SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Off­
Site
Waste
and
Recovery
Operations
(
40
CFR
part
63,
subpart
DD)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Off­
Site
Waste
and
Recovery
Operations
1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP),
were
proposed
on
October
13,
1994
and
promulgated
on
July
1,
1996.
These
standards
provide
for
control
of
hazardous
air
pollutants
(
HAPs)
emissions
from
selected
facilities
involved
in
waste
management
and
recovery
operations
that
are
not
subject
to
federal
air
standards
under
other
subparts
in
part
63
commencing
construction,
modification
or
reconstruction
after
the
date
of
proposal
if
the
facility
is
a
"
major
source"
of
HAP
emissions
as
defined
in
general
provisions
to
40
CFR
part
63.
In
addition,
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
and
organic
water
separators,
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.

Owners
or
operators
of
the
affected
facilities
described
must
make
one­
time­
only
notifications.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
Semiannual
reports
of
excess
emissions
(
or
reports
certifying
that
no
exceedances
have
occurred)
are
required.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
are
required,
in
general,
of
all
sources
subject
to
NESHAP.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.

There
is
an
annual
average
of
236
respondents
that
will
be
subject
to
the
regulations.
Due
to
the
nature
of
the
industry,
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
over
the
next
three
years.
This
information
is
based
on
discussions
with
EPA
personnel
knowledgeable
about
the
off­
site
waste
and
recovery
operations.
The
average
annual
cost
to
industry
over
the
next
three
years
of
this
Information
Collection
Request
(
ICR)
is
estimated
to
be
$
9,923,473.
2
In
the
development
of
this
Information
Collection
Request
(
ICR),
we
addressed
the
Office
of
Management
and
Budget
(
OMB)
"
Terms
of
Clearance"
(
TOC)
on
the
active
ICR.
The
TOC
are
as
follows:

This
collection
is
approved
for
three
years.
Before
the
ICR
is
next
submitted
to
OMB
for
revision
or
renewal,
EPA
should
review
its
assumption
that
no
new
sources
will
be
added
in
this
source
category.
EPA
should
also
calculate
the
cost
burden
associated
with
recordkeeping
and
reporting
activities,
including
for
example
any
costs
associated
with
mailing,
etc.
OMB
notes
that
because
EPA
has
not
included
any
burden
estimates
for
new
sources
in
its
request,
this
approval
does
not
extend
to
collection
of
information
from
new
sources.

EPA
has
addressed
each
item
of
concern
in
the
TOC
as
instructed
by
OMB
in
the
active
ICR.
Although
EPA
does
not
anticipate
any
new
sources
over
the
next
three
years,
if
a
new
source
is
constructed,
we
believe
that
the
collection
of
information
would
not
be
a
violation
of
the
Paper
Reduction
Act
(
PRA),
since
this
is
our
best
burden
estimate
associated
with
the
rule.
The
cost
burden
associated
with
photocopying
and
mailing
reports
has
been
addressed
as
part
of
the
operation
and
maintenance
cost
for
this
ICR
[
refer
to
section
6(
b)(
ii)].

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner
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.
3
In
the
Administrator's
judgment,
organic
HAP
emissions
from
off­
site
waste
and
recovery
operation
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
DD.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
organic
HAP
from
off­
site
waste
and
recovery
operations
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
organic
HAP
from
off­
site
waste
and
recovery
operations
are
the
result
of
operation
of
the
affected
facilities.
The
subject
standards
are
achieved
by
the
reduction
of
organic
HAP
emissions
using
control
technology
and/
or
leak
detection
and
repair
procedures.
The
notifications
required
in
the
applicable
regulations
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
requirements
of
the
regulations.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated
and/
or
leaks
are
being
detected
and
repaired
and
the
regulations
are
being
met.

Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standards,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
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
continue
to
operate
the
control
equipment
in
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
the
applicable
regulations,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
(
40
CFR
part
63,
subpart
DD).

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
state
or
local
agency.
If
a
state
or
local
agency
has
adopted
their
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.
4
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
68
FR
27059
on
May
19,
2003.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
For
this
information
collection,
we
referenced
the
most
recent
ICR,
the
preparer
of
the
active
ICR,
and
accessed
the
most
recent
data
available
on
the
Air
Facility
System
(
AFS)
database
as
maintained
by
the
Office
of
Compliance.
We
reviewed
information
available
from
the
Office
of
Compliance
Sector
Notebook
"
Profile
of
the
Inorganic
Chemical
Industry,"
the
United
States
Census
Bureau
via
the
internet,
and
other
websites
covering
off­
site
waste
and
recovery
operations.
We
consulted
with
EPA's
Office
of
Air
Quality
Planning
and
Standards,
Information
Transfer
and
Program
Integration
Division
and
the
Solid
Waste
Association
of
North
America,
Mr.
Steve
Ritzon,
(
800)
467­
9262,
and
Chartwell
Information,
Mr.
Grant
Ferrier,
(
619)
295­
7685.

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
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
Part
1320,
Section
1320.5.

These
standards
require
affected
facilities
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.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.
5
3(
f)
Confidentiality
Any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
CBI)
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,
September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
and
NAICS
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
off­
site
waste
and
recovery
operations
that
store,
treat,
recycle,
reprocess,
or
dispose
of
wastes
containing
organic
chemical
compounds.
The
United
States
Standard
Industrial
Classification
(
SIC)
codes
which
corresponds
to
the
North
American
Industry
Classification
System
(
NAICS)
codes
could
be
found
in
the
following
table:

Standard
SIC
Codes
NAICS
Codes
Off­
site
Waste
and
Recovery
Operations
(
40
CFR
part
63,
subpart
DD)

Petrochemical
Manufacturing
2869
325110
All
Other
Basic
Inorganic
Chemical
Manufacturing
2869
325188
Cyclic
Crude
and
Intermediate
Manufacturing
2689
325192
Ethyl
Alcohol
Manufacturing
2689
325193
All
Other
Basic
Organic
Chemical
Manufacturing
2689
325199
Industrial
Gas
Manufacturing
2689
325120
All
Other
Miscellaneous
Chemical
Product
and
Preparation
Manufacturing
2689
325998
6
Plastic
Materials
and
Resin
Manufacturing
2821
325211
Explosives
Manufacturing
2892
325920
Carbon
Black
Manufacturing
2816
325182
Inorganic
Dye
and
Pigment
Manufacturing
2816
325131
Semiconductor
and
Related
Device
Manufacturing
3674
334413
Petroleum
Refineries
2911
324110
Aircraft
Manufacturing
3721
336411
Aircraft
(
research
and
development
not
producing
prototypes)
3721
541710
Other
General
Government
Support
9199
921190
All
Other
Petroleum
and
Coal
Products
Manufacturing
3312
324199
Iron
and
Steel
Mills
3312
331111
Rolled
Steel
Shape
Manufacturing
3312
331221
4(
b)
Information
Requested
None
of
these
reporting
or
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
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Off­
Site
Waste
and
Recovery
Operations
(
40
CFR
part
63,
subpart
DD).
7
A
source
must
make
the
following
reports:

Notification
Reports
Standard
Citation
by
Section
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)

Physical
and
operational
change
63.10
Notification
of
performance
tests
63.7(
b),
and
63.697(
b)(
1)

Performance
test
results
63.8(
e)(
5),
and
63.697(
b)(
2)

Startup,
shutdown,
malfunction
reports
63.697(
b)(
3)

Notification
of
tank
floating
roof
inspection
63.686(
b)(
3)

Notification
of
oil/
water
separator
floating
roof
inspection
63.687(
d)(
6)

Notification
to
tank
refill
63.697(
d)(
1)

Notification
of
seal
gap
measurements
63.697(
d)(
2)

Reports
Initial
performance
test
results
63.10(
d)(
2)

Opacity
or
visible
emissions
63.10(
d)(
3)

Periodic
startup,
shutdown,
malfunction
reports
63.10(
d)(
5)(
I)

Source
status
report
63.10(
e)(
3)

Excess
emission
reports
63.695(
e)

Semiannual
summary
report
63.697(
b)(
4)
8
A
source
must
keep
the
following
records:

Recordkeeping
Startup,
shutdown,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative.
63.10(
b)(
2)

All
reports
and
notifications.
63.10(
b)

Record
of
applicability.
63.10(
b)(
3)

Records
of
sources
with
continuous
monitoring
systems.
63.10(
c)

Records
of
startup,
shutdown,
and
malfunctions,
and
pollution
control
system
maintenance.
63.696(
b)(
1)

Records
of
applicability
determinations.
63.696(
b)(
3)

Documentation
of
extension
of
tank
emptying
schedule.
63.696(
c)

Records
of
results
of
seal
gap
measurements
and
description
of
repairs.
63.686(
d)(
3)

Record
of
sampling
plan
for
determining
volatile
organic
hazardous
air
pollutant
(
VOHAP)
concentration
at
point
of
treatment
63.694(
c)

Record
of
sampling
plan
for
determining
maximum
HAP
vapor
pressure
in
tanks.
63.694(
j)(
2)(
1)

Record
of
maximum
HAP
vapor
pressure
determinations
for
covered
tanks.
63.686(
c)(
5)

Records
should
be
retained
for
5
years.
63.10(
b)(
1)

Electronic
Reporting
Presently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.,
leaks
and
spills
of
mercury.
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.
In
addition,
some
regulatory
agencies
are
setting
up
electronic
reporting
systems
to
allow
sources
to
report
electronically
which
is
reducing
the
reporting
burden.
However,
electronic
reporting
systems
are
still
not
widely
used
by
the
regulatory
agencies.
It
is
estimated
that
approximately
33%
of
the
respondents
use
electronic
reporting.
9
(
ii)
Respondent
Activities
Respondent
Activities
Determine
the
VOHAP
concentration
for
off­
site
material
at
the
point­
of­
delivery
and
for
the
treated
off­
site
material
streams
at
the
point­
of­
treatment.

Determine
the
required
HAP
mass
removal
rate,
actual
HAP
mass
removal,
HAP
reduction
efficiency
and
HAP
bio­
degradation
efficiency.

Determine
the
maximum
organic
HAP
vapor
pressure
of
the
off­
site
material
in
tanks
and
the
process
vent
stream
flow
rate
and
total
HAP
concentration.

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.

Adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

Currently,
sources
are
using
monitoring
equipment
that
provides
parameter
data
in
an
automated
way,
e.
g.
HAP
vapor
pressure.
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
recorkeeping.

5.
The
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.
10
Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

Review
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry.

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operational.
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
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
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
or
operator
for
five
years.

5(
c)
Small
Entity
Flexibility
A
majority
of
the
affected
facilities
are
large
entities
(
e.
g.,
large
businesses).
However,
the
impact
on
small
entities
(
i.
e.,
small
businesses)
was
taken
into
consideration
during
the
development
of
the
regulation.
Due
to
technical
considerations
involving
the
process
operations
and
the
types
of
control
equipment
employed
,
the
recordkeeping
and
reporting
requirements
are
the
same
for
both
small
and
large
entities.
The
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
entities.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
11
5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Industry
Burden
for
NESHAP
for
Off­
Site
Waste
and
Recovery
Operations.

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.
Where
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
154,306
(
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:
$
93.09
per
hour
for
Executive,
Administrative,
and
Managerial
labor;
$
64.13
per
hour
for
Technical
labor,
and
$
39.65
per
hour
for
Clerical
labor.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Managerial
$
93.09
($
44.33
+
110%)
Technical
$
64.13
($
30.54
+
110%)
Clerical
$
39.65
($
18.88
+
110%)]

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
capital/
start
up
costs
are
one­
time
cost
when
a
facility
becomes
subject
to
the
standard.
Since
this
is
based
on
no
new
sources
over
the
next
three
years,
capital
costs
associated
12
with
this
ICR
during
this
period
will
be
zero.
In
addition,
there
is
no
significant
operation
and
maintenance
costs
associated
with
this
ICR
since
sources
are
not
required
to
installed
continuous
monitoring
systems.
The
only
operational
cost
that
sources
will
incur
is
associated
with
photocopying
and
postage
which
would
be
minimal
based
on
a
rate
of
$
7.57
per
response.
There
are
approximately
708
responses
per
year
(
708
responses
x
$
7.57=
$
5,359.56),
for
a
total
annual
cost
(
O&
M)
of
$
5,360.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
5,360.
These
costs
are
shown
in
block
14(
b),
Total
annual
costs
(
O&
M),
on
the
OMB
83­
I
form.

The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs,
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
for
the
next
three
years
of
the
ICR
are
estimated
to
be
$
5,360.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
costs
to
the
Agency
are
those
costs
associated
with
analysis
of
the
reported
information.
EPA's
overall
compliance
and
enforcement
program
includes
activities
such
as
the
examination
of
records
maintained
by
the
respondents,
periodic
inspection
of
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
93,196.
This
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
39.49.
This
rate
is
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
NESHAP
for
Off­
Site
Waste
and
Recovery
Operations
(
40
CFR
part
63,
subpart
DD).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
our
research
for
this
ICR,
approximately
236
existing
sources
are
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.

Number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.
13
Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Year
(
A)
Number
of
New
Respondents
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
that
keep
records
but
do
not
submit
reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
CD

1
0
236
0
0
236
2
0
236
0
0
236
3
0
236
0
0
236
Average
0
236
0
0
236
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
236.
This
number
appears
on
the
OMB
83­
I
form
in
block
13(
a),
Number
of
respondents.

The
total
number
of
annual
responses
per
year
is
calculated
using
the
following
table:

Total
Annual
Responses
(
A)
Number
of
New
Respondents
(
B)
Number
of
Reports
for
New
Respondents
(
C)
Number
of
Existing
Respondents
(
D)
Number
of
Reports
for
Existing
Respondents
(
F)
Number
of
Existing
Respondents
that
keep
records
but
do
not
submit
reports
(
E)
Total
Annual
Responses
E=(
AxB)+(
CxD)+
F
0
0
236
3
0
708
The
number
of
Total
Annual
Responses
is
708.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
9,923,473.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Off­
Site
Waste
and
Recovery
Operations
(
40
CFR
part
63,
subpart
DD).

Note
that
the
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
is
$
5,360.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
These
costs
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
14
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
And
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
Agency
and
the
respondents
are
attached.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
218
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
adjustment
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
a
decrease
in
the
number
of
sources.
The
disposal
prices
for
the
waste
and
recovery
industry
dropped
to
about
50%
over
the
last
ten
years,
making
it
difficult
for
companies
to
breakeven
and
stay
in­
business.
The
industry
is
going
through
an
adjustment
period,
but
this
will
take
many
years
before
the
industry
can
return
to
profitability.
As
a
result,
a
number
of
plants
are
being
forced
to
close
their
operations.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
218
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA­
2003­
0031,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
N.
W.,
Washington,
D.
C.
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
Enforcement
and
Compliance
Docket
and
Information
Center
is
(
202)
566­
1752.
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
15
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,
N.
W.,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2003­
0031
and
OMB
Control
Number
2060­
0313
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
16
TABLE
1:
Annual
Industry
Burden
­
NESHAP
for
Off­
Site
Waste
Recovery
Operations
(
40
CFR
part
63,
subpart
DD)
(
Renewal)

Burden
Item
(
A)
Hours
per
Occurrence
(
B)
Occurrences/

Respondent/

year
(
C)
Hours/
Respondent/

year
(
AxB)
(
D)
Respondents
per
year
(
E)
Hours
per
year
(
CxD)
(
F)

Cost/
year
(
E
x
$
64.13)
a
1.
APPLICATIONS
Not
Applicable
2.
SURVEY
AND
STUDIES
Not
Applicable
3.
ACQUISITION,
INSTALLATION
AND
b
USE
OF
TECHNOLOGY
&
SYSTEMS
80
1
80
0
0
$
0
4.
REPORTING
REQUIREMENTS
New
Sources
A.
Read
instructions
b&
c
4
1
40
0
0
$
0
B.
Required
Activities
Included
in
5
C.
Create
information
Included
in
5
$
0
D.
Gather
existing
information
b&
d
8
1
8
0
0
$
0
E.
Write
reports
Initial
notification
report
b&
e
1
1
1
0
0
$
0
Performance
test
notification
b&
e
1
1
1
0
0
$
0
Compliance
status
notification
b&
e
2
1
2
0
0
$
0
Performance
test
reports
b&
e
8
1
8
0
0
$
0
Startup/
shutdown/
malfunction
reports
2
1
2
236
472
$
30,269
Semiannual
summary
report
f
4
2
8
236
1,888
$
121,077
5.
RECORDKEEPING
REQUIREMENTS
A.
Read
instructions
b
8
1
8
0
0
$
0
17
B.
Plan
activities
b
40
1
40
0
0
$
0
C.
Implementation
activities
a.
VOHAP
Concentration
Determination
Commercial
facilities
g
Other
facilities
h
22
260
12
520
24
118
118
61,360
2,832
$
3,935,016
$
181,616
b.
Vapor
pressure
determination
Commercial
facilities
g
Other
facilities
h
11
260
12
260
12
118
118
30,680
1,416
$
1,967,508
$
90,808
c.
Control
equipment
visual
inspection
Large
cover
Small
cover
Closed­
vent
system
15
min
3
min
30
min
10
1,000
5
2.5
50
2.5
236
236
236
590
11,800
590
$
37,837
$
756,734
$
37,837
d.
Control
equipment
leak
monitoring
Cover
vented
to
control
device
Closed­
vent
system
11
5
5
5
5
236
236
1,180
1,180
$
75,673
$
75,673
e.
Control
devices
Performance
determination
b
Continuous
monitoring
system
40
8
1
5
40
40
0
236
0
9,440
$
0
$
605,387
f.
LDAR
program
Identify
affected
waste
streams
b
Perform
monitoring/
repair
i
40
80
1
1
40
80
0
47
0
3,760
$
0
$
241,129
D.
Develop
record
system
b
Control
equipment
LDAR
program
16
40
1
1
16
40
0
0
0
0
$
0
$
0
E.
Time
to
enter
information
Cover
designs
b
Control
device
design
b
Control
equipment
testing
b
Control
equipment
inspections
Control
equipment
monitoring
Control
device
CMS
LDAR
program
Off­
Site
material
determinations
40
40
1
1
1
1
4
1
1
1
1
1
1
52
16
52
40
40
1
1
1
52
64
52
0
0
0
236
236
236
47
236
0
0
0
236
236
12,272
3,008
12,272
$
0
$
0
$
0
$
15,135
$
15,135
$
787,003
$
192,903
$
787,003
F.
Time
to
train
personnel
b
Waste
determination
methods
Control
equipment
inspect
&
monitor
LDAR
program
40
40
40
111
40
40
40
000
0
0
0
$
0
$
0
$
0
18
G.
Time
for
audit
Not
Applicable
TOTAL
ANNUAL
BURDEN
(
rounded)
154,306
$
9,923,473
Assumptions:

a.
Assume
a
technical
labor
rate
of
$
64.13
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2003,
Table
2:
Employment
Costs
of
Civilian
Workers
by
Occupational
and
Industry
Group.
The
rates
are
from
column
1:
Total
compensation.
The
wage
rate
obtained
from
the
table
has
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

b.
This
activity
is
performed
once
during
the
year
following
promulgation
of
the
rule.

c.
It
is
assumed
that
it
will
take
4
hours
to
read
instructions.

d.
Assume
that
it
will
take
eight
hours
to
gather
existing
information.

e.
Assume
that
there
will
be
no
new
sources.

f.
The
burden
of
one
an
annual
summary
report
was
included
in
the
burden
estimate
for
the
semiannual
report.

g.
It
is
assumed
that
at
50%
of
the
facilities
the
owner
or
operator
manages
for
a
fee
off­
site
materials
received
from
other
generators.

h.
It
is
assumed
that
50%
of
the
owner
or
operator
accepts
the
off­
site
material
at
another
location
and
ships
it
to
the
facility
for
storage,
treatment,
or
disposal.

i.
Assume
that
20%
of
236
facilities
will
perform
monitoring/
repair.
19
Table
2:
AVERAGE
Annual
EPA
Burden
­
NESHAP
for
Off­
Site
Waste
Recovery
Operations
(
40
CFR
part
63,
subpart
DD)
(
Renewal)

Burden
Item
(
A)

EPA
hrs/
Occurrence
(
B)
Occurrences
plant/
year
(
C)

EPA
hrs/

plant/
year
(
AxB)
(
D)

Labor
Cost
per/
year
(
Cx
$
39.49)
a
(
E)
Annual
EPA
Direct
($/
yr)
(
F)

EPA
Cost
($/
Yr)

(
D+
E)

1.
REPORT
REVIEW
New
Plants
b
Initial
Notification
2
1
2
$
0
$
0
$
0
Performance
Test
Notification
1
1
1
$
0
$
0
$
0
Compliance
Status
Notification
4
1
4
$
0
$
0
$
0
Performance
Test
Report
c
16
1
16
$
0
$
0
$
0
Existing
Plants
Startup/
Shutdown
Report
d
2
236
472
$
18,639
$
0
$
18,639
Semiannual
Summary
Report
e
4
472
1,888
$
74,557
$
0
$
74,557
Travel
expenses
f
(
1
person
x
0
plant/
year
x
3
days/
plant
x
75
per
diem)+

($
350
round
trip/
plant
x
o
plant/
year)
$
0
$
0
$
0
TOTAL
ANNUAL
EPA
BURDEN
(
rounded)
2,360
$
93,196
$
0
$
93,196
Assumptions:

a.
The
cost
is
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
39.49.
This
rate
is
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.

b.
Assume
that
there
will
be
no
new
sources
(
respondents)
over
the
3
years
period
of
this
Information
Collection
Request
(
ICR).

c.
Assumes
that
it
would
take
16
hrs
to
review
performance
test
report.

d.
Estimated
number
of
facilities
subject
to
the
rule
is
236.

e.
Assumes
that
here
will
be
two
reports
submitted
by
each
of
the
236
facilities
on
an
annual
basis.

f.
There
will
be
no
travel
expenses
associated
with
this
ICR
since
we
have
assumed
that
no
new
sources
will
become
subject
to
this
rule
over
the
three
year
period
of
this
ICR.
