1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NESHAP
Subpart
FF
Benzene
Emissions
for
Benzene
Waste
Operations
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
SUBPART
FF­
Benzene
Waste
Operations
1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Benzene
Waste
Operations
were
proposed
on
September
14,
1989
and
promulgated
on
March
7,
1990.

These
standards
apply
to
owners
and
operators
of
chemical
manufacturing
plants,
coke
by­
product
recovery
plants,
and
petroleum
refineries
as
well
as
owners
and
operators
of
hazardous
waste
treatment,
storage,
and
disposal
facilities
that
treat,
store,
or
dispose
of
hazardous
waste
generated
from
the
above
facilities.
Affected
Facilities
are
those
which
generate
wastes
that
contain
benzene
by
facilities
such
as
chemical
manufacturing
plants,
coke
by­
product
recovery
plants,
petroleum
refineries
and
those
owners
and
operators
of
hazardous
waste
treatment,
storage,
and
disposal
facilities
(
TSDF)
which
receive
wastes
from
the
above
facilities.

This
information
is
being
collected
to
assure
compliance
with
40
CFR
Part
61
Subpart
FF.

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.
Monitoring
requirements
specific
to
2
Benzene
Waste
Operations
provide
information
on
the
operation
of
the
vapor
control
device
and
compliance
with
the
standard.
Quarterly
reports
of
excess
emissions
are
required.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance;
and
are
required,
in
general,
of
all
sources
subject
to
the
NESHAPs.

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
2
years
following
the
date
of
such
records.
For
this
subpart,
there
is
a
tiered
threshold
for
burden.
Facilities
managing
waste
containing
less
than
1
megagram
of
benzene
must
simply
certify
to
that
affect
and
maintain
documentation
to
support
their
finding.
Facilities
managing
more
than
1
megagram
and
less
than
10
megagrams
of
benzenecontaining
waste
must
prepare
an
initial
certification,
test
annually
to
verify
that
their
waste
stream
still
falls
within
this
range
and
maintain
documentation
to
support
these
findings.
Finally,

facilities
managing
more
than
10
megagrams
of
waste
must
submit
quarterly
and
annual
reports
documenting
the
results
of
continuous
monitoring.
Approximately
240
sources
are
currently
subject
to
the
standard,
and
120
of
those
are
estimated
to
have
more
than
10
Mg/
yr
of
benzene
in
the
waste.
It
is
estimated
that
no
additional
sources
will
become
subject
to
the
standard
in
the
next
three
years.
The
cost
of
this
ICR
will
be
405,266
dollars.

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
EPA
Regional
Office.

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
3
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
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
Keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)

provide
such
other
information
as
he
may
reasonably
require.

In
the
Administrator's
judgment,
benzene
emissions
from
benzene
waste
operations
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAPs
were
promulgated
for
this
source
category
at
40
CFR
Part
61
Subpart
FF
.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
benzene
from
benzene
waste
operations
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
benzene
from
benzene
waste
operations
are
the
result
of
operation
of
those
facilities
which
generate
wastes
that
contain
benzene
such
as
chemical
manufacturing
plants,

coke
by­
product
recovery
plants,
petroleum
refineries
and
those
owners
and
operators
of
hazardous
waste
treatment,
storage,
and
disposal
facilities
(
TSDF)
which
receive
wastes
from
the
4
above
facilities.
These
standards
rely
on
the
reduction
of
benzene
emissions
by
treatment
process
units.
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
pollution
control
devices
are
properly
installed
and
operated
and
the
standard
is
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
standard,
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.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
61
Subpart
FF.

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
exists.

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
on
June
4,
1999.

3(
c)
Consultations
5
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
d)
Effects
of
Less
Frequent
Collection
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
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
61
Subpart
FF
or
otherwise
pertinent
to
this
request
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
contained
in
40
CFR
Part
61
Subpart
FF
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.
6
4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
SIC
codes
for
the
respondents
include
2800
(
chemical
products),
2911
(
petroleum
refineries),
3312
(
blast
furnaces
and
steel
mills),
4959
(
sanitary
services),
and
9511
(
air,
water,
solid
waste
management).

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
FF­
Benzene
Waste
Operations.

A
source
must
make
the
following
reports
Provide
notification
of:

­
construction
or
modification
application
(
61.07)

­
anticipated
startup
61.09(
a)(
1)

­
actual
startup
61.09(
a)(
2)

­
source
reporting
and
request
for
waiver
of
compliance
61.10
­
emission
test
and
waiver
of
emission
tests
for
flares
and
some
waste
incinerators
61.13
­
initial
performance
test
61.13
(
C)

­
demonstration
of
continuous
monitoring
system
61.354(
C)

­
physical
or
operational
change
61.15
Reporting:
7
­
Report
that
summarizes
the
regulatory
status
of
each
waste
stream
that
contain
benzene
61.357
(
a)

­
Initial
certification
of
necessary
equipment
and
inspection
tests
61.357
(
d)(
1)

­
Annual
certification
of
benzene
waste
steams,
benzene
concentration
and
benzene
quantity
determination
61.357
(
b)(
c)(
d)(
2)

­
Notification
of
election
to
comply
with
alternative
requirements
and
certification
of
benzene
waste
steams,
benzene
concentration
and
benzene
quantity
determination
61.357
(
d)(
4)(
5)

­
Quarterly
reports
certifying
required
inspections
61.357
(
d)(
6)

­
Quarterly
report
when
monitored
parameters
are
exceeded
61.357
(
d)(
7)

­
Initial
and
quarterly
reports
for
inspections
during
which
detectable
emissions
or
a
problem
is
identified
61.357
(
d)(
8)

­
Notification
of
election
to
comply
with
standard
61.357
(
e)

­
Initial
and
quarterly
identifying
all
seal
gap
measurements
that
are
outside
limits
61.357
(
g)

Recordkeeping:

­
Two
year
retention
of
records
61.356
(
a)

­
emission
test
results
and
other
data
needed
to
determine
emissions
61.13(
g)

­
startups,
shutdowns,
malfunctions,
periods
where
the
continuous
monitoring
system
is
inoperative
61.356
­
Measurements
and
determinations
of
annual
waste
quantity,
water
content
and
benzene
concentration
61.356
(
b)
8
­
Records
of
offsite
shipment
of
waste
61.356
(
c)

­
Record
of
control
equipment
engineering
design
61.356
(
d)

­
Records
of
engineering
calculations,
operating
conditions
and
performance
tests
61.356
(
e)

­
Records
of
detectable
emissions
from
closed
vent
systems
and
control
devices
61.356
(
f)

­
Records
of
location,
date,
and
corrective
actions
for
problems
found
during
visual
inspections
61.356
(
g)(
l)

­
Records
for
each
test
of
no
detectable
emissions
61.356
(
h)

­
Operational
records
for
each
control
device,
treatment
process
and
wastewater
treatment
system
61.356
(
I)(
j)

Monitoring:

­
Monitoring
requirements
61.14
­
Monitoring
of
operation
of
treatment
process
or
wastewater
treatment
61.354
(
a)(
b)

­
Monitoring
of
alternative
operational
or
process
parameters
61.354
(
e)

­
Monitoring
of
affected
facilities
61.343­
349
Records
are
required
to
be
retained
for
2
Years
and
they
must
be
kept
onsite.

b.
Respondent
Activities
­
Read
instructions
­
perform
initial
performance
test,
and
repeat
performance
tests
­
write
the
notifications
and
reports
listed
above
­
enter
information
required
to
be
recorded
above.
9
­
submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information;

­
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information;

­
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information;

­
adjusting
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;

­
training
personnel
to
be
able
to
respond
to
a
collection
of
information;

­
transmitting,
or
otherwise
disclosing
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
information
required
under
40
CFR
Subpart
FF:

­
Observes
initial
performance
tests
and
repeat
performance
tests
if
necessary
­
Reviews
notifications
and
reports,
including
performance
test
reports,
and
excess
emissions
reports,
required
to
be
submitted
by
industry
­
Audits
facility
records
­
Inputs,
analyzes
and
maintains
data
in
the
Aerometric
Information
Retrieval
System(
AIRS)
database
5(
b)
Collection
Methodology
and
Management
10
Following
notification
of
startup,
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
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
AIRS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
AIRS
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
AIRS
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
two
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
on
Table
2.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
2
documents
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
11
and
reporting
requirements
applicable
to
the
industry.
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
17,028
person­
hours.
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
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
I)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
of
$
23.80
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1998,
Table
2:
Employment
Costs
for
Civilian
Workers
by
Occupational
and
Industry
Group.
The
rates
are
from
column
1:
Total
compensation.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.
There
are
no
capital
or
operations
and
maintenance
costs.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
This
section
is
not
applicable
because
there
is
no
continuous
monitoring.
12
6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.

Publication
and
distribution
of
the
information
are
part
of
the
AIRS
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
$
25,585
(
from
table
1).
This
cost
is
based
on
an
average
wage
of
a
GS10
step
1
employee
rate,
or
if
previous
ICR
has
specific
breakdowns
use
them
and
travel
associated
with
compliance
activities.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
benzene
waste
operation,
subpart
FF
is
240.

The
number
of
new
sources
subject
to
benzene
waste
operation,
subpart
FF
is
0.
The
total
annual
labor
costs
are
$
405,266
and
there
is
no
total
annual
capital
and
O&
M
costs.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Industry
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
attached
tables
6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
an
adjustment
in
labor
rates.

6(
g)
Burden
Statement
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
13
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,
OP,
Regulatory
Information
Division,
U.
S.
Environmental
Protection
Agency
(
2137),
401
M
St.,
S.
W.,
Washington,
D.
C.

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
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
