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 1891.06, OMB Control Number 2060-0428

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for PubliclyOwned Treatment Works published at 40 CFR part 63, subpart VVV were proposed on 

December 1, 1998, and promulgated on October 26, 1999. These regulations apply to existing 

and new publicly-owned treatment works (POTWs) located at a major source of hazardous air 

pollutants (HAPs), or industrial POTWs that are either area or major sources. New facilities 

include those that 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 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 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.

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

affected facilities at each plant site and that each plant site has only one respondent (i.e., the 

owner/operator of the plant site).

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

standard, and no additional respondents will become subject to the standard. 

The active (previous) ICR had the following terms of clearance (TOC):

This request is approved for three years. Prior to resubmission of this 

information collection for renewal, the Agency should reassess 
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estimates of the respondent population and burden hours taking 

into account most recent experience with the program.

EPA addressed each item of concern in the TOC. The respondent universe and burden 

hours have been thoroughly checked and all estimates updated; industry consultations and 

updated labor rates were utilized to reassess the burden and cost associated with the ICR.

All the POTW facilities in the United States are owned and operated by state, local, or 

tribal government (the “Affected Public”). The burden to the “Affected Public” is listed below 

in Table 1: Annual Respondent Burden and Cost – NESHAP for Publicly-Owned Treatment 

Works (40 CFR Part 63, Subpart VVV) (Renewal). The burden to the “Federal Government” is 

attributed entirely to work performed by either Federal employees or government contractors. 

The burden to the “Federal Government” is listed below in Table 2: Average Annual EPA 

Burden and Cost – NESHAP for Publicly-Owned Treatment Works (40 CFR Part 63, Subpart 

VVV) (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 POTWs either 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 

VVV.
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2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard 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, and 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.

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

The requested recordkeeping and reporting are required under (40 CFR 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 exists.

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 (76 FR 26900) on May 9, 2011. No comments were received on the 

burden published in the Federal Register.
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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 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. Approximately six respondents 

will be subject to the standard over the three year period covered by this ICR.

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 National Association of Clean Water 

Agencies, at (202) 833-9106; and 2) the Southern California Alliance of Publicly Owned

Treatment Works (SCAP) at (760) 479-4880.

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. 

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 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 the destruction or 

nonexistence of essential records.
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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

The respondents to the recordkeeping and reporting requirements are POTWs. 

The Standard Industrial Classification (SIC) code for the respondents affected by the standards 

is SIC 4952, which corresponds to the North American Industry Classification System (NAICS) 

code 221320 for sewage treatment facilities. 

 

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 reports:

Notifications

Initial notification 63.9(b), 63.1591(b)

Request for extension of compliance 63.09(c)

Notification of special compliance requirements 63.09(d)

Notification of initial performance tests 63.09(e), 63.07(b)

Additional notification requirements for sources with CMS 63.09(g)

Notification of compliance status 63.09(h)

Notification of adjustments to time periods for submitting

required communications 63.09(i)

Notification of changes to information provided 63.09(j)
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Reports

Initial performance test report 63.10(d), 63.1590(f)

Startup, shutdown, malfunction report 63.1590(f)

Inspection and monitoring plan 63.1588(c)

Semiannual report 63.1590(f)

Excess emissions report 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. 

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.
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(ii) Respondent Activities

Respondent Activities

Read instructions.

Write the notifications and reports listed above.

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.

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. 

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, excess emissions reports, 

required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS).
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5(b) Collection Methodology and Management

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

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

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

with the emission standard, and note the operating conditions under which compliance was 

achieved. Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs. The semiannual reports are used for problem 

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

determinations.

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

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

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

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

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

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

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

years.

5(c) Small Entity Flexibility

The 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. Wherever 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 recordkeeping and reporting requirements is estimated to be 14 (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 $121.42 ($57.82+ 110%) 

Technical $99.14 ($47.21 + 110%)

Clerical $49.81 ($23.72 + 110%)

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

September 2011, “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 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 is labor costs. There are no capital/startup or operation and maintenance 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. 
10

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

$622. 

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), 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. Details upon which this estimate is 

based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for PubliclyOwned 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, approximately 6 existing respondents will be subject 

to the standard on average over the next three years, It is estimated that no additional 

respondents will become subject. The overall average number of respondents, as shown in the 

table below, is 6 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 respondent include sources with constructed, reconstructed and modified affected facilities.

.

Column D is subtracted to avoid double-counting respondents. As shown above, the 
11

average Number of Respondents over the three year period of this ICR is 6. 

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 performance test report 0 1 0 0

Startup, shutdown, 

malfunction report 0 1 0 0

Inspection and monitoring 

plan 0 1 0 0

Semiannual report 6 2 0 12

Excess emissions report 0 1 0 0

Initial report on compliance 

approach 0 1 0 0

Total 12

The number of Total Annual Responses is 12.

The total annual labor costs are $1,322. 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 in Tables 1 and 2, respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 14. 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). 

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

information is estimated to average 1 hour per response.

The total annual capital/startup and O&M costs to the regulated entity are zero. 

(ii) The Agency Tally
12

The average annual Agency burden and cost over next three years is estimated to be 14

labor hours at a cost of $622. See below Table 2: Average Annual EPA Burden and Cost –

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

6(f) Reasons for Change in Burden

There is no change in labor hours in this ICR compared to the previous ICR. This is due 

to two considerations. First, the regulations have not changed over the past three years and are 

not anticipated to change over the next three years. Secondly, the growth rate for the industry is 

very low, negative or non-existent, so there is no significant change in the overall burden. 

There is an adjustment increase in costs to both the respondents and the Agency. This is 

not due to any program changes. The increase in cost reflects an adjustment in labor rates; this 

ICR uses updated labor rates to calculate burden costs for all labor categories. 

6(g) Burden Statement

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

is estimated to average 1 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, 

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-2011-0266. 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), 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 
13

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-2011-0266 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)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Total Cost 

Per year b

1. Applications N/A

2, Survey and studies N/A

3. Reporting requirements

 a. Read instructions c4 1 4 0 0 0 0 $0 

 b. Required activities

 Initial notification 2 1 2 0 0 0 0 $0 

 Notification of compliance status 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 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 N/A

 Inspection and monitoring plan N/A

 Startup, shutdown, and malfunction plan N/A

 Semiannual report d1 2 2 6 12 0.6 1.2 $1,322.30 

 Startup, shutdown, malfunction report N/A

 Excess emissions report N/A

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

Subtotal for Reporting Requirements 13.8
15

Burden item

(A)

Person 

hours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Person 

hours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person hours 

per year

(Ex0.05)

(G)

Clerical 

person 

hours 

per year

(Ex0.1)

(H)

Total Cost 

Per year b

4. Recordkeeping requirements

 a. Read instructions See 3E

 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 N/A

 Records of treatment unit, inspections,

 defects detected, defect repair delays,

 control devices

N/A

 Methods and data used to determine HAP

 emissions, compliance with fraction

 emitted standard, and continuous

 compliance

N/A

 f. Time to transmit or disclose information N/A

 g. Time to train personnel

 h. Audits N/A

Subtotal for Recordkeeping Requirements 0

TOTAL LABOR BURDEN AND COST 

(rounded) 14 $1,322

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to this rule will be six. There will be no new sources that will become subject to the rule over 

the three-year period of the ICR. There are no emission limits or control requirements under subpart VVV for existing sources subject to this ICR. Compliance with subpart 

VVV is demonstrated by operating treatment and control devices which meet all requirements specified in the appropriate industrial NESHAP(s). Performance testing, plan 

development, and reporting are only required for new sources subject to subpart VVV. Therefore, these requirements as shown above are not applicable.

b

 This ICR uses the following labor rates: $121.42 per hour for Executive, Administrative, and Managerial labor; $99.14 per hour for Technical labor, and $49.81

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, September, 2011 “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.
16

c

 We have assumed that it will take four hours for each new respondent to read instructions.

d

 We have assumed that it will take each respondent one hour two times per year to write semiannual report.
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Table 2: Average Annual EPA Burden and Cost – NESHAP for Publicly-Owned Treatment Works (40 CFR Part 63, Subpart

 VVV) (Renewal)

Activity

(A)

EPA 

personhours per 

occurrence

(B)

No. of 

occurrences 

per plant 

per year

(C)

EPA 

personhours 

per plant 

per year

(C=AxB)

(D)

Plants 

per 

year 

a

(E)

Technical 

personhours per 

year

(E=CxD)

(F)

Management 

person-hours 

per year

(Ex0.05)

(G)

Clerical 

personhours per 

year

(Ex0.1)

(H)

Cost, $ b

Initial performance tests N/A

Repeat performance test N/A

Report review

 Initial notification 2 1 2 0 0 0 0 $0 

 Notification of compliance status 2 1 2 0 0 0 0 $0 

 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 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 

 for submitting required communications

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 N/A

 Inspection and monitoring plan N/A

 Semiannual report N/A

 Startup, shutdown, malfunction report c1 2 2 6 12 0.6 1.2 $621.89 

 Excess emissions report N/A

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

TOTAL ANNUAL BURDEN AND COST 

(rounded) 14 $622

Assumptions:

a

 We have assumed that the average number of respondents that will be subject to this rule will be six. There will be no new sources that will become subject to the 
18

rule over the three-year period of the ICR. There are no emission limits or control requirements under subpart VVV for existing sources subject to this ICR. 

Compliance with subpart VVV is demonstrated by operating treatment and control devices which meet all requirements specified in the appropriate industrial 

NESHAP(s). Performance testing, plan development, and reporting are only required for new sources subject to subpart VVV. Therefore, these requirements as shown 

above are not applicable.

b

 This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.27 for 

Managerial (GS-13, Step 5, $38.92 x 1.6), $46.21 for Technical (GS-12, Step 1, $28.88 x 1.6), and $25.01 Clerical (GS-6, Step 3, $15.63 x 1.6). These rates are from 

the Office of Personnel Management (OPM) “2011 General Schedule” which excludes locality rates of pay.

c

 We have assumed that it will take each respondent one hour two times per year to complete SSM report.