 4,033.25 201.66 403.33 $449,114.49

- Ex-situ process vents parametric monitoring e0.5 365 182.5 220.9 40,314.25 2,015.71 4,031.43 $4,489,112.68
16

Burden Item

(A) 

Person 

hours per 

occurrence

(B) 

Number of 

occurrences 

per year

(C) 

Person hrs 

per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

person

hrs per 

year 

(E=CxD)

(F) 

Management 

person 

hrs per year 

(F=Ex0.05)

(G) 

Clerical 

person hrs 

per year 

(G=Ex0.1)

(H)

Total Cost 

per year ($) b

- Inspect tank covers 2 12 24 216.7 5,200.8 260.04 520.08 $579,124.68

- Inspect container covers 0.5 12 6 220.9 1,325.4 66.27 132.54 $147,587.27

- Inspect surface impoundment covers f2 12 24 4.2 100.8 5.04 10.08 $11,224.38

- Inspect separator covers h2 12 24 4.2 100.8 5.04 10.08 $11,224.38

- Inspect transfer system covers 0.5 12 6 220.9 1,325.4 66.27 132.54 $147,587.27

- Leak detection and repair program g100 1 100 8.5 850 42.5 85 $94,650.05

- Develop record system 100 1 100 0 0 0 0 0

- Enter information i2 52 104 243 25,272 1,263.6 2,527.2 $2,814,113.02

- Personnel training 20 0 0 0 0 0 0 0

Subtotal Recordkeeping for Private Sector 92,334.3 $8,940,610.32

Total for the Private Sector 114,690.3 $11,105,312.64

State, Local or Tribal Government

1. Applications NA

2. Surveys and Studies NA

3. Parametric 40 1 40 0 0 0 0 0

Monitoring System

4. Reporting requirements

- Read instructions 16 1 16 0 0 0 0 0

- Conduct performance test 120 1 120 0 0 0 0 0

- Initial notification 0 1 0 0 0 0 0 0

- Performance test notification 0 1 0 0 0 0 0 0

- Initial compliance determination 40 1 40 0 0 0 0 0

- Performance test report 80 1 80 0 0 0 0 0
17

Burden Item

(A) 

Person 

hours per 

occurrence

(B) 

Number of 

occurrences 

per year

(C) 

Person hrs 

per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

person

hrs per 

year 

(E=CxD)

(F) 

Management 

person 

hrs per year 

(F=Ex0.05)

(G) 

Clerical 

person hrs 

per year 

(G=Ex0.1)

(H)

Total Cost 

per year ($) b

- Semiannual report d40 2 80 14 1,120 56 112 $124,715.36

- SSM report 8 0 0 0 0 0 0 0

Subtotal Reporting for State/Local/Tribal 

Government 1,288 $124,715.36

5. Recordkeeping requirements

- Read instructions 40 1 40 0 0 0 0 0

- Plan activities 100 1 100 0 0 0 0 0

- Prepare SSM plan 80 1 80 0 0 0 0 0

- Prepare documentation for exempted sources 80 1 80 1.3 104 5.2 10.4 $11,580.71

- In-situ process vents parametric monitoring c0.5 365 182.5 1.3 237.25 11.86 23.73 $26,418.50

- Ex-situ process vents parametric monitoring e0.5 365 182.5 12.7 2,317.75 115.89 231.78 $258,088.42

- Inspect tank covers 2 12 24 12.5 300 15 30 $33,405.90

- Inspect container covers 0.5 12 6 12.7 76.2 3.81 7.62 $8,485.10

- Inspect surface impoundment covers f2 12 24 0.2 4.8 0.24 0.48 $534.49

- Inspect separator covers h2 12 24 0.2 4.8 0.24 0.48 $534.49

- Inspect transfer system covers 0.5 12 6 12.7 76.2 3.81 7.62 $8,485.10

- Leak detection and repair program g100 1 100 0.5 50 2.5 5 $5,567.65

- Develop record system 100 1 100 0 0 0 0 0

- Enter information i2 52 104 14 1,456 72.8 145.6 $162,129.97

- Personnel training 20 0 0 0 0 0 0 0

Subtotal Recordkeeping for State/Local/Tribal 

Government 5,321.1 $515,230.33

Total for the State, Local or Tribal Government 6,609.1 $639,945.69

Federal Government

1. Applications NA
18

Burden Item

(A) 

Person 

hours per 

occurrence

(B) 

Number of 

occurrences 

per year

(C) 

Person hrs 

per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

person

hrs per 

year 

(E=CxD)

(F) 

Management 

person 

hrs per year 

(F=Ex0.05)

(G) 

Clerical 

person hrs 

per year 

(G=Ex0.1)

(H)

Total Cost 

per year ($) b

2. Surveys and Studies NA

3. Parametric 

Monitoring System 40 1 40 0 0 0 0 0

4. Reporting requirements

- Read instructions 16 1 16 0 0 0 0 0

- Conduct performance test 120 1 120 0 0 0 0 0

- Initial notification 0 1 0 0 0 0 0 0

- Performance test notification 0 1 0 0 0 0 0 0

- Initial compliance determination 40 1 40 0 0 0 0 0

- Performance test report 80 1 80 0 0 0 0 0

- Semiannual report d 40 2 80 29 2,320 1,160 232 $385,122.32

- SSM report 8 0 0 0 0 0 0 0

Subtotal Reporting for Federal Government 3,712 $385,122.32

5. Recordkeeping requirements

- Read instructions 40 1 40 0 0 0 0 0

- Plan activities 100 1 100 0 0 0 0 0

- Prepare SSM plan 80 1 80 0 0 0 0 0

- Prepare documentation for exempted sources 80 1 80 2.6 208 104 20.8 $34,528.21

- In-situ process vents parametric monitoring c 0.5 365 182.5 2.6 474.5 237.25 47.45 $78,767.47

- Ex-situ process vents parametric monitoring e 0.5 365 182.5 26.4 4,818 2,409 481.8 $799,792.82

- Inspect tank covers 2 12 24 25.9 621.6 310.8 62.16 $103,186.22

- Inspect container covers 0.5 12 6 26.4 158.4 79.2 15.84 $26,294.56

- Inspect surface impoundment covers f 2 12 24 0.5 12 6 1.2 $1,992.01

- Inspect separator covers h 2 12 24 0.5 12 6 1.2 $1,992.01

- Inspect transfer system covers 0.5 12 6 26.4 158.4 79.2 15.84 $26,294.56

- Leak detection and repair program g 100 1 100 1 100 50 10 $16,600.10

- Develop record system 100 1 100 0 0 0 0 0
19

Burden Item

(A) 

Person 

hours per 

occurrence

(B) 

Number of 

occurrences 

per year

(C) 

Person hrs 

per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

person

hrs per 

year 

(E=CxD)

(F) 

Management 

person 

hrs per year 

(F=Ex0.05)

(G) 

Clerical 

person hrs 

per year 

(G=Ex0.1)

(H)

Total Cost 

per year ($) b

- Enter information i 2 52 104 29 3,016 1,508 301.6 $500,659.02

- Personnel training 20 0 0 0 0 0 0 0

Subtotal Recordkeeping for Federal Government 15,326.2 $1,590,106.98

Total for the Federal Government 19,038.2 $1,975,229.30

Total Labor Burden and Cost (rounded) 140,338 $13,720,488

Assumptions:

a We have assumed that there are approximately 286 respondents, with no additional new sources becoming subject to the rule over the next three years. The breakdown if as 

follows: 243 respondents for from the private sector, 29 from the Federal government, and 14 from state, local or tribal governments. 

 

b

. This ICR uses the following labor rates: $100.23 for technical, $121.44 for managerial, and $50.51 for clerical labor. These rates are from the United States 

 Department of Labor, Bureau of Labor Statistics, March 2012, “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.

 

c

 We have assumed that 26 out of 286 respondents (9 percent) are estimated to use an in-situ treatment process. At each of these sites, it is assumed that a control device is

 required on the process vent.

 

d

 We have assumed that each respondents will take 40 hours twice per year to complete semiannual report.

 

e

 We have assumed that respondents will each take 0.5 hours 365 time per year to monitor ex-situ process vents parametric. It is also assumed that out of 286 respondents, 90

 percent or (260 respondents)will use an on-site ex-situ treatment process.

 

f

 We have assumed that respondents will beach take 2hours once per month to inspect surface impoundment. It is assumed that 5 out of 260 sites use a surface impoundment in

 place of tanks.

 

g We have assumed that 10 facilities will be implementing a LDAR program.

 

h

 We have assumed that each respondent will take 2 hours once per month to inspect separator covers. It is also assumed that five of the sites will use oil-water separators.

 

i

 We have assumed that each respondent will take 2 hours 52 times per year to enter information.
20

Table 2: Average Annual EPA Burden and Cost – NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG) 

(Renewal)

Burden Item

(A) 

Person 

hours per 

occurrence

(B) 

Number of 

occurrences 

per year

(C) 

Person hrs 

per 

respondent 

per year 

(C=AxB)

(D) 

Respondents 

per year a

(E) 

Technical 

person hrs 

per year 

(E=CxD)

(F) 

Management 

person hrs per 

year 

(F=Ex0.05)

(G) 

Clerical 

person hrs 

per year 

(G=Ex0.1)

(H) 

Cost per year 

($)

Report Review

a. Initial notification 4 0 0 0 0 0 0 0

b. Performance test notification 2 0 0 286 0 0 0 0

c. Initial compliance determination 24 0 0 0 0 0 0 0

d. Performance test reports 24 0 0 286 0 0 0 0

e. Semiannual report c 8 2 16 286 4,576 2,288 457.6 $365,375.30

Total Annual Burden and Cost (rounded) 7,322 $365,375

Assumptions:

a We have assumed that there are approximately 286 respondents, with no additional new sources becoming subject to the rule over the next three years. The breakdown if as 

follows: 243 respondents for from the private sector, 29 from the Federal government, and 14 from state, local or tribal governments.

b

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of Personnel Management 

(OPM), 2011 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 We have assumed that it will take eight hours twice per year for each respondent to review semiannual report.