                             SUPPORTING STATEMENT
                        ENVIRONMENTAL PROTECTION AGENCY
                                       
NESHAP for Off-Site Waste and Recovery Operations (Revised)
1. Identification of the Information Collection
      1(a)  Title of the Information Collection
      National Emission Standards for Hazardous Air Pollutants (NESHAP) for Off-Site Waste and Recovery Operations (OSWRO) (40 CFR part 63, subpart DD) (Revised), EPA ICR Number 1717.11, OMB Control Number 2060-0313. 
      1(b)  Short Characterization/Abstract
      The amendments to this information collection request (ICR) are a result of the review of the existing NESHAP for OSWRO (40 CFR part 63, subpart DD) as required by the Clean Air Act (CAA). The NESHAP published at 40 CFR part 63, subpart DD were proposed on October 13, 1994, and promulgated on July 1, 1996. The regulation applies to hazardous air pollutants (HAP) emissions from selected facilities involved in waste management and recovery operations that are not subject to Federal air standards under other subparts in 40 CFR part 63, if the facility is a major source of HAP emissions, as defined in general provisions to 40 CFR part 63. In addition, 40 CFR part 63, subpart DD cross-references control requirements to be applied to specific types of affected sources: tanks-level 1; containers; surface impoundments; individual drain systems; oil-water separators; organic water separators; and loading, transfer, and storage systems. This information is being collected to assure compliance with 40 CFR part 63, subpart DD. Organic HAP emissions are the pollutants regulated under this subpart.
      In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP. Semi-annual summary reports are also required.
      This final rulemaking amends title 40, chapter I, part 63 subpart DD revising the leak detection and repair (LDAR) requirements. In addition, the proposed amendments also add requirements to monitor each pressure relief device (PRD) that is designed to release to the atmosphere using a device or system that is capable of identifying and recording the time and duration of each pressure release and of notifying operators that a release has occurred. Information related to these new provisions is required to be submitted in the semi-annual reports required by the existing NESHAP. In addition, the EPA is finalizing requirements that require storage vessels of certain sizes and containing materials above certain vapor pressures to use Level 2 controls (i.e., obtain a 95 percent organic HAP emissions reduction). Burden changes associated with these proposed amendments would result from new recordkeeping and reporting requirements associated with the LDAR and PRD monitoring requirements for all facilities subject to subpart DD. 
      The Office of Management and Budget (OMB) approved the currently active ICR without any "Terms of Clearance." The overall change in burden found in this ICR reflect the provision changes, an update in the cost of labor, and corrections to the number of affected facilities found in EPA ICR number 1717.09.
      The period considered in this ICR and throughout this supporting statement is the first three years following the promulgation of the amended OSWRO NESHAP. The estimates of the size of the regulated universe are based on data from the National Emissions Inventory (NEI) database, available permit data and information collected in the 2013 OSWRO CAA section 114 survey. There are an estimated 56 major source facilities in the OSWRO source category. Based on available permit information, seven facilities are known to be exempt from most of the rule requirements due to the low HAP content of the off-site waste they receive. These facilities are not expected to be affected by the rule. Therefore, we estimate that there is an annual average of 49 respondents that will be subject to the regulation. We do not know of any new facilities that are expected to be constructed in the foreseeable future, so consequently it is estimated that no additional sources will become subject to the standard over the next three years. 
2. Need for and Use of the Collection
      2(a)  Need/Authority for the Collection
      The EPA is charged under section 112 of the CAA, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of HAP. These standards are applicable to new or existing sources of HAP and must require the maximum degree of emission reduction. In addition, section 114(a) of the CAA states that the Administrator may require any owner or operator subject to any requirement of this Act to:
            (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably require.
      2(b)  Practical Utility/Users of the Data
      The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which were promulgated in accordance with the CAA. In addition, the collected information is used for targeting inspections and as evidence in legal proceedings.
      Performance tests are required in order to determine an affected facility's initial capability to comply with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.
      The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to ensure that the pollution control devices are properly installed and operated, that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed.
      The required semi-annual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures, and for compliance determinations.
	The information generated by the monitoring, recordkeeping and reporting requirements described in this ICR is used by the Agency to ensure that facilities affected by the NESHAP continues to operate the control equipment in compliance with the regulation.
3. Non-duplication, Consultations, and Other Collection Criteria
      3(a)  Non-duplication
      A search of the EPA's existing standards and ongoing ICRs revealed no duplication of information gathering efforts. However, certain reports required by state or local agencies may duplicate information required by this NESHAP. In these cases, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists.
      3(b)  Public Notice Required Prior to ICR Submission to OMB
      This ICR is related to final amendments to 40 CFR part 63, subpart DD for the OSWRO source category. Comments were solicited on the proposal package and the proposed ICR, and no comments were received regarding the proposed ICR.
      3(c)  Consultations
      Over the next three years, an average of 49 facilities per year will be subject to the standard, with no additional sources per year becoming subject to the standard. In estimating the affected number of sources and the growth rate of OSWRO facilities subject to this standard during a previous renewal, we referenced the most recent ICR, and used other resources to obtain the most recent data available. We reviewed information available from the Online Tracking Information System (OTIS), which is the primary source of information regarding the number of existing sources. OTIS data was used in conjunction with industry consultation to verify the number of sources and the industry growth rate. 
      3(d)  Effects of Less Frequent Collection
      Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required by these standards was collected less frequently, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely.
      3(e)  General Guidelines
      These reporting or recordkeeping requirements are consistent with the regulations established by OMB at 5 CFR part 1320, section 1320.5.
      These standards require the respondents to maintain all records, including reports and notifications for at least five years. This is consistent with the General Provisions as applied to the standards. EPA believes that the five-year records retention requirement is consistent with the Part 70 permit program and the five-year statute of limitations on which the permit program is based. The retention of records for five years allows EPA to establish the compliance history of a source, any pattern of non-compliance, and to determine the appropriate level of enforcement action. The EPA has found that the most flagrant violators have violations extending beyond the five years. Without the five-year record retention, the EPA would be prevented from pursuing the violators due to the destruction or nonexistence of essential records.
      3(f)  Confidentiality
      Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (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
      None of the reporting or recordkeeping requirements contain sensitive questions.
4. The Respondents and the Information Requested
      4(a)  Respondents
      The respondents to the recordkeeping and reporting requirements are OSWRO that store, treat, recycle, reprocess, or dispose of wastes containing organic chemical compounds. The United States Standard Industrial Classification (SIC) codes, which correspond to the North American Industry Classification System (NAICS) codes, could be found in the following table:
                    Off-site Waste and Recovery Operations 
                         (40 CFR part 63, subpart DD)
                                     NAICS
Crude Petroleum and Natural Gas Extraction
                                    211111
Water Supply and Irrigation Systems
                                    221310
Highway, Street, and Bridge Construction
                                    237310
Petroleum Refineries
                                    324110
Other Basic Inorganic Chemical Manufacturing
                                    325180
Cyclic Crude, Intermediate, and Gum and Wood 
Chemical Manufacturing
                                    325194
All Other Basic Organic Chemical Manufacturing
                                    325199
Plastics Material and Resin Manufacturing
                                    325211
Cement Manufacturing
                                    327310
Alumina Refining and Primary Aluminum Production
                                    331313
Photographic and Photocopying Equipment Manufacturing
                                    333316
Aircraft Manufacturing
                                    336411
Other Chemical and Allied Products Merchant Wholesalers
                                    424690
Office Administrative Services
                                    561110
Solid Waste Collection
                                    562111
Hazardous Waste Treatment and Disposal
                                    562211
Solid Waste Combustion and Incinerators
                                    562213
Other Nonhazardous Waste Treatment and Disposal
                                    562219
Materials Recovery Facilities
                                    562920
National Security[a]
                                    928110
[a] One facility is operated by the U.S. Department of Defense. Small business size standards are not established for this sector. 
      
      4(b)  Information Requested
      None of these reporting and recordkeeping requirements violate any of the regulations established by OMB at 5 CFR part 1320, section 1320.5.
            (i)  Data Items
	All data in this ICR that is recorded and/or reported is required by NESHAP for OSWRO (40 CFR part 63, subpart DD).
	A source must make the following notifications:

                 Notifications for 40 CFR part 63, subpart DD
Notification and application of construction/reconstruction
                                    63.5(d)
Notification of initial startup
                                    63.9(b)
Notification of initial performance test
                              63.7(b) and 63.9(e)
Rescheduled initial performance test
                                  63.7(b)(2)
Demonstration of continuous monitoring system
                                    63.9(g)
Compliance status
                                    63.9(h)
Notification of performance tests
                           63.7(b) and 63.697(b)(1)
Performance test results
                          63.8(e)(5) and 63.697(b)(2)
Notification of tank floating roof inspection and seal gap measurements
                                   63.697(c)

      A source must make the following reports:
                    Reports for 40 CFR part 63, subpart DD
Initial performance test results 
                                  63.10(d)(2)
Excess emission reports 
                                  63.10(e)(3)
Initial pressure relief device description
                                 63.697(a)(1)
Malfunction reports (included with semi-annual reports)
                                 63.697(b)(3)
Semi-annual summary report 
                               63.697(b)(4)-(6)

      A source must keep the following records:
                 Recordkeeping for 40 CFR part 63, subpart DD
Reports and notifications
                     63.10(b)(1) and 63.10(b)(2)(vi)-(xi)
Record of applicability
                                  63.10(b)(3)
Records of sources with continuous monitoring systems
                                   63.10(c)
Records of tank floating roof design, inspections, defects and repairs
                                   63.696(d)
Records of tank fixed roof inspections, defects and repairs
                                   63.696(e)
Records of tank enclosure measurements and calculations
                                   63.696(f)

Records of anticipated and completed planned routine maintenance
                                   63.696(g)
Control device malfunction records
                                   63.696(h)
Records of releases from pressure relief devices
                                   63.696(i)
Records of control device bypasses 
                                   63.696(j)
Records should be retained for 5 years.
                                  63.10(b)(1)
	Currently, sources are using monitoring equipment that automatically records parameter data. Although personnel at the source still need to evaluate the data, this type of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. However for this rule, we are only proposing electronic reporting of performance tests. 
      (ii) Respondent Activities
                             Respondent Activities
Read instructions.
Install, calibrate, maintain and operate CMS.
Perform initial performance test and repeat performance tests if necessary. Perform analyses and calculations.
Write the notifications and reports listed above.
Enter information required to be recorded above.
Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information.
Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information.
Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information.
Train personnel to be able to respond to a collection of information.
Adjust existing ways to comply with any previously applicable instructions and requirements.
Transmit, or otherwise disclose the information.

5. The Information Collected: Agency Activities, Collection Methodology, and Information Management
      5(a)  Agency Activities
      The 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, and malfunction reports required to be submitted by industry.
Audit facility records.
Input, analyze and maintain data in the Online Tracking Information System (OTIS).

      5(b)  Collection Methodology and Management
      Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source's initial capability to comply with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
      Information contained in the reports is entered into OTIS which is operated and maintained by EPA's Office of Compliance. OTIS is EPA's database for the collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government-owned facilities. EPA uses the OTIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data.
      The records required by this regulation must be retained by the owner/operator for five years. 
      5(c)  Small Entity Flexibility
--------------------------------------------------------------------------------
      The impact on small entities was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the type of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these requirements the minimum needed to ensure compliance and, therefore, cannot reduce them further for small entities. 
      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 of Reporting and Recordkeeping Requirements for the Proposed NESHAP for OSWRO (40 CFR part 63, subpart DD) (Revised).
6. Estimating the Burden and Cost of the Collection
      Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.
      The Agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number.
      6(a)  Estimating Respondent Burden
      The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 49,118 (Total Labor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously approved ICR, and any comments received.
      6(b)  Estimating Respondent Costs
            (i)  Estimating Labor Costs 
--------------------------------------------------------------------------------
      This ICR uses the following labor rates: 
 				Technical $54.66 ($26.29 + 110%)
                      Managerial $115.96 ($55.81 + 110%)
                  Clerical $38.14 ($18.39 + 110%)
These labor rates are based on the May 2013 National Occupational Employment and Wage Estimates for the United States for Production Occupations (http://www.bls.gov/oes/current/oes_nat.htm#51-0000), occupational codes 51-8091 for chemical plant and system operators (technical), 11-1021 for general and operations managers (managerial) and 43-6010 for secretaries and administrative assistants (clerical).	
		(ii)  Estimating Capital/Startup and Operation and Maintenance Costs
      The type of industry costs associated with the information collection activities in the subject standard are labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one-time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.
      As part of the amendments to the OSWRO NESHAP, facility owners or operators are required to monitor each PRD that is designed to release to the atmosphere using a device or system that is capable of identifying and recording the time and duration of each pressure release and of notifying operators that a release has occurred. For purposes of estimating the costs of this requirement, we assumed that operators would install electronic indicators on each PRD in organic HAP service that vents to the atmosphere. The cost of each monitoring system depends on the number of PRDs at the facilities. For OSWRO facilities, based on information received in the 2013 ICR survey, there is an average of 13 PRDs at each plant. The cost for this system for the 49 affected facilities in the OSWRO source category is expected to be $1.9 million. For equipment leaks, facility owners or operators would also be required to follow the leak detection and repair (LDAR) requirements of 40 CFR part 63, subpart H, including connector monitoring requirements, rather than 40 CFR part 63, subpart V under the amendments to the OSWRO NESHAP. The capital costs associated with this requirement are estimated to be $2.1 million. The rule requires storage vessels of certain sizes and containing materials above certain vapor pressures to use Level 2 controls. Compared to current requirements, the requirements lower the vapor pressure threshold at which control is required for tanks of certain sizes, making additional storage tanks subject to the use of Level 2 controls. In determining the impacts of the requirements, it was assumed that tanks would require ducting to a carbon adsorber as a control device. The capital costs associated with this requirement are estimated to be approximately $139,000.
      Based on a previous ICR for the Pesticide Active Ingredient source category, which estimated the annual O&M costs to be $1,450 per source in 2011 dollars, inflating this number from 2011 dollars to 2013 dollars gives $1,505 per source. The total annual O&M cost for the OSWRO source category is approximately $74,000. For the PRD monitors, annualized costs are calculated by multiplying the capital recovery factor by the capital cost. The capital recovery factor is 0.1424 based on an interest rate of 7 percent and an assumed equipment life of 10 years. For the LDAR requirements, the capital recovery factor is also 0.1424, and for storage tank requirements, the capital recovery factor is 0.1098 based on an interest rate of 7 percent and an assumed equipment life of 15 years. In addition, for the LDAR and storage tank requirements, other annual monitoring and operating costs are included in the annual costs. The annualized costs for the PRD, LDAR and storage vessels requirements is approximately $1.1 million. 
      
      
      
      
      (iii)  Capital/Startup and Operation and Maintenance (O&M) Costs
         Capital/Startup and Operation and Maintenance (O&M) Costs
                                      (A)
                                   Cost Type
                                      (B)
                                   Capital/
                        Startup Cost for One Respondent
                                      (C)
                          Number of New Respondents 
                                      (D)
                                    Total 
                                   Capital/
                                 Startup Cost 
                                   (B X C) 
                                      (E)
                       Annual Costs for One Respondent 
                                      (F)
                            Number of Respondents 
                                      (G)
                               Total Annual Cost
                                    (E X F)
                                    O&M
                                      $0
                                      49
                                      $0
                                    $1,505
                                      49
                                    $73,745
                                     LDAR
                                    $42,626
                                      49
                                  $2,088,689
                                    $13,550
                                      49
                                   $663,955
                           PRD Monitoring Equipment
                                    $38,886
                                      49
                                  $1,905,410
                                    $5,537
                                      49
                                   $271,313
                                Storage Tanks 
                                      [1]
                                   $139,497
                                       -
                                   $139,497
                                   $191,886
                                       -
                                   $191,886
                                     Total
                                       
                                       
                                  $4,133,596
                                       
                                       
                                  $1,200,899
--------------------------------------------------------------------------------
[1]Costs shown are the total costs for the estimated 14 additional tanks captured under the new threshold.
--------------------------------------------------------------------------------
      The total capital/startup costs for this ICR are $4,133,596. This is the total of column D in the above table. The total annual and operation and maintenance (O&M) costs for this ICR are $1,200,899 and is shown in column G.
      6(c)  Estimating Agency Burden and Cost
--------------------------------------------------------------------------------
      The only costs to the Agency are those costs associated with analysis of the reported information. The EPA compliance and enforcement program includes activities such as: the examination of records maintained by the respondents; periodic inspection of sources of emissions; and the publication and distribution of collected information.
--------------------------------------------------------------------------------
      The average annual Agency cost during the three years of the ICR is estimated to be $22,017.
--------------------------------------------------------------------------------
This cost is based on the average hourly labor rate as follows:
--------------------------------------------------------------------------------
		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 
--------------------------------------------------------------------------------
		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)
--------------------------------------------------------------------------------
		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)
--------------------------------------------------------------------------------
      These rates are from the Office of Personnel Management (OPM), 2013 General Schedule, which excludes locality rates of pay (http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2013/general-schedule/2013-gs-hourlyovertime-rates-by-grade-and-step/). The rates have been increased by 60 percent to account for the benefit packages available to government employees. Details upon which this estimate is based appear below in Table 2:  Average Annual EPA Burden for the Proposed NESHAP for OSWRO (40 CFR part 63, subpart DD) (Revised).
--------------------------------------------------------------------------------
      6(d)  Estimating the Respondent Universe and Total Burden and Costs
      The number of major source respondents was updated based on the NEI database, which was used during the analysis to determine the MACT. The EPA also used available permit data and information collected in the 2013 OSWRO ICR survey. The number of respondents is calculated using the following table which addresses the 3 years covered by this ICR. Over the three year period of this ICR, we expect 49 existing facilities to be respondents. 
      The total number of annual responses per year is calculated using the following table:
                                     YEAR
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                       
                           Number of New Respondents
                          Number Existing Respondents
  Number of Existing Respondents That Keep Records But Do Not Submit Reports
         Number of Existing Respondents That Are Also New Respondents
                       Number of Respondents (E=A+B+C-D)
                                       1
                                       0
                                      49
                                       0
                                       0
                                      49
                                       2
                                       0
                                      49
                                       0
                                       0
                                      49
                                       3
                                       0
                                      49
                                       0
                                       0
                                      49
                                    Average
                                       0
                                      49
                                       0
                                       0
                                      49

To avoid double-counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three-year period of this ICR is 49. 
      The total number of annual responses per year is calculated using the following table:
--------------------------------------------------------------------------------
Total Annual Responses
--------------------------------------------------------------------------------
(A)
--------------------------------------------------------------------------------
Information Collection Activity
--------------------------------------------------------------------------------
(B)
--------------------------------------------------------------------------------
Number of Respondents
--------------------------------------------------------------------------------
(C)
--------------------------------------------------------------------------------
Number of Responses
--------------------------------------------------------------------------------
(D)
--------------------------------------------------------------------------------
Number of Existing Respondents That Keep Records But Do Not Submit Reports
--------------------------------------------------------------------------------
(E)
--------------------------------------------------------------------------------
Total Annual Responses
--------------------------------------------------------------------------------
E=(BxC)
--------------------------------------------------------------------------------
Initial notification (PRD)
--------------------------------------------------------------------------------
49
--------------------------------------------------------------------------------
0.33
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
16
--------------------------------------------------------------------------------
Semiannual periodic report
--------------------------------------------------------------------------------
49
--------------------------------------------------------------------------------
2
--------------------------------------------------------------------------------
0
--------------------------------------------------------------------------------
98
--------------------------------------------------------------------------------
Total Number of Annual Responses
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------

--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
114
      
      The number of Total Annual Responses is 114. 
      6(e)  Bottom Line Burden Hours Burden Hours and Cost Tables
--------------------------------------------------------------------------------
      The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectively, and summarized below. 
--------------------------------------------------------------------------------
            (i)  Respondent Tally
      The average annual respondent burden and cost over next three years is estimated to be 49,118 labor hours at a cost of $2,745,132. See below Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements for the Proposed NESHAP for OSWRO (40 CF93R Part 63, Subpart DD) (Revised). 
       	(ii)  The Agency Tally
      The average annual Agency burden and cost over next three years is estimated to be 489 labor hours at a cost of $22,017. See below Table 2:  Average Annual EPA Burden for the Proposed NESHAP for OSWRO (40 CFR part 63, subpart DD) (Revised).
      6(f)  Reasons for Change in Burden
      The rulemaking amends title 40, chapter I, part 63 subpart DD to include revisions to the storage tank requirements, revisions to the LDAR requirements and requirements to monitor PRDs. The number of affected facilities under this subpart is not expected to increase. At this time, none of the amendments will affect area sources. The overall change in burden found in this ICR reflect the provision changes, an update in the cost of labor, an update to the number of affected facilities and corrections to errors found in EPA ICR number 1717.09. 
	6(g)  Burden Statement
      The annual public reporting and recordkeeping burden for this collection of information is estimated to average 431 hours per response. Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; to 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; to adjust the existing ways to comply with any previously applicable instructions and requirements; to train personnel to be able to respond to a collection of information; to search data sources; to complete and  review the collection of information; and  to transmit or otherwise disclose the information.
--------------------------------------------------------------------------------
      An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA's regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.
      
Part B of the Supporting Statement
      This part is not applicable because no statistical methods were used in collecting this information.

Table 1: Annual Respondent Burden and Cost of Reporting and Recordkeeping Requirements for the 
       Proposed NESHAP for OSWRO (40 CFR part 63, subpart DD) (Revised)
                                       
                                  Burden Item
                        Person-hours per occurrence (A)
                  No. of occurrences per source per year (B)
                   Person-hours per source per year (C=AxB)
                           Respondents per year (D)
                   Technical person- hours per year (E=CxD)
                   Management person-hours per year (Ex0.05)
                    Clerical person-hours per year (Ex0.1)
                                    Cost,$



























1. Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
2. Survey and Studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
3. Reporting Requirements
                                       
    A. Read instructions 
                                       4
                                       1
                                       4
                                      49
                                      196
                                      9.8
                                     19.6
                                                                       $12,597 
    B. Required activities
Included in 4C
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    C. Create information
Included in 4C
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    D. Gather existing information
Included in 4C
                                       
                                       
                                       
                                       
                                       
                                       
                                       
    E. Write report
                                       
         Initial notification report (d)
                                       1
                                     0.33
                                     0.33
                                      49
                                     16.17
                                    0.8085
                                     1.617
                                                                        $1,039 
         Semiannual summary report
                                       8
                                       2
                                      16
                                      49
                                      784
                                     39.2
                                     78.4
                                                                       $50,389 
REPORTING SUBTOTAL (Rounded)
                                       
                                     1,146
                                                                       $64,026 
4.  Recordkeeping Requirements
                                       
    A. Read instructions
                                       8
                                       1
                                       8
                                      49
                                      392
                                     19.6
                                     39.2
                                                                       $25,195 
    B.  Plan activities
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
    C.  Implementation activities
                                       
       a.  VOHAP concentration determination
                                       
           Commercial facilities (e)
                                       2
                                      260
                                      520
                                      25
                                    13,000
                                      650
                                     1,300
                                                                      $835,536 
           Other facilities (f)
                                       2
                                      12
                                      24
                                      25
                                      600
                                      30
                                      60
                                                                       $38,563 
      b.  Vapor pressure determination
                                       
            Commercial facilities (e)
                                       1
                                      260
                                      260
                                      25
                                     6,500
                                      325
                                      650
                                                                      $417,768 
            Other facilities (f)
                                       1
                                      12
                                      12
                                      25
                                      300
                                      15
                                      30
                                                                       $19,282 
        c.  Control equipment visual inspection
                                       
             Large cover
                                     0.25
                                      10
                                      2.5
                                      49
                                      123
                                       6
                                      12
                                                                        $7,873 
             Small cover
                                     0.05
                                     1000
                                      50
                                      49
                                     2,450
                                      123
                                      245
                                                                      $157,466 
             Closed vent system
                                      0.5
                                       5
                                      2.5
                                      49
                                      123
                                       6
                                      12
                                                                        $7,873 
       d.  Control equipment leak monitoring
                                       
            Cover vented to control device
                                       1
                                       5
                                       5
                                      49
                                      245
                                      12
                                      25
                                                                       $15,747 
            Closed vent system
                                       1
                                       5
                                       5
                                      49
                                      245
                                      12
                                      25
                                                                       $15,747 
       e.  Control devices
                                       
            Performance determination
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
            Continuous monitoring system
                                       8
                                       5
                                      40
                                      49
                                     1,960
                                      98
                                      196
                                                                      $125,973 
       f.  LDAR program
                                       
          Identify affected waste streams
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
            Perform monitoring/repair
                                      80
                                       1
                                      80
                                      49
                                     3,920
                                      196
                                      392
                                                                      $251,946 
       g.  PRD monitoring
 
 
                                       
                                       
                                       
 
 
 
            Identification of PRD devices
                                       8
                                       1
                                       8
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
            Perform monitoring/repair
                                      16
                                       1
                                      16
                                      49
                                      784
                                      39
                                      78
                                                                       $50,389 
   D. Develop record system
                                       
        Control equipment
                                      16
                                       1
                                      16
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
        LDAR program
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
        PRD program
                                       8
                                       1
                                       8
                                      49
                                      392
                                      20
                                      39
                                                                       $25,195 
   E. Time to enter information
                                       
        Cover designs
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
        Control device design
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
        Control equipment testing
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
        Control equipment inspections
                                       1
                                       1
                                       1
                                      49
                                      49
                                       2
                                       5
                                                                        $3,149 
        Control equipment monitoring
                                       1
                                       1
                                       1
                                      49
                                      49
                                       2
                                       5
                                                                        $3,149 
        Control device CMS
                                       1
                                      52
                                      52
                                      49
                                     2,548
                                      127
                                      255
                                                                      $163,765 
        LDAR program
                                       4
                                      16
                                      64
                                      49
                                     3,136
                                      157
                                      314
                                                                      $201,557 
        PRD program
                                       2
                                      16
                                      32
                                      49
                                     1,568
                                      78
                                      157
                                                                      $100,778 
        Off-site material determinations
                                       1
                                      52
                                      52
                                      49
                                     2,548
                                      127
                                      255
                                                                      $163,765 
    F. Time to train personnel 
                                       
         Waste determination methods
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
         Control equipment inspect and monitor
                                      40
                                       1
                                      40
                                       0
                                       0
                                       0
                                       0
                                                                            $0 
         LDAR program
                                       8
                                       1
                                       8
                                      49
                                      392
                                      20
                                      39
                                                                       $25,195 
         PRD program
                                       8
                                       1
                                       8
                                      49
                                      392
                                      20
                                      39
                                                                       $25,195 
    G. Time for audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                       
RECORDKEEPING SUBTOTAL (Rounded)
                                       
                                    47,972
                                  $2,681,106 
TOTAL LABOR BURDEN AND COST (Rounded)
 
 
                                       
                                       
                                    49,118
                                  $2,745,132 

Table 2:  Average Annual EPA Burden for the Proposed NESHAP for OSWRO (40 CFR part 63, subpart DD) (Revised)




                                  Burden Item
                                      (A)
                                      (B)
                                      (C)
                                      (D)
                                      (E)
                                      (F)
                                      (G)
                                      (H)

                        EPA person-hours per occurrence
                     No. of occurrences per plant per year
                  EPA person-hours per plant per year (C=AxB)
                                Plants per year
                    Technical person-hours per year (E=CxD)
                   Management person-hours per year (Ex0.05)
                    Clerical person-hours per year (Ex0.1)
                                    Cost,$ 




































REPORT REVIEW
 
 
 
 
 
 
 
 
     New Plants
 
 
 
 
 
 
 
 
            Initial notification (PRD) (a)
                                       2
                                     0.33
                                     0.67
                                      49
                                      33
                                       2
                                       3
                                    $1,701 
            Performance test notification
                                       1
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      $0 
            Compliance status notification
                                       4
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      $0 
            Performance test report
                                      16
                                       0
                                       0
                                       0
                                       0
                                       0
                                       0
                                      $0 
     Existing Plants
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
            Semiannual summary report
                                       4
                                       2
                                       8
                                      49
                                      392
                                      20
                                      39
                                   $20,315 
TOTAL ANNUAL EPA BURDEN AND COST (Rounded)
                                       
                                       
                                       
                                       
                                      489
                                   $22,017 
(a) Assumes 1 PRD initial notification in the 3 years.


