SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
Y)

1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)
(
40
CFR
part
63,
subpartY)

1(
b)
Short
Characterization/
Abstract
The
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Marine
Tank
Vessel
Loading
Operations,
published
at
40
CFR
part
63,
subpart
Y,
were
proposed
on
May
13,
1994,
and
promulgated
on
September
19,
1995.
These
regulations
apply
maximum
achievable
control
technology
(
MACT)
standards
to
existing
facilities
and
new
facilities
that
load
marine
tank
vessels
with
petroleum
or
gasoline
and
have
aggregate
actual
HAP
emissions
of
10
tons
or
more
of
each
individual
HAP
or
25
tons
or
more
of
all
HAP
combined.
These
regulations
also
apply
reasonably
available
control
technology
(
RACT)
standards
to
such
facilities
with
an
annual
throughput
of
10
million
or
more
barrels
of
gasoline
or
200
million
or
more
barrels
of
crude
oil.
New
facilities
include
those
that
commenced
construction
or
reconstruction
after
the
date
of
proposal.
This
information
is
being
collected
to
assure
compliance
with
40
CFR
part
63,
subpart
Y.

In
general,
all
NESHAP
standards
require
initial
notifications,
performance
tests,
and
periodic
reports
by
the
owners/
operators
of
the
affected
facilities.
They
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.
These
notifications,
reports,
and
records
are
essential
in
determining
compliance,
and
are
required
of
all
affected
facilities
subject
to
NESHAP.

Any
owner/
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
five
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.
In
addition,
the
owner/
operator
shall
keep
the
written
operation
and
maintenance
plan
on
record
for
the
life
of
the
facility.
All
reports
are
sent
to
the
delegated
state
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
United
States
Environmental
Protection
Agency
(
EPA)
regional
office.
Once
received
by
the
authority,
reports
are
reviewed
and
the
data
are
entered,
analyzed,
and
maintained
in
the
Air
Facility
System
(
AFS).
Information
from
these
reports
can
be
used
by
any
regions,
states,
agencies
and
offices
with
access
to
AFS
and
may
be
used
in
determining
where
inspections
and
enforcement
actions
may
be
necessary.

Based
on
consultations
with
industry
representatives
during
rulemaking,
there
is
an
2
average
of
one
affected
source
at
each
plant
site
and
that
each
plant
site
has
only
one
respondent
(
i.
e.,
the
owner/
operator
of
the
plant
site).

The
following
information
is
based
on
data
from
the
Online
Targeting
Information
System
(
OTIS)
and
from
consultation
with
the
Army
Corps
of
Engineers.
These
numbers
were
also
compared
with
the
estimates
from
previous
ICRs.
Approximately
38
respondents
are
currently
subject
to
the
emissions
standards
of
the
regulation.
An
additional
766
facilities
with
aggregate
actual
HAP
emissions
of
less
than
10
tons
of
each
individual
HAP
and
less
than
25
tons
of
all
HAP
combined
are
subject
to
recordkeeping
requirements
only.
It
is
estimated
that
no
additional
respondents
per
year
will
become
subject
to
the
regulation
in
the
next
three
years.
The
annual
cost
of
this
information
collection
will
be
$
0
for
nonlabor
and
$
629,850
for
labor,
based
on
a
labor
burden
of
9,872
hours,
for
a
total
of
$
629,850.

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
The
EPA
is
charged
under
Section
112
of
the
Clean
Air
Act,
as
amended,
to
establish
standards
of
performance
for
each
category
or
subcategory
of
major
sources
and
area
sources
of
hazardous
air
pollutants.
These
standards
are
applicable
to
new
or
existing
sources
of
hazardous
air
pollutants
and
shall
require
the
maximum
degree
of
emission
reduction.
In
addition,
Section
114(
a)
states
that
the
Administrator
may
require
any
owner/
operator
subject
to
any
requirement
of
this
Act
to:

(
A)
Establish
and
maintain
such
records;
(
B)
make
such
reports;
(
C)
install,
use,
and
maintain
such
monitoring
equipment,
and
use
such
audit
procedures,
or
methods;
(
D)
sample
such
emissions
(
in
accordance
with
such
procedures
or
methods,
at
such
locations,
at
such
intervals,
during
such
periods,
and
in
such
manner
as
the
Administrator
shall
prescribe);
(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;
(
F)
submit
compliance
certifications
in
accordance
with
Section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require.

In
the
Administrator's
judgment,
HAP
and
volatile
organic
compounds
(
VOC)
emissions
from
marine
tank
vessel
loading
operations
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
the
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
part
63,
subpart
Y.

2(
b)
Practical
Utility/
Users
of
the
Data
3
The
control
of
emissions
of
HAP/
VOC
from
marine
tank
vessel
loading
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
HAP/
VOC
from
marine
tank
vessel
loading
are
the
result
of
operation
of
the
affected
facilities.
These
standards
rely
on
the
reduction
of
HAP/
VOC
emissions
by
flares
and
other
emission
reduction
procedures.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standards.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
leaks
are
being
detected
and
repaired,
and
the
standards
are
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
The
annual
reports
are
used
to
determine
periods
of
excess
emissions,
identify
problems
at
the
facility,
verify
operation/
maintenance
procedures
and
for
compliance
determinations.

The
information
generated
by
the
recordkeeping
and
reporting
requirements
described
in
this
ICR
is
used
by
the
Agency
to
ensure
that
facilities
affected
by
the
NESHAP
continue
to
operate
the
control
equipment
and
achieve
compliance
with
the
regulation.
Adequate
monitoring,
recordkeeping,
and
reporting
are
necessary
to
ensure
compliance
with
these
standards,
as
required
by
the
Clean
Air
Act.
The
information
collected
from
recordkeeping
and
reporting
requirements
is
also
used
for
targeting
inspections,
and
is
of
sufficient
quality
to
be
used
as
evidence
in
court.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
The
requested
recordkeeping
and
reporting
are
required
under
40
CFR
part
63,
subpart
Y.

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
or
local
agency.
If
a
state
or
local
agency
has
adopted
its
own
similar
standards
to
implement
the
Federal
standards,
a
copy
of
the
report
submitted
to
the
state
or
local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
standards.
Therefore,
no
duplication
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
(
69
FR
55430)
on
September
14,
2004.
No
comments
were
received
on
the
burden
published
in
the
Federal
Register.

3(
c)
Consultations
4
EPA
consulted
with
Michael
LaMarca
of
the
U.
S
Army
Corps
of
Engineers
(
ACE)
(
Phone
number,
504­
862­
1409)
regarding
the
size
and
growth
of
the
regulated
universe
for
this
rule.
The
following
information
came
from
commerce
data
from
the
Oracle
Waterborne
System
(
TOWS)
of
the
U.
S.
Army
Corps
of
Engineers,
Waterborne
Commerce
Statistics
Center:

U.
S.
Terminals
or
Ports
Loading
Gasoline
or
Crude
Oil
Year
Number
1999
842
2000
852
2001
888
2002
827
2003
804
EPA
used
the
data
from
2003,
which
is
the
most
recent
data
available
from
the
ACE.
The
Online
Targeting
Information
System
(
OTIS)
was
also
used
to
estimate
the
size
of
the
regulated
industry.

3(
d)
Effects
of
Less
Frequent
Collection
Less
frequent
information
collection
would
decrease
the
margin
of
assurance
that
facilities
are
continuing
to
meet
the
standards.
Requirements
for
information
gathering
and
recordkeeping
are
useful
techniques
to
ensure
that
good
operation
and
maintenance
practices
are
applied
and
emission
limitations
are
met.
If
the
information
required
by
these
standards
was
collected
less
frequently,
the
likelihood
of
detecting
poor
operation
and
maintenance
of
control
equipment
and
noncompliance
would
decrease.

3(
e)
General
Guidelines
None
of
these
reporting
or
recordkeeping
requirements
violate
any
of
the
regulations
established
by
OMB
at
5
CFR
part
1320,
section
1320.5.

These
standards
require
the
respondents
to
maintain
all
records,
including
reports
and
notifications
for
at
least
five
years.
This
is
consistent
with
the
General
Provisions
as
applied
to
the
standards.
EPA
believes
that
the
five
year
records
retention
requirement
is
consistent
the
part
70
permit
program
and
the
five
year
statute
of
limitations
on
which
the
permit
program
is
based.
Also,
the
retention
of
records
for
five
years
would
allow
EPA
to
establish
the
compliance
history
of
a
source
and
any
pattern
of
compliance
for
purposes
of
determining
the
appropriate
level
of
enforcement
action.
Historically,
EPA
has
found
that
the
most
flagrant
violators
frequently
have
violations
extending
beyond
the
five
years.
EPA
would
be
prevented
from
pursuing
the
worst
violators
due
to
the
destruction
or
nonexistence
of
records
if
records
were
retained
for
less
than
five
years.

3(
f)
Confidentiality
5
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
to
the
recordkeeping
and
reporting
requirements
are
marine
tank
vessel
loading
operations
at
marine
terminals.
The
SIC
code
for
the
respondents
affected
by
the
standards
is
SIC
(
United
States
Standard
Industrial
Classification)
4491,
Marine
Cargo
Handling,
which
corresponds
to
the
NAICS
(
North
American
Industry
Classification
System)
488310,
Operations
of
Ports
and
Waterfront
Terminals,
and
NAICS
488320,
Marine
Cargo
Handling.

4(
b)
Information
Requested
(
i)
Data
Items
All
data
in
this
ICR
that
are
recorded
and/
or
reported
are
required
by
40
CFR
part
63
subpart
Y
­
National
Emission
Standards
for
Hazardous
Air
Pollutants
for
Marine
Tank
Vessel
Loading
Operations.

A
source
must
make
the
following
reports:

Notification
Reports
Notification
of
performance
test.
63.7(
b),
63.9(
e),
63.567(
a)

Notification
of
the
date
the
CMS
performance
evaluation
is
scheduled
to
begin.
63.8(
e)(
2),
63.9(
g)(
1),
63.567(
a)

Notification
of
compliance
status.
63.9(
h),
63.567(
a)

Notifications
of
adjustments
to
time
periods
or
deadlines
for
submittal
and
review
of
required
communications.
63.9(
i),
63.567(
a)

Notification
of
changes
in
information
provided
to
the
Administrator.
63.9(
j),
63.567(
a)
6
Notification
Reports
Initial
notifications,
applications
for
approval
of
construction
or
reconstruction.
63.5,
63.566,
63.567(
a)
and
(
b)(
1)­
(
b)(
5)

Notification
of
intent
to
construct/
reconstruct.
63.5,
63.9(
b)(
4),
63.567(
a)
and
(
b)(
4)(
i)

Notification
of
the
date
when
construction/
reconstruction
was
commenced.
63.567(
a)
and
(
b)(
4)(
ii)

Notification
of
the
anticipated
date
of
startup
of
the
source.
63.567(
b)(
4)(
iii)

Notification
of
the
actual
date
of
startup
of
the
source.
63.567(
a)
and
(
b)(
4)(
iv)

Additional
initial
notifications
for
MACT
sources.
63.567(
b)(
5)

Request
for
extension
of
compliance.
63.6(
i)(
4)(
i)(
B),
(
i)(
5),
and
(
i)(
6),
63.567(
c)

Reports
Report
of
performance
(
opacity)
testing
of
flares.
63.567(
d),
63.565(
e),
63.11
Annual
summary
reports
of
excess
emissions
and
continuous
monitoring
system
performance
reports
(
semiannual,
if
there
are
excess
emissions).
63.10(
c)(
5),
63.10(
c)(
8),
63.10(
c)(
10)
through
(
c)(
13),
63.563(
b),
63.567(
a)
and
(
e)

Engineering
report
for
vapor
collection
systems.
63.567(
f)

Annual
report
of
source's
HAP
control
efficiency
including
identification
of
each
pollutant
monitored.
63.10(
e)(
3)(
vi),
63.565(
l),
63.567(
a)
and
(
j)(
3)

Reporting
results
of
performance
tests/
evaluations.
63.7,
63.8(
e),
63.9(
h),
63.10(
d),
63.10(
e)(
1),
63.567(
a)
7
Reports
Progress
reports
related
to
an
extension
of
compliance.
63.6(
i),
63.10(
d)(
4),
63.567(
a)

A
source
must
keep
the
following
records:

Recordkeeping
Records
of
all
excess
emissions
and
monitoring
system
performance
reports.
63.567(
e)(
4)

Records
of
engineering
reports
describing
vent
system
or
vapor
collection
system.
63.567(
f)

Records
of
all
periods
when
flow
bypassing
the
control
device
is
indicated.
63.563(
a)(
1),
63.564(
b),
63.567(
g)(
1)

Records
of
changes
in
position
and
maintenance
of
car­
sealed
valves.
63.564(
b)(
3),
63.567(
g)(
2)

Records
of
vapor
tightness
documentation.
63.563(
a)(
4),
63.567(
h)

Documentation
of
vapor
tightness
test
results
for
marine
tank
vessels.
63.563(
a)(
4),
63.565(
c)(
1)
and
(
2),
63.567(
i)

Retain
records
of
the
current,
written
operation
and
maintenance
plan
for
the
life
of
the
source.
If
plan
is
revised,
retain
records
of
the
previous
(
i.
e.,
superseded)
operation
and
maintenance
plan
for
at
least
5
years
after
the
revision.
63.562(
e)(
5)

Records
of
measurements,
calculations,
etc.
used
to
identify
exempted
commodities.
63.560(
d),
63.567(
j)(
1)

Records
of
emissions
estimation
calculations.
63.565(
l),
63.567(
j)(
2)

Records
of
emissions
estimates
and
actual
throughput
for
owners
and
operators
of
marine
tank
vessel
loading
operations.
63.560(
a)(
3),
63.565(
l),
63.567(
j)(
4)

Records
of
leak
detection
and
repair
of
vapor
collection
systems
and
control
devices.
63.563(
c),
63.567(
k)
8
Recordkeeping
Records
of
the
occurrence
and
duration
of
each
malfunction
of
the
control
equipment.
63.10(
b)(
2)(
ii),
63.567(
a)

Records
of
all
maintenance
performed
on
the
air
pollution
control
equipment.
63.10(
b)(
2)(
iii),
63.567(
a)

Records
of
periods
during
which
a
CMS
is
malfunctioning.
63.10(
b)(
2)(
vi),
63.567(
a)

Records
of
all
measurements,
results
from
performance
tests,
CMS
calibration
checks,
adjustments
made
to
CMS,
emission
levels,
information
demonstrating
whether
a
source
is
meeting
the
requirements
for
a
waiver,
and
supporting
documentation
for
initial
notifications
and
notification
of
compliance
status.
63.10(
b)(
2)(
vii)
through
(
b)(
2)(
xiv),
63.567(
a)

Records
of
all
CMS
measurements.
63.10(
c)(
1),
63.567(
a)

Records
of
all
CMS
malfunctions
or
exceedances.
63.10(
c)(
8)
and
(
c)(
10)
through
(
c)(
13),
63.567(
a)

Electronic
Reporting
At
the
present,
respondents
are
using
monitoring
equipment
that
automatically
records
parameter
data
(
e.
g.,
temperature).
Although
personnel
at
the
affected
facility
must
evaluate
the
data,
this
internal
automation
has
significantly
reduced
the
burden
associated
with
monitoring
and
recordkeeping
at
the
plant
site.

Also,
regulatory
agencies
in
cooperation
with
the
respondents,
continue
to
create
reporting
systems
to
transmit
data
electronically.
However,
electronic
reporting
systems
are
still
not
widely
used.
The
extent
of
this
practice
among
respondents
is
unclear,
but
EPA
estimates
that
less
than
10
percent
of
the
respondents
use
electronic
reporting.

(
ii)
Respondent
Activities
Respondent
Activities
Read
instructions.

Install,
calibrate,
maintain,
and
operate
CMS
for
opacity,
temperature
change,
and
VOC
emissions
temperature
change,
and
VOC
emissions
for
control
devices
listed
in
40
CFR
63.564(
a)
through
(
j).
9
Respondent
Activities
Perform
initial
performance
test,
using
the
procedures
listed
in
40
CFR
63.7
according
to
the
applicability
in
Table
1
of
63.560,
the
procedures
listed
in
63.564,
and
the
test
methods
listed
in
63.565,
and
repeat
performance
tests
if
necessary.

Write
the
notifications
and
reports
listed
above.

Enter
information
required
to
be
recorded
above.

Submit
the
required
reports
developing,
acquiring,
installing,
and
utilizing
technology
and
systems
for
the
purpose
of
collecting,
validating,
and
verifying
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
processing
and
maintaining
information.

Develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purpose
of
disclosing
and
providing
information.

Adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements.

Train
personnel
to
be
able
to
respond
to
a
collection
of
information.

Transmit,
or
otherwise
disclose
the
information.

The
rule
does
not
require
use
of
information
collection
techniques
such
as
automated,
mechanical
or
other
technical
collection
techniques.
Electronic
submissions
can
be
made
but
they
must
be
followed
up
with
a
hard
copy
that
is
signed
by
the
owner/
operator
of
the
facility.

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

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

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

Audit
facility
records.

Input,
analyze,
and
maintain
data
in
the
Air
Facility
System
(
AFS).
10
5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
was
achieved.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.
The
annual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
reports
is
entered
into
the
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Compliance.
AFS
is
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
data
for
approximately
125,000
industrial
and
government­
owned
facilities.
EPA
uses
the
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
state
regulatory
agencies,
EPA
regional
offices
and
EPA
headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner/
operator
for
five
years,
except
for
the
operation
and
maintenance
plan,
which
must
be
retained
for
the
life
of
the
facility.

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

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
in
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)(
40
CFR
part
63,
subpart
Y),
below.

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
the
subpart
included
in
this
ICR.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

The
Agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
Control
Number.
11
6(
a)
Estimating
Respondent
Burden
The
average
annual
burden
to
industry
over
the
next
three
years
from
these
recordkeeping
and
reporting
requirements
is
estimated
to
be
9,872
hours
(
Total
Labor
Hours
from
Table
1).
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
regulation,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
the
following
labor
rates:

Managerial
$
95.32
($
45.39
+
110%)
Technical
$
64.60
($
30.76
+
110%)
Clerical
$
40.09
($
19.09
+
110%)

These
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
December,
2003,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Estimating
Capital/
Startup
and
Operation
and
Maintenance
Costs
The
only
costs
to
the
regulated
industry
resulting
from
information
collection
activities
required
by
the
subject
standards
are
labor
costs.
There
are
no
capital/
startup
costs
because
no
additional
facilities
are
expected
to
become
subject
to
the
NESHAP
in
the
next
three
years.
There
are
no
operations
and
maintenance
costs.
The
industry
has
elected
not
to
install
continuous
monitoring
devices,
which
was
an
option
under
the
NESHAP.
The
industry
has
installed
primarily
flares
to
control
emissions.
Hence
the
only
industry
costs
are
the
labor
costs
for
performance
tests,
reporting,
and
keeping
records.

(
iii)
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs
The
only
types
of
industry
costs
associated
with
the
information
collection
activity
in
the
regulations
are
labor
costs.
There
are
no
capital/
startup
or
operation
and
maintenance
costs.

The
total
capital/
startup
costs
for
this
ICR
are
$
0.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
a),
Total
annualized
capital/
startup
costs.

The
total
operation
and
maintenance
(
O&
M)
costs
for
this
ICR
are
$
0.
These
costs
are
shown
on
the
OMB
83­
I
form
in
block
14(
b),
Total
annual
costs
(
O&
M).
12
The
total
respondent
costs
in
block
14
have
been
calculated
as
the
addition
of
the
capital/
startup
costs
and
the
annual
operation
and
maintenance
costs.
The
average
annual
cost
for
capital/
startup
and
operation
and
maintenance
costs
to
industry
over
the
next
three
years
of
the
ICR
is
estimated
to
be
$
0.
This
cost
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
numbers
in
block
14
of
the
OMB
83­
I
form
are
rounded
to
show
the
cost
in
thousands
of
dollars.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
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
sources
of
emissions,
and
the
publication
and
distribution
of
collected
information.

The
average
annual
Agency
cost
during
the
three
years
of
the
ICR
is
estimated
to
be
$
27,657
(
see
Table
2
in
Section
6(
e)).

This
cost
is
based
on
the
average
hourly
labor
rate
as
follows:

Managerial
$
54.66
(
GS­
13,
Step
5,
$
34.16
x
1.6)
Technical
$
40.56
(
GS­
12,
Step
1,
$
25.35
x
1.6)
Clerical
$
21.95
(
GS­
6,
Step
3,
$
13.72
x
1.6)

These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
"
2004
General
Schedule"
which
excludes
locality
rates
of
pay.
Details
upon
which
this
estimate
is
based
appear
in
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)(
40
CFR
part
63,
subpart
Y),
below.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
data
from
the
ACE
it
is
estimated
that
there
are
804
marine
tank
vessel
loading
facilities
that
load
gasoline
or
crude
oil
nationwide.
Based
on
our
research
for
this
ICR,
approximately
38
existing
sources
are
currently
subject
to
the
emissions
standards.
Therefore,
an
estimated
766
facilities
are
not
subject
to
the
emissions
standards,
but
are
still
subject
to
some
of
the
recordkeeping
requirements
of
the
NESHAP.
It
is
estimated
that
no
additional
sources
per
year
will
become
subject
to
the
standard
in
the
next
three
years.

The
number
of
respondents
is
calculated
using
the
following
table
which
addresses
the
three
years
covered
by
this
ICR.
13
Number
of
Respondents
Respondents
That
Submit
Reports
Respondents
That
Do
Not
Submit
Any
Reports
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
38
766
0
804
2
0
38
766
0
804
3
0
38
766
0
804
Average
0
38
766
0
804
1
New
respondents
include
sources
with
constructed
or
reconstructed
affected
facilities.
In
this
standard
existing
respondents
submit
initial
notifications.

To
avoid
double­
counting
respondents
column
D
is
subtracted.
As
shown
above,
the
average
Number
of
Respondents
over
the
three
year
period
of
this
ICR
is
804.
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
per
Source
(
D)
Number
of
Existing
Respondents
That
Keep
Records
But
Do
Not
Submit
Reports
(
E)
Total
Annual
Responses
E=(
B
×
C)+
D
Notification
of
construction/
reconstruction
0
1
0
0
Notification
of
anticipated
startup
0
1
0
0
Notification
of
actual
startup
0
1
0
0
Initial
notification
of
applicability
report
0
1
0
0
Waiver
application
0
1
0
0
Alternate
test
method/
monitoring
application
0
1
0
0
Preparation
of
site­
specific
test
plan
0
1
0
0
Notification
of
initial
0
1
0
0
14
Total
Annual
Responses
compliance
test
date
Notification
of
initial
compliance
status
(
initial
performance
test)
0
1
0
0
Annual
report
of
excess
emissions
and
monitoring
exceedances
and/
or
summary
report
38
1
0
38
Annual
report
of
HAP
control
efficiency
38
1
0
38
Retain
records
of
emissions
estimates
and
actual
throughput
0
0
766
766
Total
842
The
number
of
Total
Annual
Responses
is
842.
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
costs
are
$
629,850.
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,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
Y),
below.
15
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
Y)
Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences
/
Respondent
/
Yr.
(
C)
Hours/
Respondent
/
Yr.

[
C
=
A
×
B]
(
D)
a
Number
of
Respondents
(
E)
Technical
Hrs/
Yr.

[
E
=
C
×
D]
(
F)
Management
Hours/
Yr.

[
F
=
0.05
×
E]
(
G)
Clerical
Hours/
Yr.

[
G
=
0.1
×
E]
(
H)
b,
c
Total
Labor
Costs/
Yr.
($)

1.
Applications
Not
applicable
2.
Survey
and
Studies
Not
applicable
3.
Reporting
Requirements
A.
Read
instructions
1
1
1
38
38
2
4
2,788
B.
Required
activities
i.
Performance
Test
(
d,
e)
280
1
280
0
0
0
0
0
ii.
Repeat
of
Performance
Test
(
d,
e,
f)
280
1
280
0
0
0
0
0
iii.
Annual
leak
checks
(
g,
h)
16
1
16
38
608
30
61
44,612
iv.
Annual
vapor
tightness
check
(
i,
j)
8
1
8
450k
3,600
180
360
264,150
C.
Create
information
See
3B
D.
Gather
existing
information
See
3E
E.
Write
reports
i.
Notification
of
construction/
reconstruction
(
d)
2
1
2
0
0
0
0
0
ii.
Notification
of
anticipated
startup
(
d)
2
1
2
0
0
0
0
0
iii.
Notification
of
actual
startup
(
d)
2
1
2
0
0
0
0
0
iv.
Initial
notification
of
applicability
report
(
d)
4
1
4
0
0
0
0
0
v.
Waiver
application
(
d,
l)
2
1
2
0
0
0
0
0
vi.
Alternate
test
method/

monitoring
application
(
d,
m)
1
1
1
0
0
0
0
0
vii.
Preparation
of
site­
specific
test
plan
See
3B
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
Y),
Continued
16
Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences
/
Respondent
/
Yr.
(
C)
Hours/
Respondent
/
Yr.

[
C
=
A
×
B]
(
D)
a
Number
of
Respondents
(
E)
Technical
Hrs/
Yr.

[
E
=
C
×
D]
(
F)
Management
Hours/
Yr.

[
F
=
0.05
×
E]
(
G)
Clerical
Hours/
Yr.

[
G
=
0.1
×
E]
(
H)
b,
c
Total
Labor
Costs/
Yr.
($)

viii.
Notification
of
initial
compliance
test
date
(
d)
2
1
2
0
0
0
0
0
ix.
Notification
of
initial
compliance
status
(
initial
performance
test)
(
d)
See
3B
Notification
of
changes
in
information
provided
to
Administrator
1
1
1
0
0
0
0
Request
for
extension
of
compliance
1
1
1
0
0
0
0
Extension
of
compliance
progress
reports
1
1
1
0
0
0
0
Report
of
results
of
performance
test/
evaluations
1
1
1
0
0
0
0
x.
Annual
excess
emissions
and
monitoring
exceedances
report
and/
or
summary
report
(
ongoing
compliance
status
report)
(
n)
32
1
32
38
1,216
61
122
89,224
xi.
Report
of
HAP
control
efficiency
8
1
8
38
304
15
30
22,306
Reporting
Requirement
Subtotal
5,766
288
577
423,080
4.
Recordkeeping
Requirements
A.
Read
instructions
1
1
1
38
38
2
4
2,788
B.
Plan
activities
Not
applicable
C.
Implement
activities
(
d)
16
1
16
0
0
0
0
0
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
Y),
Continued
17
Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences
/
Respondent
/
Yr.
(
C)
Hours/
Respondent
/
Yr.

[
C
=
A
×
B]
(
D)
a
Number
of
Respondents
(
E)
Technical
Hrs/
Yr.

[
E
=
C
×
D]
(
F)
Management
Hours/
Yr.

[
F
=
0.05
×
E]
(
G)
Clerical
Hours/
Yr.

[
G
=
0.1
×
E]
(
H)
b,
c
Total
Labor
Costs/
Yr.
($)

D.
Develop
record
system
(
d)
16
1
16
0
0
0
0
0
E.
Enter
information
1
52
52
38
1,976
99
198
144,989
F.
Train
personnel
Not
applicable
G.
Perform
audits
Not
applicable
H.
Retain
records
of
emissions
estimates
and
actual
throughput
(
facilities
with
HAP
emissions
of
less
than
10
and
25
tons)
1
1
1
766
766
38
77
56,205
I.
Record
and
disclose
information
1
1
1
38
38
2
4
2,788
Recordkeeping
Requirement
Subtotal
2,818
141
282
206,770
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
9,872
$
629,850
a.
Number
of
respondents
per
year
is
explained
in
the
text.
No
new
sources
are
expected,
therefore
no
respondents
are
expected
for
any
of
the
one­
time
only
notifications
in
the
next
three
years.

b.
Calculation
of
burden
and
cost
values
reflects
rounding
of
numbers.

c.
Cost
is
based
on
rates
from
the
U.
S.
Dept.
of
Commerce,
Bureau
of
Labor
Statistics,
December
2003,
Table
10:
Employment
Costs
for
Private
Industry
by
Occupational
and
Industrial
Group.
The
wage
rates
have
been
loaded
by
adding
110%
overhead:
Executive,
Administrative
and
Managerial
=
$
95.32
($
45.39
+
110%);
Technical
=
$
64.60
($
30.76
+
110%);
Clerical
=
$
40.09
($
19.09
+
110%)

d.
One­
time
only
costs.

e.
Assumes
Method
25
or
25A
test
f.
Assumes
15
percent
of
the
initial
performance
tests
are
repeated
due
to
failure
of
the
first
test.

g.
All
affected
facilities
must
report
this
information
each
year.

h.
Assumes
a
Method
21
test
for
system
tightness.

i.
This
burden
is
to
the
owners
of
marine
vessels
and
not
to
the
affected
facilities.

j
Assumes
a
Method
21
test
on
a
vessel
takes
8
hours.
Table
1:
Annual
Respondent
Burden
and
Cost,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)
(
40
CFR
part
63,
subpart
Y),
Continued
18
k.
This
number
is
based
on
factors
calculated
for
the
original
ICR
in
1995.
That
ICR
used
fleet
factors
and
affected
facility
throughput
and
then
divided
in
half.
Assumes
that
half
of
the
facilities
load
at
negative
pressure.

l.
Assumes
5
percent
of
facilities
request
a
waiver.

m.
Assumes
1
percent
of
facilities
will
request
alternative
test
methods
or
monitoring
methods.

n.
Semiannual
reports
are
required
when
there
are
excess
emissions.
Assumes
that
there
will
be
no
excess
emissions,
therefore
each
facility
will
submit
one
excess
emissions
and
monitoring
exceedances
report
and/
or
summary
report
per
year.
19
The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entities
are
$
0.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
699
labor
hours
at
a
cost
of
$
27,657.
See
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations,
below.
20
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)(
40
CFR
part
63,
subpart
Y)

Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences
/
Respondent
/
Yr.
(
C)
Hours/
Respondent/

Yr.

[
C
=
A
×
B]
(
D)
c
Number
of
Respondents
(
E)
Technical
Hrs/
Yr.

[
E
=
C
×
D]
(
F)
Management
Hours/
Yr.

[
F
=
0.05
×
E]
(
G)
Clerical
Hours/
Yr.

[
G
=
0.1
×
E]
(
H)
a,
b
Total
Labor
Costs/
Yr.

($)

1.
Attend
Initial
Performance
Test
(
d,
e)
40
1
40
0
0
0
0
0
2.
Attend
Repeat
Performance
Test
(
d,
e)
40
1
40
0
0
0
0
0
3.
Report
Review
A.
Review
of
notification
of
construction/
reconstruction
(
e)
2
1
2
0
0
0
0
0
B.
Review
of
notification
of
anticipated
startup
(
e)
2
1
2
0
0
0
0
0
C.
Review
of
notification
of
actual
startup
(
e)
2
1
2
0
0
0
0
0
D.
Review
of
initial
notification
of
applicability
report
(
e)
2
1
2
0
0
0
0
0
E.
Review
of
notification
of
initial
compliance
test
date
(
e)
2
1
2
0
0
0
0
0
F.
Review
of
waiver
application
(
e,
f)
2
1
2
0
0
0
0
0
G.
Review
of
notification
of
initial
compliance
status
(
initial
performance
test)
(
e)
4
1
4
0
0
0
0
0
H.
Review
of
alternate
test
method/

monitoring
application
(
e,
g)
1
1
1
0
0
0
0
0
I.
Review
of
excess
emissions
and
monitoring
exceedances
report
and/
or
summary
report
(
ongoing
compliance
status
report)
(
h)
8
1
8
38
304
15
30
13,828
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)(
40
CFR
part
63,
subpart
Y),

Continued
21
Activity
(
A)
Technical
Hrs/
Occurrence
(
B)
Occurrences
/
Respondent
/
Yr.
(
C)
Hours/
Respondent/

Yr.

[
C
=
A
×
B]
(
D)
c
Number
of
Respondents
(
E)
Technical
Hrs/
Yr.

[
E
=
C
×
D]
(
F)
Management
Hours/
Yr.

[
F
=
0.05
×
E]
(
G)
Clerical
Hours/
Yr.

[
G
=
0.1
×
E]
(
H)
a,
b
Total
Labor
Costs/
Yr.

($)

J.
Review
of
report
of
HAP
control
efficiency
8
1
8
38
304
15
30
13,828
TOTAL
LABOR
BURDEN
AND
COST
(
rounded)
699
$
27,657
a.
Cost
is
based
on
the
sum
of
personnel
hours
multiplied
by
their
hourly
labor
rates
[(
Technical
hours
x
$
40.56)
+
(
Management
hours
x
$
54.66)
+
(
Clerical
hours
x
$
21.95)].

b.
Calculation
of
burden
and
cost
values
reflects
rounding
of
numbers.

c.
Number
of
respondents
per
year
is
explained
in
the
text.
No
new
sources
are
expected,
therefore
no
respondents
are
expected
for
any
of
the
one­
time
only
notifications
in
the
next
three
years.

d.
Assumes
EPA
will
attend
10
percent
of
the
initial
performance
tests
and
will
attend
no
repeat
tests.

e.
One­
time
only
costs.

f.
Assumes
5
percent
will
request
a
waiver.

g.
Assumes
1
percent
of
facilities
will
request
alternative
test
methods
or
monitoring
methods.

h.
Semiannual
reports
are
required
when
there
are
excess
emissions.
Assumes
that
there
will
be
no
excess
emissions,
therefore
each
facility
will
submit
one
excess
emissions
and
monitoring
exceedances
report
and/
or
summary
report
per
year.
22
6(
e)
Bottom
Line
Burden
Hours
Burden
Hours
and
Cost
Tables
The
detailed
bottom
line
burden
hours
and
cost
calculations
for
the
respondents
and
the
Agency
are
shown
in
Tables
1
and
2,
respectively,
and
summarized
below.

(
i)
Respondent
Tally
The
Total
Hours
Requested
is
shown
on
the
OMB
83­
I
form
in
block
13(
c).
The
total
annual
labor
costs
are
$
629,850.
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,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal)(
40
CFR
part
63,
subpart
Y),
above.
Furthermore,
the
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
12
hours
per
response.

The
total
annual
capital/
startup
and
O&
M
costs
to
the
regulated
entity
are
$
0.
This
number
is
shown
on
the
OMB
83­
I
form
in
block
14(
c),
Total
annualized
cost
requested.
The
cost
calculations
are
detailed
in
Section
6(
b)(
iii),
Capital/
Startup
vs.
Operation
and
Maintenance
(
O&
M)
Costs.

(
ii)
The
Agency
Tally
The
average
annual
Agency
burden
and
cost
over
next
three
years
is
estimated
to
be
699
labor
hours
at
a
cost
of
$
27,657.
See
Table
2:
Annual
Agency
Burden
and
Cost,
NESHAP
for
Marine
Tank
Vessel
Loading
Operations
(
Renewal),
above.

6(
f)
Reasons
for
Change
in
Burden
The
decrease
in
burden
from
the
most
recently
approved
ICR
is
due
to
five
adjustments.
Two
adjustments
contributed
decreases
in
burden
and
three
adjustments
contributed
increases
in
burden,
with
a
net
decrease
in
burden.
The
first
adjustment
decrease
in
burden
is
due
to
a
decrease
in
the
number
of
sources.
In
support
of
the
promulgation
of
the
NESHAP
in
1995,
EPA
performed
a
Regulatory
Impact
Analysis
and
estimated
that
28
marine
terminals
would
be
affected
by
these
standards.
In
the
active
ICR,
approved
May
9,
2002,
EPA
estimated
105
terminals
were
subject
to
the
NESHAP,
an
increase
of
11
terminals
per
year.
According
to
information
received
for
the
active
ICR,
this
industry
has
had
little
or
no
growth.
Therefore,
EPA
believes
that
the
estimate
of
105
sources
in
the
active
ICR
is
inaccurate.
EPA
searched
its
internal
databases,
including
OTIS,
for
enforcement
and
compliance
records
for
this
industry.
EPA
found
records
for
38
MACT
sources
subject
to
the
NESHAP.
EPA
used
38
as
the
number
of
respondents
for
calculating
the
burden
associated
with
the
NESHAP,
a
64%
decrease
in
the
number
of
respondents
from
the
active
ICR.

The
second
adjustment
decrease
in
burden
is
due
to
a
decrease
in
the
number
of
occurrences
per
respondent
per
year
for
the
report
of
HAP
control
efficiency.
The
active
ICR
calculated
the
burden
associated
with
this
activity
based
on
four
occurrences
per
respondent
per
year
(
i.
e.,
quarterly
reporting).
However,
the
respondents
are
required
to
submit
only
an
annual
report
of
HAP
control
efficiency
under
40
CFR
63.597(
j)(
3).
EPA
believes
the
use
of
four
occurrences
per
respondent
per
year
is
a
holdover
from
the
ICR
originally
written
in
1995
in
support
of
the
proposed
NESHAP.
Prior
to
the
promulgation
of
the
NESHAP,
EPA
considered
requiring
quarterly
reporting.
In
the
final
rule,
however,
EPA
required
only
annual
reporting.
Therefore,
EPA
23
calculated
the
burden
in
this
ICR
using
only
one
occurrence
per
respondent
per
year
for
the
report
of
HAP
control
efficiency.
This
adjustment
reduced
the
calculated
burden
on
both
industry
and
the
Agency.

The
third
adjustment
contributed
an
increase
in
burden
due
to
the
consideration
of
the
recordkeeping
burden
on
facilities
with
aggregate
actual
HAP
emissions
of
less
than
10
tons
of
each
individual
HAP
and
less
than
25
tons
of
all
HAP
combined.
These
facilities
do
not
have
emission
reduction
requirements
under
the
NESHAP,
but
are
required
to
retain
records
of
annual
HAP
emissions
estimates
and
actual
throughput
by
commodity.
EPA
estimated
that
766
facilities
would
spend
one
hour
once
per
year
to
maintain
these
records
under
the
NESHAP.
This
burden
was
not
included
in
the
original
or
active
ICR.

The
fourth
adjustment
contributed
an
increase
in
burden
due
to
the
increase
of
labor
rates.
Industry
labor
rates
increased
by
an
average
of
16.7%
from
the
active
ICR.
The
Agency
technical
labor
rate
increased
by
9.7%
from
the
active
ICR.
The
fifth
adjustment
contributed
an
increase
in
burden
by
including
managerial
and
clerical
labor
in
the
Agency
burden
calculations.
The
active
ICR
did
not
include
burdens
associated
with
managerial
and
clerical
labor.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
12
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
2004­
0035,
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
Ave.,
NW,
Washington,
DC.
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
Enforcement
and
Compliance
Docket
and
Information
Center
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,
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,
DC
24
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OECA­
2004­
0035
and
OMB
Control
Number
2060­
0289
in
any
correspondence.

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