STATEMENT
SUPPORTING
THE
RENEWAL
OF
THE
INFORMATION
COLLECTION
REQUIREMENTS
FOR
RISK
MANAGEMENT
PROGRAM
REQUIREMENTS
and
PETITIONS
TO
MODIFY
THE
LIST
OF
REGULATED
SUBSTANCES
UNDER
SECTION
112(
r)
OF
THE
CLEAN
AIR
ACT
EPA
#
1656.12
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
Request
Risk
Management
Program
Requirements
and
Petitions
to
Modify
the
List
of
Regulated
Substances
under
section
112(
r)
of
the
Clean
Air
Act.

1(
b)
Short
Characterization
This
information
collection
request
(
ICR)
renews
a
previously
approved
ICR
(
1656.11),
OMB
No.
2050­
0144,
expiring
October
31,
2005,
for
130,803
annual
burden
hours.

This
information
collection
request
(
ICR)
addresses
the
following
information
requirements:

(
1)
Documenting
sources'
risk
management
programs
and
submitting
a
source
risk
management
plan
(
RMP)
under
CAA
Section
112(
r)(
7)

The
regulations
include
requirements
for
covered
sources
to
implement
and
maintain
documentation
for
a
risk
management
program
and
submit
a
RMP
(
including
information
on
a
source's
hazard
assessment,
prevention
program,
and
emergency
response
program)
to
EPA.
EPA
has
assumed
responsibility
for
maintaining
a
database
of
submitted
RMPs,
which
will
be
made
available
electronically
to
the
implementing
agency,
states,
local
governments,
and
(
except
for
the
Offsite
Consequence
Analysis
data)
to
the
public.
EPA
has
developed
an
electronic
submission
system
(
RMP*
Submit
 
)
that
is
available
to
sources
on
diskette
and
is
also
available
on
EPA's
internet.

(
2)
Collecting
and
submitting
information
to
support
petitions
to
modify
the
list
of
regulated
substances
under
CAA
Section
112(
r)(
3)

The
regulations
include
requirements
for
a
petitioner
to
submit
sufficient
information
in
support
of
a
petition
to
scientifically
support
the
request
to
add
or
delete
a
chemical
from
the
list
of
regulated
substances.
The
Agency
will
use
this
information
in
making
the
decision
to
grant
or
deny
a
petition.
All
the
information
collected
requesting
modification
of
the
chemical
listings
is
stored
in
a
docket
created
for
that
purpose.

CAA
section
112(
r)(
7)
required
EPA
to
promulgate
reasonable
regulations
and
appropriate
guidance
to
provide
for
the
prevention
and
detection
of
accidental
releases
and
for
responses
to
such
releases.
EPA
issued
the
final
rule
on
June
20,
1996
(
61
FR
31668).
The
regulations
include
requirements
for
submittal
of
an
RMP,
including
source
registration,
to
EPA.
The
RMP
includes
information
on
a
source's
hazard
assessment,
prevention
program,
and
emergency
response
program.
The
RMP
requirements
have
been
amended
few
times
since
the
1996
final
rule.
The
regulations
are
codified
in
40
2
CFR
part
68.
The
rule
requires
sources
to
submit
their
RMPs
every
five
years
beginning
June
21,
1999.
The
first
submissions
of
RMP
were
received
in
June
1999.
Sources
submitted
their
second
submissions
on
June
21,2004.

The
final
rule
establishing
the
list
of
regulated
substances
and
threshold
quantities
under
CAA
section
112r
was
published
on
January
31,
1994
(
59
FR
4478),
which
also
includes
provisions
and
procedures
for
submitting
a
petition
to
add
or
delete
a
substance.

Part
68
provides
for
tiering
of
the
regulatory
requirements
to
take
into
consideration
differences
between
various
types
and
classes
of
sources,
as
well
as
the
risk
posed
by
the
different
sources.
The
regulatory
program
consists
of
three
tiers
of
risk
management
programs.
Sources
are
classified
into
program
tiers
based
on
the
degree
of
risk
posed
by
potential
releases
and
coverage
by
OSHA=
s
Process
Safety
Management
(
PSM)
standard.
Sources
with
processes
classified
as
Program
1
pose
little
risk
and
face
minimal
compliance
requirements.
Sources
with
processes
classified
as
Program
2
must
implement
a
streamlined
list
of
prevention
program
requirements.
Sources
with
processes
classified
in
Program
3
must
complete
a
prevention
program
identical
to
that
required
by
the
OSHA
PSM
Standard
(
29
CFR
1910.119).

The
compliance
schedule
for
the
Part
68
requirements,
established
by
rule
on
June
20,
1996,
requires
the
implementation
of
the
source
risk
management
programs
and
the
submission
of
initial
RMPs
by
June
21,
1999,
and
every
five
years
after
the
initial
submission.
After
the
initial
submission,
few
sources
re­
submitted
their
RMPs
because
they
had
some
changes
to
their
processes
or
changes
in
the
thresholds.
These
sources
were
then
assigned
a
five­
year
compliance
deadline
based
on
the
date
of
their
revised
plan
submission.
EPA
received
the
second
submissions
on
June
21,
2004.
EPA
expects
that
some
sources
may
submit
their
revised
RMP
before
the
next
compliance
deadline,
June
21,
2009.
This
may
result
a
new
compliance
deadline
for
these
sources
based
on
each
source's
submission
date.
This
ICR
covers
from
November
1,
2005
to
October
31,
2008.
Since
the
next
submission
is
only
due
June
21,
2009,
this
ICR
only
accounts
for
on­
going
program
implementation
costs
and
compliance
costs
for
new
sources
that
may
become
subject
to
the
regulations.
Specifically,
the
costs
to
sources
in
this
ICR
include
the
following:

°
Compliance
costs
for
new
sources;
°
Submissions
of
revised
RMPs
for
those
sources
required
to
update
their
RMPs;
°
Documentation
of
on­
going
program
implementation
activities;
and
°
Petitions.

Because
of
the
schedule
for
certain
activities
established
in
Part
68,
some
costs
do
not
occur
in
the
three­
year
time
period
covered
by
this
ICR.
For
example,
most
sources
will
not
have
to
revise
their
RMPs
or
update
their
process
hazard
analyses,
hazard
reviews,
and
offsite
consequence
analyses
until
June
2009,
the
next
five­
year
submission
deadline.
Consequently,
the
record
keeping
and
reporting
costs
for
Part
68
will
fluctuate
considerably
from
ICR
to
ICR.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
3
Risk
Management
Plans
Information
collection
for
on­
site
documentation
is
authorized
by
CAA
sections
112(
r)(
7)(
B)(
i)
and
(
ii),
which
state
that
"
The
Administrator
shall
promulgate
reasonable
regulations
and
appropriate
guidance
to
provide
...
for
the
prevention
and
detection
of
accidental
releases
of
regulated
substances....@
and
AThe
regulations
...
shall
require
the
owner
or
operator
...
to
prepare
and
implement
a
risk
management
plan
to
detect
and
prevent
or
minimize
accidental
releases...@
Information
collection
for
submitting
an
RMP
is
authorized
under
CAA
section
112(
r)(
7)(
B)(
iii),
which
states
in
relevant
part
that
AThe
owner
or
operator
of
each
stationary
source...
shall
register
a
risk
management
plan...
with
the
Administrator
before
the
effective
date
of
the
regulations...
in
such
form
and
manner
as
the
Administrator
shall,
by
rule,
require...
and
shall
be
available
to
the
public
under
section
114(
c)."
Information
collection
for
on­
site
documentation
and
submittal
of
RMPs
is
also
authorized
by
CAA
114(
a)(
1).
The
list
and
thresholds
promulgated
under
CAA
section
112(
r)(
3)
determine
which
sources
must
comply
with
the
accident
prevention
regulations;
a
source
must
comply
with
the
CAA
section
112(
r)(
7)
regulations
if
it
holds
more
than
a
threshold
quantity
of
a
listed
substance
in
a
process.
State
and
local
authorities
will
use
the
information
in
RMPs
to
modify
and
enhance
their
community
response
plans.
The
agencies
implementing
RMP
rule
will
use
RMPs
to
evaluate
compliance
with
part
68
and
identify
sources
for
inspection
because
they
may
pose
significant
risks
to
the
community.
Citizens
may
use
RMPs
to
assess
and
address
chemical
hazards
in
their
communities.

Petitions
This
information
collection
is
authorized
under
CAA
section
112(
r)(
3),
which
states
in
relevant
part
that
"
The
Administrator
shall
establish
procedures
for
the
addition
and
deletion
of
substances
from
the
list
established
under
this
paragraph
consistent
with
those
applicable
to
the
list
in
subsection
(
b).@
The
information
collected
during
the
petition
process
will
provide
the
primary
basis
for
EPA
to
determine
if
it
is
appropriate
to
add
or
delete
a
chemical.
To
be
consistent
with
the
petition
process
under
CAA
section
112(
b),
EPA
is
required
to
consider
and
respond
to
petitions
to
modify
the
list
of
regulated
substances
within
18
months
of
submission
of
the
petition;
complete
data
supporting
the
petition
are
necessary
to
allow
EPA
to
finish
its
review
within
that
time
period.

2(
b)
Use/
Users
of
the
Data
Risk
Management
Plans.
The
information
collected
in
the
RMP
is
critical
for
assisting
government
agencies
in
assessing
the
quality
and
thoroughness
of
a
source's
hazard
assessment,
prevention
program,
and
emergency
response
program.
The
information
also
would
be
used
by
state
and
local
emergency
planners
to
prepare
or
modify
community
response
plans
and
to
identify
hazards
to
the
community
and
provide
a
basis
for
working
with
sources
to
prevent
accidents.

Risk
Management
Programs.
Documentation
of
the
implementation
of
risk
management
programs
is
necessary
to
assist
government
agencies
in
determining
whether
a
source
has
complied
with
the
regulations.
In
some
cases
(
e.
g.,
safety
information
and
operating
procedures),
the
documentation
is
a
critical
requirement
of
the
rule,
providing
the
basis
for
other
rule
elements.

Petitions.
The
information
collected
in
support
of
a
petition
to
modify
the
list
of
regulated
substances
is
to
be
used
by
EPA
to
determine
whether
to
grant
or
deny
a
petition
to
add
or
delete
a
4
chemical
from
the
list.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
Risk
Management
Plans.
Some
sources
may
have
submitted
information
to
EPA
Headquarters
or
Regions
under
other
regulations
(
i.
e.,
Form
R
or
RCRA
Biennial
Reports)
that
is
similar
to
the
information
requested
in
the
registration
form
under
these
regulations.
(
EPCRA
Section
312
Tier
II
forms,
which
include
similar
information,
are
submitted
only
to
states
and
local
planning
authorities,
not
EPA.)
The
information
available
through
Form
R
and
RCRA
Biennial
Reports
is
scattered,
unorganized,
and
incomplete
for
the
requirements
of
the
Act.
In
addition,
most
sources
covered
by
this
rule
are
neither
manufacturers
(
Form
R)
nor
are
permitted
under
RCRA
(
Biennial
Report),
and
thus
have
not
previously
submitted
this
information.
For
EPA
to
best
comply
with
the
Act,
it
is
most
beneficial
if
the
information
requested
for
registration
is
submitted
in
a
concise
and
organized
format,
using
the
RMP
form.

Confidential
Business
Information.
Some
sources
may
have
submitted
substantiation
of
CBI
claims
for
chemical
identity
or
other
information
to
EPA
Headquarters
or
Regions
under
other
regulations
that
is
similar
to
the
information
requested
under
these
regulations.
For
EPA
to
best
comply
with
the
Act
and
most
effectively
evaluate
such
claims,
it
is
most
beneficial
if
the
CBI
substantiation
accompanies
the
submission
of
the
RMP.

3(
b)
Consultations
Prior
to
developing
this
ICR,
the
Agency
contacted
a
few
sources
to
develop
estimates
on
burden
hours
and
costs
associated
with
this
ICR.
Some
of
the
sources
contacted
have
resubmitted
the
RMP
between
the
two
reporting
periods
(
June
21,
1999
and
2004)
for
changes
in
their
processes
or
changes
in
their
worst­
case
scenario
or
alternative
scenario.
Others
had
resubmitted
only
minor
changes
to
their
previous
RMP.
Since
the
sources
that
were
contacted
vary
in
sizes
and
the
processes,
the
Agency
developed
the
estimates
using
a
weighted
average.
The
following
sources
were
contacted.

Chris
Harden
Morgan
Walker
Anheuser­
Busch,
Inc.
(
FTE
=
1000)
Bayway
Refinery
(
FTE
=
850)
15800
Roscoe
Rd
1400
Park
Avenue
Van
Nuys
CA
91406
Linden,
NJ
07036
(
818)
908­
5593
(
908)
523­
6288
Kevin
Halligan
Harold
Demmer
Borden
&
Remington
(
FTE
=
40)
Formosa
Plastics
(
FTE
=
383)
106
Ferry
Street
End
of
GSU
Rd.
Falls
River,
MA
02722
Baton
Rouge,
LA
70821
(
508)
675­
0096
(
225)
356­
3341
5
Jocelyn
Manship
John
Cote
Elan
Inc.
(
FTE
=
80)
Chem
Design
Corp.
(
FTE
=
86)
268
Doremus
Avenue
99
Development
Road
Newark,
NJ
07105
Fitchburg,
MA
01420
(
973)
344­
8014
(
978)
345­
9999
Ralph
Werling
Guy
Miller
Daikin
America
Inc.
(
FTE
=
250)
Heico
Chemicals
Inc.
(
FTE
=
45)
State
Docks
Road
Rt.
611
Adjacent
DW
Fire
Co.
Decatur,
AL
35601
Delaware
Water
Gap,
PA
18327
(
256)
306­
5000
(
570)
420­
3900
Stephen
Adams
City
of
Loveland
WTP
(
FTE
=
11)
920
South
Boise
Avenue
Loveland,
CO
80537
(
970)
962­
3559
3(
c)
Public
Notice
In
compliance
with
the
Paperwork
Reduction
Act
(
44
U.
S.
C.
3501
et
seq.),
the
Agency
notified
the
public
through
the
Federal
Register
notice
on
the
renewal
of
this
ICR
on
XXXX
XX
XXXX
(
XX
FR
XXXXX).

3
(
d)
Effects
of
Less
Frequent
Collection
Sources
are
required
to
register
and
submit
an
RMP
only
once
every
five
years,
unless
there
are
significant
changes
in
the
information
provided.
There
is
a
statutory
requirement
for
sources
to
register,
submit,
and
update
an
RMP.

3(
e)
General
Guidelines
CAA
section
112(
r)(
7)(
B)(
iii)
requires
that
sources
update
their
RMPs
periodically.
To
maintain
consistency
with
OSHA
PSM
requirements,
EPA=
s
implementing
rule
requires
sources
to
update
PHAs
and
hazard
assessments
every
five
years.
Thus,
sources
are
required
to
maintain
such
documentation
for
five
years,
which
is
greater
than
the
three
years
specified
in
OMB's
general
guidelines.

3(
f)
Confidentiality
and
Sensitive
Questions
(
i)
Confidentiality
Some
of
the
elements
mandated
in
the
regulation
for
the
risk
management
plan
may
require
the
6
submittal
of
data
viewed
as
proprietary,
trade
secret,
or
confidential.
As
described
above,
EPA
has
adopted
procedures
for
sources
to
claim
certain
information
as
confidential
business
information.

(
ii)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
included
in
any
of
the
information
collection
requirements.
The
information
submitted
in
an
RMP
includes
information
on
a
source's
hazard
assessment,
prevention
program,
and
emergency
response
program,
and
the
information
submitted
in
support
of
a
petition
to
modify
the
list
of
regulated
substances
includes
toxicity
data
and
accident
history
data.
This
information
is
not
private.
The
information
collection
requested
under
the
EPA
rulemaking
is
in
compliance
with
the
Privacy
Act
of
1974
and
OMB
Circular
A­
108.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
Risk
Management
Programs
and
Plans
The
accidental
release
prevention
program
under
the
CAA
was
developed
for
sources
that
manufacture,
react,
mix,
store,
or
use
regulated
substances
in
processes
that
require
equipment
designed,
constructed,
installed,
operated,
or
maintained
in
specific
ways
to
prevent
accidental
releases
and
ensure
safe
operations.
The
CAA
requires
sources
to
comply
with
the
regulations
if
they
have
more
than
a
threshold
quantity
of
a
listed
regulated
substance.
Based
on
submissions
of
RMPs,
the
rule
applies
to
manufacturers
(
i.
e.,
sources
categorized
in
North
American
Industry
Classification
System
(
NAICS)
codes
31­
33),
as
well
as
some
non­
manufacturers,
including
federal
sources,
utilities
(
NAICS
code
221:
electric
utilities,
drinking
water
systems,
wastewater
treatment
works),
warehouses,
large
ammonia
refrigeration
systems
(
e.
g.
food
processors
and
distributors),
wholesalers,
ammonia
retailers,
and
gas
processors.

Based
on
the
submissions
of
RMPs
in
1999
and
2004,
there
are
approximately
15,305
sources
subject
to
the
RMP
rule.

Petitions
Any
person
may
petition
EPA
to
modify,
by
addition
or
deletion,
the
list
of
regulated
substances.
Potential
petitioners
are
likely
to
include
environmental
groups,
industry,
and
state
and
local
agencies.
Due
to
the
nature
of
their
activities,
the
chemical
manufacturing
sector
is
likely
to
be
the
primary
industry
producing,
using,
or
storing
listed
regulated
substances
affected
by
the
petition
process.
Since
the
list
rule
was
promulgated
in
January
1994,
however,
only
one
petition
has
been
submitted
to
EPA;
this
petition
was
withdrawn.
Based
on
this
record,
EPA
assumes
that
no
additional
petitions
will
be
submitted
in
the
period
covered
by
this
ICR.

4(
b)
Information
Requested
Data
requirements
and
respondent
activities
vary
by
program
level.
Program
1
requires
the
least
amount
of
data
and
time
from
respondents,
while
Program
3
requires
the
most.
All
sources
are
required
to
update
and
submit
every
five
years
an
RMP
that
includes
basic
facility
data,
an
executive
summary,
five­
7
year
accident
history,
data
on
the
worst­
case
release
scenarios
(
at
least
one
for
toxics
and
one
for
flammables),
and
data
on
emergency
response
regardless
of
their
program
classification.
In
addition,
Program
2
and
3
sources
must
also
submit
data
on
alternative
release
scenarios
(
one
for
each
toxic
and
one
for
flammables)
and
their
prevention
programs
(
by
process).
If
a
change
at
the
source
(
e.
g.,
a
substantial
change
in
the
quantity
held,
a
major
modification
of
a
source)
leads
to
a
change
in
certain
data
submitted
in
the
previous
RMP
or
requires
an
update
to
add
a
new
process,
the
RMP
must
be
revised
and
resubmitted.
Depending
on
the
event
that
triggers
the
need
for
an
update,
the
source
must
resubmit
the
revised
RMP
either
before
the
change
is
implemented
(
e.
g.,
the
addition
of
a
new
regulated
substance)
or
within
six
months
of
the
change
(
e.
g.,
a
major
process
modification).

(
i)
Data
Items
Risk
Management
Plans
Registration.
Sources
must
submit
the
following
information
to
EPA
in
the
registration
section
of
the
RMP:

°
Name
and
location
of
the
stationary
source,
and
latitude
and
longitude,
as
well
as
the
method
used
to
determine
the
latitude
and
longitude
and
an
indication
of
the
specific
location
at
the
source
that
it
represents;

°
The
name,
telephone
number,
and
mailing
address
of
the
owner/
operator
of
the
source;

°
Name
and
title
or
position
of
the
person
responsible
for
RMP
implementation
at
the
source;

°
Name,
title,
phone
number,
24­
hour
telephone
number
and
the
email
address
of
the
emergency
contact
at
the
source;
°
°
Name,
the
mailing
address,
and
the
telephone
number
of
the
contractor
who
prepared
the
RMP
(
if
any);

°
The
source's
(
and
parent
company=
s,
if
applicable)
Dun
and
Bradstreet
number,
which
is
a
common
identifier
for
sources
and
would
allow
EPA
to
cross­
reference
the
data
with
other
EPA
databases;

°
For
each
covered
process,
the
names,
CAS
numbers,
and
quantities
(
to
two
significant
digits)
of
all
regulated
substances
and
the
applicable
NAICS
code(
s);

°
Number
of
full­
time
employees
at
the
source;

°
Whether
the
source
is
covered
under
the
OSHA
PSM
program
and
EPCRA
302;

°
The
sources
CAA
Title
V
permit
number
(
if
applicable);
and
°
The
type
of
and
reason
for
any
changes
being
made
to
a
previously
submitted
RMP;
8
Voluntary
data
elements
that
may
be
provided
as
part
of
the
registration
include
the
LEPC
for
the
planning
district
in
which
the
source
is
located
and,
to
support
communication
with
the
public,
a
public
contact
phone
number
for
the
source,
the
WWW
homepage
address
of
the
source
or
its
parent
company,
and
the
e­
mail
address
of
the
source.

Program
1.
Sources
with
Program
1
processes
are
required
to
prepare
an
executive
summary
and
include
a
five­
year
accident
history
and
emergency
response
data
in
their
RMP.
In
addition,
for
Program
1
processes,
owners/
operators
are
required
to
document
the
worst­
case
release
in
the
RMP
and
certify
that:

(
1)
Their
worst­
case
release
would
not
reach
any
public
receptors;

(
2)
The
process
has
had
no
accidents
in
the
previous
five
years
that
resulted
in
certain
impacts
offsite;
and
(
3)
Public
emergency
responders
will
not
enter
within
certain
distances
except
as
previously
arranged.

Programs
2
and
3.
Sources
with
Program
2
and
Program
3
processes
are
required
to
submit
an
RMP
that
includes
the
following
information:
°
An
executive
summary;

°
A
five­
year
accident
history
for
each
incident
that
caused
specific
on­
site
or
offsite
impacts
from
a
release
of
a
regulated
substance
held
above
its
threshold
in
a
covered
process;

°
The
results
of
the
offsite
consequence
analysis
(
OCA)
(
worst­
case
and
alternative
release
scenarios);

°
Information
concerning
the
prevention
program
and
process
hazards,
controls,
mitigation
systems,
and
detection
systems
identified
during
the
PHA
or
hazard
review
for
each
covered
process;

°
Information
concerning
emergency
response
steps
and
coordination
with
the
LEPC
plan;
and
°
Certification
of
the
accuracy
of
the
information
submitted.

The
requested
information
in
the
RMP
is
critical
in
assisting
government
agencies
in
assessing
the
quality
and
thoroughness
of
a
source's
prevention,
detection,
and
response
program.
The
information
will
assist
agencies
in
identifying
sources
that
should
be
visited
to
ensure
safe
source
operations.

Deregistration.
Sources
that
are
no
longer
subject
to
Part
68
are
required
to
notify
EPA
in
writing
within
six
months
of
the
date
on
which
they
are
no
longer
covered.

Risk
Management
Programs
9
Prevention
Program
Documentation
All
previously
covered
sources
with
Program
2
or
3
processes
will
need
to
conduct
a
compliance
audit
within
the
three­
year
period
of
this
ICR.
All
previously
covered
sources
are
assumed
to
incur
costs
for
accident
investigation.
Other
on­
going
costs
for
documentation
for
Program
2
processes
are
for
keeping
the
safety
information
and
operating
procedures
up­
to­
date.
For
Program
3
processes,
the
on­
going
costs
include
keeping
Process
Safety
Information
(
PSI)
and
Standard
Operating
Procedures
(
SOPs)
up­
to
date,
documenting
refresher
training,
training
of
new
employees,
maintenance,
and
management
of
change.
Any
source
that
has
an
emergency
response
plan
is
subject
to
OSHA
HAZWOPER;
all
costs
for
updating
the
plan
accrue
to
the
OSHA
rule.
Only
chemical
wholesalers
are
expected
to
change
their
OCAs
over
the
three­
year
period.
The
documentation
for
those
costs
is
considered
in
the
RMP
costs.

Program
1.
New
Program
1
sources
will
need
to
maintain
only
on­
site
records
of
their
worst­
case
release
analysis,
and
their
simplified
RMP.
Maintaining
copies
of
these
submissions
is
expected
to
require
no
additional
effort
by
these
sources.

Program
2.
New
Program
2
sources
will
need
to
maintain
on­
site
records
supporting
the
contents
of
their
RMP
and
compliance
with
other
rule
requirements.
These
sources
must
also
maintain
records
of
any
compliance
audits
performed
and
any
accident
investigation
reports.

The
on­
site
documentation
associated
with
the
risk
management
program
for
Program
2
sources
consists
of
information
that
will
be
generated
automatically
during
the
development
of
the
hazard
assessment,
the
SOPs,
compliance
audits,
and
safety
information.
Each
required
data
item
is
an
integral
element
of
a
good
program;
maintenance
of
these
data
on
site
will
allow
EPA
or
state
or
local
authorities
to
conduct
effective
source
audits
without
requiring
submittal
of
sensitive
business
information.
Under
the
requirements,
Program
2
sources
must
maintain
the
following
specific
on­
site
documentation:

 
Records
of
the
hazard
assessment,
including
data
and
assumptions
used,
and
descriptions
of
alternative
and
worst­
case
release
scenarios
(
updated
once
every
five
years);

 
Applicable
parameters
and
other
documentation
associated
with
the
safety
information
requirements;

 
Written
operating
procedures
for
each
Program
2
process;

 
Hazard
review
report
using
models,
checklists,
or
What
Ifs
(
updated
once
every
five
years);

 
Compliance
audit
reports;

 
The
emergency
response
plan,
including
procedures
for
warning
employees
and
the
public,
a
list
of
response
personnel
and
equipment,
and
response
action
procedures.
10
Program
3.
EPA's
risk
management
program
identifies
specific
information
that
Program
3
sources
are
required
to
maintain
on
site,
as
well
as
specific
information
to
be
included
in
the
RMP.
Most
Program
3
processes
are
covered
by
OSHA's
PSM
program.
Therefore,
these
sources
are
expected
to
incur
the
costs
of
maintaining
on­
site
documentation
for
only
those
activities
performed
for
processes
and
substances
not
already
covered
under
OSHA's
PSM
program.

The
on­
site
documentation
consists
of
information
that
will
be
generated
automatically
during
the
development
and
performance
of
the
hazard
assessment,
the
PHA,
safety
information,
the
SOPs,
the
maintenance
and
training
programs,
compliance
audits,
management
of
change,
accident
investigations,
and
emergency
response.
On­
site
documentation
for
Program
3
sources
will
include
the
following:

 
Records
of
the
hazard
assessment,
including
data
and
assumptions
used,
and
descriptions
of
alternative
and
worst­
case
release
scenarios
(
updated
once
every
five
years);

 
Chemical
and
process
information,
including
equipment
specifications,
and
diagrams
of
equipment,
piping,
pumps,
valves,
controls,
and
instrumentation
(
P&
IDs)
for
each
Program
3
process;

 
The
process
hazard
analysis
report
and
management
steps
to
address
identified
hazards
(
updated
once
every
five
years);

 
Written
operating
procedures
for
each
Program
3
process;

 
Records
of
all
training
programs;

 
Records
of
the
maintenance
program,
including
inspection
and
testing
schedules;

 
Procedures
for
conducting
pre­
startup
reviews;

 
Procedures
used
for
managing
changes
in
processes,
operations,
and
procedures;

 
Compliance
audit
reports;

 
Accident
investigation
procedures;
and
 
The
emergency
response
plan,
including
procedures
for
warning
employees
and
the
public,
a
list
of
response
personnel
and
equipment,
and
response
action
procedures.

All
information
cited
above
is
integral
to
an
efficient
and
effective
risk
management
program.
Sources
and
processes
covered
by
OSHA's
rule
are
already
required
to
maintain
all
of
this
information
11
(
except
the
hazard
assessment)
on
site
and
are
assumed
to
incur
only
the
additional
costs
to
maintain
onsite
records
of
the
hazard
assessment.
For
example,
there
are
assumed
to
be
no
additional
costs
associated
with
developing
pre­
startup
review
and
management
of
change
procedures
because
all
Program
3
sources
are
already
required
to
have
such
procedures
in
place
under
the
OSHA
PSM
program.

Confidential
Business
Information
Section
68.210
provides
that
information
will
be
available
to
the
public
under
CAA
section
114(
c),
which
provides
for
protection
of
trade
secrets.
To
clarify
procedures
for
submitting
RMPs
that
contain
confidential
business
information
(
CBI),
EPA
added
two
sections
to
the
rule.
In
general,
however,
the
rules
governing
CBI
that
already
exist
in
40
CFR
part
2
will
also
apply
and
provide
procedures
for
determining
the
appropriateness
of
CBI
claims
as
well
as
the
substantive
criteria
that
must
be
met
to
assert
such
claims.
About
35
CBI
claims
were
submitted
for
reporting
year
2004.

To
qualify
for
CBI
protection,
the
substantive
criteria
set
forth
at
40
CFR
2.301
must
be
met.
These
criteria
generally
require
that
the
data
not
be
available
to
the
public
through
other
means,
that
the
source
take
appropriate
steps
to
prevent
disclosure,
and
that
disclosure
of
the
data
would
be
likely
to
cause
substantial
harm
to
the
source's
competitive
position.

To
assert
a
CBI
claim,
a
source
is
required
to
submit
a
sanitized
version
of
its
RMP,
which
would
then
become
part
of
the
RMP
database.
The
sanitized
version
will
identify
each
data
element,
except
chemical
identity,
claimed
as
CBI
by
the
notation
"
CBI"
in
the
data
field.
For
chemical
identity,
the
source
is
required
to
provide
a
generic
chemical
category
or
class
name
in
lieu
of
the
actual
chemical
name.
At
the
same
time,
the
source
is
also
required
to
submit
to
EPA
the
data
claimed
as
confidential
on
a
separate,
paper
form.
The
source
must
also
substantiate
why
each
item
claimed
as
CBI
meets
CBI
criteria.
Substantiation
information
may
be
claimed
as
CBI;
if
all
or
part
of
the
substantiation
is
claimed
as
CBI,
a
sanitized
version
of
substantiation
must
also
be
filed
with
EPA.
Review
of
the
CBI
claims
will
be
handled
as
provided
for
in
40
CFR
part
2.

Claiming
data
as
CBI
must
be
done
at
the
time
of
submittal.
The
source's
owner,
operator,
or
senior
official
is
required
to
certify
the
accuracy
of
the
CBI
substantiation
claims.

Petitions
Any
person
may
petition
the
Administrator
to
modify,
by
addition
or
deletion,
the
list
of
regulated
substances
in
40
CFR
68.130.
Based
on
the
information
presented
by
the
petitioner,
EPA
may
grant
or
deny
a
petition.
Under
§
68.120(
g),
all
petitions
must
contain
the
following
information:

 
Name
and
address
of
the
petitioner
and
a
brief
description
of
the
organization(
s)
that
the
petitioner
represents,
if
applicable;

 
Name,
address,
and
telephone
number
of
a
contact
person
for
the
petition;

 
Common
chemical
name(
s),
common
synonym(
s),
Chemical
Abstract
Service
(
CAS)
number(
s),
and
chemical
formula
and
structure;
12
 
Action
requested
(
addition
or
deletion
of
a
substance);

 
Rationale
supporting
the
petitioner's
position
C
how
the
substance
meets
the
criteria
for
addition
or
deletion.
A
short
summary
of
the
rationale
must
be
submitted
along
with
a
more
detailed
narrative;
and
 
Supporting
data
C
the
petition
must
include
sufficient
information
to
scientifically
support
the
request
to
modify
the
list.
EPA
believes
that
the
information
required
to
be
submitted
in
support
of
a
petition
is
the
minimum
information
that
would
enable
the
Agency
to
determine
whether
to
grant
or
deny
a
petition
within
the
18­
month
time
frame.
The
information
must
include:

­­
A
list
of
all
supporting
documents;

­­
Documentation
of
literature
searches
conducted,
including,
but
not
limited
to,
identification
of
the
database(
s)
searched,
the
search
strategy,
dates
covered,
and
printed
results;

­­
Effects
data
(
animal,
human,
and
environmental
test
data)
indicating
the
potential
for
death,
injury,
or
serious
adverse
human
and
environmental
impacts
from
acute
exposure
following
an
accidental
release.
Printed
copies
of
the
data
sources,
in
English,
should
be
provided;
and
­­
Exposure
data
or
previous
release
accident
history
data
indicating
the
potential
for
serious
adverse
human
health
or
environmental
effects
from
accidental
releases.
These
data
might
include,
but
are
not
limited
to,
physical
and
chemical
properties
of
the
substance
(
such
as
vapor
pressure);
modeling
results
(
including
data
and
assumptions
used
and
model
documentation);
and
historical
accident
data,
citing
data
sources.

(
ii)
Respondent
Activities
Rule
Familiarization
All
newly
affected
sources
are
expected
to
spend
time
to
read
and
understand
the
requirements
when
they
first
become
subject
to
part
68.
This
ICR
covers
from
November
1,
2005
to
October
31,
2008.
Burden
for
currently
covered
sources
for
rule
familiarization
was
included
in
previous
ICRs.

Risk
Management
Programs
and
Plans
Deregistration.
Any
source
that
is
no
longer
subject
to
Part
68
is
required
to
notify
EPA
in
writing
within
six
months
of
the
date
on
which
they
are
no
longer
covered.

Program
1.
Burden
for
new
sources
to
prepare
and
submit
a
RMP
is
in
this
ICR.
Burden
for
existing
program
1
sources
that
may
revise
their
RMP
is
included
in
this
ICR.
Existing
sources
with
Program
1
processes
are
not
expected
to
incur
any
recordkeeping
burden
during
the
period
covered
by
this
13
ICR.

Program
2.
Program
2
sources
incur
the
burden
of
preparing
or
revising
an
RMP
and
maintaining
specific
on­
site
documentation
of
the
items
listed
in
the
previous
section.
The
burden
estimates
for
preparing
the
RMP
and
maintaining
on­
site
documentation
for
sources
with
Program
2
processes
are
presented
in
section
6(
a)
of
this
ICR.

Program
3.
Program
3
sources
will
incur
the
burden
of
assembling
information
for
the
purpose
of
maintaining
on­
site
documentation
and
preparing
and
revising
an
RMP.
The
burden
estimates
for
sources
submitting
an
RMP
for
Program
3
processes
are
presented
in
section
6(
a)
of
this
ICR.

Confidential
Business
Information
Based
on
the
CBI
claims
received
for
reporting
years
1999
and
2004,
EPA
believes
that
sources
with
processes
in
Program
2
and
Program
3
may
seek
to
claim
certain
RMP
information
as
confidential
business
information.
The
activities
required
for
such
sources
include
the
preparation
of
a
sanitized
RMP
(
estimated
as
described
above
for
all
sources)
and
a
substantiation
of
the
claim
for
each
data
element
(
and
potentially
the
substantiation
itself)
claimed
as
confidential,
the
list
of
unsanitized
data
elements
and
the
submission
of
these
documents
to
EPA
at
the
time
of
the
submission
of
RMP.
Burden
estimates
for
these
activities
are
presented
in
section
6(
a)
of
this
ICR.

Petitions
To
submit
a
petition
to
modify
the
list
of
regulated
substances,
a
petitioner
would
be
expected
to
perform
the
following
activities:

 
Read
EPA
guidance
document
and
consult
with
EPA;
 
Plan
activities;
 
Prepare
literature
search;
 
Conduct
literature
search;
 
Process
information;
 
Review
and
focus
information;
 
Write
petition;
 
Review
and
edit
petition;
and
 
Submit
petition
to
EPA
and
file.

The
burden
estimates
developed
for
these
activities
are
presented
in
section
6(
a)
of
this
ICR.

5.
THE
INFORMATION
COLLECTED
C
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Federal,
State,
and
Local
Government
Activities
Burden
to
State
and
Local
Agencies
and
Others
The
burden
and
cost
estimates
developed
for
the
following
state
and
local
government
activities
are
14
presented
in
section
6(
b)
of
this
ICR.

Program
Management
Approximately
12
states
have
been
approved
to
serve
as
the
implementing
agencies
for
part
68.
Three
more
states
have
requested
delegation.
So,
during
the
period
of
this
ICR,
there
will
be
a
total
of
15
states
that
may
have
obtained
delegation
to
implement
part
68.
These
states
will
be
required
to
implement
and
enforce
the
program
for
all
or
some
of
the
sources
in
their
states.
Implementing
agencies
will
need
to
keep
records
of
reviews,
audits,
and
inspections
conducted,
any
administrative
and
legal
actions
taken,
and
other
correspondence
between
the
agency
and
sources,
other
agencies,
EPA,
and
the
public.
Implementing
agencies
will
also
need
to
document
their
budgets,
for
internal
purposes,
and
any
agreements
they
reach
with
other
state,
local,
or
federal
agencies.
To
receive
delegation
of
the
program
from
EPA,
a
state
must
be
able
to
show
that
it
has
the
personnel
and
other
resources
to
perform
these
tasks.

Burden
to
the
Federal
Government
The
burden
estimates
developed
for
the
following
federal
government
activities
are
presented
in
section
6(
d)
of
this
ICR.

Federal
Program
Management
EPA
will
serve
as
the
implementing
agency
for
any
state
that
does
not
seek
or
is
not
granted
delegation.
EPA
will
need
to
keep
records
of
reviews,
audits,
and
inspections
conducted,
any
administrative
and
legal
actions
taken,
and
other
correspondence
between
the
agency
and
sources,
other
agencies,
and
the
public.
EPA
will
also
need
to
document
its
budgets,
for
internal
purposes,
and
any
agreements
it
reaches
with
other
state,
local,
or
federal
agencies.

Risk
Management
Plans
EPA
has
developed
and
made
available
a
software
suite
of
applications
which
perform
various
functions
to
assist
with
the
RMP
program.
They
include
RMP*
Submit,
the
software
application
that
creates
an
electronic
file
for
submission.
RMP*
Submit
includes
pick
lists
for
certain
data
elements,
chemical
names,
LEPCs
from
which
a
source
may
choose).
EPA
has
posted
the
software
and
accompanying
documentation
on
its
web
site.
(
Note:
RMPs
are
required
in
electronic
format.
A
waiver
may
be
obtained
for
filing
on
paper
if
necessary.)

Other
RMP
software
applications
allow
processing
of
the
RMPs
and
creation
of
a
database,
functions
to
be
performed
by
contractors
who
operate
the
RMP
Reporting
Center
to
which
facilities
mail
their
RMPs.
The
suite
of
applications
also
includes
RMP*
Info,
a
database
formerly
on
the
EPA
website,
with
extracts
from
the
main
RMP
database
and
query
functions;
and
RMP*
Review,
software
to
assist
in
querying
the
database.

The
Agency
performs
the
following
activities:

°
Make
the
RMP
software
and
forms
available;
°
Process
the
RMPs
submitted
by
sources
into
a
database
and
make
the
information
15
available
through
various
means;
°
Answer
any
questions
from
sources
concerning
the
process;
°
Process
any
claims
of
confidential
business
information;
°
Notify
each
submitter
of
the
status
of
their
RMP
(
complete
or
incomplete);
°
Store
RMP
submissions
and
retrieve
information;
°
Provide
technical
assistance
to
sources;
and
°
Maintain
the
RMP
database.

RMPs
are
mailed
on
disks
or
CDs
to
a
contractor
operating
the
reporting
center
that
EPA
has
established.
The
reporting
center
processes
RMPs
submitted
on
disks
and
CDs
and
manually
enters
RMPs
submitted
on
paper.
The
center
also
responds
to
questions
from
sources
and
handles
any
CBI
information.
EPA
in
2004
made
available
a
web­
based
application
in
its
Central
Data
Exchange,
operated
by
the
reporting
center
contractor,
for
facilities
who
must
report
RMPs;
the
CDX
web
tool
allows
submission
of
a
limited
number
of
RMP
data
elements
through
the
web.
EPA
is
working
to
further
develop
this
web
tool
to
allow
for
more
data
submission
and
for
web
access
to
the
database
by
state
and
local
officials
and
by
the
facilities
themselves.
The
reporting
center
also
supports
the
maintenance
of
and
development
of
updates
for
the
RMP
software.

Petitions
For
each
petition
submitted
under
40
CFR
68.120,
EPA
would
perform
the
following
activities:

 
Answer
respondent's
questions;
 
Review
petition
for
completeness;
 
Publish
notice
of
petition
receipt
and
request
for
comments;
 
Review
data
submissions;
 
Record
or
enter
the
data
submissions;
 
Store
the
data;
and
 
Prepare
and
publish
the
final
decision.

5(
b)
Collection
Methodology
and
Management
Respondents
complete
an
RMP
electronically
or
on
paper.
EPA
manages
the
data
as
discussed
above.

5(
c)
Small
Entity
Flexibility
The
rule
includes
several
measures
to
reduce
the
burden
to
small
entities.
Most
sources
subject
to
Program
3
requirements
are
already
required
to
comply
with
the
OSHA
PSM
program.
All
other
sources
face
reduced
requirements
under
Programs
1
and
2.
In
addition,
the
quantity
of
information
submitted
in
the
RMP
and
the
associated
burden
varies
with
the
size
of
the
source
(
i.
e.,
smaller
sources
would
have
a
lower
burden).
EPA
has
developed
industry­
specific
guidance
documents
to
help
smaller
sources
comply
with
the
rule.
Therefore,
the
RMP
regulations
do
not
impose
a
disproportionate
burden
of
compliance
on
16
small
sources.

5(
d)
Collection
Schedule
Risk
Management
Plans.
Sources
with
more
than
a
threshold
quantity
of
a
listed
substance
in
a
process
are
required
to
be
in
compliance
with
the
risk
management
program
beginning
June
21,
1999,
and
every
five
years
after.
After
submitting
an
RMP,
a
source
must
update
it
by
the
time
it
adds
a
new
(
to
the
source)
listed
substance
in
a
process
above
threshold
quantity.
Also,
if
certain
other
information
provided
in
the
RMP
becomes
inaccurate
at
any
time
after
submission,
the
source
is
required
to
submit
an
amended
RMP
within
six
months
of
the
change.
Otherwise,
sources
are
required
to
resubmit
their
RMP
within
five
years
of
their
last
submittal
even
if
other
RMP
data
change
during
the
five­
year
period
(
e.
g.,
RMPs
need
not
be
updated
in
cases
such
as
change
in
number
of
employees,
contact
names
etc.).

Petitions.
Each
petitioner
need
only
submit
information
once
in
support
of
a
petition.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
Because
the
burden
for
many
of
the
activities
varies
based
on
the
size
and
complexity
of
the
source,
weighted
averages
for
unit
burden
and
unit
cost
were
developed
for
each
category
of
source
for
each
item.

6(
a)
Respondent
Burden
Respondent
Burden
for
Rule
Familiarization
(
New
Sources)

The
burden
associated
with
rule
familiarization
was
estimated
in
previous
ICRs
for
those
sources
that
are
currently
subject
to
the
regulations.
This
ICR
only
estimates
burden
for
any
new
sources
that
may
be
subject
to
regulations
during
the
period
covered
by
this
ICR.
Between
2001
to
2003
(
between
the
two
mandatory
deadline
1999
and
2004),
an
average
of
332
sources
became
subject
to
the
regulations.
EPA
assumes
this
same
growth
each
year
covered
by
this
ICR.

New
sources
were
mainly
in
the
non­
manufacturing
sectors.
There
were
also
a
few
in
the
chemical
and
non­
chemical
manufacturing
sectors
(
small/
medium
size
sources).
The
unit
burden
is
estimated
to
range
from
20
to
40
hours
for
the
various
sectors
covered
by
the
regulations.
The
total
annual
burden
for
all
sectors
to
become
familiar
with
the
rule
is
estimated
to
be
8040
hours
at
a
cost
of
$
304,134
dollars
(
24,120
hours
at
a
cost
of
$
912,402
for
three
years.)

Respondent
Burden
for
Initial
RMP
Preparation
and
Submission
(
New
Sources)

Exhibit
4
presents
the
estimated
unit
burden
hours
for
preparing
and
submitting
an
RMP
for
sources
that
will
be
subject
to
the
regulations
during
the
period
covered
by
this
ICR.
As
stated
above,
based
on
the
RMPs
submitted
between
the
two
reporting
years,
1999
and
2004,
about
332
sources
will
submit
RMPs
annually.
The
sources
are
mainly
in
the
non­
manufacturing
sectors.
There
are
a
few
in
the
manufacturing
sectors
as
mentioned
above.
The
average
unit
burden
to
prepare
and
submit
an
RMP
range
from
10
to
30
hours
for
the
various
sectors
covered
by
the
regulations.
The
total
annual
burden
for
the
universe
of
new
sources
for
preparing
and
submitting
an
RMP
is
estimated
to
be
4,340
hours
at
a
cost
of
$
160,905
dollars
(
13,020
hours
at
a
cost
of
$
482,715
dollars
for
three
years).
17
New
sources
also
have
costs
for
developing
documentation
for
prevention
program
elements.
Estimates
of
the
respondent
burden
hours
for
maintaining
on­
site
documentation
vary,
depending
on
the
size
of
the
source
and
the
complexity
of
the
on­
site
processes
as
well
as
on
whether
the
source
is
already
covered
by
OSHA
PSM
rule.
Based
on
recent
new
RMPs
received,
there
are
150
of
the
new
sources
that
will
not
be
subject
to
the
OSHA
PSM
standard.
The
estimated
unit
burden
for
prevention
program
for
the
new
sources
range
from
70
to
95
hours.
The
total
annual
burden
for
the
150
non­
PSM
sources
is
estimated
to
be
10,820
hours
at
a
cost
of
$
331,213
dollars
(
32,460
hours
at
a
cost
of
$
993,639
dollars
for
three
years).

RMP
Resubmission
Initial
RMPs
were
submitted
in
June
1999.
Since
the
initial
submission
and
before
the
five­
year
mandatory
deadline
in
June
2004,
many
sources
resubmitted
their
RMP.
These
sources
were
then
assigned
a
new
five­
year
submission
deadline.
Adding
new
processes
or
other
activities
at
these
sources
were
the
result
of
the
revision
and
the
re­
submission
of
the
RMP.
New
processes
or
other
activities
at
these
sources
was
the
result
of
the
revision
and
re­
submission
of
the
RMP.

EPA
contacted
few
sources
that
resubmitted
RMP
between
reporting
years
1999
and
2004
in
order
to
develop
an
estimate
on
the
burden
imposed
to
revise
and
re­
submit
RMP.
See
Section
3(
b)
of
this
document.
In
addition
to
calculating
burden
for
new
facilities
that
may
become
subject
to
part
68,
this
ICR
only
accounts
burden
for
re­
submission
and
on­
site
documentation
for
sources
that
are
currently
subject
to
the
regulations.
EPA
only
contacted
those
sources
that
re­
submitted
RMP
between
the
two
reporting
years.
Based
on
the
number
of
re­
submitted
RMPs
received
between
the
two
reporting
years,
EPA
estimates
that
approximately
1050
RMPs
may
be
re­
submitted
annually.
The
sources
that
were
contacted
by
EPA
reported
that
it
took
approximately
between
2
to
40
hours
to
resubmit
the
RMP.
To
be
conservative,
EPA
is
assuming
that
it
will
take
approximately
10
to
40
hours
for
various
sectors
covered
by
the
regulations
to
re­
submit
their
RMP.
Sources
contacted
were
of
different
sizes
in
various
sectors.
Each
had
various
reasons
to
re­
submit
the
RMP.

The
total
number
of
hours
for
the
three­
year
period
is
13,300
hours
annually
at
a
cost
of
$
434,794
dollars
(
39,900
hours
at
cost
of
$
1,304,382
dollars
for
three
years).

Prevention
Program
Documentation
(
on­
going
for
currently
covered
sources)

As
above,
estimates
of
the
respondent
burden
hours
for
maintaining
on­
site
documentation
vary,
depending
upon
the
size
of
the
source
and
the
complexity
of
on­
site
processes
as
well
as
on
whether
the
source
is
already
covered
by
the
OSHA
PSM
rule.
Burden
hour
estimates
were
developed
for
previous
ICRs
are
also
used
in
this
ICR.

All
sources
with
Program
2
or
3
processes
will
need
to
conduct
a
compliance
audit
within
the
three­
year
period
of
this
ICR.
The
cost
of
the
audit
documentation
is
the
cost
of
producing
the
audit
report.
All
sources
are
assumed
to
incur
costs
for
accident
investigation.
The
only
other
on­
going
costs
for
documentation
for
Program
2
processes
are
for
keeping
the
safety
information
and
operating
procedures
up­
to­
date.
For
Program
3
processes,
the
on­
going
costs
include
keeping
PSI
and
SOPs
up­
to
date,
documenting
refresher
training,
training
of
new
employees,
maintenance,
and
management
of
change.

The
estimated
unit
burden
ranges
from
3
to
146
hours
for
the
various
sectors
covered
by
the
18
regulations.
Total
annual
on­
site
documentation
55,380hours
at
a
cost
of
$
2,024,754
dollars
(
166,140
hours
at
a
cost
of
$
6,074,262
dollars
for
three
years).

Respondent
Burden
for
Confidential
Business
Information
Claims
The
requirement
that
substantiation
for
CBI
claims
be
submitted
with
the
claims
will
impose
costs
on
those
sources
making
the
CBI
claims.

Previous
ICRs
estimated
that
the
time
required
to
develop
and
submit
CBI
substantiation
is
9.5
hours
per
claim.
EPA
is
assuming
the
same
in
this
ICR.
EPA
received
34
claims
for
the
reporting
year
1999
and
35
claims
for
reporting
year
2004.
Based
on
the
CBI
submissions
received
for
these
reporting
years,
EPA
assumes
that
we
may
receive
35
CBI
submissions
each
year
covered
by
this
ICR.
We
assume
that
only
new
sources
that
may
be
required
to
comply
with
part
68
during
this
ICR
period
may
submit
claims.
As
a
result,
for
the
estimated
35
sources
preparing
and
submitting
CBI
claims,
the
estimated
industry
annual
burden
is
323
hours
at
cost
of
$
14,673
dollars
(
969
hours
at
a
cost
of
$
14,673
dollars
for
three
years).

Respondent
Burden
for
Petitions
Since
the
list
of
chemicals
were
published
in
1994,
EPA
only
received
one
petition
to
remove
a
chemical
from
the
list.
EPA
do
not
expect
to
receive
any
petition
during
the
period
covered
by
this
ICR.
Therefore,
we
did
not
account
any
burden
for
filing
petitions.

6(
b)
Estimating
Respondent
Costs
Although
EPA
contacted
few
industries
to
develop
the
burden
included
in
this
ICR,
EPA
used
estimates
from
previous
ICRs.
The
burden
reported
by
the
industries
contacted
was
lower
than
EPA
estimates.
The
estimated
costs
of
documenting
risk
management
program
activities
and
submitting
an
RMP
are
a
function
of
the
time
expended
by
the
respondent
(
i.
e.,
the
burden
estimates
presented
in
section
6(
a))
and
the
hourly
wage
rates
for
the
appropriate
categories
of
labor.

The
estimated
unit
costs
for
private
firms
were
based
on
four
categories
of
labor
(
legal,
managerial,
technical,
and
clerical)
and
wage
rates
reported
by
the
Bureau
of
Labor
Statistics
(
BLS),
in
its
November
2003
edition
of
Occupational
Employment
and
Wages.
The
annual
salaries
for
these
categories
were
broken
out
by
four
facility
sub­
categories
(
chemical
manufacturer,
other
manufacturer,
non­
manufacturer,
and
wholesaler)
to
account
for
differences
in
wages
rates
among
the
affected
facilities.
The
wage
rates
include
benefits,
based
on
BLS
data.
Exhibit
2
provides
the
wage
rates
for
various
industries
affected.

The
estimated
labor
and
wage
rates
for
state
and
federal
employees
were
based
on
three
categories
of
labor
(
attorney,
environmental
engineer,
and
clerical)
and
wage
rates
as
reported
by
BLS's,
Employer
Cost
for
Employee
Compensation,
data
query
based
on
4th
quarter
2004
costs
for
state
employees
and
the
Federal
Office
of
Personnel
Management
(
OPM)
Salary
Table,
effective
January
2005,
for
the
Rest
of
U.
S.
Federal
wage
rates
are
based
on
a
GS­
15,
step
5
Attorney,
GS­
13
step
5
Environmental
Engineer,
and
a
GS­
5,
step
5
Clerk.
Exhibit
3
provides
19
the
wage
rates
for
state
and
federal
employees
of
the
implementing
agencies.

Implementing
Agency
Costs
Although
EPA
does
not
require
states
to
obtain
delegation
to
implement
Part
68
program,
to
date,
there
are
12
states
that
obtained
delegation
to
implement
the
program.
Since
EPA
will
not
be
granting
funds
to
states
as
part
of
the
delegation
process,
the
burden
and
cost
the
states
will
incur
is
added
to
the
respondent
burden
in
this
ICR.
If
the
states
do
not
obtain
delegation
of
the
program,
EPA
will
be
the
implementing
agency.

Three
more
states
have
requested
delegation,
so
there
will
be
15
states
that
have
obtained
delegation
during
the
period
covered
by
this
ICR.
EPA
will
serve
as
the
implementing
agency
for
all
other
states.
Implementing
agencies
are
expected
to
review
RMPs,
audit
RMPs,
inspect
sources,
provide
technical
assistance,
and
conduct
standard
program
management
activities
(
e.
g.,
developing
budgets,
filing
administrative
orders
and
enforcement
actions).
Initial
reviews,
which
are
first
checks
of
the
RMPs
to
identify
any
problems
(
e.
g.,
clear
inconsistencies
in
reported
data,
failure
to
list
obvious
hazards
such
as
flammability
for
a
listed
flammable)
are
estimated
to
require
one
to
five
hours,
depending
on
the
number
and
complexity
of
processes
covered
in
the
RMP.
Audits
are
assumed
to
be
detailed
reviews
of
the
RMPs,
requiring
from
two
to
twelve
hours
per
RMP;
audits
require
technical
staff
capable
of
identifying
data
that
may
indicate
safety
problems
(
e.
g.,
failure
to
report
chemical
or
process
hazards,
which
could
indicate
an
inadequate
PHA,
or
lack
of
normal
process
controls,
which
could
indicate
either
an
incomplete
RMP
or
inadequate
safety
practices).
Audits
may
be
totally
offsite
or
may
include
a
site
visit
to
review
documentation
and
other
aspects
of
the
program.
The
results
of
the
audits
will
help
select
sources
that
may
require
inspection
to
determine
whether
the
source
is
in
compliance
with
the
rule
and
operating
safely.
Inspections
are
site
visits
to
review
the
activities
and
documentation.
Inspections
are
estimated
to
take
4
to
80
hours.
Technical
assistance
estimates
are
based
on
the
assumption
that
every
covered
source
will
call
once,
with
calls
from
the
manufacturing
sources
taking
one
hour
and
calls
from
non­
manufacturers
taking
half
that
time.
The
assumption
of
every
source
calling
is
conservative
and
recognizes
that
not
all
sources
will
seek
help,
but
that
those
that
do
may
take
more
than
the
time
estimated.
Program
management
is
assumed
to
involve
three
experienced
staff
per
state
and
per
region,
one­
fifth
of
an
FTE
for
an
attorney,
and
one­
tenth
of
an
FTE
of
clerical
time.

Recordkeeping
related
to
these
activities
is
assumed
to
take
10
percent
of
the
total
time
required,
except
for
inspection
reports,
which
are
assumed
to
take
12.5
percent
of
the
total
time
for
inspections.
The
estimated
burden
for
recordkeeping
related
to
these
activities
is
11,000
hours
(
6,160
for
states
and
4,840
for
EPA
annually
).
The
total
annual
cost
is
estimated
to
be
$
556,000
over
three
years
($
221,000
for
states
and
$
335,000
for
EPA).

Capital
Costs
(
State
and
Local
agencies)

Because
RMPs
will
be
available
electronically
and
EPA
will
provide
them
to
anyone
who
does
not
have
Internet
access,
state
and
local
agencies
are
expected
to
incur
no
capital
costs
related
to
RMPs.
Implementing
agencies
will
incur
limited
capital
costs
to
maintain
documents
on
program
implementation.
The
paper
files
associated
with
these
programs
will
be
limited
and
will
vary
with
the
size
of
the
regulated
community
overseen.
EPA
assumed
that
each
agency
would
require
two
file
cabinets
over
the
three­
year
period,
at
a
cost
of
$
600
per
file
cabinet.
The
annualized
cost
to
a
state
would
be
$
200.
The
total
cost
to
the
15
implementing
agencies
would
be
$
1000
annualized,
$
3000
for
the
three­
year
period.
1
The
RMP
submitted
to
EPA
by
the
majority
of
sources
is
expected
to
be
about
six
to
ten
pages
in
length.
The
RMP
for
larger,
more
complex
sources
may,
however,
be
significantly
longer,
in
excess
of
100
pages
for
the
very
largest
source
with
multiple
processes
and
substances.

20
6(
c)
Estimating
Annual
Respondent
Cost
Burden
(
Operating
&
Maintenance
Costs)

This
section
estimates
the
annual
cost
burden
to
respondents.
These
costs
are
in
addition
to
the
burden
hours
and
associated
costs
estimated
in
the
previous
two
sections.
Specifically,
this
section
considers
additional
capital
or
startup
costs,
annual
operating
and
maintenance
costs,
or
costs
for
services,
such
as
consultant
services,
incurred
by
respondents
for
the
collection
of
information.

Sources
are
not
required
or
expected
to
use
consultants
to
prepare
and
submit
their
RMP
or
their
on­
site
documentation.
The
RMP
program
has
been
specifically
designed,
by
simplifying
the
requirements
and
allowing
sources
to
use
prepared
forms
and
models,
to
eliminate
the
need
for
sources
to
use
consultants
to
meet
the
requirements
of
this
program.

There
are
expected
to
be
no
significant
resources
expended
by
respondents
to
acquire,
install,
or
use
additional
technology
or
computer
systems
to
prepare
and
submit
the
RMP
and
maintain
on­
site
documentation
by
sources.
Sources
with
computers
will
be
encouraged
to
submit
the
data
electronically
on
disk.
EPA
has
developed
software
required
to
submit
the
RMP
electronically
and
made
it
available
on­
line,
at
no
cost
to
participants.
Most
sources
already
have
access
to
the
Internet;
therefore,
the
connection
charge
associated
with
Internet
access
is
not
applied
to
this
rule.

All
sources
will
need
to
mail
new
or
revised
RMPs,
whether
on
disk
or
in
hardcopy
form,
to
EPA.
Based
on
the
estimates
presented
in
previous
sections
in
this
document,
about
996
sources
are
expected
to
submit
new
RMPs
or
3,150
sources
may
submit
revised
RMPs
via
mail
over
the
three­
year
period
covered
by
this
ICR
(
332
new
RMP
submissions
and
1050
revised
RMP
submissions
annually).
All
of
these
sources
will
incur
the
cost
of
mailing
at
approximately
$
5.00
per
submission.
Using
this
unit
cost
estimate,
the
total
cost
to
respondents
for
mailing
the
RMPs
(
new
and
revised)
is
estimated
to
be
$$
20,730
dollars
for
the
three
years
covered
by
this
ICR
(
or
$
6,910
dollars
annually).

Sources
maintaining
on­
site
documentation
will
require
file
cabinet
space
to
retain
the
required
information.
EPA
took
the
following
steps
to
estimate
the
cost
associated
with
providing
file
cabinet
space:

 
Estimate
the
total
volume
of
materials
to
be
retained
by
all
sources.
The
RMP
submitted
to
EPA
and
maintained
on
site
is
estimated
to
be
about
18
pages,
on
average,
for
sources
covered
under
the
RMP
rule;
most
RMPs,
however,
are
expected
to
be
stored
electronically.
1
New
Program
2
sources
are
expected
to
maintain
approximately
20
pages,
on
average,
of
documentation
materials;
most
of
this
material
is
likely
to
be
stored
as
paper
(
e.
g.,
MSDSs,
equipment
specifications,
operating
procedures).
Any
new
Program
3
source
will
be
covered
by
OSHA
PSM
and
HAZWOPER
programs.
Therefore,
only
the
RMPs
will
need
to
be
stored
under
this
rule;
prevention
and
emergency
response
documentation
costs
accrue
to
the
OSHA
rules.
Under
these
assumptions,
it
is
estimated
that
about
26,600
pages
of
material
not
created
and
accounted
for
under
the
previous
ICR
will
be
retained
by
all
sources.
2
Based
on
an
OMB­
approved
discount
rate
of
seven
percent
(
OMB
Circular
A­
94)
and
an
estimated
life
of
15
years
for
a
file
cabinet,
based
on
the
15­
year
manufacturer's
warranty.

21
 
Estimate
the
number
of
standard­
size
file
cabinets
required
to
retain
the
estimated
volume
of
materials.
Given
that
the
standard­
size,
five­
drawer,
lateral
file
cabinet
is
expected
to
hold
approximately
36,000
pages
of
material,
EPA
estimates
that
the
affected
sources
would
need
to
purchase
approximately
one
file
cabinet
to
retain
copies
of
the
RMP
and
on­
site
documentation
required
within
the
time
period
of
this
ICR.
Using
an
estimated
cost
of
$
530
per
file
cabinet,
the
cost
of
purchasing
the
file
cabinet
is
estimated
at
$
530.

Calculate
the
annualized
cost.
EPA
used
the
following
annualized
net
present
formula
to
calculate
the
annual
cost
to
the
affected
sources
to
acquire
the
file
cabinets:

$
530
x
[
1/(
 1/(
1+
k)
t)]
for
t=
1
to
15
where
k
=
discount
rate
of
7
percent;

t
=
life
of
equipment
(
15
years).
2
Thus,
the
additional
annual
cost
burden
for
respondents
during
the
time
period
covered
by
this
ICR
is
estimated
to
be
$
10,000
virtually
all
of
which
represents
operating
and
maintenance
expenses.
The
total
cost
for
the
ICR
is
$
30,000.

6(
d)
Estimating
Burden
and
Costs
to
the
Public
Sector
Federal
Costs
EPA
will
bear
costs
for
three
sets
of
activities:
EPA
will
serve
as
the
implementing
agency
for
part
68
regulations
in
any
state
that
does
not
seek
and
obtain
delegation;
EPA
will
oversee
programs
delegated
to
states;
and
EPA
will
collect
and
make
available
RMPs.

EPA
has
developed
a
software
system
for
submission
of
RMPs
(
RMP*
Submit),
a
secure
database
with
complete
RMP
data
(
RMP*
Review)
for
states
and
local
agencies,
and
a
public
database
without
OCA
data
(
RMP*
Info)
that
will
be
used
to
make
RMPs
available
to
the
public.
EPA
has
established
a
records
center
to
handle
RMPs
and
answer
questions
from
the
public.
The
center
staff
will
be
responsible
for
entering
RMPs
that
are
submitted
on
paper
into
the
system
and
handling
RMPs
that
arrive
on
disk.
The
cost
of
operating
the
records
center
is
estimated
to
be
$
2.7
million
over
three
years
($
900,000
annually).
This
cost
includes
hardware,
software,
systems
support;
quality
assurance;
error
notices
and
mail­
outs.
The
cost
changes
slightly
every
year
due
to
the
number
of
RMPs
that
need
to
be
processed,
the
costs
increase
during
the
reporting
year,
which
EPA
receive
about
15,000
RMPs.

EPA
will
oversee
part
68
programs
implemented
by
state
and
local
agencies.
Such
oversight
will
include
reviewing
submissions
from
states
and
local
agencies,
providing
assistance
to
these
agencies,
and
working
with
them
on
issues.
EPA
estimates
that
oversight
will
require
1.1
FTE
per
region
(
one
senior
staff
member
plus
a
tenth
of
the
time
of
a
clerical
staff
member),
plus
three
staff
members
at
EPA
22
headquarters.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
Exhibit
9
presents
the
estimated
total
costs
for
all
sources.
The
total
annual
estimated
costs
to
sources
for
all
activities
are
estimated
to
be
$
3.2
million.
The
total
annual
estimated
cost
for
the
states/
local
agencies
is
$
221,000.

The
total
annual
estimated
cost
to
EPA
for
all
activities
are
estimated
to
be
$
2.1
million;
most
of
the
burden
is
incurred
by
EPA
for
managing
RMPs.

6(
f)
Reasons
for
Change
in
Burden
This
ICR
estimates
a
total
decrease
in
the
burden
of
32,300
hours
(
from
130,803
hours
to
98,501)
for
all
sources
and
states.
This
decrease
mainly
due
to
the
RMP
submission
schedule.
The
last
submission
of
RMPs
by
all
sources
was
in
June
2004.
The
next
compliance
deadline
is
June
2009,
which
is
after
this
ICR
period.
This
ICR
only
accounts
compliance
burden
for
new
sources
that
may
become
subject
to
the
regulations,
any
revised
RMP
that
may
be
submitted
by
existing
sources
and
on­
site
documentation
for
existing
sources.
The
burden
may
increase
in
the
next
ICR
renewal
since
the
next
deadline
for
all
sources
to
submit
RMP
will
fall
within
the
next
ICR
period.

6(
g)
Burden
Statement
The
public
reporting
burden
will
depend
on
the
regulatory
program
tier
into
which
sources
are
categorized.
In
this
ICR,
the
public
reporting
burden
for
rule
familiarization
for
new
sources
is
estimated
to
range
from
20
to
40
hours
per
source.
The
public
reporting
burden
to
prepare
and
submit
a
RMP
for
new
sources
is
estimated
to
range
from
10
to
30
hours.
The
public
reporting
burden
for
new
sources
to
develop
prevention
program
is
estimated
to
range
from
70
to
95
hours
per
source.
The
public
reporting
burden
for
CBI
claims
is
estimated
to
be
9.5
hours
per
source.
RMP
revisions
are
estimated
to
range
from
10
to
40
hours
per
source.
The
public
record
keeping
burden
to
maintain
on­
site
documentation
for
currently
covered
sources
is
estimated
to
range
from
3
hours
to
146
hours.
The
total
annual
public
reporting
burden
for
new
sources
to
become
familiar
with
the
rule,
develop
and
submit
a
RMP,
develop
prevention
program,
substantiate
claims
for
confidential
business
information,
submit
revised
RMP,
and
develop
on­
site
documentation
for
existing
sources
is
about
92,341
hours
(
277,023
hours
over
three
years).
The
total
annual
burden
estimated
for
15
states
that
may
be
implementing
Part
68
program,
is
6,160
hours
(
18,480
hours
for
three
years).
Therefore,
the
total
annual
burden
for
all
sources
and
states
is
estimated
to
be
98,500
hours
(
295,503
hours
for
three
years).

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
23
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
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
No.
OAR­
2003­
0052,
which
is
available
for
public
viewing
at
the
Air
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
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
Air
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
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
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0052)
and
OMB
control
number
(
2050­
0144)
in
any
correspondence.
24
APPENDIX
EXHIBIT
1
NUMBER
OF
Sources
Total
Sources
Sources
Not
Subject
to
OSHA
PSM
Small/
medium
chemical
1490
196
Large
high
complexity
chemical
385
18
Other
manufacturers
2080
258
Non
manufacturer
6640
2735
Wholesale
4710
4155
Total
15,305
7,362
EXHIBIT
2
WAGE
RATES
­
Sources
25
Legal
Management
Technical
Source
Chemical
Manufacturers
$
100.00
$
59.77
$
47.07
Bureau
of
Labor
Statistics,
Occupational
Employment
and
Wages,
Nov.
2003.

Other
Manufacturers
$
100.00
$
59.77
$
40.03
Bureau
of
Labor
Statistics,
Occupational
Employment
and
Wages,
Nov.
2003.

Non
Manufacturers
$
100.00
$
59.77
$
24.41
Bureau
of
Labor
Statistics,
Occupational
Employment
and
Wages,
Nov.
2003.

Wholesale
$
100.00
$
59.77
$
23.27
Bureau
of
Labor
Statistics,
Occupational
Employment
and
Wages,
Nov.
2003.

EXHIBIT
3
WAGE
RATES
­
STATE
AND
FEDERAL
State
Wage
Loaded
Rate
Attorney
$
30.90
$
38.63
Environmental
Engineer
$
30.60
$
38.25
Clerical­
office
clerk
general
$
15.24
$
19.05
Federal
Attorney
$
54.38
$
67.98
Environmental
Engineer
$
39.12
$
48.90
Clerical­
office
clerk
general
$
14.97
$
18.71
Federal:
Office
of
Personnel
Management,
Salary
Table,
January
2005,
Rest
of
U.
S.

State:
Bureau
of
Labor
Statistics,
Employer
Cost
for
Employee
Compensation,
data
query
for
4th
quarter
2004.

EXHIBIT
4
26
RESPONDENT
UNIT
BURDEN
HOURS

New
Sources
Rule
Familiarization
and
RMP
Preparation
Rule
Familiarization
RMP
Preparation
Management
Technical
Management
Technical
Small/
Medium
Chemical
10
30
5
25
Large
high
Complexity
Chemical
­­
­­
­­
­­

Other
Manufacturers
10
30
3
17
Non­
Manufacturers
5
15
2
8
Wholesale
5
15
2
8
Exhibit
5
UNIT
BURDEN
FOR
PREVENTION
PROGRAM
DOCUMENTATION­
New
Sources
Management
Technical
Small/
Medium
Chemical
15
80
Large
Complex
Chemical
­­­­
­­­­­

Other
Manufacturers
15
80
Non­
Manufacturers
10
60
Wholesale
10
60
Note:
Based
on
the
most
recent
data
of
new
sources
that
submitted
RMP,
EPA
do
not
expect
any
large
complex
chemical
companies
to
submit
RMP
for
the
period
covered
by
this
ICR.
27
EXHIBIT
6
RESPONDENT
UNIT
BURDEN
HOURS

CBI
Legal
Management
Technical
1
3
5.5
EXHIBIT
7
UNIT
BURDEN
FOR
PREVENTION
PROGRAM
DOCUMENTATION
(
on­
going
for
currently
covered
non­
PSM
sources)

(
Technical
Hours)

Non­
PSM
Sources
Unit
Burden
Small/
medium
chemical
196
122
Large
high
complexity
chemical
18
146
Other
manufacturers
258
11
Non
manufacturers
2735
5
Wholesale
4155
3
28
EXHIBIT
8
TOTAL
BURDEN
HOURS
FOR
RMP
BY
SECTOR
­
Annual
Rule
Familiarization
(
new
sources)
RMP
(
new
Sources)
Prevention
Program
(
New
Sources)
Revised
RMPs
(
Currently
Covered
Sources)
CBI
Claims
(
New
Sources)
On­
Site
Documentation
Total
Hours
Small/
medium
chemical
1,280
960
570
1,200
29
23,912
27,951
Large
high
complexity
chemical
­
­
­
2,000
­
2,628
4,628
Other
manufacturers
1,520
760
380
2,700
38
2,838
8,236
Non
manufacturers
3,240
1,620
4,060
4,000
95
13,675
26,690
Wholesale
2,000
1,000
5,810
3,400
162
12,465
24,837
TOTAL
8,040
4,340
10,820
13,300
323
55,518
92,341
EXHIBIT
9
ESTIMATED
TOTAL
Annual
BURDEN
COSTS
Rule
Familiarization
(
new
sources)
RMPs
(
new
sources)
Prevention
Program
(
new
sources)
Revised
RMPs
(
currently
covered
sources)
CBI
(
new
sources)
On­
Site
Documentation
(
currently
covered
sources)
Total
Small/
medium
chemical
$
64,318
$
47,222
$
27,975
$
56,488
$
1,615
$
1,125,539
$
1,323,557
Large
high
complexity
chemical
­
­
­
$
94,146
­
$
123,670
$
217,816
Other
manufacturers
$
68,345
$
32,672
$
16,395
$
108,073
$
1,998
$
115,670
$
343,153
Non
manufacturers
$
66,508
$
31,486
$
171,194
$
93,080
$
4,136
$
315,035
$
681,439
Wholesale
$
104,963
$
49,525
$
115,649
$
83,008
$
6,924
$
344,840
$
704,909
TOTAL
$
304,134
$
160,905
$
331,213
$
434,795
$
14,673
$
2,024,754
$
3,270,874
29
30
