**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

- O wned Treatment Works (40 CFR Part 63, Subpart VVV) (Renewal), EPA I CR Number 1891.06, OMB Control Number 2060

- 0428 **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Publicly

O wned 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 publicl y - 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 an y startup, shutdown, or malfunction in the operation of an affected facilit y, or an y period during which the monitoring s ys tem is ino perative. 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 mea surements, 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. 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 ye ars, an average of six respondents per ye ar will be subject to the standard , and no additional re spondents will become subject to the standard. The active (previous) IC R had the following terms of clearance (TOC) : This request is approved for three ye ars. Prior to resubmission of this information collection for renewal, the Agency should reassess2 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; i ndustry consultations and updated labor rates were utilized to reassess the burden and cost associated with the I CR. All the POTW facilities in the United States are owned and operated b y state, local, or tribal government (the “Affected Publi c”). The burden to the “Affected Public” is listed below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Publicly

- O wned Treatment Works (40 CFR Part 63, Subpart VVV ) (Renewal). T he burden to the “Federal Government” is attributed entirel y to w ork performed b y either F ederal emplo ye es or government contractor s
. The burden to the “Federal Government” is listed below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Publicly

- O wned 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 source s 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, 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 (i n 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 Admini strator may reasonabl y require. In the Administrator's judgment, HAP emiss ions from POTWs either cause or contribute to air pollution that may

reasonabl y 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 use d 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 ensur e 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 notification s 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 properl y 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 fac ility , 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 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 exists. **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 ( 76 FR 26900 ) on May 9, 2011 . No comments were received on the burden published in the Federal Register

.4

**3(c) Consultations** The Agency

has consulted i ndustry

experts and internal data sources to project the number of affected facilities and industry growth over the next three y ears. 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 Sy stem (OTIS ) , which is operated and maintained b y EPA's Office of Compliance. OTI S 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 ye ar period covered by this I CR.
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 previousl y reviewed to determine the minimum information needed for compliance purposes. In developing this I CR, we contacted : 1) the National Association of Clean Water Agencies , at (202) 833

- 9106 ; and 2) the Southern California Alliance of Publicly O wned Treatme nt 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 f irst Federal Register n otice. **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. I f 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**
T hese 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 y ears. This is consistent with the General Provisions as applied to the standards. EPA believes that the five

- ye ar records retention requirement is consistent the Part 70 permit program and the five

- y ear statute of limitations on which the permit program is based. T he retention of records for five ye ars allow s EPA to establish the compliance history of a source , an y pattern of non - compliance and to determine the appropriate level of enforcement action

. EPA has found that the most flagrant violators have violations extending bey ond five ye ars. In addition, EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records

.5

**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**
T he reporting or recordkeeping requirements in the standard do not include sensitive questio ns. **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 ( SI C ) code for the respondents affected by the standards is SI C 4952 , which corresponds to the North American Industry Classification Sy stem (NAICS ) code 221320 for sewage treatment facilities

. **4(b) Information Requested (i) Data Items** 
In this ICR , al l the data that is recorded or reported is required b y the NESHAP for Publicly

- O wned Treatment Works (40 CFR Part 63, Subpart VVV )

. A source must make the following reports:

**Notification s**  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)6

**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 delay s 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 r espondents 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 c ooperation with the respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting.7 **(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 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, an d utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with an y previously applicable instructions and requirements. Train personnel to be able to respond to a collection of informatio n. 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 s ys tem. Although personnel at the source still need to evaluate the data, this t ype 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, anal yz e, and maintain data in the Online Tracking Information Sy stem ( OTI S )

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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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capab ility to compl y 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.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement 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/operator for five ye ars. **5(c) Small Entity F lexibility**  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 employ ed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requir ements 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

- O wned Treatment Works (40 CFR Part 63, Subpart VVV ) (Renewal)

. **6. Estimating the Burden an d 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 ver appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

.9

The Agency

may not c onduct or sponsor, and a person is not required to respond to, a collection of information unless it display s a currently valid OMB Control Number. **6(a) Estimating Respondent Burden** The average annual burden to industry over the next three y ears from these record

keeping and reporting requirement s is estimated to be 14 ( T otal Labor Hours from Table 1 below ). T hese hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 42 ($5 7

. 82 + 110%) Technical $ 99.14 ($4 7

. 21 + 110%) Clerical $4 9

. 81 ($2 3

. 7 2 + 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 b y 110 percent to account for the benefit packages available to those employ ed 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 b y the sub

ject 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 t ype 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 cos ts associated with anal ys is of the reported information. EPA's overall compliance and enforcement program i ncludes 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 y ears of the ICR is estimated to be $622

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

Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 1 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 employ ees
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost

– NESHAP for Publicly

O wned 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, approximately 6 existing respondents will be subject to the standard on average over the ne xt three y ears, Itis estimated that no additional respondents will become subject. The overall average number of respondent s, as shown in the table below, is 6 per ye ar. The number of respondents is calculated using the following table that addre sses 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 respondent include sources with constructed, reconstructed and modified affected facilities.

. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the11

average Number of Respondents over the three ye ar period of this ICR is 6

. 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 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

- O wned 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, respectivel y, 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

- O wned 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 y ears 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

- O wned 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 I CR compared to the previous I CR. This is due to two considerations. First, the regulations have not changed over the past three ye ars and are not anticipated to change over the next three ye ars. 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 cost s 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 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, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, proce ssing 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 display s a valid OMB Co ntrol 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 re spondent 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

- 2011

- 0266 . An electronic version of the public docket is available at http://www.regulations.gov/ wh ich 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 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), EPA West, Roo m 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 legal13

holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telep hone 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

- 20 11

- 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.14

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

**– NESHAP**  **for Publicly** 
**- O**  **wned 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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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 c 4 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 R equirements 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 P rovided 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 d 1 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 13.815

**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 person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **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

**Assu mpti**  **ons:** 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 s ources 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 indus trial NESHAP(s). Performance te sting, 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, Septem ber , 20 11 “T able 2. Civilian Workers, by Occupational and Indu stry 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 ne w respondent to read instructions. d We have assumed that it will take each respondent one hour tw o times per year to write semiannual report.17

**Table 2: Average Annual EPA Burden and Cost** 

**– NESHAP for**  **Publicly**
**- O**  **wned Treatment Works**  **(40 CFR Part 63**  **, Subpart VVV** **) (Renewal)**

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**  **** **hours per plant**  **per year (C=AxB)**  **(D)**

**Plants per**  **year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per**  **year (Ex0.05)**  **(G)**

**Clerical person**  **** **hours 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 R equirements 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 s ources 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 P rovided 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 c 1 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

**Assu mptions:**  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 s ources that will become subject to the18

rule over the three

- year period of the ICR. There are no emission limits or control requi rements under subpart VVV for existing sources subject to this ICR. Com pliance 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 s hown above are not applicable. b This cost is based on the following labor rates w hich 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 Ma nagement (OPM) “2011 General Schedule” which excludes locality rates of pay. c We have assumed that it will take each respondent one hour tw o times per year to complete SSM report.