1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARD
OF
PERFORMANCE
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
FOR
VINYL
CHLORIDE
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP
Subpart
F­
Vinyl
Chloride
1(
b)
Short
Characterization/
Abstract
The
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Vinyl
Chloride
(
VC)
were
proposed
on
December
24,
1975,
promulgated
on
October,
21,
1976,
and
amended
on
June
7,
1977,
September
30,
1986,
September
23,
1988
and
December
23,
1992.
These
standards
apply
to
exhaust
gases
and
oxychlorination
vents
at
ethylene
dichloride
(
EDC)
plants;
exhaust
gases
at
vinyl
chloride
monomer
(
VCM)
plants;
and
exhaust
gases,
reactors
opening
losses,
manual
vent
valves,
and
stripping
residuals
at
polyvinyl
chloride
(
PVC)
plants.
The
standards
also
apply
to
relief
valves
and
fugitive
emission
sources
at
all
three
types
of
plants.
In
the
Administrator's
judgement,
vinyl
chloride
emissions
from
polyvinyl
chloride
(
PVC),
ethylene
dichloride
(
EDC),
and
vinyl
chloride
monomer
(
VCM)
plants
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
result
in
an
increase
in
mortality
or
an
increase
in
serious
irreversible,
or
incapaciting
reversible
illness.
Vinyl
chloride
is
a
known
human
carcinogen
which
causes
a
rare
cancer
of
the
liver.

Establishment
of
a
continuous
monitoring
program
is
a
high
priority
of
the
Agency.
The
standards
require
continuous
monitoring
of
the
reactor
pressure
and
temperature.
The
continuous
monitoring
system
monitors
VC
emissions
from
the
stack
to
judge
compliance
with
the
numerical
limits
in
the
standards.
The
parameters
are
used
to
judge
the
operation
of
the
reactor
so
that
the
source
and
EPA
will
be
aware
of
improper
operation
and
maintenance.

Adequate
recordkeeping
and
reporting
ensures
that
affected
facilities
continue
to
operate
control
equipment
and
use
proper
work
practices
to
achieve
compliance.
In
addition,
reporting
assists
EPA
in
identifying
new
facilities
subject
to
the
standards.
The
standards
implicitly
require
initial
reports
required
by
the
General
Provisions
of
40
CFR
§
61.7
and
§
61.9.
These
initial
reports
include
application
for
approval
of
construction
or
modification,
the
notification
of
startup,
and
the
notification
of
performance
testing.
The
standards
also
require
quarterly
reporting
of
vinyl
chloride
emissions
from
stripping,
reactor
openings,
and
exhausts.
Reports
must
be
submitted
within
10
days
of
each
valve
discharge
and
manual
vent
valve
discharge.
All
reports
are
sent
to
the
delegated
State
authority.
In
the
event
that
there
is
no
such
delegated
State
2
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.
Facilities
must
also
maintain
records
of
reactor
parameters
and
emissions
as
well
as
records
related
to
malfunctions,
calibrations,
and
leaks
detected.

Approximately
44
sources
are
currently
subject
to
the
standard,
and
it
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.

Following
approval
of
the
previous
ICR,
OMB
requested
that
EPA
undertake
a
review
of
the
need
for
continuous
area
monitoring­
and
of
whether
there
may
be
other
less
burdensome
approaches
that
would
provide
the
public
with
equal
or
greater
protection
in
the
event
of
major
chemical
releases.
EPA
considered
OMB's
comment
and
upon
review
of
alternative
monitoring
approaches
has
concluded
that
emissions
of
vinyl
chloride,
a
hazardous
air
pollutant,
should
be
continuously
monitored
to
ensure
adequate
protection
of
public
health.
EPA
considers
the
existing
monitoring
requirements
to
be
the
least
burdensome
on
the
regulated
entities.

2.
Need
for
and
Use
of
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
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
audit
procedures,
or
methods;
and
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
Keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require."

In
the
Administrator's
judgement,
vinyl
chloride
emissions
from
the
National
Emission
Standard
for
Vinyl
Chloride
can
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
National
Emission
Standards
for
Hazardous
Air
Pollutants
were
promulgated
for
this
source
category
at
40
CFR
Part
61,
Subpart
F.

2(
b)
Practical
Utility/
Users
of
the
Data
The
control
of
emissions
of
vinyl
chloride
from
plants
which
produce:
1)
ethylene
3
dichloride
by
reaction
of
oxygen
and
hydrogen
chloride
with
ethylene,
2)
vinyl
chloride
by
any
process
and/
or
3)
one
or
more
polymers
containing
any
fraction
of
polymerized
vinyl
chloride
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
vinyl
chloride
from
these
plants
result
from
the
operation
of
the
affected
facilities.
These
standards
rely
on
the
reduction
of
vinyl
chloride
emissions
by
monitoring
on
a
continuous
basis
the
emissions
from
the
sources
for
which
emissions
limits
are
prescribed
in
§
§
61.62(
a)
and
(
b),
61.63
(
a),
and
61.64(
a)(
1),
(
b),
(
c),
and
(
d),
and
for
any
control
system
to
which
reactor
emissions
are
required
to
be
ducted
in
§
61.64(
a)(
2)
or
to
which
fugitive
emissions
are
required
to
be
ducted
in
§
61.65(
b)(
1)(
ii),
and
(
b)(
2),
(
b)(
5),
(
b)(
6)
(
ii)
and
(
b)(
9)(
ii).
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
standard
is
being
met.
The
information
generated
by
the
monitoring,
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
continue
to
operate
in
compliance
with
the
National
Emissions
Standard
for
Vinyl
Chloride.
Adequate
monitoring,
recordkeeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
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.
Non­
duplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
is
required
under
40
CFR
Part
61,
Subpart
F.

3(
a)
Non­
duplication
If
the
standard
has
not
been
delegated,
the
information
is
sent
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
regulation
to
implement
the
Federal
Regulation,
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
Standard.
Therefore,
no
duplication
exits.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
February
1,
2001.

3(
c)
Consultations
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
4
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
required
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
main
consequence
would
be
that
the
chances
of
detecting
poor
operation
and
maintenance
of
control
equipment
would
decrease.

3(
e)
General
Guidelines
None
of
the
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
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/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
owners
or
operators
of
ethylene
dichloride,
vinyl
chloride,
and
polyvinyl
chloride
manufacturing
plants.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
U.
S.
Standard
Industrial
Classification)
2821
which
corresponds
to
the
NAICS
(
The
North
American
Industry
Classification
System)
325211.

4(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
61,
Subpart
F
­
National
Emission
Standard
for
Vinyl
Chloride.

A
source
must
make
the
following
reports
5
Reports
for
NESHAP
SUBPART
F
Notification
of
construction
or
modification
application
61.07
Notification
of
anticipated
startup
61.09(
a)(
1)

Notification
of
actual
startup
61.09(
a)(
2)

Notification
of
emissions
testing
(
performance
test)
61.13(
c)

Emissions
test
(
performance
test)
report
61.13(
f)

Notification
of
physical
or
operational
change
61.15
Application
for
waiver
of
testing
61.13(
i)(
1)

Application
for
equivalent
equipment
and
procedures
61.66
Initial
report
61.69
Quarterly
report
61.70
Manual
vent
valve
(
MVV)
discharge
report
61.64(
a)(
3)

Relief
valve
discharge
(
RVD)
report
61.65(
a)

A
source
must
maintain
the
following
records
Recordkeeping
for
NESHAP
SUBPART
F
Startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
61.14(
f)

Emission
test
results
and
other
data
needed
to
determine
emissions
61.13(
g)
&
61.71(
a)(
3)

Records
of
leak
detected
61.71
(
a)(
1&
2)

Performance
test
records,
leaks
detected,
emissions
records,
and
daily
operating
records
are
required
to
be
retained
on­
site
for
3
Years.
61.67(
f)
&
61.71
(
ii.)
Respondent
Activities
Respondent
Activities
Read
instructions.
Respondent
Activities
6
Write
the
notifications
listed
above
Perform
initial
performance
test,
Reference
Method
106,
107,
and/
or
601
and
repeat
performance
tests
if
necessary.

Prepare
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.

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
conducts
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
distribution
of
the
required
information.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.

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

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
database.

5(
b)
Collection
Methodology
and
Management
7
Following
notification
of
start­
up,
the
reviewing
authority
might
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
operations
and
maintenance
of
equipment
and
the
use
of
proper
work
practices
by
trained
operators.

Information
contained
in
the
reports
is
entered
into
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
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
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
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
three
(
3)
years.

5(
c)
Small
Entity
Flexibility
There
are
no
small
businesses
affected
by
this
standard.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
subject
to
this
Subpart.
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
at
16,159
persons­
hours
(
Column
E
of
Table
2).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
program,
the
previously
approved
ICR,
and
8
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
Technical
Labor
Rate
of
$
55.34
per
hour.
This
rate
is
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
In
order
to
be
consistent
with
the
previous
ICR,
we
are
using
the
technical
wage
rate
which
was
also
used
in
the
previous
ICRs.
This
rate
is
from
column
1,
"
Total
Compensation."
The
wage
rate
has
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
industry
costs
associated
with
the
information
collection
activity
in
this
standard
are
labor
and
the
capital
start­
up
and
operations
and
maintenance
(
O&
M)
costs
associated
with
continuous
emissions
monitoring.
The
capital
start­
up
costs
are
one­
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
annual
O&
M
costs
are
ongoing
costs
to
maintain
the
monitoring
system
as
well
as
other
administrative
costs
such
as
photocopying
and
postage.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
(
A)

Continuous
Monitoring
device
(
B)

Startup
cost
($)
for
1
affected
facility
(
C)

#
of
new
affected
facilities
to
start­
up
(
D)

Total
start
up
(
B
X
C)
(
E)

Annual
O&
M
costs
($)
for
1
affected
facility
(
F)

#
of
affected
facilities
with
O&
M
(
G)

Total
O&
M
(
E
X
F)

Continuous
Emission
Monitor
(
CEM)
$
150,000
0
$
0
$
45,000
44
$
1,980,000
The
total
capital/
start­
up
costs
for
this
ICR
are
$
0.
The
capital
start­
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
this
subpart.
This
is
based
on
our
assumption
that
no
new
sources
will
be
subject
to
this
subpart
over
the
next
three
(
3)
years.
This
is
the
total
of
column
D.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
a:
Total
annualized
capital/
startup
costs.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.
9
The
total
operating
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
1,980,000.
This
based
on
44
existing
sources
multiplied
by
$
45,000.00
for
upkeep
of
the
monitoring
devices.
This
is
the
total
of
column
G.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
b:
Total
annual
costs
(
O&
M).
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

The
total
respondent
costs
is
the
sum
of
the
capital
start
up
costs
and
the
annual
operations
and
maintenance
costs.
Thus
the
industry's
average
annual
cost
for
capital
and
O&
M
for
this
subpart
over
the
next
three
years
is
estimated
to
be
$
1,980,000.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14
letter
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
Federal
costs
are
user
cost
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
AFS
program.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
142,721.92.
The
cost
is
based
on
an
average
hourly
wage
of
a
GS­
10
step
1
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden
(
A
different
hourly
rate
was
used
in
the
past,
but
because
the
previous
ICR
provided
no
explanation
for
the
dollar
amount
for
salary
this
renewal
will
use
the
going
standard
fee.).

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Respondent
Universe
Regulation
Title
(
A)
#
new
sources
per
year
(
B)
#
of
initial
reports
for
new
sources
(
C)
#
existing
sources
(
D)
#
of
reports
for
existing
sources
(
E)
total
annual
responses
(
AxB.)+(
CxD)

NESHAP,
Subpart
F
0
5
44
7
308
The
number
of
total
respondents
is
44.
This
number
is
the
sum
of
Column
A
and
Column
C
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
a.
This
is
the
number
of
existing
sources
plus
the
number
of
new
sources
anticipated
in
one
year.

The
total
annual
responses
is
308.
This
number
is
in
column
E
of
the
Respondent
Universe
10
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
b.
The
total
annual
labor
costs
are
$
894,239.06.
This
number
is
not
shown
on
the
OMB
83­
I
form,
only
the
burden
hours
are
reflected
in
block
13c.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

The
total
annual
capital
and
O&
M
costs
to
the
regulated
entity
are
$
1,980,000.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14
c.
These
costs
are
detailed
in
section
6
b
(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
Tables
Reference
Tables
1
&
2.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
the
use
of
more
accurate
industry
and
EPA
hourly
wages
supported
by
information
from
the
Bureau
of
Labor
Statistics.

6(
g)
Burden
Statement
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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency
,
Mail
code
2822,
1200
Pennsylvania
Avenue,
NW,
Washington,
DC
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
and
OMB
Control
Number
in
any
correspondence.

Part
B
of
the
Supporting
Statement
11
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
