1
SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers
(
40
CFR
part
264,
subpart
CC
and
40
CFR
part
265,
subpart
CC)
(
Renewal)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers
(
40
CFR
part
264,
subpart
CC
and
40
CFR
part
265,
subpart
CC)
(
Renewal)

1(
b)
Short
Characterization/
Abstract
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
33490),
and
promulgated
on
December
6,
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
of
hazardous
wastes
in
tanks,
surface
impoundments
and
containers
that
are
subject
to
subparts
I,
J
or
K
of
these
parts
except
for
Sections
264.1
and
265.1
and
those
management
units
identified
at
Sections
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)).

RCRA
subpart
CC
requires
controls
for
minimizing
the
release
of
volatile
organic
air
emissions
from
tanks,
surface
impoundments
and
containers
holding
hazardous
waste.
Records
and
reports
are
necessary
to
determine
that
the
standards
are
implemented
and
maintained
to
protect
human
health
and
the
environment.
All
reports
are
sent
to
the
delegated
State.
In
the
event
that
there
is
no
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.
The
data
collected
by
the
affected
facility
is
retained
at
the
facility
for
a
minimum
of
three
years.

The
potential
number
of
respondents
subject
to
these
regulations
is
6,209
over
the
next
three
years.
This
number
was
derived
by
the
following
methodology.
It
was
estimated
during
rule
development
that
70%
of
treatment,
storage
and
disposal
facilities
(
TSDFs)
and
25%
of
large
quantity
generators
(
LQGs)
would
be
subject
to
RCRA
subpart
CC
requirements.
Based
on
information
obtained
from
the
RCRA
Info
database,
there
are
2,393
TSDFs
and
18,135
LQGs.
The
regulated
universe
is
the
sum
of
applicable
TSDFs
and
LQGs.
Therefore,
the
following
applies:

70%
of
2,393
=
1,675
(
TSDFs
subject
to
RCRA
subpart
CC)
25%
of
18,135
=
4,534
(
LQGs
subject
to
RCRA
subpart
CC)
2
1,675
+
4,534
=
6,209
respondents
subject
to
RCRA
subpart
CC.

The
estimated
respondent
burden
for
this
Information
Collection
Request
(
ICR)
is
711,477
hours
at
a
cost
of
$
45,014,910.
Furthermore,
the
available
data
shows
that
no
new
facilities
will
become
subject
to
RCRA
subpart
CC
in
the
next
three
years.
OMB
approved
the
currently
active
ICR
without
any
"
Terms
of
Clearance."

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
air
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
air
emissions
from
TSDFs
are
estimated
to
be
approximately
1
million
megagrams
per
year.

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
for
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
for
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
recommended
standards
are
applicable
to
Treatment,
Storage
and
Disposal
facilities
(
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
3
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:
1)
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;
2)
a
container
that
has
a
design
capacity
less
than
0.1
cubic
meters
(
26.4
gallons);
or
3)
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
air
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
is
less
than
76.6
kilopascals
(
kPa)
[
11.1
pounds
per
square
inch
(
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
less
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
4
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
heat­
generating
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
massweighted
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
air
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
the
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
(
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
for
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
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
closedvent
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.
5
v.
Waste
Determinations.

If
an
owner
or
operator
chooses
to
determine
that
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
noncontinuous
source,
the
waste
determination
must
be
performed
for
each
discrete
quantity
of
hazardous
waste
generated
before
the
waste
is
placed
in
a
waste
management
unit
not
controlled
for
organic
air
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
6
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.
Recordkeeping
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
on­
site
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
of
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
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
40
CFR
Sections
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")
7
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
return
to
compliance.
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
for
external
floating
roofs
and
10
years
for
internal
floating
roofs.

The
collected
information
will
be
used
by
the
EPA
enforcement
personnel
to
ensure
that
the
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
requested
recordkeeping
and
reporting
are
required
under
40
CFR
parts
264
and
265.

3(
a)
Nonduplication
If
the
subject
standards
have
not
been
delegated,
the
information
is
sent
directly
to
the
appropriate
EPA
regional
office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
agency.

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
November
3,
2003
(
68
FR
62289).
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.
8
3(
c)
Consultations
Tom
Yarnick
was
consulted
to
discuss
the
recordkeeping
and
reporting
burden
of
these
rules
(
Tom
Yarnick;
Phone,
281­
870­
6068;
ExxonMobil).
Tom,
and
colleagues
that
he
has
spoken
to,
feel
that
40
CFR
part
264
subpart
CC
and
part
265
subpart
CC
are
unnecessarily
complex,
difficult
to
understand,
and
could
be
written
more
clearly.
Part
of
the
problem
is
that
personnel
responsible
for
managing
RCRA
hazardous
waste
are
often
not
familiar
with
the
terms
and
procedures
used
in
regulations
addressing
air
emission
controls.
The
other
problem
is
that
these
rules
are
written
in
a
way
that
makes
them
more
confusing
than
they
need
to
be.
They
contain
numerous
cross­
references
to
other
sections
of
the
rules
and
devote
too
many
pages
near
the
beginning
of
the
subpart
to
one
facility.
He
suggests
putting
the
discussion
of
the
Stonewall
Plant
at
the
end
of
the
subpart
or
including
it
as
an
appendix
to
avoid
confusing
the
many
readers
for
which
it
has
no
applicability.

To
determine
the
current
number
of
facilities
and
the
industry
growth
rate
for
this
ICR
EPA
personnel
in
the
Office
of
Solid
Waste
and
Emergency
Response
and
the
RCRA
Enforcement
Division
were
consulted.
The
main
source
for
the
number
of
facilities
and
growth
rate
was
the
Resource
Conservation
and
Recovery
Act
database,
called
RCRA
Info.

3(
d)
Effects
of
Less
Frequent
Collection
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
that
may
occur,
as
defined
in
the
rules.
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
9
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
(
or
delegated
State)
having
jurisdiction
for
a
particular
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
1320.5
(
d)(
2).

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
facilities
that
treat,
store,
or
dispose
of
RCRA
Subtitle
C
hazardous
waste.
Refer
to
the
following
table
for
the
applicable
Standard
Industrial
Classification
(
SIC)/
North
American
Industry
Classification
System
(
NAICS)
codes.
10
Regulation
SIC
Codes
NAICS
Codes
RCRA
subpart
CC
­
Standards
of
Performance
for
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers
20
thru
39
Series
31
thru
33
Series
4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
are
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:

Notification
Reports
The
owner
or
operator
notifies
the
RA
in
writing
that
hazardous
waste
generated
by
an
organic
peroxide
manufacturing
process
or
processes
meeting
the
conditions
of
paragraph
(
d)(
1)
of
this
section
are
managed
at
the
facility
in
tanks
or
containers
meeting
the
conditions
of
paragraph
(
d)(
2)
of
this
section.
264.1080(
d)(
3)

Not
withstanding
the
exemption,
the
Stonewall
Plant
at
Elkton,
WV
must
still
comply
with
264.1085
and
all
that
is
referenced
there
including
complying
with
264.1087,
264.1089
and
the
part
of
264.1090
applicable
to
surface
impoundments
and/
or
closed­
vent
systems
and
control
devices.
264.1080(
e)(
2)

The
Sistersville,
WV
plant
shall
provide
to
the
EPA
and
WVDEP
written
notification
of
the
actual
date
of
initial
startup
of
the
thermal
incinerator,
and
commencement
of
the
methanol
recovery
operation.
264.1080(
f)(
2)(
i)(
B)

Prior
to
each
inspection
of
the
internal
floating
roof
the
owner
or
operator
shall
notify
the
RA
in
advance
of
each
inspection
to
provide
the
RA
with
the
opportunity
to
have
an
observer
present
during
the
inspection
264.1084(
e)(
3)(
iv)

265.1085(
e)(
3)(
iv)
Notification
Reports
11
Prior
to
each
visual
inspection
of
an
internal
floating
roof
in
a
tank
that
has
been
emptied
and
degassed,
written
notification
shall
be
prepared
and
sent
by
the
owner
or
operator
so
that
it
is
received
by
the
RA
at
least
30
calendar
days
before
refilling
the
tank
except
when
an
inspection
is
not
planned
as
provided
for
in
paragraph
(
e)(
3)(
iv)(
B)
of
this
section
264.1084(
e)(
3)(
iv)(
A)

265.1085(
e)(
3)(
iv)(
A)

When
a
visual
inspection
is
not
planned
and
the
owner
or
operator
could
not
have
known
about
the
inspection
30
calendar
days
before
refilling
the
tank,
the
owner
or
operator
shall
notify
the
RA
as
soon
as
possible,
but
no
later
than
7
calendar
days
before
refilling
of
the
tank
264.1084(
e)(
3)(
iv)(
B)

265.1085(
e)(
3)(
iv)(
B)

Reports
The
reporting
requirements
of
264.1090
are
applicable
to
the
Sistersville,
WV
plant
and
are
applicable
to
surface
impoundments
and
closed­
vent
systems
with
control
devices
associated
with
surface
impoundments
264.1080(
f)(
1)(
iv)

The
Sistersville,
WV
plant
shall
comply
with
the
reporting
requirements
of
paragraphs
264.1080(
f)(
2)(
viii)(
A)
through
(
G)
of
this
section.
264.1080(
f)(
1)(
viii)

Each
owner
or
operator
managing
hazardous
waste
in
a
tank,
surface
impoundment,
or
container
exempted
from
using
air
emission
controls
as
specified
under
40
CFR
264.1082(
c)
shall
report
to
the
RA
each
occurrence
when
hazardous
waste
is
placed
in
a
waste
management
unit
in
noncompliance
with
40
CFR
264.1082(
c)(
1)
or
(
c)(
2)
of
this
part,
as
applicable.
The
owner
or
operator
shall
submit
a
written
report
within
15
calendar
days
of
the
time
that
they
become
aware
of
the
occurrence.
264.1090(
a)

Each
owner
or
operator
using
air
emission
controls
on
a
tank
in
accordance
with
40
CFR
264.1084(
c)
of
this
subpart
shall
report
to
the
RA
each
occurrence
when
hazardous
waste
is
managed
in
a
tank
in
noncompliance
with
40
CFR
264.1084(
b)
of
this
subpart.
The
owner
or
operator
shall
submit
a
written
report
within
15
calendar
days
of
the
time
that
they
become
aware
of
the
occurrence.
264.1090(
b)

Each
owner
or
operator
using
control
device
in
accordance
with
40
CFR
264.1087
of
this
subpart
shall
submit
a
semiannual
report
to
the
RA.
264.1090(
c)
Reports
12
A
report
to
the
RA
in
accordance
with
the
requirements
of
paragraph
(
c)
of
this
section
is
not
required
for
a
6
month
period
during
which
all
control
devices
subject
to
this
subpart
are
operated
by
the
owner
or
operator
such
that:
(
1)
During
no
period
of
24
hours
or
longer
did
a
control
device
operate
continuously
in
noncompliance
with
the
applicable
operating
values
defined
in
264.1035(
c)(
4);
and
(
2)
No
flare
was
operated
with
visible
emissions
for
5
minutes
or
longer
in
a
2­
hour
period,
as
defined
in
264.1033(
d).
264.1090(
d)

A
source
must
keep
the
following
records.

Recordkeeping
The
owner
or
operator
must
keep
a
written
operating
record
of
his
facility.
264.73
265.73
The
requirements
of
this
subpart,
except
for
the
recordkeeping
requirements
specified
in
264.1089(
i)
of
this
subpart,
are
administratively
stayed
for
a
tank
or
container
used
for
the
management
of
hazardous
waste
generated
by
organic
peroxide
manufacturing.

The
requirements
of
this
subpart,
except
for
the
recordkeeping
requirements
specified
in
264.1090(
i)
of
this
subpart,
are
administratively
stayed
for
a
tank
or
container
used
for
the
management
of
hazardous
waste
generated
by
organic
peroxide
manufacturing.
264.1080(
d)

265.1080(
d)
Recordkeeping
13
The
owner
or
operator
prepares
documentation
in
accordance
with
264.1089(
i)
of
this
subpart,
explaining
why
an
undue
safety
hazard
would
be
created
if
air
emission
controls
specified
in
264.1084
through
264.1087
of
this
subpart
are
installed
and
operated
on
the
tanks
and
containers
used
at
the
facility
to
manage
the
hazardous
waste
generated
by
the
organic
peroxide
manufacturing
process
or
processes
meeting
the
conditions
of
paragraph
(
d)(
1)
of
this
section.

The
owner
or
operator
prepares
documentation
in
accordance
with
264.1090(
i)
of
this
subpart,
explaining
why
an
undue
safety
hazard
would
be
created
if
air
emission
controls
specified
in
264.1085
through
264.1088
of
this
subpart
are
installed
and
operated
on
the
tanks
and
containers
used
at
the
facility
to
manage
the
hazardous
waste
generated
by
the
organic
peroxide
manufacturing
process
or
processes
meeting
the
conditions
of
paragraph
(
d)(
1)
of
this
section.
264.1080(
d)(
2)

265.1080(
d)(
2)

The
Sistersville,
WV
plant
shall
keep
on­
site,
up
to
date
records
of
the
information
described
in
paragraphs
(
f)(
2)(
ii)(
C)(
1)
through
((
f)(
2)(
ii)(
C)(
4)
of
this
section.
264.1080(
f)(
2)(
ii)(
C)

265.1080(
f)(
2)(
ii)(
C)

The
Sistersville,
WV
plant
shall
develop
and
implement
a
startup
plan
as
required
by
the
provisions
set
forth
in
paragraph
(
f)(
2)(
ii)(
D)
of
this
section.
264.1080(
f)(
2)(
ii)(
D)(
1)

265.1080(
f)(
2)(
ii)(
D)(
1)

The
Sistersville,
WV
plant
shall
maintain
a
record
of
the
defect
repair
in
accordance
with
the
requirements
specified
in
paragraph
(
f)(
2)(
iii)(
D)
of
this
section.
264.1080(
f)(
2)(
iii)(
C)(
3)(
ii)

265.1080(
f)(
2)(
iii)(
C)(
3)(
ii)

The
Sistersville,
WV
plant
shall
keep
on
site
up
to
date
readily
accessible
records
of
the
inspections
and
repairs
required
to
be
performed
by
paragraph
(
f)(
2)(
iii)
of
this
section.
264.1080(
f)(
2)(
iii)(
D)

265.1080(
f)(
2)(
iii)(
D)

The
Sistersville,
WV
plant
shall
record
the
dates
and
times
during
which
the
capper
unit
and
the
condenser
are
operating.
264.1080(
f)(
2)(
iv)(
B)(
3)

265.1080(
f)(
2)(
iv)(
B)(
3)

The
Sistersville,
WV
plant
shall
keep
on
site
up
to
date
records
of
the
parameters
specified
to
be
monitored
under
paragraph
(
f)(
2)(
iv)(
B)
of
this
section.
264.1080(
f)(
2)(
iv)(
C)

265.1080(
f)(
2)(
iv)(
C)
Recordkeeping
14
The
Sistersville,
WV
plant
shall
keep
on
site
up
to
date
readily
accessible
records
of
the
amounts
of
collected
methanol
directed
to
reuse,
recovery,
thermal
recovery/
treatment
and
biotreatment
necessary
for
the
measurements
required
under
paragraph
264.1080(
f)(
2)(
iv)(
B)
of
this
section.

The
Sistersville,
WV
plant
shall
keep
on
site
up
to
date
readily
accessible
records
of
the
amounts
of
collected
methanol
directed
to
reuse,
recovery,
thermal
recovery/
treatment
and
biotreatment
necessary
for
the
measurements
required
under
paragraph
265.1080(
f)(
2)(
iv)(
B)
of
this
section.
264.1080(
f)(
2)(
v)(
C)

265.1080(
f)(
2)(
v)(
C)

The
Sistersville,
WV
plant
shall
maintain
on
site
each
record
required
by
paragraph
264.1080(
f)(
2)
of
this
section
through
the
MON
compliance
date.

The
Sistersville,
WV
plant
shall
maintain
on
site
each
record
required
by
paragraph
265.1080(
f)(
2)
of
this
section
through
the
MON
compliance
date.
264.1080(
f)(
2)(
vii)

265.1080(
f)(
2)(
vii)

Within
30
days
of
the
date
the
Sistersville
Plant
receives
written
notice
of
the
revocation
under
paragraph
(
f)(
3)(
iv)
of
this
section,
the
Sistersville
Plant
shall
enter
and
maintain
in
the
facility
operating
record
an
implementation
schedule.
264.1080(
g)(
1)(
ii)

265.1080(
g)(
1)(
ii)

Perform
initial
inspection
of
the
fixed
roof
and
its
closure
devices
on
or
before
the
date
that
the
tank
becomes
subject
to
this
section
and
thereafter
at
least
once
per
year.
264.1084(
c)(
4)(
ii)
265.1085(
c)(
4)(
ii)

Maintain
a
record
of
the
inspection
required
by
264.1084(
c)(
4)(
ii)
in
accordance
with
the
requirements
in
264.1089(
b)
of
this
subpart.

Maintain
a
record
of
the
inspection
required
by
264.1085(
c)(
4)(
ii)
in
accordance
with
the
requirements
in
265.1090(
b)
of
this
subpart.
264.1084(
c)(
4)(
iv)

264.1085(
c)(
4)(
iv)

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
264.1089(
b)
of
this
subpart.

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
265.1090(
b)
of
this
subpart.
264.1084(
e)(
3)(
vi)

265.1085(
e)(
3)(
vi)
Recordkeeping
15
The
owner
or
operator
shall
perform
measurements
of
the
gaps
between
the
tank
wall
and
the
primary
seal
within
60
calendar
days
after
initial
operation
of
the
tank
following
installation
of
the
floating
roof
and
thereafter,
at
least
once
every
5
years.
264.1084(
f)(
3)(
i)(
A)

265.1085(
f)(
3)(
i)(
A)

The
owner
or
operator
shall
perform
measurements
of
the
gaps
between
the
tank
wall
and
the
secondary
seal
within
60
calendar
days
after
initial
operation
of
the
tank
following
installation
of
the
floating
roof
and
thereafter,
at
least
once
every
year.
264.1084(
f)(
3)(
i)(
B)

265.1085(
f)(
3)(
i)(
B)

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
264.1089(
b)
of
this
subpart.

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
265.1090(
b)
of
this
subpart.
264.1084(
f)(
3)(
i)(
F)

265.1085(
f)(
3)(
i)(
F)

The
owner
or
operator
shall
perform
an
initial
inspection
of
the
external
floating
rook
and
its
closure
devices
on
or
before
the
date
that
the
tank
becomes
subject
to
this
standard.
Thereafter
the
owner
or
operator
shall
perform
these
inspections
at
least
once
every
year.
264.1084(
f)(
3)(
ii)(
B)

265.1085(
f)(
3)(
ii)(
B)

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
264.1089(
b)
of
this
subpart.

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
265.1090(
b)
of
this
subpart.
264.1084(
f)(
3)(
ii)(
D)

265.1085(
f)(
3)(
ii)(
D)

Prior
to
each
inspection
of
the
external
floating
roof
the
owner
or
operator
shall
notify
the
RA
in
advance
of
each
inspection
to
provide
the
RA
with
the
opportunity
to
have
an
observer
present
during
the
inspection.
264.1084(
f)(
3)(
iii)

265.1085(
f)(
3)(
iii)

Prior
to
each
inspection
to
measure
external
floating
roof
seal
gaps
as
required
under
paragraph
(
f)(
3)(
i)
of
this
section,
written
notification
shall
be
prepared
and
sent
by
the
owner
or
operator
so
that
it
is
received
by
the
RA
at
least
30
calendar
days
before
the
measurements
are
scheduled
to
be
performed.
264.1084(
f)(
3)(
iii)(
A)

265.1085(
f)(
3)(
iii)(
A)
Recordkeeping
16
Prior
to
each
visual
inspection
of
the
external
floating
roof
in
a
tank
that
has
been
emptied
and
degassed,
written
notification
shall
be
prepared
and
sent
by
the
owner
or
operator
so
that
it
is
received
by
the
RA
at
least
30
calendar
days
before
refilling
the
tank
except
when
an
inspection
is
not
planned
as
provided
for
in
paragraph
(
f)(
3)(
iii)(
C)
of
this
section.
264.1084(
f)(
3)(
iii)(
B)

265.1085(
f)(
3)(
iii)(
B)

When
a
visual
inspection
is
not
planned
and
the
owner
or
operator
could
not
have
known
about
the
inspection
30
calendar
days
before
refilling
the
tank,
the
owner
or
operator
shall
notify
the
RA
as
soon
as
possible,
but
no
later
than
7
calendar
days
before
refilling
of
the
tank.
264.1084(
f)(
3)(
iii)(
C)

265.1085(
f)(
3)(
iii)(
C)

The
owner
or
operator
shall
perform
an
initial
inspection
of
the
air
emission
control
equipment
on
or
before
the
date
that
the
tank
becomes
subject
to
this
section.
Thereafter
the
owner
or
operator
shall
perform
these
inspections
at
least
once
every
year.
264.1084(
g)(
3)(
iii)

265.1085(
g)(
3)(
iii)

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
264.1089(
b)
of
this
subpart.

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
265.1090(
b)
of
this
subpart.
264.1084(
g)(
3)(
v)

265.1085(
g)(
3)(
v)

The
owner
or
operator
who
uses
an
enclosure
vented
through
a
closed­
vent
system
to
an
enclosed
combustion
control
device
to
control
air
pollution
emission
shall
perform
the
verification
procedure
for
the
enclosure
as
specified
in
Section
5.0
to
"
Procedure
T­
Criteria
for
and
Verification
of
a
Permanent
of
Temporary
Total
Enclosure"
initially
when
the
enclosure
is
first
installed
and,
thereafter
annually.
264.1084(
i)(
1)

265.1085(
i)(
1)

Prepare
a
written
explanation
for
the
cover
stating
the
reasons
why
the
cover
is
unsafe
to
inspect
and
monitor
264.1084(
l)(
1)(
i)

265.1085(
l)(
1)(
i)

Develop
and
implement
a
written
plan
and
schedule
to
inspect
and
monitor
the
cover,
using
the
procedures
specified
in
the
applicable
section
of
this
subpart,
as
frequently
as
practicable
during
those
times
when
a
worker
can
safely
access
the
cover.
264.1084(
l)(
1)(
ii)

265.1085(
l)(
1)(
ii)
Recordkeeping
17
The
owner
or
operator
shall
perform
an
initial
inspection
of
the
floating
membrane
cover
and
its
closure
devices
on
or
before
the
date
that
the
surface
impoundment
becomes
subject
to
this
section.
Thereafter
the
owner
or
operator
shall
perform
these
inspections
at
least
once
every
year.
264.1085(
c)(
3)(
ii)

265.1086(
c)(
3)(
ii)

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
264.1089(
c)
of
this
subpart.

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
265.1090(
c)
of
this
subpart.
264.1085(
c)(
3)(
iv)

265.1086(
c)(
3)(
iv)

The
owner
or
operator
shall
perform
an
initial
inspection
of
the
air
emission
control
equipment
on
or
before
the
date
that
the
surface
impoundment
becomes
subject
to
this
section.
Thereafter
the
owner
or
operator
shall
perform
these
inspections
at
least
once
every
year.
264.1085(
d)(
3)(
iii)

265.1086(
d)(
3)(
iii)

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
264.1089(
c)
of
this
subpart.

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
in
accordance
with
the
requirements
specified
in
265.1090(
c)
of
this
subpart.
264.1085(
d)(
3)(
v)

265.1086(
d)(
3)(
v)

Prepare
a
written
explanation
for
the
cover
stating
the
reasons
why
the
cover
is
unsafe
to
visually
inspect
or
to
monitor,
if
required.
264.1085(
g)(
1)

265.1086(
g)(
1)

Develop
and
implement
a
written
plan
and
schedule
to
inspect
and
monitor
the
cover
using
the
procedures
specified
in
the
applicable
section
of
this
subpart
as
frequently
as
practicable
during
those
times
when
a
worker
can
safely
access
the
cover.
264.1085(
g)(
2)

265.1086(
g)(
2)

When
a
hazardous
waste
is
already
in
the
container
at
the
time
the
owner
or
operator
first
accepts
possession
of
the
container
and
the
container
is
not
emptied
within
24
hours
after
the
container
is
accepted
the
owner
or
operator
shall
visually
inspect
the
container
and
its
cover
and
closure
devices.
264.1086(
c)(
4)(
i)
264.1086(
d)(
4)(
i)

265.1087(
c)(
4)(
i)
265.1087(
d)(
4)(
i)
Recordkeeping
18
When
a
container
used
for
managing
hazardous
waste
remains
at
the
facility
for
a
period
of
one
year
or
more
the
owner
or
operator
shall
visually
inspect
the
container
and
its
cover
and
closure
devices
initially
and
thereafter
at
least
once
every
12
months.
264.1086(
c)(
4)(
ii)
264.1086(
d)(
4)(
ii)

265.1087(
c)(
4)(
ii)
265.1087(
d)(
4)(
ii)

The
owner
or
operator
shall
maintain
at
the
facility
a
copy
of
the
procedure
used
to
determine
that
containers
with
capacity
of
0.46
cubic
meters
or
greater,
which
do
not
meet
the
DOT
regulations
as
specified
in
paragraph
(
f)
of
this
section,
are
not
managing
hazardous
waste
in
light
material
service.
264.1086(
c)(
5)

265.1087(
c)(
5)

Owners
or
operators
that
use
Container
Level
3
controls
in
accordance
with
the
provisions
of
this
subpart
shall
prepare
and
maintain
the
records
specified
in
264.1089(
d)
of
this
subpart.

Owners
or
operators
that
use
Container
Level
3
controls
in
accordance
with
the
provisions
of
this
subpart
shall
prepare
and
maintain
the
records
specified
in
264.1089(
d)
of
this
subpart.
264.1086(
e)(
5)

265.1087(
e)(
5)

For
closed­
vent
systems
and
control
devices
the
closed­
vent
system
joints,
seams,
or
other
connections
that
are
permanently
or
semi­
permanently
sealed
shall
be
visually
inspected
at
least
once
per
year.
264.1033(
l)(
1)(
ii)(
A)

Closed
vent
components
or
connections
other
than
those
specified
in
paragraph
(
l)(
1)(
ii)(
A)
of
this
section
shall
monitor
annually
and
at
other
times
specified
by
the
RA.
264.1033(
l)(
1)(
ii)(
B)

For
closed­
vent
systems
and
control
devices
that
operate
at
pressure
below
atmospheric
pressure
the
owner
or
operator
shall
perform
an
initial
inspection
of
the
closed
vent
system
on
or
before
the
system
becomes
subject
to
this
section,
and
at
least
once
per
year.
264.1033(
l)(
2)(
ii)

The
owner
or
operator
shall
maintain
a
record
of
the
inspection
and
monitoring
in
accordance
with
the
requirements
specified
in
264.1035
of
this
subpart.
264.1033(
l)(
2)(
iv)

The
owner
or
operator
shall
maintain
a
record
of
the
defect
repair
in
accordance
with
the
requirements
specified
in
264.1035
of
this
subpart.
264.1033(
l)(
3)(
iv)

The
owner
or
operator
using
a
carbon
adsorption
system
to
control
air
pollution
emissions
shall
document
the
proper
disposal
of
spent
hazardous
carbon.
264.1034(
n)
Recordkeeping
19
The
owner
or
operator
shall
demonstrate
compliance
with
the
requirement
that
period
of
planned
routine
maintenance
of
the
control
device,
during
which
the
control
device
does
not
properly
control
emissions
as
required
by
264.1087(
c)(
1),
shall
not
exceed
240
hours,
by
recording
the
information
specified
in
264.1089(
e)(
1)(
v).

The
owner
or
operator
shall
demonstrate
compliance
with
the
requirement
that
period
of
planned
routine
maintenance
of
the
control
device,
during
which
the
control
device
does
not
properly
control
emissions
as
required
by
265.1088(
c)(
1),
shall
not
exceed
240
hours,
by
recording
the
information
specified
in
265.1090(
e)(
1)(
v).
264.1087(
c)(
2)(
iv)

265.1088(
c)(
2)(
iv)

The
owner
or
operator
shall
develop
and
implement
a
written
plan
and
schedule
to
perform
the
inspections
and
monitoring
required
by
paragraph
(
a)
of
this
section.
The
owner
or
operator
shall
incorporate
this
plan
and
schedule
into
the
facility
inspection
plan
required
under
40
CFR
264.15.

The
owner
or
operator
shall
develop
and
implement
a
written
plan
and
schedule
to
perform
the
inspections
and
monitoring
required
by
paragraph
(
a)
of
this
section.
The
owner
or
operator
shall
incorporate
this
plan
and
schedule
into
the
facility
inspection
plan
required
under
40
CFR
265.15.
264.1088(
b)

265.1089(
b)

Each
owner
or
operator
of
a
facility
subject
to
the
requirements
of
this
subpart
shall
record
and
maintain
the
information
specified
in
paragraphs
(
b)
through
(
j)
of
this
section.
264.1089(
a)

265.1090(
a)

The
owner
or
operator
of
a
tank
using
air
emission
controls
in
accordance
with
the
requirements
of
264.1084
of
this
subpart
shall
prepare
and
maintain
records.

The
owner
or
operator
of
a
tank
using
air
emission
controls
in
accordance
with
the
requirements
of
265.1085
of
this
subpart
shall
prepare
and
maintain
records.
264.1089(
b)

265.1090(
b)
Recordkeeping
20
The
owner
or
operator
of
a
surface
impoundment
using
air
emission
controls
in
accordance
with
the
requirements
of
264.1085
of
this
subpart
shall
prepare
and
maintain
records
for
the
surface
impoundment.

The
owner
or
operator
of
a
surface
impoundment
using
air
emission
controls
in
accordance
with
the
requirements
of
265.1086
of
this
subpart
shall
prepare
and
maintain
records
for
the
surface
impoundment.
264.1089(
c)

265.1090(
c)

The
owner
or
operator
of
containers
using
Container
Level
3
air
emission
controls
in
accordance
with
the
requirements
of
264.1086
of
this
subpart
shall
prepare
and
maintain
records.

The
owner
or
operator
of
containers
using
Container
Level
3
air
emission
controls
in
accordance
with
the
requirements
of
265.1087
of
this
subpart
shall
prepare
and
maintain
records.
264.1089(
d)

265.1090(
d)

The
owner
or
operator
using
a
closed­
vent
system
and
control
device
in
accordance
with
the
requirements
of
264.1087
of
this
subpart
shall
prepare
and
maintain
records.

The
owner
or
operator
using
a
closed­
vent
system
and
control
device
in
accordance
with
the
requirements
of
265.1088
of
this
subpart
shall
prepare
and
maintain
records.
264.1089(
e)

265.1090(
e)

The
owner
or
operator
of
a
tank,
surface
impoundment,
or
container
exempted
from
standards
in
accordance
with
the
provisions
of
264.1082(
c)
of
this
subpart
shall
prepare
and
maintain
records.

The
owner
or
operator
of
a
tank,
surface
impoundment,
or
container
exempted
from
standards
in
accordance
with
the
provisions
of
265.1083(
c)
of
this
subpart
shall
prepare
and
maintain
records.
264.1089(
f)

265.1090(
f)
Recordkeeping
21
An
owner
or
operator
designating
a
cover
as
"
unsafe
to
inspect
and
monitor"
pursuant
to
264.1084(
l)
or
264.1085(
g)
of
this
subpart
shall
record
in
a
log
kept
in
the
facility
operating
record
the
following
information:
The
identification
numbers
for
waste
management
units
with
covers
that
are
designated
as
"
unsafe
to
inspect
and
monitor,"
the
explanation
for
each
cover
stating
why
the
cover
is
unsafe
to
inspect
and
monitor,
and
the
plan
and
schedule
for
inspecting
and
monitoring
each
cover.

An
owner
or
operator
designating
a
cover
as
"
unsafe
to
inspect
and
monitor"
pursuant
to
265.1085(
l)
or
265.1086(
g)
of
this
subpart
shall
record
in
a
log
kept
in
the
facility
operating
record
the
following
information:
The
identification
numbers
for
waste
management
units
with
covers
that
are
designated
as
"
unsafe
to
inspect
and
monitor,"
the
explanation
for
each
cover
stating
why
the
cover
is
unsafe
to
inspect
and
monitor,
and
the
plan
and
schedule
for
inspecting
and
monitoring
each
cover.
264.1089(
g)

265.1090(
g)

The
owner
or
operator
of
a
facility
that
is
subject
to
this
subpart
and
to
the
control
device
standards
in
40
CFR
part
60,
subpart
VV,
or
40
CFR
part
61,
subpart
V,
may
elect
to
demonstrate
compliance
with
the
applicable
sections
of
this
subpart
by
documenting
either
pursuant
to
this
subpart,
or
pursuant
to
the
provisions
of
40
CFR
part
60,
subpart
VV
or
40
CFR
part
61,
subpart
V,
to
the
extent
that
the
documentation
required
by
40
CFR
parts
60
and
61
duplicates
the
documentation
required
by
this
section.
264.1089(
h)

265.1090(
h)
Recordkeeping
22
For
each
tank
or
container
not
using
air
emission
controls
specified
in
264.1084
through
264.1087
of
this
subpart
in
accordance
with
the
conditions
specified
in
264.1080(
d)
of
this
subpart
shall
record
and
maintain
the
following
information:
(
1)
A
list
of
the
individual
organic
peroxide
compounds
manufactured
at
the
facility
that
meet
the
conditions
specified
in
264.1080(
d)(
1)
(
2)
A
description
of
how
the
hazardous
waste
containing
the
organic
peroxide
compounds
identified
in
paragraph
(
i)(
1)
are
managed
at
the
facility
in
tanks
and
containers.
(
3)
An
explanation
of
why
managing
the
hazardous
waste
containing
the
organic
peroxide
compounds
identified
in
paragraph
(
i)(
1)
of
this
section
in
the
tanks
and
containers
as
described
in
paragraph
(
i)(
2)
of
this
section
would
create
an
undue
safety
hazard
if
the
air
emission
controls,
as
required
under
264.1084
through
264.1087
of
this
subpart,
are
installed
and
operated
on
these
waste
management
units.

For
each
tank
or
container
not
using
air
emission
controls
specified
in
265.1085
through
265.1088
of
this
subpart
in
accordance
with
the
conditions
specified
in
265.1080(
d)
of
this
subpart
shall
record
and
maintain
the
following
information:
(
1)
A
list
of
the
individual
organic
peroxide
compounds
manufactured
at
the
facility
that
meet
the
conditions
specified
in
265.1080(
d)(
1)
(
2)
A
description
of
how
the
hazardous
waste
containing
the
organic
peroxide
compounds
identified
in
paragraph
(
i)(
1)
are
managed
at
the
facility
in
tanks
and
containers.
(
3)
An
explanation
of
why
managing
the
hazardous
waste
containing
the
organic
peroxide
compounds
identified
in
paragraph
(
i)(
1)
of
this
section
in
the
tanks
and
containers
as
described
in
paragraph
(
i)(
2)
of
this
section
would
create
an
undue
safety
hazard
if
the
air
emission
controls,
as
required
under
265.1085
through
265.1088
of
this
subpart,
are
installed
and
operated
on
these
waste
management
units.
264.1089(
i)

265.1090(
i)
Recordkeeping
23
For
each
hazardous
waste
management
unit
not
using
air
emission
controls
specified
in
264.1084
through
264.1087
of
this
subpart
in
accordance
with
the
requirements
of
264.1080(
b)(
7)
of
this
subpart,
the
owner
and
operator
shall
record
and
maintain
the
following
information:
(
1)
Certification
that
the
waste
management
unit
is
equipped
with
and
operating
air
emission
controls
in
accordance
with
the
requirements
of
an
applicable
Clean
Air
Act
regulation
codified
under
40
CFR
part
60,
part
61,
or
part
63.
(
2)
Identification
of
the
specific
requirements
codified
under
40
CFR
part
60,
part
61,
or
part
63
with
which
the
waste
management
unit
is
in
compliance.

For
each
hazardous
waste
management
unit
not
using
air
emission
controls
specified
in
265.1085
through
265.1088
of
this
subpart
in
accordance
with
the
requirements
of
265.1080(
b)(
7)
of
this
subpart,
the
owner
and
operator
shall
record
and
maintain
the
following
information:
(
1)
Certification
that
the
waste
management
unit
is
equipped
with
and
operating
air
emission
controls
in
accordance
with
the
requirements
of
an
applicable
Clean
Air
Act
regulation
codified
under
40
CFR
part
60,
part
61,
or
part
63.
(
2)
Identification
of
the
specific
requirements
codified
under
40
CFR
part
60,
part
61,
or
part
63
with
which
the
waste
management
unit
is
in
compliance.
264.1089(
j)

265.1090(
j)

(
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.
Respondent
Activities
24
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
RCRA
Info
database.

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
a
facility
to
determine
whether
pollution
control
devices
are
properly
installed
and
operated,
and
determine
compliance
with
40
CFR
parts
264
and
265.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
Also,
reports
are
used
to
identify
problems
and
determine
compliance
at
facilities.

Publication
and
distribution
of
the
information
are
part
of
the
Resource
Conservation
and
Recovery
Information
System
(
RCRA
Info)
which
is
jointly
operated
and
maintained
by
the
EPA's
Office
of
Solid
Waste
(
OSW)
and
Office
of
Compliance
(
OC).
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
records
required
by
40
CFR
parts
264
and
265
must
be
retained
at
the
facility
by
the
owner
or
operator
for
3
years.

5(
c)
Small
Entity
Flexibility
25
The
EPA
recognizes
that
owners
or
operator
of
small
businesses
often
do
not
have
the
personnel
and
financial
resources
available
to
large
companies
for
performing
information
collection.
However,
in
EPA's
experience
the
information
required
by
the
standard
is
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
compliance
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
Table
1:
Annual
Respondent
Burden
and
Costs
as
a
Result
of
RCRA
subpart
CC,
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Table
1
documents
the
computation
of
individual
burdens
for
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry
for
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.
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
711,477
person­
hours
(
Total
Labor
Hours
from
Table
1).
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.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
a
Technical
Labor
Rate
of
$
64.47
per
hour,
a
Management
Labor
Rate
of
26
$
93.09
per
hour,
and
a
Clerical
Labor
Rate
of
$
39.65
per
hour.
These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
June
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
only
costs
to
the
regulated
industry
resulting
from
the
information
collection
activities
required
by
the
subject
standards
are
labor
costs.
There
are
no
capital/
startup
costs.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
The
operations
and
maintenance
cost
for
the
regulated
industry
is
estimated
to
be
$
12,418,000
annually.
This
assumes
a
cost
of
$
2,000
per
facility.
There
are
no
capital/
startup
costs.

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

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
268,843
(
See
Table
2
below).
For
estimating
government
cost
this
ICR
uses
a
Technical
Labor
Rate
of
$
40.08
per
hour,
a
Management
Labor
Rate
of
$
54.02
per
hour,
and
a
Clerical
Labor
Rate
of
$
21.70
per
hour.
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2003
General
Schedule"
which
excludes
locality
rates
of
pay.
These
rates
can
be
obtained
from
the
OPM
web
site,
http:
www.
opm.
gov/
oca/
payrates/
index/
htm.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Average
Annual
EPA
Resource
Requirement
as
a
Result
of
RCRA
subpart
CC,
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers,
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
Costs
Based
on
our
research
for
this
ICR,
approximately
6,209
existing
facilities
are
currently
subject
to
the
standard.
It
is
estimated
that
no
additional
facilities
will
become
subject
to
the
standard
in
the
next
three
years.
The
number
of
respondents
and
the
total
annual
responses
were
derived
using
the
following
assumptions
and,
by
using
the
"
Number
of
Respondents"
and
"
Total
Annual
Responses"
tables
that
follow.

It
was
estimated
during
rule
development
that
70%
of
treatment
storage
and
disposal
facilities
(
TSDFs)
and
25%
of
large
quantity
generators
(
LQGs)
would
be
subject
to
RCRA
subpart
CC
requirements.
Based
on
information
obtained
from
RCRA
Info
data,
there
are
2,393
TSDFs
and
18,135
LQGs.
The
regulated
universe
is
the
sum
of
applicable
TSDFs
and
LQGs.
Therefore,
the
following
applies:

Regulated
Universe
27
70%
of
2,393
=
1,675
(
TSDFs
subject
to
RCRA
subpart
CC)
25%
of
18,135
=
4,534
(
LQGs
subject
to
RCRA
subpart
CC)

1,675
+
4,534
=
6,209
respondents
subject
to
RCRA
subpart
CC.

Semiannual
Reporting
It
is
assumed
that
0.5%
of
control
devices
malfunction
resulting
in
the
need
for
a
semiannual
report.
The
Sistersville
Plant
XL
project
always
reports
semiannually.

0.5%
of
6209
=
31
31
+
Sistersville
Plant
=
32
(
Semiannual
Reports)

Other
Reports
For
exceedances
it
is
assumed
that
1%
of
waste
determination
results
in
exceedance
annually.
This
would
result
in
the
need
for
a
report
to
EPA
within
15
calendar
days.
Therefore,
1%
of
the
regulated
universe
would
submit
a
report
to
EPA
within
15
calendar
days,
once
per
year.

1%
of
6209
=
62
(
report
to
EPA
within
15
calendar
days,
once
per
year)

Notification
Reports
It
is
assumed
that
10%
of
internal
floating
roofs
and
20%
of
external
floating
roofs
will
require
notifications
annually.
One
facility
notifies
EPA
that
they
will
use
the
hydrogen
peroxide
management
exemption
(
40
CFR
264.1080(
d)
and
40
CFR
265.1080(
d).

10%
of
6,209
=
621
20%
of
6,209
=
1,242
1,242
+
621
+
Facility
using
hydrogen
peroxide
exemption
=
1,864
(
Notification
Reports)

1,864
+
62
=
1,926
(
Annual
Reports)

1,926
+
32
=
1,958
(
Number
of
Existing
Respondents
that
Submit
Reports)

Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
Number
of
Respondents
28
Year
(
A)
Number
of
New
Respondents
1
(
B)
Number
of
Existing
Respondents
(
C)
Number
of
Existing
Respondents
that
keep
records
but
do
not
submit
reports
(
D)
Number
of
Existing
Respondents
That
Are
Also
New
Respondents
(
E)
Number
of
Respondents
(
E=
A+
B+
C­
D)

1
0
1,958
4,251
0
6,209
2
0
1,958
4,251
0
6,209
3
0
1,958
4,251
0
6,209
Average
0
1,958
4,251
0
6,209
As
shown
above,
the
average
Number
of
Respondents
over
the
three
year
period
of
this
ICR
is
6,209.
This
number
appears
on
the
OMB
83­
I
form
in
block
13
(
a),
Number
of
respondents.

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

Total
Annual
Responses
(
A)

Information
Collection
Activity
(
B)

Number
of
Respondents
(
C)

Number
of
Responses
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
BxC)+
D
Notification
Reports
1,864
1
NA
1,864
Semiannual
Reports
32
2
NA
64
Other
Reports
62
1
NA
62
All
Recordkeeping
Requirements
NA
NA
4,251
4,251
Total
6,241
The
Total
Annual
Responses
is
6,241.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
13(
b),
Total
annual
responses.

The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
cost
are
$
45,014,910.
The
annual
labor
costs
are
not
shown
on
the
OMB
83­
I
form.
Details
regarding
these
estimates
may
be
found
in
Table
1.
Annual
Respondent
Burden
and
Cost,
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers
(
40
CFR
part
264,
subpart
CC
and
40
CFR
part
265,
subpart
CC).

The
total
annual
capital
costs
to
the
regulated
entity
are
$
0
and
annual
O&
M
costs
to
the
regulated
entity
are
$
12,418,000.
The
total
is
shown
on
the
OMB
83­
I
form
in
block
14
(
c),
Total
Annualized
Cost
Requested.
These
costs
are
detailed
in
section
6(
b)(
iii)
Capital/
Start­
up
vs.
Operation
and
Maintenance
(
O&
M)
Costs.
29
6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
The
bottom
line
burden
hours
and
cost
tables
for
both
the
respondents
and
the
Agency
appear
below.
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
114
hours
per
response.

6(
f)
Reasons
for
Change
in
Burden
The
increase
in
burden
from
the
most
recently
approved
ICR
is
due
to
adding
reporting
and
recordkeeping
requirements
that
have
not
previously
been
in
this
ICR.
This
is
due
to
an
omission
from
the
previous
ICRs.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
114
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.

An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to
a
collection
of
information
unless
it
displays
a
valid
OMB
Control
Number.
The
OMB
Control
Numbers
for
EPA's
regulations
are
listed
at
40
CFR
part
9
and
48
CFR
Chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
Number
OECA
2003­
0142,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
D.
C.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
OECA
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
to
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA
2003­
0142
and
OMB
Control
Number
2060­
0318
in
any
correspondence.

Part
B
of
the
Supporting
Statement
30
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
31
APPENDIX
A
BURDEN
TABLES
32
Table
1:
Annual
Respondent
Burden
and
Costs
as
a
Result
of
RCRA
subpart
CC,
Air
Emission
Standards
for
Tanks,
Surface
Impoundments
and
Containers.

Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
1.
Applications
NA
2.
Survey
and
Studies
NA
3.
Reporting
Requirements
A.
Read
Instructions
4
1
4
6,209
24,836
1,242
2,484
1,815,286
B.
Required
Activities
0
0
0
0
0
0
0
0
C.
Create
Information
0
0
0
0
0
0
0
0
D.
Gather
Existing
Information
1
1
1
6,209
6,209
310
621
453,775
E.
Write
Report
F.
Annual
Project
Reportb
1
1
1
1
1
0.05
0.1
73
G.
Final
Project
Reportb
1
0
0
1
0
0
0
0
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
33
H.
Report
required
by
264.1080(
f)(
2)

(
viii)(
F)
b
1
0
0
1
0
0
0
0
I.
Semiannual
Reportc
1
2
2
32
64
3.2
6.4
4,678
J.
Report
to
EPA
within
15
calendar
days
of
waste
determination
exceedanced
1
1
1
62
124
6.2
12.4
9,063
J.
Notify
EPA/
WVDEP
60
days
in
advance
for
performance
test
of
incineratorb
1
0
0
1
0
0
0
0
K.
Performance
test
results
report
for
Sistersville
Plantb
1
0
0
1
0
0
0
0
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
34
L.
Notification
regarding
hydrogen
peroxide
managementh
1
1
1
1
1
0.05
0.1
73
M.
Notify
RA
30
days
in
advance
of
any
gap
measurements
to
be
taken
1
1
1
1,242e
1,242
62
124
90,761
N.
Notify
RA
30
days
in
advance
of
filling
or
refilling
tank
1
1
1
621f
621
31
62
45,380
4.
Recordkeeping
Requirements
A.
Recordkeeping
for
Sistersville,

WV
plantg
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
35
I.
Prepare
and
record
documentation
that
air
emission
control
present
undue
hazard
1
1
1
1
1
0.05
0.1
73
II.
Information
going
into
annual
report
a.
Emissions
analysis
0.33
1
0.33
1
0.33
0.02
0.03
27
b.
Plant
performance
evaluation
0.33
1
0.33
1
0.33
0.02
0.03
27
c.
Description
of
anticipated
problems
0.33
1
0.33
1
0.33
0.02
0.03
27
III.
Startup/

shutdown
plan
1
0
0
1
0
0
0
0
IV.
Records
of
defect
repair
0.5
2
1
1
1
0.05
0.1
73
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
36
V.
Records
of
the
inspection
and
repair
of
the
closed­
vent
system
0.5
2
1
1
1
0.05
0.1
73
VI.
Record
dates
and
time
that
capper
unit
and
condenser
are
operating
0.25
365
91
1
91
5
9
6,689
VII.
Record
amount
of
methanol
generated
and
recovered;
and
condenser
temperature.
0.25
365
91
1
91
5
9
6,689
VIII.
Records
of
amounts
of
methanol
directed
to
reuse,
recovery,

thermal
recovery/
treatment
and
biotreatment
0.25
365
91
1
91
5
9
6,689
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
37
B.
Read
Instructions
4
1
4
6,209
24,836
1,242
2,484
1,815,286
C.
Plan
Activities
16
1
16
6,209
99,344
4,967
9,934
7,260,969
D.
Implement
Activities
I.
Waste
determination
for
VO
concentration
at
the
point
of
origin
a.
Waste
determination
once
every
12
months
2
1
2
6,209
12,418
621
1,242
907,642
II.
Waste
determination
for
treated
hazardous
waste
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
38
a.
Waste
determination
for
batch
process
once
every
12
months
2
1
2
6,209
12,418
621
1,242
907,642
III.
Inspect
and
monitor
each
closed
vent
system
0.08
365
29
3,105
90,045
4,502
9,005
6,581,340
IV.
Write
and
implement
an
inspection
plan
and
place
in
facility
inspection
plan
4
1
4
0
0
0
0
0
V.
Inspect
all
coverings
and
monitor
for
initial
detectable
emissions,

initial
operation,

using
Method
21
a.
Tanks
4
1
4
0
0
0
0
0
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
39
b.
Surface
Impoundments
5
1
5
0
0
0
0
0
c.
Containers
2
1
2
0
0
0
0
0
VI.
Inspect
all
coverings
and
monitor
for
detectable
emissions
at
least
once
every
6
months
using
Method
21
a.
Tanks
(
Includes
Method
27
­
Transportation
vehicles)
4
2
8
6,209
49,672
2,484
4,967
3,630,532
b.
Surface
Impoundments
5
2
10
119
1,190
60
119
87,022
c.
Containers
2
2
4
6,209
24,836
1,242
2,484
1,815,286
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
40
VII.
Owner/
operato
r
writes
and
implements
plan
with
schedule
to
inspect
unsafe
covers
1
1
1
0
0
0
0
0
VIII.
Owner/
operato
r
writes
and
implements
plan
with
schedule
to
inspect
difficult
to
inspect
covers
1
1
1
0
0
0
0
0
IX.
Secondary
seal
inspection
once
a
year
4
1
4
6,209
24,836
1,242
2,484
1,815,286
X.
Primary
seal
inspection
once
every
5
years
4
1
4
1,242d
4,968
248
497
363,079
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
41
XI.
General
standards,

Record
ID
number
of
BIF
or
incinerator
used
to
treat
waste
0.25
1
0.25
0
0
0
0
0
XII.
Tanks
with
unsafe
covers,
record
list
of
ID
numbers
for
tanks
with
unsafe
covers,

explain
why
it's
unsafe
and
plan
to
inspect
and
monitor
each
cover
0.3
1
0.3
0
0
0
0
0
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
42
XIII.
Tanks
with
difficult
to
inspect
covers,
record
list
of
ID
numbers,

explain
why
difficult
and
plan
to
inspect
and
monitor
each
cover
0.3
1
0.3
0
0
0
0
0
E.
Develop
Record
System
16
1
16
0
0
0
0
0
F.
Time
to
Enter
Information
I.
Record
each
cover
installed
on
a
tank
and
certifies
to
its
specifications
0.25
1
0.25
0
0
0
0
0
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
43
II.
Record
each
floating
membrane
installed
on
a
surface
impoundment
and
certifies
to
its
specifications
0.25
1
0.25
0
0
0
0
0
III.
Record
each
enclosure
used
to
control
air
emissions
and
certifies
to
its
specifications
0.25
1
0.25
0
0
0
0
0
IV.
Record
for
each
closed
vent
and
control
device
it
is
designed
to
operate
at
the
performance
level
for
tank,

surface
impoundment
or
container
0.25
1
0.25
0
0
0
0
0
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
44
V.
Records
all
Method
27
tests
performed
by
owner/
operator
for
each
container
0.5
1
0.5
6,209
3,105
155
311
226,939
VI.
Records
all
visual
inspections
of
each
tank,

surface
impoundment
and
container,

including
covers
1
1
1
6,209
6,209
310
621
453,775
Tanks
with
air
emission
controls:

VII.
Records
date
of
each
attempts
to
repair
leak,

repair
methods
applied
and
date
of
successful
repair
0.5
2
1
6,209
6,209
310
621
453,775
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
45
VIII.
Records
all
continuous
monitoring
0.25
365
91
621
56,511
2,826
5,651
3,930,959
IX.
Records
management
of
carbon
removed
from
a
carbon
adsorption
system
0.5
2
1
3,105
3,105
155
311
226,939
X.
Records
date
and
time
of
each
sample
0.25
2
0.5
6,209
3,105
155
311
226,939
XI.
Records
results
of
each
sample
0.25
2
0.5
6,209
3,105
155
311
226,939
XII.
Records
tank
dimensions
and
design
capacity
0.3
1
1
0
0
0
0
0
Tanks
with
alternative
emission
controls
(
floating
roofs):
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
46
XIII.
Records
in
the
facility
operating
plan
the
internal
floating
roof
0.25
1
0.25
0
0
0
0
0
XIV.
Records
the
equipment
design
and
certifies
that
it
meets
applicable
requirements
0.25
1
0.25
0
0
0
0
0
XV.
Records
each
inspection,
the
tank,
date,
and
what
components
were
inspected
0.25
2
0.5
6,209
3,105
155
311
226,939
a.
If
defects
found,
identify
the
tank
and
describe
the
repairs
made
0.25
2
0.5
6,209
3,105
155
311
226,939
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
47
XVI.
Records
in
the
facility
operating
plan
the
external
floating
roof
0.25
1
0.25
0
0
0
0
0
XVII.
Records
the
equipment
design
and
certifies
that
it
meets
applicable
requirements
0.25
1
0.25
0
0
0
0
0
XVIII.
Records
gap
measurements
of
the
tank,

date
of
inspection,
raw
data
and
calculations
0.25
1
0.25
6,209
1,552
78
155
113,464
a.
If
defects
found,
records
the
tank,
date
tank
was
emptied
or
repairs
made
and
the
nature
of
the
repair
0.25
1
0.25
6,209
1,552
78
155
113,464
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
48
IXX.
Continuous
Monitoring
Inspections
a.
Closed­
Vent
Systems
4
1
4
6,209
24,836
1,242
2,484
1,815,286
XX.
Roof
Inspections/

Gap
Measurements:

a.
Secondary
seal
inspection
(
once
a
year)
4
1
4
6,209
24,836
1,242
2,484
1,815,286
b.
Primary
seal
inspection
(
once
every
5
years)
4
0.2
0.8
1,242d
994
50
99
72,663
G.
Train
Personnel
I.
Waste
determination
methods
8
1
8
6,209
49,672
2,484
4,967
3,630,532
II.
Control
equipment
inspection
and
monitor
8
1
8
6,209
49,672
2,484
4,967
3,630,532
Requirements
Tech.
Hours/

Occur.

(
A)
Occur./

Plant/

Year
(
B)
Hours/
Rspndnt.

(
C)

(
C=
A
x
B)
Number
of
Rspndnts.

(
D)
Technical
Hours/
Year
(
E)

(
E=
C
x
D)
Management
Hours
/
Year
(
F)

(
F=
0.05
x
E)
Clerical
Hours/
Year
(
G)

(
G=
0.1
x
E)
Total
Cost/

Year
($)

(
H)
a
49
H.
Audits
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
711,477
$
45,014,910
50
Assumptions
for
Table
1:

a
­
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hours
x
$
64.47)
+
(
Management
hours
x
$
93.09)
+

(
Clerical
hours
x
$
39.65).

b
­
Reporting
for
Sistersville,
WV
Plant
XL
Project
only.

c
­
Assume
0.5%
of
control
devices
malfunction
resulting
in
exceedance
(
0.5%
of
6,209=
31).
The
Sistersville
Plant
XL
project
always
reports
semiannually,

so
31
+
1=
32
semiannual
reports.

d
­
Assume
1%
waste
determination
results
in
exceedance
annually
(
1%
of
6,209
=
62)

e
­
Assume
that
20%
of
the
tank
roofs
will
be
inspected
each
year
(
external
roof).

f
­
Assume
10%
of
respondents
will
empty
and
refill
a
tank
(
internal
floating
roof).

g
­
Recordkeeping
for
Sistersville,
WV
Plant
XL
Project
only.

h
­
Currently
only
one
facility
uses
the
exemption
regarding
hydrogen
peroxide
management
located
at
40
CFR
264.1080(
d)
and
40
CFR
265.1080(
d).

Total
number
of
respondents
subject
to
TSDF
requirements
=
2,393
70%
subject
to
these
rules
=
1,675
Total
number
of
respondents
subject
to
LQG
requirements
=
18,135
25%
subject
to
these
rules
=
4,534
Total
number
of
respondents
=
6,209
1,675
TSDFs
averaging
4
tanks
and
15
containers
subject
to
regulations
4
Tanks
x
1,675
=
6,700
15
containers
x
1,675
=
25,125
4,534
LQGs
averaging
1
tank
(
25%)
or
6
containers
(
75%)
subject
to
regulations
1
tank
x
4,534
x
0.25
=
1,134
6
containers
x
4,534
x
0.75
=
20,403
Total
tanks
subject
=
5,742
Total
containers
subject
=
36,499
10%
of
containers
using
cover
and
closed­
vent
system
=
3,650
Total
surface
impoundments
=
91
Respondents
using
Method
25D
for
waste
determinations
=
10%

Respondents
reporting
waste
exceedances
=
1%

Respondents
reporting
control
device
operating
parameter
exceedances
=
0.5%

Average
number
of
waste
streams
on­
site
=
10
51
Table
2:
Average
Annual
EPA
Resource
Requirement
as
a
Result
of
RCRA
subpart
CC,
Air
Emission
Standards
for
Tanks,

Surface
Impoundments
and
Containers.

Activity
Technical
Hrs/
Occurrence
(
A)
Number
of
Responses/
Yr.

(
B)
Technical
Hrs/
Yr.

(
C)

(
C
=
A
x
B)
Management
Hours/
Yr.

(
D)

(
D=
0.05
x
C)
Clerical
Hours/
Yr.

(
E)

(
E=
0.1
x
C)
Total
Labor
Costs/
Yr.

($)

(
D)
a
1.
Review
Reports
A.
Waste
exceedance
reports
4
62
b
252
13
25
10,289
B.
Control
device
exceedance
reports
4
31
c
128
6
13
5,200
C.
Notification
reports
1
1,864d
1,864
93.2
186.4
83,789
2.
Review
Records
A.
Select
site
and
review
permit
8
520
4,160
208
416
169,565
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
7,365
$
268,843
Assumptions
for
Table
2:

a
­
This
cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hours
x
$
40.08)
+
(
Management
hours
x
$
54.02)
+

(
Clerical
hours
x
$
21.70).

b
­
Annual
responses
assumes
1%
of
waste
determination
results
in
an
exceedance
(
1%
of
6,209
potential
respondents).

c
­
Semiannual
responses
assumes
0.5%
of
control
devices
malfunction
resulting
in
an
exceedance
(
0.5%
of
6,209
potential
respondents),
plus
the
Sistersville,

WV
Plant.

d
­
Annual
responses
assumes
10%
of
6,209
(
internal
floating
roof)
plus
20%
of
6,209
(
external
roof)
will
submit
notification
reports.
