1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NATIONAL
EMISSION
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
(
NESHAP)
FOR
OFF­
SITE
WASTE
AND
RECOVERY
OPERATIONS
(
SUBPART
DD)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
ICR
for
NESHAP
Subpart
DD
­
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
(
HAP)
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
or
the
facility
potential
to
emit
is
more
than
10
tons
per
year
for
a
single
HAP
or
more
than
25
tons
per
year
for
multiple
HAP.
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
5
years
following
the
date
of
such
reports,
and
records
(
2
years
at
the
site;
the
remaining
3
years
may
be
retained
off
site).
Approximately
250
sources
are
currently
subject
to
the
standard
with
a
0
growth
projected
in
new
sources.
This
is
based
on
facility
off­
site
transfer
information
from
the
Toxics
Release
Inventory
and
Biennial
Reporting
System
data
bases.
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
hazardous
air
2
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,
organic
HAP
emissions
from
Subpart
DD
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
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
Subpart
DD
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
organic
HAP
from
Subpart
DD
are
the
result
of
operation
of
the
off­
site
waste
receiving
facilities.
These
standards
rely
on
the
control
of
organic
HAP
emissions
by
control
technology.
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,
leaks
are
being
detected
and
repaired
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.
The
information
generated
by
the
monitoring,
record
keeping
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
and
achieve
compliance
with
the
regulation.
MACT
continue
to
operate
the
control
equipment
and
achieve
continuous
compliance
with
the
regulation.
Adequate
monitoring,
record
keeping,
and
reporting
is
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
record
keeping
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
3(
a)
Nonduplication
The
record
keeping
and
reporting
requested
is
required
under
40
CFR
Part
63
Subpart
DD.
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
3
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
October
29,
1999.

3(
c)
Consultations
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
63
Subpart
DD
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
63
Subpart
DD
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
of
the
recordkeeping
and
reporting
requirements
are
businesses
that
store,
treat,
recycle,
reprocess,
or
dispose
of
wastes
containing
organic
chemical
compounds
listed
as
HAP
that
are
not
generated
on­
site
but
instead
have
been
generated
at
other
location
and
transported
to
the
facility
4
commencing
construction,
modification
or
reconstruction
after
October
13,
1994
if
the
facility
is
a
"
major
source"
of
HAP
emissions
as
defined
in
general
provisions
to
40
CFR
Part
63.
They
are
listed
under
SIC
Code(
s)
2869,
2800,
3312,
9199,
2821,
2892,
3674,
2911,
3721
and
2816.
The
governments
is
in
the
process
of
transitioning
to
the
new
North
American
Industrial
Classification
System
(
NAICS).
The
NAICS
code
for
this
industry
are
325000.

4(
b)
INFORMATION
REQUESTED
(
I)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
63
Subpart
DD.

A
source
must
make
the
following
reports:

Notification
Reports
Construction/
reconstruction
63.5
Initial
notifications
63.9(
b)

Actual
startup
60.7(
a)(
3),
61.09(
a)(
2)

Initial
performance
test
63.7(
b),
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
or
operational
change
63.
X
Notification
of
performance
tests
63.697
(
b)
(
1)

Performance
test
results
63.697
(
b)
(
2)

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

Semi­
annual
summary
report
63.697
(
c)

Notification
of
tank
floating
roof
inspection
63.686
(
d)
(
3)
(
vi)

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

Notification
of
tank
refill
63.697
(
d)
(
1)

Notification
of
seal
gap
measurements
63.697
(
d)
(
2)
5
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)

Report
of
the
range
and
explanation
of
monitored
operating
parameters
63.697
(
c)

A
source
must
keep
the
following
records:

Recordkeeping
Startups,
shutdowns,
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
for
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)
(
v)
(
C)

Record
of
sampling
plan
for
determining
VOHAP
concentration
at
point
of
treatment
63.694
(
c)
(
1)
(
iii)

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

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

Records
are
required
to
be
retained
for
5
years.
All
MACT
standards
require
5
years
of
record
retention.
The
first
2
years
of
records
must
be
kept
onsite;
the
remaining
3
years
may
be
retained
off
site.
ii.
Respondent
Activities
6
Respondent
Activities
Determine
the
VOHAP
concentration
for
of­
site
material
at
the
point­
of­
delivery
and
for
the
treated
offsite
material
streams
at
the
point­
of­
treatment.

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

The
owner
or
operator
may
use
the
example
report
forms
that
EPA
has
made
available
in
EPA's
draft
"
The
Plain
Language
Guide
to
40
CFR
Part
63
Subaprt
DD
(
Off­
Site
Waste
and
Recovery
Operations
NESHAP)"
but
they
are
not
required
to
use
them.
The
owner
or
operator
may
want
to
check
with
your
State
or
local
air
pollution
control
board
to
make
sure
that
they
do
not
have
their
own
forms.
If
the
EPA
forms
are
used,
first
be
sure
that
they
met
any
requirements
that
the
State
or
local
agency
has
or
other
technical
collection
techniques
including
electronic
submissions.

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
DD.

Agency
Activities
Observe
initial
performance
tests
and
repeat
performance
tests
if
necessary.
Agency
Activities
7
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)
database.

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
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
five
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
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
under
40
CFR
Part
63,
Subpart
DD.
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
162,050
person­
hours.
These
hours
are
based
on
Agency
studies
8
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
Executive,
Administrative,
and
Managerial
­
$
73.93;
Technical
­
$
54.94;
Clerical
­
$
34.42;
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
1999,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industry
Group.
The
rates
are
from
column
1:
Total
compensation.
The
labor
rates
shown
have
been
loaded
by
including
an
110%
overhead.

(
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
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
and
CEMs.
The
capital
start
up
costs
are
one
time
costs
when
a
facility
becomes
subject
to
the
standard.
The
capital
start
up
costs
for
this
regulation
are
0
dollars.
This
is
based
on
0
new
sources
per
year.
The
annual
operations
and
maintenance
costs
are
0
dollars.
This
is
because
reporting
and
recordkeeping
requirements
on
the
part
of
the
respondents
are
required
under
the
General
Provisions
for
MACT
standards.

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
$
156,105
(
from
Table
1).
This
cost
is
based
on
an
average
wage
of
a
GS
10
step
1
employee
rate,
($
16.52
hr
+
110%
overhead
=
$
34.69)
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
40
CFR
Part
63,
Subpart
DD
is
250.
The
number
of
new
sources
subject
to
40
CFR
part
63
Subpart
DD
is
0.
The
number
of
total
respondents
is
250.
This
is
the
number
of
existing
sources
plus
the
number
of
sources
anticipated
in
one
year.
The
total
annual
responses
is
1000.
This
number
is
calculated
from
the
number
of
new
sources
multiplied
by
the
number
of
initial
reports,
plus
the
number
of
existing
sources
multiplied
by
the
number
quarterly
reports.
The
total
annual
labor
costs
are
$
9,044,008.
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.
9
6(
f)
Reasons
for
Change
in
Burden
The
attached
responded
burden
estimate
represents
a
decrease
in
burden
from
the
most
recently
approved
ICR.
The
162,050
person­
hours
burden
estimate
shown
on
the
attached
tables
represent
a
reduction
of
46,083
person­
hours
per
year
based
on
the
previous
ICR
burden
estimate
of
208,133
personhours
This
annual
average
burden
reduction
is
due
primarily
to
the
need
not
to
include
the
burden
estimate
from
the
one
time
activities
that
facility
owners
and
operators
performed
during
the
first
year
of
following
promulgation
of
the
Subpart
DD
rule.

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,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania,
Ave.,
NW,
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
renewal
number
1717.03
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.
