1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
AIR
EMISSION
STANDARDS
FOR
TANKS,
SURFACE
IMPOUNDMENTS
AND
CONTAINERS
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
RCRA
Subpart
CC
­
Standards
of
Performance
for
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers
1(
b)
Short
Characterization/
Abstract
This
information
collection
request
is
to
allow
the
Agency
to
continue
requiring
regulated
companies
to
collect
and
report
necessary
information
in
order
to
determine
that
such
affected
companies
are
complying
with
RCRA
Subpart
CC.

The
air
emission
standards
for
tanks,
surface
impoundments
and
containers
at
40
CFR
Part
264,

Subpart
CC
and
40
CFR
Part
265,
Subpart
CC
were
proposed
on
July
22,
1991(
56
FR
33491),
and
promulgated
on
December
1994
(
59
FR
62896).
Amendments
to
this
Subpart
were
added
on
November
25
1996
(
61
FR
59931).
The
requirements
of
this
Subpart
apply
to
owners
and
operators
of
all
facilities
that
treat,
store
or
dispose
(
TSD)
of
hazardous
wastes
in
tanks,
surface
impoundments
and
containers
that
are
subject
to
Subparts
I,
J
or
K
of
these
Parts
except
for
§
§
264.1,
265.1
and
those
management
units
identified
at
§
§
264.1080(
b)
and
265.1080(
b).
Also,
the
requirements
of
this
Subpart
apply
to
large
quantity
generators
that
manage
hazardous
wastes
in
either
tanks
or
containers;
(
262.34(
a)(
1)(
i
and
ii).

The
potential
number
of
respondents
subject
to
these
regulations
is
6,497
respondents
over
the
next
three
years.
On
an
annualized
basis,
the
number
of
respondents
subject
to
this
requirement
is
6,318.
This
number
was
derived
from
20,316
large
quantity
generators
(
LQGs)
and
2,025
treatment,

storage
and
disposal
facilities
(
TSDFs),
obtained
from
the
latest
RCRA
Hazardous
Waste
Biennial
Report
(
1997).
However,
not
all
of
these
respondents
will
be
subject
to
the
Subpart
CC
regulations.
It
is
estimated
70%
of
the
2,025
TSDFs
and
25%
of
the
20,316
large
quantity
generators
or
6,497
facilities
will
be
subject
to
Subpart
CC
requirements.
This
is
a
increase
of
269
respondents
from
the
last
information
collection
request.
The
total
number
of
respondents
is
based
on
information
obtained
from
2
the
Agency's
1997
Biennial
Report,
the
most
recent
data
available.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
Organic
air
emissions
from
hazardous
waste
TSDFs
can
contain
toxic
chemical
compounds.

Cancer
and
other
adverse
noncancerous
human
health
effects
can
result
from
exposure
to
these
emissions.
Also,
organic
emissions
from
TSDFs
react
photochemically
with
other
compounds
in
the
atmosphere
to
form
ozone.
Excessive
ambient
ozone
concentrations
are
a
major
air
quality
problem
in
many
cities
throughout
the
United
States.
Nationwide
organic
emissions
from
TSDFs
are
estimated
to
be
approximately
1
million
megagrams
per
year.
These
organic
emissions
are
estimated
to
result
in
48
excess
incidences
of
cancer
per
year
nationwide
and
a
3
x
10­
2
maximum
individual
risk
(
MAR).

In
1984,
Congress
passed
the
Hazardous
and
Solid
Waste
Amendments
(
HSWA)
to
the
Resource
Conservation
and
Recovery
Act
(
RCRA)
of
1976.
Section
3004(
n)
of
HSWA
directs
the
EPA
to
promulgate
regulations
for
the
monitoring
and
control
of
air
emissions
from
TSDFs
as
may
be
necessary
to
protect
human
health
and
the
environment.
Recommended
standards
have
been
developed
by
the
EPA
under
the
authority
of
Sections
3002
and
3004
of
RCRA
to
reduce
organic
air
emissions
from
certain
TSDF
tanks,
surface
impoundments,
and
containers;
and
certain
hazardous
waste
generator
accumulation
tanks.

The
experience
of
the
EPA
in
implementing
and
enforcing
New
Source
Performance
Standards
(
NSPS)
and
National
Emission
Standards
tor
Hazardous
Air
Pollutants
(
NESHAP)
promulgated
under
authority
of
the
Clean
Air
Act
has
demonstrated
that
certain
information
must
be
collected
to
ensure
compliance
with
air
emission
standards.
Information
collection
is
needed
by
the
EPA
tor
this
rulemaking
to
determine:
(
a)
whether
a
hazardous
waste
contains
sufficiently
low
concentrations
of
volatile
organics
to
allow
the
waste
to
be
managed
in
a
tank,
surface
impoundment,
or
container
without
the
use
of
emission
controls,
and
(
b)
for
units
requiring
emission
controls,
whether
the
controls
are
being
properly
operated
and
maintained.

2(
b)
Practical
Utility/
Users
of
the
Data
The
collected
information
will
be
used
by
the
EPA
enforcement
personnel
to
ensure
that
the
3
requirements
of
the
recommended
rules
are
being
properly
applied
and
that
emission
control
devices
are
being
properly
operated
and
maintained
on
a
continuous
basis.

In
addition,
records
and
reports
are
necessary
to
enable
the
EPA
to
identify
TSDF
owners
or
operators
that
may
not
be
operating
in
compliance
with
the
standards.
The
reported
information
is
used
by
the
EPA
to
target
TSDFs
for
inspection
and
identify
what
records
or
waste
management
units
should
be
inspected
at
the
TSDF.
The
information
that
TSDF
owners
or
operators
are
required
to
maintain
is
recorded
in
sufficient
detail
to
enable
owners
or
operators
to
demonstrate
their
means
of
complying
with
the
applicable
standards.
The
data
collected
by
the
affected
facility
is
retained
at
the
facility
for
a
minimum
of
three
years.

In
addition,
the
information
collected
from
the
recordkeeping
and
reporting
requirements
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
264.1089,
264.1090
and
265.1090.

3(
a)
Nonduplication
Since
Subpart
CC
is
a
recent
rule,
most
States
have
not
been
authorized
to
implement
this
program
until
such
time
their
state
hazardous
waste
program
is
consistent
with
the
federal
program
regarding
this
particular
activity.
Until
that
time,
States
cannot
implement
this
particular
activity
under
their
RCRA
program.
Therefore,
there
is
no
duplication
of
effort
by
State
agencies.
If
States
become
authorized
during
this
next
ICR
cycle,
the
reports
or
notifications
would
be
submitted
to
the
State
program
office
and
not
to
the
EPA.

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
August
17,
2000.
(
65
FR
50196)

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

3(
d)
Effects
of
Less
Frequent
Collection
4
If
the
information
required
by
the
standard
was
not
collected,
the
Agency
would
have
no
means
for
ensuring
that
compliance
with
RCRA
Subpart
CC
is
achieved
and
maintained
by
large
quantity
generators
and
treatment,
storage
or
disposal
facilities.
Under
these
circumstances,
an
owner
or
operator
could
elect
to
reduce
operating
expenses
by
not
installing,
maintaining,
or
otherwise
operating,
the
cover,

roof
or
control
technology
required
by
the
standards.
In
the
absence
of
the
information
collection
requirements,
compliance
with
the
standards
could
be
ensured
only
through
continuous
on­
site
inspections
by
regulatory
agency
personnel.
Consequently,
not
collecting
the
information
would
result
in
either
greatly
increased
expenditures
of
resources,
or
the
inability
to
ensure
compliance
with
the
standards.

Respondents
are
required
to
submit
reports
only
when
circumstances
occur
at
the
facility
that
result
in
improper
management
of
hazardous
waste
in
units
not
using
the
required
air
emission
controls
and
when
a
control
device
malfunction
cannot
be
corrected
within
24
hours
of
being
detected.
There
are
no
reporting
requirements
for
owners
and
operators
of
interim­
status
TSDFs
(
subject
to
the
requirements
of
40
CFR
part
264).
Owners
and
operators
of
permitted
TSDFs
(
subject
to
the
requirements
of
40
CPR
part
265)
must
report
within
15
calendar
days
circumstances
resulting
in
the
management
of
hazardous
waste
subject
to
the
rules
in
a
tank,
surface
impoundment,
or
container
not
using
the
required
air
emission
controls.
In
addition,
an
owner
or
operator
of
a
permitted
TSDF
that
uses
a
control
device
to
comply
with
the
requirements
of
the
rules
must
submit
a
semiannual
written
report
of
any
exceedances,

as
defined
in
the
rules,
that
may
occur.
If
no
exceedances
have
occurred
during
the
reporting
period,
no
report
is
required.

The
recommended
rules
require
the
TSDF
owner
or
operator
to
record
certain
information
to
the
on­
site
facility
operating
logs
or
files.
Consistent
with
40
CFR
264.73
and
40
CFR
265.73,
the
rules
require
that
air
emission
control
equipment
design
records
and
certain
other
records
be
maintained
in
the
facility
operating
record
until
facility
closure.
Records
and
results
of
waste
determinations,
inspections,

monitoring,
control
device
exceedances
and
actions
taken
to
remedy
them,
leak
repairs,
and
management
of
carbon
removed
from
carbon
adsorption
systems
are
required
to
be
kept
for
at
least
3
years
from
the
date
of
entry.

All
reports
are
to
be
submitted
to
the
EPA
Regional
office
having
jurisdiction
for
a
particular
5
TSDF
location.
The
reports
must
be
signed
and
dated
by
an
authorized
representative
of
the
facility
owner
or
operator.
The
information
is
needed
by
the
EPA
to
identify
facilities
where
the
owners
or
operators
are
having
difficulty
complying
with
the
requirements
of
the
rules.

3(
e)
General
Guidelines
None
of
these
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:

Regulation
SIC
Codes
NAICS
Codes
RCRA
Subpart
CC
­
Standards
of
Performance
for
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers
20
thru
39
and
33­
37
281,282,
283,
284,
285,
286,
287
4(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
264
and
Part
265,

RCRA
Subpart
CC
­
Air
Emission
Standards
for
Tanks,
surface
Impoundments
and
Containers.

A
source
must
make
the
following
reports:
6
Reports
for
RCRA
Subpart
CC
Affected
Waste
Management
Unit
Substantive
Requirement
Reporting
Requirements
Unit
managing
hazardous
waste
containing
less
than
500ppmw,
mass­
weighted
average,
volatile
organics
at
point
of
waste
generation.
Waste
volatile
organic
concentration
determination
at
point
of
generation.
264.1083(
c)(
1)
265.1084(
c)(
1)
Report
waste
determination
results
exceeding
500ppmw
volatile
organics
on
a
massweighted
average
basis.
264.1090(
a)

Affected
Waste
Management
Unit
Substantive
Requirement
Reporting
Requirement
Unit
managing
hazardous
waste
treated
in
accordance
with
one
of
the
organic
destruction
or
removal
processes.
Waste
volatile
organic
concentration
determination
at
point
of
generation
of
waste
origination.
264.1083(
a)(
2)
265.1084(
a)

Treatment
process
exit
concentration
limit
determination.
264.1083(
b)

Treatment
process
required
mass
removal
of
organics
determination.
264.1083
(
b)

Treatment
process
or
organic
mass
removal
and
actual
mass
removal
of
organics
determination.
264.1083(
b)
Report
waste
determination
results
indicating
that
the
process
used
to
treat
the
waste
fails
to
meet
the
applicable
conditions
specified
in
the
rule.
264.1090(
a)

Tank
using
cover
only.
Maximum
organic
vapor
pressure
of
hazardous
waste
in
a
tank
determination.
264.1083(
c)
265.1084(
c)
Report
waste
Tank
using
alternative
controls:
internal
or
external
floating
roofs.
Annual
visual
inspection
of
floating
roof.
264.1091(
b0
265.109(
b)
Report
date
of
inspection
30
days
in
advance.
264.1091(
b)
265.1091(
b)
7
Monitoring
of
external
floating
roof
seals
at
least
every
five
years.
264.1091(
b)
265.1091(
b)
Report
date
of
monitoring
results
30
days
in
advance.
264.1091(
b)
265.1091(
b)

Surface
impoundment
using
cover
closed
vent
system
and
control
device.
Continuous
monitoring
of
control
device
operating
parameter.
264.1088(
d)
265.1089(
d)
Report
monitoring
results
exceeding
the
values
specified
in
standards
if
control
device
malfunction
is
not
corrected
within
24
hours.
264.1090(
c)

Container
used
for
wastefixating
heat
generating
or
heat
using
treatment
process.
Continuous
monitoring
of
control
device
operating
parameter.
264.1088(
d)
265.1089(
d)
Report
monitoring
results
exceeding
the
values
specified
in
standards
if
control
device
malfunction
is
not
corrected
within
24
hours.
264.1090(
c)

A
source
must
keep
the
following
records.

Recordkeeping
for
RCRA
Subpart
CC
Affected
Waste
Management
Unit
Substantive
Requirement
Recordkeeping
Requirements
Unit
managing
hazardous
waste
containing
less
than
500ppmw,
mass­
weighted
average,
volatile
organics
at
point
of
waste
generation.
Waste
volatile
organic
concentration
determination
at
point
of
generation.
264.1083(
c)(
1)
265.1084(
c)(
1)
Record
waste
determination
results.
264.1089(
c)
265.1090(
c)
8
Unit
managing
hazardous
waste
treated
in
accordance
with
one
of
the
organic
destruction
or
removal
processes.
Waste
volatile
organic
concentration
determination
at
point
of
generation
of
waste
origination.
264.1083(
a)(
2)
265.1084(
a)

Treatment
process
exit
concentration
limit
determination.
264.1083(
b)

Treatment
process
required
mass
removal
of
organics
determination.
264.1083
(
b)

Treatment
process
or
organic
mass
removal
and
actual
mass
removal
of
organics
determination.
264.1083(
b)
Record
waste
determination
results
264.1089(
c)
265.1090(
c)

Treatment
by
incinerator
in
compliance
with
40
CFR
264
Subpart
O
or
in
compliance
with
40
CFR
Part
265
Subpart
H
and
Part
270.
264.1082(
c)(
2)(
vi)
Record
identification
number
of
incinerator
or
BIF.
264.1089(
e)

Affected
Waste
Management
Unit
Substantive
Requirement
Recordkeeping
Requirements
9
Tank
using
cover
with
closed
vent
system
with
control
device.
Design
control
system
to
meet
specified
performance
level
and
equipment
specifications.
264.1084(
b)
and
264.1088(
c)
265.1085(
b)
and
265.1088
(
b)
and
(
c)
Record
closed
vent
system
and
control
device
design
specifications
and,
if
used,
performance
test
results.
264.1089(
a)(
4)
265.1090(
a)(
4)

Maintain
records
in
operating
record
for
a
minimum
of
three
years,
and
all
records
pertaining
to
the
operations
of
the
air
emission
control
equipment
for
as
long
as
it
is
in
service.
264.1089(
g)

Continuous
monitoring
or
control
device
operating
parameter.
264.1088(
d)
265.1089(
d)
Record
monitoring
results
264.1089(
a)(
9)
265.1090(
a)(
9)

Semiannual
visual
inspection
of
cover.
264.1088(
b)
265.1089(
f)(
2)
Record
inspection
results.
264.1089(
a)(
6)
265.1090(
a)(
6)

Semiannual
Method
21
monitoring
of
cover
fittings.
264.1088(
b0
265.1089.(
f)(
2)
Record
closed
vent
system
and
control
device
design
specifications
and,
if
used,
performance
test
results.
264.1089(
a)(
4)
265.1090(
a)(
4)

Annual
visual
inspection
of
closed
vent
system
and
control
device.
264.1088(
c)
and
(
d)
265.1089(
c)
and
(
d)
Record
inspection
results.
264.1089(
a)(
6)
265.1090(
a)(
6)

Annual
Method
21
monitoring
of
closed
vent
system.
264.1088(
c)
265.1089(
f)(
7)
Record
monitoring
results.
264.1089(
a)(
7)
265.1090(
a)(
7)

Repair
leaks
detected
by
inspection
or
monitoring
264.1088(
c)
265.1089(
f)(
7)
Record
repair
results.
264.1089(
a)(
8)
265.1090(
a)(
8)

Affected
Waste
Management
Unit
Substantive
Requirement
Recordkeeping
Requirements
10
Manage
carbon
removed
from
carbon
adsorption
system.
264.1087(
c)(
3)(
i)
264.1088(
c)(
3)(
i)
Record
carbon
management
methods.
264.1089(
a)(
10)
265.1090(
a)(
10)

Inspection
and
monitoring
of
unsafe
to
inspect
and
monitor
covers.
264.1088(
b)
265.1089(
f)(
2)(
ii)
Record
inspection
and
monitoring
plan
and
explanation
of
why
cover
unsafe
to
inspect
and
monitor.
264.1089(
f)(
1)
265.1090(
f)(
1)

Inspection
and
monitoring
of
difficult
to
inspection
and
monitor
covers.
264.1088(
b)
265.1089(
f)(
2)(
iii)
Record
inspection
and
monitoring
schedule
and
explanation
of
why
cover
difficult
to
inspect
and
monitor.
264.1089(
f)(
2)
265.1090(
f)(
2)

Tank
using
cover
only.
Maximum
organic
vapor
pressure
of
hazardous
waste
in
a
tank
determination.
264.1083(
c)
265.1084(
c)
Record
waste
determination
results.
264.1089(
b)(
2)
265.1090(
b)(
2)

Alternative
compliance
for
tanks
with
covers.
264.1089(
b)
265.1090(
b)

Semiannual
visual
inspection
of
cover.
264.1088(
b)
265.1089(
f)(
2)
Record
inspection
results.
264.1089(
a)(
6)
265.1090(
a)(
6)

Annual
Method
21
monitoring
of
cover
fittings.
264.1088(
b)
265.1089(
f)
Record
monitoring
results
264.1089(
a)(
7)
265.1090(
a)(
7)

Repair
leaks
detected
by
inspection
or
monitoring.
264.1088(
c)
265.1089(
f)(
7)
Record
repair
results.
264.1089(
a)(
8)
265.1090(
a)(
8)

Inspection
and
monitoring
of
unsafe
to
inspect
and
monitor
covers.
264.1088(
b)
265.1089(
f)(
5)
Record
inspection
and
monitoring
plan
and
explanation
of
why
cover
unsafe
to
inspect
and
monitor.
264.1089(
f)(
1)
265.1090(
f)(
1)

Affected
Waste
Management
Unit
Substantive
Requirement
Recordkeeping
Requirement
11
Inspection
and
monitoring
of
difficult
to
inspect
and
monitor
covers.
264.1088(
b)
265.1089.(
f)(
6)
Record
inspection
and
monitoring
schedule
and
explanation
of
why
cover
difficult
to
inspect
and
monitor.
264.1089(
f)(
2)
265.1090(
f)(
2)

Tank
using
alternative
controls:
internal
or
external
floating
roofs.
Design
floating
roof
to
meet
equipment
specifications.
264.1091(
a)
265.1091(
a)
Record
floating
roof
design
specifications.
264.1089(
a)(
1)
265.1090(
a)(
1)

Annual
visual
inspection
of
floating
roof.
264.1091(
b0
265.109(
b)
Record
inspection
results.
264.1091(
c)
265.1091(
c)

Monitoring
of
external
floating
roof
seals
at
least
every
five
years.
264.1091(
b)
265.1091(
b)
Record
monitoring
results.
264.1091(
c)

Surface
impoundment
using
cover
closed
vent
system
and
control
device.
Design
control
system
to
meet
specified
performance
level
and
equipment
specifications.
264.1085(
b)
and
264.1087(
c)
265.1086(
b)
and
265.1088(
c)
Record
closed
vent
system
and
control
device
design
specifications
and,
if
used,
performance
test
results.
264.1089(
a)(
4)
265.1090(
a)(
4)

Continuous
monitoring
of
control
device
operating
parameter.
264.1088(
d)
265.1089(
d)
Record
monitoring
results.
264.1089(
a)(
9)
265.1090(
a)(
9)

Semiannual
visual
inspection
of
cover.
264.1088(
b0
265.1089(
f)(
2)
Record
inspection
results.
264.1089(
a)(
6)
265.1090(
a)(
6)

Semiannual
Method
21
monitoring
of
cover
fittings.
264.1088(
b)
265.1089(
f)
Record
monitoring
results.
264.1089(
a)(
7)
265.1090(
a)(
7(

Annual
visual
inspection
of
closed
vent
system
and
control
device.
264.1088(
c)
and
(
d)
265.1089(
c)
and
(
d)
Record
inspection
results.
264.1089(
a)(
7)
265.1090(
a)(
7)

Affected
Waste
Management
Unit
Substantive
Requirement
Recordkeeping
Requirement
12
Annual
Method
21
monitoring
of
closed
vent
system
264.1088(
c)
265.1089(
c)
Record
monitoring
results.
264.1089(
a)(
7)
265.1090(
a)(
7)

Repair
leaks
detected
by
inspection
or
monitoring.
264.1088(
f)(
7)
265.1089(
f)(
7)
Record
repair
results.
264.1089(
a)(
8)
265.1090(
a)(
8)

Manage
carbon
removed
from
carbon
adsorption
system.
264.1087(
c)(
3)(
i)
265.1088(
c)(
3)(
i)
Record
carbon
management
methods.
264.1089(
a)(
10)
265.1099(
a)(
10)

Surface
Impoundment
using
cover
only.
Design
cover
to
meet
equipment
specifications.
264.1085(
e)
265.1086(
e)
Record
cover
design
specifications.
264.1089.(
a)(
2)
265.1090(
a)(
2)

Semiannual
visual
inspection
of
cover.
264.1088(
h)
265.1089(
f)(
4)
Record
inspection
results.
264.1089.(
a)(
6)
265.1090(
a)(
6)

Semiannual
Method
21
monitoring
of
cover
fittings.
264.1088(
b)
265.1089(
f)(
4)
Record
monitoring
results.
264.1089(
a)(
7)
265.1090(
a)(
7)

Repair
leaks
detected
by
inspection
or
monitoring.
264.1088(
c0
265.1089(
f)(
7)
Record
repair
results.
264.1089(
a)(
8)
265.1090(
a)(
8)

Manage
carbon
removed
from
carbon
adsorption
system.
264.1087(
c)(
3)(
i)
265.1088(
c)(
3)(
i)
Record
carbon
management
methods.
264.1089(
a)(
10)
265.1090(
a)(
10)

Container
with
design
capacity
greater
than
or
equal
to
0.1
m3
(
26.4
gallons)
used
for
waste
handling,
preparation
or
storage.
Semiannual
visual
inspection
of
cover.
264.1088(
b)
Record
inspection
results.
264.1089(
a)(
6)
265.1090(
a)(
6)

Semiannual
Method
21monitoring
of
cover
fittings
on
containers
having
a
design
capacity
greater
than
or
equal
to
0.42
m3
(
110
gallons).
264.1088(
f)
Record
monitoring
results.
264.1089(
a)(
7)
265.1090(
a)(
7)

Repair
leaks
detected
by
inspection
or
monitoring.
264.1088(
c)
Record
repair
results.
264.1089(
a)(
8)
265.1090(
a)(
8)

Affected
Waste
Management
Unit
Substantive
Requirement
Recordkeeping
Requirement
13
Container
used
for
wastefixating
heat
generating
or
heat
using
treatment
process.
Design
control
system
to
meet
specified
performance
level
and
equipment
specifications.
264.1086(
b)(
20
and
264.1087(
c)
265.1087(
b)(
2)
and
265.1088.(
c)
Record
control
system
design
specifications
and,
if
used,
performance
test
results.
264.1089(
a)(
3)
and
(
4)
265.1090(
a)(
3)
and
(
4)

Continuous
monitoring
of
control
device
operating
parameter.
264.1088(
d)
265.1089(
d)
Record
monitoring
results.
264.1089(
a)(
9)
265.1090(
a)(
9)

Semiannual
visual
inspection
of
cover.
264.1088(
h)
265.1089(
f)
Record
inspection
results.
264.1089(
a)(
6)
265.1090(
a)(
6)

Semiannual
Method
21monitoring
of
cover
fittings.
264.1088(
b)
265.1089(
f)
Record
monitoring
results.
264.1089(
a)(
7)
265.1090(
a)(
7)

Annual
visual
inspection
of
closed
vent
system
and
control
device.
264.1088(
c)
and
(
d)
265.1089(
c)
and
(
d)
Record
repair
results.
264.1089(
a)(
6)
265.1090(
a)(
6)

Annual
Method
21
monitoring
of
closed
vent
system.
264.1088(
c)
265.1089(
f)(
3)(
i)
Record
monitoring
results.
264.1089(
a)(
7)
265.1090(
7)

Repair
leaks
detected
by
inspection
or
monitoring
264.1088(
c)
265.1089(
f)(
7)
Record
repair
results.
264.1089(
a)(
8)
265.1090(
a)(
8)

Annual
visual
inspection
of
closed
vent
system
and
control
device.
264.1088(
c)
and
(
d)
265.1089(
c)
and
(
d)
Record
repair
results.
264.1089(
a)(
6)
265.1090(
a)(
6)

Annual
Method
21
monitoring
of
closed
vent
system.
264.1088(
c)
265.1089(
f)(
3)(
i)
Record
monitoring
results.
264.1089(
a)(
7)
265.1090(
7)

Repair
leaks
detected
by
inspection
or
monitoring
264.1088(
c)
265.1089(
f)(
7)
Record
repair
results.
264.1089(
a)(
8)
265.1090(
a)(
8)

Manage
carbon
removed
from
carbon
adsorption
system.
264.1087(
c)(
3)(
i)
265.1088(
c)(
3)(
i)
Record
carbon
management
methods.
264.1089(
a0(
10)
265.1090(
a)(
10)

Affected
Waste
Management
Unit
Substantive
Requirement
Recordkeeping
Requirement
14
Container
with
a
design
capacity
less
than
or
equal
to
.46m3
equipped
with
a
cover
and
complies
with
all
applicable
DOT
regulations.
Annual
testing
method
of
transportation
containers
by
Method
27.
264.1086(
b)(
1)(
iii)
265.1087(
b)(
1)(
iii)
Record
Method
27
test.
264.1089(
a)(
5)
265.1090(
a)(
5)

ii.
Respondent
Activities
Respondent
Activities
Read
instructions.

Sample
waste
streams
and
make
waste
determinations
at
the
point
of
generation.

Install,
calibrate,
maintain,
and
operate
floating
roof
or
vapor
recovery
system.

Take
gap
measurements,
inspect
primary
and
secondary
roofs.

Write
the
notifications
and
reports
listed
above
­
4(
b)(
i)
Reports
Enter
information
required
to
be
recorded
above
­
4(
b)(
i)
Recordkeeping
Inspect
and
monitor
difficult
and/
or
unsafe
tank
roofs.

Monitor
and
inspect
cover
fittings,
roofing
systems,
closed
vent
systems.

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
Review
notifications
and
reports
required
to
be
submitted
by
industry.

Inspect
the
facility
for
compliance
including
records
and
reports.

Input,
analyze,
and
maintain
data
in
the
Resource
Conservation
and
Recovery
database
known
as
RCRIS.

5(
b)
Collection
Methodology
and
Management
15
The
recommended
standards
are
applicable
to
TSDF
subject
to
the
existing
RCRA
Subtitle
C
permitting
requirements.
The
standards
require
organic
emission
control
equipment
to
be
used
on
permitted
and
interim­
status
TSDF
tanks,
surface
impoundments
and
containers
that
manage
hazardous
waste
with
an
average
volatile
organic
concentration
at
the
point
of
waste
generation
greater
than
or
equal
to
500
parts
per
million
by
weight
(
ppmw)
on
a
mass­
weighted
average
basis.
In
addition,
the
recommended
standards
are
applicable
to
hazardous
waste
generators
accumulating
hazardous
wastes
in
tanks
and
containers
pursuant
to
conditions
specified
in
40
CFR
Part
262.34
(
a).
These
units
are
exempt
from
RCRA
Subtitle
C
permitting
requirements
provided
the
waste
generator
accumulates
waste
In
the
unit
for
no
more
than
90
days
and
complies
with
the
control
requirements
specified
in
40
CFR
Part
265,
Subparts
I
and
J.

The
standards
are
not
applicable
to
certain
waste
management
units.
For
example,
the
requirements
of
the
Subpart
CC
standards
do
not
apply
to;
a
tank
or
surface
impoundment
in
which
an
owner
or
operator
stops
adding
hazardous
waste
and
begins
undergoing
closure
or
which
is
closed
in
accordance
with
existing
RCRA
regulations;
a
container
that
has
a
design
capacity
less
than
0.1
m3
(
26.4
gallons);
or
a
tank,
surface
impoundment
or
container
that
contains
hazardous
waste
prior
to
the
rule's
effective
date
if
no
new
hazardous
waste
is
added
to
the
unit
on
or
after
the
effective
date.

Each
owner
or
operator
of
an
affected
tank,
surface
impoundment
or
container
is
required
by
the
recommended
standards
to
comply
with
the
requirements
summarized
below.

i.
Standards
for
Tanks.
The
owner
or
operator
of
a
tank
used
to
manage
hazardous
waste
with
a
mass­
weighted
average
volatile
organic
content
greater
than
or
equal
to
500
ppmw
at
the
point
of
waste
generation
is
required
to
install
and
use
emission
control
equipment.
The
control
equipment
requirements
are
to
install,
operate,
and
maintain
either
a
cover
connected
through
a
closed­
vent
system
to
a
control
device,
an
external
floating
roof,
a
fixed
roof
with
an
internal
floating
cover,
or
a
pressure
tank
that
operates
with
no
detectable
organic
emissions.
An
owner
or
operator
is
allowed
to
use
a
cover
without
a
closed­
vent
system
and
control
device
on
a
tank
that
satisfies
all
of
the
following
conditions:
(
1)

the
hazardous
waste
managed
in
the
tank
is
not
mixed,
stirred,
agitated,
or
circulated
within
the
tank
by
the
owner
or
operator
using
a
process
that
results
in
splashing,
frothing,
or
visible
turbulent
flow
on
the
waste
surface
during
normal
process
operations;
(
2)
no
waste
fixating,
heat­
using
(
except
the
minimum
heating
required
to
prevent
waste
freezing
or
to
maintain
adequate
waste
flow
conditions
for
continuing
normal
process
operations
during
cold
weather),
or
heat
generating
process
is
conducted
In
the
tank;
and
(
3)
either
the
tank
capacity
is
less
than
75
m3
(
20,000
gallons)
and
the
maximum
organic
vapor
pressure
16
is
less
than
76.6
kPa
(
11.1
psi),
the
tank
capacity
is
less
than
151
m3
(
40,000
gallons)
and
the
maximum
organic
vapor
pressure
is
less
than
27.6
kPa
(
4.0
psi),
or
the
capacity
of
the
tank
is
equal
to
or
greater
than
151
m3
and
the
maximum
organic
vapor
pressure
is
lese
then
5.2
kPa
(
0.75
psi).

ii.
Standards
for
Surface
Impoundments.
The
owner
or
operator
of
a
surface
impoundment
used
to
manage
hazardous
waste
with
a
mass­
weighted
average
volatile
organic
content
greater
than
or
equal
to
500
ppmw
at
the
point
of
waste
generation
is
required
to
install
and
use
emission
control
equipment.

The
control
equipment
requirement
is
to
install,
operate
and
maintain
either
a
cover
or
enclosure
connected
through
a
closed­
vent
system
to
a
control
device.
An
owner
or
operator
is
allowed
to
use
a
contact
cover
(
e.
g.,
floating
membrane
cover)
without
a
closed­
vent
system
and
control
device
on
a
surface
impoundment
that
satisfies
all
of
the
following
conditions:
(
1)
the
hazardous
waste
managed
in
the
surface
impoundment
is
not
mixed,
stirred,
agitated,
or
circulated
within
the
surface
impoundment
by
the
owner
or
operator
using
a
process
that
results
in
splashing,
frothing,
or
visible
turbulent
flow
on
the
waste
surface
during
normal
process
operations;
and
(
2)
no
waste
fixating,
heat­
treating
or
heatgenerating
process
is
conducted
in
the
surface
impoundment.

iii.
Standards
for
Containers.
The
owner
or
operator
of
a
container
used
to
manage
hazardous
waste
with
a
mass­
weighted
average
volatile
organic
content
greater
than
or
equal
to
500
ppmw
is
required
to
use
the
following
procedures.
The
owner
or
operator.
must
place
the
hazardous
waste
either
into
a
container
equipped
with
a
cover
that
operates
with
no
detectable
organic
emissions
when
all
openings
are
secured
in
a
closed,
sealed
position;
or
a
container
having
a
design
capacity
less
than
or
equal
to
0.42
m3
(
110
gallons)
that
complies
with
all
applicable
Department
of
Transportation
regulations
for
packaging
hazardous
waste
for
transport
under
49
CFR
Part
178;
or
a
container
that
is
attached
to
or
forms
a
part
of
any
truck,
trailer,
or
railcar
and
has
been
tested
for
organic
vapor
tightness
within
tho
preceding
12
months
in
accordance
with
EPA
Method
27.
A
container
is
required
to
be
covered
except
when
waste
is
being
added,
removed,
inspected,
or
sampled
or
the
container
is
vented
in
accordance
with
good
engineering
and
safety
practices
for
handling
flammable,
combustible,
explosive,
or
other
hazardous
materials.
A
loading
operation
conducted
by
pumping
into
a
container
having
a
design
capacity
greater
than
or
equal
to
0.42
m3
(
approximately
110
gallons)
must
be
performed
using
a
conveyance
system
that
uses
a
tube
(
e.
g.,
pipe
or
hose)
to
add
waste
into
the
container
below
the
waste
surface
or
within
15.2
cm
(
6
inches)
of
the
bottom
of
the
container.
A
container
used
tor
waste
fixation
is
required
(
during
the
fixation
process)
to
be
located
in
an
enclosure
with
a
closed­
vent
system
that
is
operating
with
sufficient
airflow
to
capture
and
route
all
organic
vapors
vented
from
the
container
to
a
17
control
device.
The
enclosure
may
have
permanent
or
temporary
openings
but
must
be
maintained
at
a
pressure
below
atmospheric
pressure
such
that
whenever
an
open
container
is
placed
inside
the
enclosure
no
organic
vapors
released
from
the
container
exit
through
the
openings.

iv.
Standards
for
Closed­
Vent
Systems
and
Control
Devices.
The
requirements
under
the
recommended
Subpart
CC
standards
for
an
individual
closed­
vent
system
with
control
device
are
identical
to
those
already
applicable
to
TSDF
owners
and
operators
under
Subpart
AA
in
40
CFR
Parts
264
and
265.
The
Subpart
AA
standards
were
promulgated
in
June
of
1990
and
require
TSDF
owners
and
operators
to
use
closed­
vent
systems
and
control
devices
to
control
organic
air
emissions
from
process
vents
associated
with
distillation,
fractionation,
thin­
film
evaporation,
solvent
extraction,
and
air
or
steam
stripping
operations
at
a
TSDF.

v.
Waste
Determinations.
If
an
owner
or
operator
chooses
to
determine
if
a
particular
tank,

surface
impoundment,
or
container
is
not
subject
to
specific
control
requirements
on
the
basis
of
the
volatile
organic
concentration
at
the
point
of
waste
generation
or
organic
vapor
pressure
of
the
hazardous
waste
being
managed
in
the
unit,
the
owner
or
operator
is
required
to
perform
periodic
waste
determinations.
Either
direct
measurement
or
knowledge
of
the
waste
is
used
to
determine
that
a
waste
contains
a
mass­
weighted
average
concentration
at
the
point
of
waste
generation
of
less
than
500
ppmw
volatile
organics
or
is
below
the
organic
vapor
pressure
limit.

Direct
measurement
of
the
waste
volatile
organic
concentration
or
organic
liquid
vapor
pressure
is
performed
using
EPA
reference
test
methods.
Knowledge
constitutes
documentation
that
conclusively
shows
that
the
waste
volatile
organic
concentration
or
organic
vapor
pressure
is
below
the
specified
limit
under
all
conditions.
For
example,
a
company
that
generates
a
hazardous
waste
as
a
result
of
manufacturing
a
product
could
provide
the
EPA
with
evidence
that
no
volatile
organic
chemicals
are
used
in
the
manufacturing
process.

The
waste
determination
for
a
waste
generated
as
a
continuous
flow
needs
to
be
performed
initially
before
the
first
time
any
portion
of
the
hazardous
waste
is
placed
in
a
unit
subject
to
the
final
standards
and
repeated
at
least
annually.
In
addition,
the
owner
or
operator
is
required
to
perform
a
new
waste
determination
whenever
changes
to
the
process
generating
or
treating
the
hazardous
waste
could
potentially
cause
the
average
volatile
organic
concentration
to
increase
to
or
above
500
ppmw
or
cause
the
treatment
process
performance
to
decline
below
the
minimum
efficiency
requirements
specified
in
the
rule.
For
a
hazardous
waste
that
is
generated
as
a
discrete
quantity
of
material
from
a
batch
process,
sequenced
or
intermittent
operation,
or
non­
continuous
source,
the
waste
determination
must
be
18
performed
for
each
discrete
quantity
of
hazardous
waste
generated
before
the
waste
is
placed
in
a
waste
management
unit
not
controlled
for
organic
emissions.

vi.
Monitoring
and
Inspection
Requirements.
To
ensure
that
emission
control
equipment
is
properly
operated
and
maintained,
the
recommended
standards
require
the
owner
or
operator
to
include
certain
emission
control
equipment
items
as
part
of
the
inspections
the
owner
or
operator
is
already
conducting
to
comply
with
existing
RCRA
standards
(
e.
g.,
40
CFR
264.195
for
tanks,
40
CFR
264.254
for
surface
impoundments,
40
CFR
264.174
for
containers).
During
the
visual
inspections,
emission
control
equipment
covers
on
tanks
are
to
be
checked
semiannually
by
the
facility
workers
to
ensure
that
equipment
is
being
used
properly
(
i.
e.,
covers
are
closed
and
latched
except
when
an
opening
must
be
used
in
accordance
with
conditions
specified
in
the
rules)
and
the
equipment
is
being
maintained
in
good
condition
(
e.
g.,
no
visible
holes,
gaps,
tears,
or
splits
have
developed
in
covers).

Continuous
monitoring
of
control
device
operation
is
required
under
the
rules.
This
involves
the
use
of
automated
instrumentation
to
measure
critical
operating
parameters
that
indicate
whether
the
control
device
is
operating
correctly
or
is
malfunctioning.
Semiannual
leak
detection
monitoring
using
EPA
Reference
Method
21
also
is
required
for
certain
cover
components
to
ensure
gaskets
and
seals
are
in
good
condition,
and
for
closed­
vent
systems
to
ensure
all
fittings
remain
leak­
tight.
In
addition,
each
closed­
vent
system
must
be
monitored
for
leaks
using
Reference
Method
21
at
least
once
per
year.

vii.
Rcordkeeping
Requirements.
To
provide
the
EPA
enforcement
personnel
with
a
means
of
verifying
compliance
with
the
recommended
standards,
the
owner
or
operator
is
required
to
record
certain
information
documenting
emission
control
equipment
performance
and
maintenance
in
the
onsite
facility
operating
logs
or
files.
This
information
will
be
available
for
review
by
the
EPA
enforcement
personnel
during
on­
site
compliance
inspection.
The
information
to
be
collected
and
recorded
includes:

the
results
of
all
waste
determinations
such
as
of
volatile
organic
concentration
at
the
point
of
generation
and
organic
vapor
pressure;
waste
determination
documentation
for
units
not
using
air
emission
controls
in
accordance
with
the
rule
control
requirements;
design
specifications
for
closed
vent
systems
and
control
equipment
inspection
and
control
equipment;
emission
control
equipment
inspection
and
monitoring
results;
Reference
Method
27
test
results;
control
device
exceedances
and
actions
taken
to
remedy
them;
leak
repairs;
management
or
carbon
removed
from
carbon
adsorption
systems,
and
identification
of
equipment
fittings
designated
as
difficult
or
unsafe
to
monitor
or
inspect.

At
a
facility
where
air
emission
control
equipment
required
by
the
recommended
rules
cannot
be
in
operation
by
the
effective
date,
the
owner
or
operator
is
required
to
prepare
and
record
an
19
implementation
schedule
for
the
air
emission
control
equipment.
The
implementation
schedule
must
specify
dates
by
which
progress
will
be
completed
by
the
facility
owner
or
operator
that
demonstrates
and
ensures
the
required
air
emission
controls
are
in
operation
no
later
than
three
years
after
promulgation
of
the
rules.

Consistent
with
§
§
264.73
and
265.73,
the
recommended
standards
require
that
all
records
be
maintained
in
the
facility
operating
record
until
facility
closure
except
records
and
results
of
inspections
and
monitoring,
which
need
to
be
kept
for
at
least
three
years
from
the
date
of
entry.

viii.
Reporting
Requirements.
The
recommended
reporting
requirements
for
the
owner
or
operator
of
a
TSDF
are
simple
and
straightforward.
There
are
no
reporting
requirements
for
the
owner
or
operator
of
an
interim
status
TSDF.
The
owner
or
operator
of
a
permitted
TSDF
is
not
required
to
submit
any
reports
unless:
(
1)
a
control
device
malfunction
is
not
corrected
within
24
hours
of
detection;
or
(
2)
a
hazardous
waste
with
organic
content
at
the
point
of
waste
generation
that
equals
or
exceeds
the
500
ppmw
mass­
weighted
average
volatile
organic
concentration
or
that
has
been
treated
by
a
process
that
fails
to
meet
applicable
general
requirements
in
the
recommended
rule
is
managed
in
a
unit
without
proper
emission
controls.
If
any
of
these
events
(
referred
to
as
"
exceedances)
occur,
the
owner
or
operator
is
required
to
maintain
a
record
of
the
exceedance.
For
control
device
exceedance,
the
owner
or
operator
is
required
to
submit
a
written
report
to
the
EPA
on
a
semiannual
basis
describing
any
exceedances
that
occurred
during
the
past
6­
month
period
and
explain
why
each
exceedance
occurred
and
what
action
was
taken
to
remedy
the
situation.
For
waste
exceedances,
the
owner
or
operator
is
required
to
submit
a
written
report
to
the
EPA
within
15
calendar
days
of
the
time
that
the
owner
or
operator
becomes
aware
of
the
circumstances
explaining
why
the
hazardous
waste
was
not
managed
in
accordance
with
the
requirements
of
the
standards.

For
some
TSDF
tanks,
an
owner
or
operator
is
allowed
to
use
either
a
fixed
roof
with
an
internal
floating
cover
or
an
external
floating
roof
as
an
alternative
to
a
cover
vented
to
a
control
device.

Reporting
requirements
for
internal
and
external
floating
roofs
require
the
owner
or
operator
to
notify
the
EPA
at
least
30
days
prior
to
the
filling
of
the
empty
tank
to
provide
the
EPA
the
opportunity
to
inspect
the
roof
and
seals
for
compliance
with
the
standards
prior
to
refilling.
This
requirement
is
necessary
because
the
internal
or
external
roof
seals
can
only
be
inspected
when
the
tank
is
empty.
Inspection
is
required
initially
and
no
more
than
once
every
five
years.

5(
c)
Small
Entity
Flexibility
The
EPA
recognizes
that
owners
or
operator
of
small
businesses
often
do
not
have
the
20
personnel
and
financial
resources
available
to
large
companies
for
performing
information
collection.

However,
only
information
is
required
for
the
recommended
standards
that
the
EPA's
experience
has
demonstrated
to
be
necessary
to
determine
compliance
with
air
emission
standards.
Separate
and
simplified
requirements
for
small
businesses
such
as
less
frequent
monitoring
and
inspection
of
emission
control
equipment
operation
cannot
be
used
without
compromising
the
protection
of
human
health
and
the
environment
that
would
be
provided
by
the
recommended
standards.
The
minimum
information
that
the
EPA's
experience
has
demonstrated
to
be
necessary
to
determine
compliance
with
air
emission
standards
is
required.
The
specific
information
selected
serves
both
the
public
interest,
by
ensuring
all
TSDFs
comply
with
the
air
emission
standards,
and
the
best
interest
of
the
individual
owner
or
operator
to
clearly
demonstrate
to
the
EPA
enforcement
inspector
that
a
unit
is
in
compliance.

The
reporting,
notification
and
recordkeeping
burden
to
respondents
has
been
minimized
by
requiring
the
collection
or
reporting
of
only
that
information
which
the
Agency
considers
essential
to
ensure
that
affected
storage
tanks,
surface
impoundments
and
containers
of
hazardous
waste
exceeding
500
ppmw
are
properly
maintained
and
operated
on
a
continuous
basis.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Section
6(
d),
Table
2:
Industry
Burden.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Section
6(
d),
Table
2
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
RCRA
Subpart
CC.
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
in
this
ICR.
Responses
to
this
information
collection
are
mandatory.
(
See
Section
4(
b)(
i).
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.

The
burden
to
the
Agency
can
be
found
at
Section
6(
c),
Table
1.

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
617,040
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
RCRA
program,
the
previously
approved
ICR,
and
any
comments
received.
21
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
$
49.62
per
hour
for
Technical
labor
cost.
This
rate
is
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
Table
1­
1.
Summary,
United
States:
Mean
hourly
earnings
and
weekly
hours
by
selected
characteristics,
private
industry
and
State
and
local
government,

National
Compensation
Survey,
1998
The
wage
rate
includes
a
110%
overhead
cost.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
cost
associated
with
the
information
collection
activity
in
the
standards
is
labor
cost.

There
are
capital
and
operations
and
maintenance
costs.
The
capital
startup
costs
are
a
one
time
cost
when
a
facility
becomes
subject
to
the
standard.
The
annual
operations
and
maintenance
costs
are
the
ongoing
costs
to
maintain
the
emission
control
equipment.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
The
total
Capital/
Start­
up
costs
for
this
ICR
are
$
$
1,460,333.
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
truncated
to
show
the
cost
in
thousands
of
dollars.
This
is
the
estimated
cost
for
the
269
new
facilities.
There
are
no
Operating
and
Maintenance
(
O&
M)
Costs
for
this
ICR,
therefore,
the
total
Capital
and
O&
M
cost
is
$
1,460,333.

Section
6
(
c),
Table
1
identifies
the
costs
to
the
Agency
associated
with
the
analysis
of
submitted
information
relating
to
new,
modification,
or
reconstruction
notices
sent
to
the
Agency.
Publication
and
distribution
of
the
information
are
part
of
the
Resource
Conservation
and
Recovery
Information
System
(
RCRIS)
which
is
jointly
operated
and
maintained
by
the
EPA's
Office
of
Solid
Waste
(
OSWER)
and
Office
of
Compliance
(
OECA)
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
incidentally
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
burden
to
the
Agency
over
the
next
three
years
from
the
recordkeeping
and
reporting
requirements
is
estimated
to
be
52,380
hours.
The
costs
to
conduct
this
effort
have
been
calculated
on
the
basis
of
$
17.09
per
hour
plus110
percent
overhead.
The
average
annual
cost
to
the
Agency
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
2,545,725.
This
cost
is
based
on
the
possibility
of
a
facility
reporting
a
waste
exceedance
report,
inspecting
facilities
for
compliance
with
Subpart
CC
regulations
and
possible
enforcement
follow­
up
for
violations.
22
6(
c)
Table
1
­
Estimating
Agency
Burden
and
Cost
as
a
Result
of
RCRA
Subpart
CC,
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers
Total
Annual
Total
Annual
Hours
per
Annual
Number
Person
Hours
Labor
Costs
Occurrence
of
Responses
per
year
per
year
a
(
A)
(
B)
C
=
(
AxB)
(
D)
23
1.
REVIEW
REPORTS
A.
Waste
Exceedance
Reports
4
63
b
252
9,044
B.
Control
Device
Exceedance
Reports
4
32
c
128
4,594
2.
COMPLIANCE
INSPECTIONS
A.
Select
site
and
review
permit
8
520
e
4,160
149,302
B.
Travel
to/
from
site,
labor
8
520
e
4,160
149,302
Travel
to/
from
site,
transp
d
520
156,000
C.
On­
site
Inspection
8
520
e
4,160
149,302
D.
Prepare
Inspection
Report
16
520
e
8,320
298,605
3.
ENFORCEMENT
ACTIONS
A.
Notice
of
Non­
Compliance
160
52
f
8,320
298,605
B.
Follow­
up
Enforcement
9
40
52
f
2,080
74,651
Travel
to/
from
site,
transpd
52
15,600
C.
Litigation
2,080
10h
20,800
1,381,120
a.
1
TOTAL
ESTIMATED
HOURS
AND
COST:
52,380
$
2,545,725
Assumptions
a
Personnel
costs
based
on
$
17.09
(
GS­
10,
Step
1)
plus
110
percent
overhead
($
35.89)
for
staff.
a.
1
Personnel
costs
based
on
$
31.62
(
GS­
14,
Step
1)
plus
110
percent
overhead
($
66.40)
for
attorney.
b
Annual
number
of
responses
assumes
1%
of
waste
determination
results
in
an
exceedance
(
1
%
of
8,997
potential
respondents)
c
Annual
number
of
responses
assumes
.5%
of
control
devices
malfunction
resulting
in
an
exceedance
(.
5%
of
8,997
potential
respondents)
d
Average
cost
per
trip
for
transportation
and
per
diem
is
assumed
to
be
$
300.
e
Annual
number
of
inspections
assumes
each
EPA
Regional
office
schedules
one
compliance
inspection
of
a
TSDF
per
week.
f
Annual
number
of
notice
of
non­
compliance
assumes
10%
of
inspected
facilities
require
enforcement
actions
to
correct
a
problem.
9
Labor
hours
and
travel
costs
per
follow­
up
enforcement
inspection
assumed
to
be
equal
to
values
assumed
for
one
compliance
inspection
as
shown
in
Item
2B,
above.
h
Annual
number
of
litigations
assumes
each
EPA
Regional
Office
initiates
one
legal
case
against
a
TSDF
owner/
operator
per
year.

6(
d)
Table
2
­
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
as
a
Result
of
RCRA
SUBPART
CC
Hours
per
Occurrences
Hours
per
Occurrence
per
respondent
respondent
Respondents
Hours
per
Cost
per
per
year
per
year
year
yeara
(
A)
(
B)
C
=
(
AxB)
(
D)
E
=
(
CxD)
(
F)

1.
APPLICATIONS
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Not
Applicable
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
2.
SURVEY
AND
STUDIES
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Not
Applicable
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
24
.
.
.
.
.
.
.
3.
REPORTING
REQUIREMENTS
A.
Read
Instructions
4
1
4
6,318
25,272
1,253,997
B.
Required
Activities
0
C.
Create
Information
0
D.
Gather
Existing
Information
1
1
1
6,318
6,318
313,499
E.
Write
Report
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Not
Applicable
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
4
1
4
6,318
25,272
1,253,997
B.
Plan
Activities
16
1
16
6,318
101,088
5,015,987
C.
Implement
Activities
I.
Waste
determination
for
VOC
concentration
at
the
point
of
origination
a.
Waste
determination
.
once
every
12
months
2
1
2
6,318
12,632
626,800
II.
Waste
determination
for
treated
hazardous
waste
a.
waste
determination
for
batch
process
once
every
12
months
2
1
2
6,318
12,632
626,800
III.
Inspect
and
monitor
each
closed
vent
system
.08
365
29
4,413
127,977
6,350,219
IV.
Write
and
implement
an
inspection
plan
and
place
in
the
facility
inspection
plan
4
1
4
90
360
17,863
V.
Inspect
all
coverings
and
monitor
for
initial
detectable
emissions,
initial
operation,
using
Method
21
a.
Tanks
4
1
4
90
360
17,863
b.
Surface
Impoundments
5
1
5
90
450
22,329
c.
Containers
2
1
2
90
180
8,932
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
as
a
Result
of
RCRA
SUBPART
CC,
cont.

Hours
per
Occurrences
Hours
per
Occurrence
per
respondent
respondent
Respondents
Hours
per
Cost
per
per
year
per
year
year
yeara
(
A)
(
B)
C
=
(
AxB)
(
D)
E
=
(
CxD)
(
F)

VI.
Inspect
all
coverings
and
monitor
for
detectable
emissions
at
least
once
every
6
months,
using
Method
21
25
a.
Tanks
(
includes
Method
27
­
transportation
vehicles)
4
2
8
6,31
8
50,544
2,507,993
b.
Surface
Impoundments
5
2
10
110
1,110
55,078
c.
Containers
2
2
4
6,318
25,272
1,253,997
Vll.
O/
O
writes
and
implements
plan
with
schedule
to
inspect
unsafe
covers
1
1
1
90
90
4,466
VIII.
O/
O
writes
and
implements
plan
with
schedule
to
inspect
difficult
to
inspect
covers
1
1
1
90
90
4,466
lX.
Notify
RA
30
days
in
advance
of
any
gap
measurements
to
be
taken
1
1
1
6,318
6,318
313,499
X.
Notify
RA
30
days
in
advance
of
filling
or
refilling
of
tank
1
1
1
632
b
632
31,360
XI.
Secondary
seal
inspection
once
a
year
4
1
4
6,318
25,272
1,253,977
XII.
Primary
seal
inspection
once
every
5
years
4
1
4
1264
c
5,056
250,879
XIII.
General
standards,
Record
ID
number
of
BIF
or
incinerator
used
to
treat
waste
.25
1
.25
90
23
1,141
XIV.
Tanks
with
unsafe
covers,
record
list
of
identification
numbers
for
tanks
with
unsafe
covers,
explain
why
its
unsafe
.30
1
.30
90
27
1,340
and
a
plan
to
inspect
and
monitor
each
cover
XV.
Tanks
with
difficult
to
inspect
covers,
record
list
of
identification
numbers,
.30
1
.30
90
27
1,340
explain
why
difficult
and
plan
to
inspect
and
monitor
each
cover
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
as
a
Result
of
RCRA
SUBPART
CC,
cont.

Hours
per
Occurrences
Hours
per
Occurrence
per
respondent
respondent
Respondents
Hours
per
Cost
per
per
year
per
year
year
yeara
(
A)
(
B)
C
=
(
AxB)
(
D)
E
=
(
CxD)
(
F)

D.
Develop
Record
System
16
1
16
90
1,440
71,453
26
E.
Time
to
Enter
Information
I.
Record
each
cover
installed
on
a
tank
and
certifies
to
its
specifications.
.25
1
.25
90
23
1,141
II.
Record
each
floating
membrane
installed
on
a
surface
impoundment
and
certifies
to
its
specifications.
.25
1
.25
90
23
1,141
III.
Record
each
enclosure
used
to
control
air
emissions
and
certifies
to
its
specifications.
.25
1
.25
90
23
1,141
IV.
Record
for
each
closed
vent
and
control
device
it
is
designed
to
operate
at
the
performance
level
for
tank,
surface
impoundment
or
container.
.25
1
.25
90
23
1,141
V.
Records
all
Method
27
tests
performed
by
O/
O
for
each
container.
.5
1
.5
6,318
3,159
156,748
Vl.
Records
all
visual
inspections
of
each
tank,
surface
impoundment
and
container,
including
covers.
1
1
1
6,318
6,318
313,499
Vll.
Records
date
of
each
attempt
to
repair
leak,
repair
methods
applied
and
date
of
successful
repair
.5
2
1
6,318
6,318
313,499
VlII.
Records
all
continuous
monitoring
.25
365
91
632
57,512
2,853,745
IX.
Records
management
of
carbon
removed
from
a
carbon
adsorption
system
.5
2
1
4,413
4,413
218,973
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
as
a
Result
of
RCRA
SUBPART
CC,
cont..

Hours
per
Occurrences
Hours
per
Occurrence
per
respondent
respondent
Respondents
Hours
per
Cost
per
per
year
per
year
year
yeara
(
A)
(
B)
C
=
(
AxB)
(
D)
E
=
(
CxD)
(
F)

E.
Time
to
Enter
Information,
cont.

Tanks
with
air
emission
controls
X.
Records
date
and
time
of
27
each
sample
.25
2
.5
6,318
3,159
156,750
XI.
Records
results
of
each
sample
.25
2
.5
6,318
3,159
156,750
XII.
Records
tank
dimensions
and
design
capacity
.30
1
1
90
90
4,466
Tanks
with
alternative
emissions
controls
(
floating
roofs)

XIII.
Records
in
the
facility
operating
plan
the
internal
floating
roof
.25
1
.25
54
14
695
XIV.
Records
the
equipment
design
and
certifies
that
it
meets
applicable
requirements
.25
1
.25
54
14
695
XV.
Records
each
inspection,
the
tank,
date,
what
components
inspected.
.25
2
.5
6,318
3,159
156,750
a.
If
defects
found,
identify
the
tank
and
describe
the
repairs
made.
.25
2
.5
6,318
3,159
156,750
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
as
a
Result
of
RCRA
SUBPART
CC,
cont..

Hours
per
Occurrences
Hours
per
Occurrence
per
respondent
respondent
Respondents
Hours
per
Cost
per
per
year
per
year
year
yeara
(
A)
(
B)
C
=
(
AxB)
(
D)
E
=
(
CxD)
(
F)

E.
Time
to
Enter
Information,
cont.

XVI.
Records
in
the
facility
operation
plan
the
external
floating
roof.
.25
1
.25
202
51
2,531
XVII.
Records
the
equipment
design
and
certifies
that
it
meets
28
applicable
requirements
.25
1
.25
202
51
2,531
XVIII.
Records
gap
measurements
of
the
tank,
date
of
inspection,
raw
data
and
calculations.
.
.25
1
.25
6,318
1,580
78,400
a.
If
defects
found,
records
the
tank,
date
tank
was
emptied
or
repairs
made
and
the
nature
of
the
repair.
.25
1
.25
6,318
1,580
78,400
F.
Train
Personnel
i.
Waste
determination
methods
8
1
8
6,318
50,544
2,507,933
ii.
Control
equip.
inspection
&
monitor
8
1
8
6,318
50,544
2,507,933
G.
Audits
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
Not
Applicable
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

TOTAL
ESTIMATED
ANNUAL
HOURS
617,040
TOTAL
ESTIMATED
ANNUAL
COST
$
30,930,887
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
as
a
Result
of
RCRA
SUBPART
CC,
cont..

Assumptions
for
Table
2
a
­
Assume
an
hourly
wage
of
$
49.62
which
includes
the110%
overhead
cost.
b
­
Assume
10%
of
respondents
will
empty
and
re­
fill
a
tank
c
­
Assume
that
20%
of
the
tank
roofs
will
be
inspected
each
year
Total
number
of
respondents
subject
to
TSDF
requirements
2,025
70%
subject
to
these
rules
1418
Total
number
of
respondents
subject
to
LQG
requirements
20,316
25%
subject
to
these
rules
5079
Total
number
of
respondents
over
a
three
year
period
6497
Number
of
respondents
­
Annualized
6318
1418
TSDFs
averaging
4
Tanks
and
15
containers
subject
to
regs
4
Tanks
x
1418
=
5672
15
containers
x
1418
=
21,270
29
5079
LQGs
averaging
1
Tank
(
25%)
or
6
containers
(
75%)
subject
to
regs
1
Tank
x
5079
x
.25
=
1270
6
containers
x
5079
x
.75
=
22,856
Total
Tanks
subject
=
6942
Total
Containers
subject
=
44,126
10%
of
Containers
using
enclosed
close­
vent
system
=
4,413
Total
Surface
Impoundments
=
110
Respondents
using
Method
25D
for
waste
determinations
10%
Respondents
reporting
waste
exceedances
1%
Respondents
reporting
control
device
operating
parameter
exceedances
.5%
Average
number
of
waste
streams
on­
site
10
Table
3.
CAPITAL
EXPENDITURE
OF
MONITORING
EQUIPMENT
REGULATING
AIR
EMISSION
STANDARDS
FOR
TANKS,
SURFACE
IMPOUNDMENTS
AND
CONTAINERS,
RCRA
SUBPART
CC
Number
Installation
Cost
#
of
New
Install­
Cost
this
(
A)
(
B)
C=(
AxB)
ons
ICR
(
D)
Period
E=(
BxD)

A.
Roofs
and
Closed
Vent
Systems
Item
External
Floating
Roof
4671
$
18,500
a
$
79,662,000
202
3,737,000
Internal
Floating
Roof
1246
$
10.000
a
$
11,250,000
54
540,000
Closed
Vent
System
311
$
8,000
a
$
2,028,000
13
104,000
CAPITAL
EXPENDITURE
FROM
2000
­
2003
269
$
4,381,000
CAPITAL
EXPENDITURE
ANNUALIZED
90
$
1,460,333
B.
Continuous
Monitoring
Inspections
30
Hours
per
Occurrences
Hours
per
Occurrence
per
respondent
respondent
Respondents
Hours
per
Cost
per
per
year
per
year
year
yeara
(
A)
(
B)
C
=
(
AxB)
(
D)
E
=
(
CxD)
(
F)

For
Closed
Vent
Systems:
4
1
4
6,318
25,272
1,253,997
For
Roof
Inspections/
Gap
Measurements:

Secondary
seal
inspection
once
a
year
4
1
4
6,318
25,272
1,253,997
Primary
seal
inspection
once
every
4
1
4
1,264
b
5,056
250,879
5
years
55,600
$
2,758,873
a
Cost
estimates
provided
by
ASTT
Corp.,
New
Providence,
PA.
An
installer
of
floating
roof
systems
and
VOC
monitors.
b
Assume
that
20%
of
the
floating
roofs
with
primary
seals
will
be
inspected
each
year.
31
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)

RCRA
Subpart
CC
90
*
6228
*
*

*
­
See
explanation
in
annual
responses
paragraph
The
total
number
of
affected
sources
is
6,318.
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
number
of
annual
responses
is
95.
This
assumes
1%
of
waste
determination
results
in
exceedance
(
1%
of
6,318
potential
respondents)
plus
the
assumption
that
.5%
of
control
devices
malfunction
resulting
in
an
exceedance
(.
5%
of
6,318).
This
number
is
in
column
E
of
the
Respondent
Universe
table.
It
is
shown
on
the
OMB
83­
I
form
in
block
13
b.

The
total
annual
capital,
O&
M
and
compliance
costs
to
the
regulated
entity
are
$
35,150,193,
while
Capital
and
O&
M
costs
are
$
1,460,333
and
are
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
Cost
Tables
See
Section
6(
c),
Table
1,
EPA's
Burden
for
complete
details.
In
summary,
the
burden
to
the
Agency
is
52,380
hours
at
a
cost
of
$
2,545,725
a
year.
Section
6(
d),
Table
2,
Respondents'
Burden
has
the
complete
details
for
industry.

In
summary,
the
burden
to
comply
with
RCRA
Subpart
CC
is
672,640
hours
at
a
cost
of
$
33,689,760
per
year.
Total
Capital
and
O&
M
costs
are
$
1,460,333.

6(
f)
Reasons
for
Change
in
Burden
The
change
in
burden
is
due
to
the
increase
in
the
number
of
facilities
subject
to
RCRA
Subpart
CC,
from
6,228
to
6,497
or
a
difference
of
269
facilities.
The
information
that
determined
this
change
(
increase)
was
data
obtained
from
comparing
1995
and
1997
(
most
recent
and
available)
RCRA
Biennial
Reports.

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,
32
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
a
respondent's
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,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.

20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1593.05
and
OMB
control
number
2060­
0318
in
any
correspondence.

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