SF­
83
SUPPORTING
STATEMENT
ENVIRONMENTAL
PROTECTION
AGENCY
STANDARDS
OF
PERFORMANCE
NESHAP
Subpart
M
National
Emission
Standard
for
Asbestos
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
NESHAP
Subpart
M
­
National
Emission
Standard
for
Asbestos
1(
b)
Short
Characterization/
Abstract
The
revised
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP),
for
Asbestos
were
proposed
on
January
10,1989
and
promulgated
on
November
20,
1990.
The
standards
apply
to
the
following
facilities:
demolition
and
renovation
of
facilities;
the
disposal
of
asbestos
waste;
asbestos
milling,
manufacturing
and
fabricating;
the
use
of
asbestos
on
roadways;

asbestos
waste
conversion
facilities;
and
the
use
of
asbestos
insulation
and
sprayed­
on
materials.

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

Milling,
Manufacturing,
Fabricating,
Waste
Disposal
and
Waste
Conversion
Facilities
Owners
or
operators
of
the
affected
milling,
manufacturing,
fabricating,
waste
disposal,

and
waste
conversion
facilities
described
must
make
the
following
one­
time­
only
reports:

notification
of
the
date
of
construction
or
reconstruction;
notification
of
the
anticipated
and
actual
dates
of
startup;
notification
of
any
physical
or
operational
change
to
an
existing
facility
which
may
increase
the
regulated
pollutant
emission
rate.
Owners
or
operators
are
also
required
to
maintain
records
of
the
occurrence
and
duration
of
any
startup,
shutdown,
or
malfunction
in
the
operation
of
an
affected
facility,
or
any
period
during
which
the
monitoring
system
is
inoperative.

These
notifications,
reports
and
records
are
required,
in
general,
of
milling,
manufacturing,
2
fabricating,
and
waste
disposal
sources
subject
to
the
NESHAP
Subpart
M.

The
recordkeeping
requirements
for
the
facilities
mentioned
above
consist
of
the
occurrence
and
duration
of
any
startup
and
malfunction
as
described.
They
include
the
initial
performance
test
results
including
information
necessary
to
determine
the
conditions
of
the
performance
test,
and
performance
test
measurements
and
results,
including
monitoring
each
potential
source
of
asbestos
emissions
for
visible
emissions
to
the
outside
air
and
inspecting
air
cleaning
devices
to
ensure
proper
operation.
Records
of
startups,
shutdowns,
and
malfunctions
should
be
noted
as
they
occur.
Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
two
years
following
the
date
of
such
measurements,
maintenance
reports,
and
records.

The
reporting
requirements
for
this
industry
currently
include
the
initial
notifications
listed,

the
initial
performance
test
results,
and
quarterly
reports
of
instances
when
visible
emissions
are
observed
at
any
time
during
the
quarter.

All
reports
are
sent
to
the
delegated
State
or
local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.
Notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
and
if
the
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions
under
which
compliance
was
achieved.

The
quarterly
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
3
Renovations
and
Demolitions
Owners
and
operators
of
demolitions
and
renovations
must
notify
EPA
in
advance
of
the
initiation
of
any
asbestos
removal
work.
The
notice
provides
information
on
the
dates
of
operation,
the
nature
of
the
removal
operation,
the
quantity
of
asbestos,
and
controls
to
be
used.

The
reviewing
authority
may
then
inspect
the
source
to
ensure
compliance
with
the
standard.

Demolitions
and
renovations
tend
to
be
short
projects,
and
it
is
difficult
at
best
to
determine
compliance
with
the
standard
once
the
project
has
been
completed.
Therefore,
it
is
important
that
the
delegated
authority
be
notified
of
the
changes
as
necessary
when
information
in
the
original
notification
changes.
Additionally,
without
notification
of
the
changes,
the
Agency
or
delegated
authority
may
needlessly
inspect
a
demolition
or
renovation
site
where
the
project
has
been
delayed.
The
demolition
and
renovation
standard
requires
that
a
representative
(
such
as
a
foreman
or
management­
level
person)
trained
in
the
provisions
of
the
standard
be
present
at
the
facility.
Evidence
that
the
required
training
has
been
completed
is
required
in
order
to
ensure
compliance
with
this
provision
of
the
standard.
The
regulation
requires
asbestos
removal
contractors
that
claim
exemption
from
the
wetting
provisions
because
of
freezing
temperatures
to
take
temperature
readings
throughout
the
day
and
record
the
information.
The
provisions
require
that
all
containers
of
asbestos
waste
be
labeled
including
the
name
of
the
waste
generator
and
the
location
of
where
the
waste
was
generated.
Owners
or
operators
of
demolitions
and
renovations
are
required
to
prepare
and
maintain,
for
at
least
two
years,
records
of
each
waste
shipment
as
to
its
destination,
the
quantity
of
waste,
and
the
date
of
shipment,
and
to
furnish
a
copy
of
the
record
to
disposal
site
owners
or
operators.
The
regulation
also
requires
that
the
generators
of
asbestos
waste
attempt
to
reconcile
instances
in
which
a
signed
copy
of
the
waste
shipment
record
is
not
received
from
the
disposal
site
and
that
the
generator
notify
EPA
if
delivery
to
the
disposal
site
4
cannot
be
confirmed.

Owners
and
operators
of
waste
disposal
sites
are
required
to
document
all
asbestos
waste
shipments
that
are
received
and
send
a
copy
of
each
record
back
to
the
generator.
A
record
of
the
location
and
quantity
of
asbestos
in
the
landfill
is
required
as
well
as
noting
the
presence
and
location
of
asbestos
in
the
landfill
property
deed.
Disposal
site
owners
and
operators
have
to
report
to
EPA
any
discrepancies
between
the
amount
of
waste
designated
on
the
waste
shipment
record
and
the
amount
actually
received,
as
well
as
instances
of
improperly
contained
waste.

Disposal
sites
are
required
to
maintain
records
for
at
least
two
years.
An
owner
or
operator
of
an
operation
in
which
asbestos­
containing
materials
are
spray­
applied
must
notify
EPA
in
advance
of
the
spraying
operation.
The
notice
provides
information
on
the
name
and
address
of
the
owner
or
operator,
location
of
the
spraying
operation,
and
procedures
to
be
followed.

Any
owner
or
operator
subject
to
the
provisions
of
this
part
shall
maintain
a
file
of
these
measurements,
and
retain
the
file
for
at
least
2
years
following
the
date
of
such
measurements,
and
records.

There
are
approximately
430
milling,
manufacturing
and
fabricating
sources
based
on
a
recent
Air
Facility
Subsystem
(
AFS)
review.
No
new
facilities
were
identified
as
having
notified
in
the
past
three
years.
There
is
no
expectation
that
there
will
be
an
increase
in
the
number
of
active
sources.

There
were
8,434
operators
at
92,790
demolition/
renovation
sources
identified
as
of
FY
2001
that
notified
the
National
Asbestos
Registry
System
(
NARS).
This
is
an
increase
of
1,
234
over
the
past
three
years
or
311
per
year.
It
is
expected
this
number
will
remain
the
same
for
the
next
three
years
as
renovations
and
demolitions
will
continue.
5
It
is
estimated
that
there
are
1,967
waste
disposal
sites
in
existence
as
of
2000
(
EPA's
Office
of
Solid
Waste,
Municipal
Solid
Waste
Division,

http://
www.
epa.
gov/
epaoswer/
non­
hw/
muncpl/
facts.
htm).
Of
these,
one­
half
allow
the
disposal
of
asbestos
containing
material
(
984
sites).
It
is
estimated
that
10
waste
disposal
sites
will
close
and
10
additional
waste
disposal
sites
each
year
will
become
subject
to
the
standard
in
the
next
three
years.
The
cost
of
this
ICR
will
be
$
2,869,124
for
milling,
manufacturing
and
fabricating,

$
1,481,233
for
waste
disposal
and
$
12,676,608
for
demolition
and
renovations
or
a
total
of
$
16,613,609
dollars.
All
reports
are
sent
to
the
delegated
State
or
Local
authority.
In
the
event
that
there
is
no
such
delegated
authority,
the
reports
are
sent
directly
to
the
EPA
Regional
Office.

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
or
operator
subject
to
any
requirement
of
this
Act
to
(
A)
establish
and
maintain
such
records,
(
B)
make
such
reports,
(
C)
install,
use,
and
maintain
such
monitoring
equipment
or
methods
(
in
accordance
with
such
methods
at
such
locations,
at
such
intervals,
and
in
such
manner
as
the
Administrator
shall
prescribe),
and
(
D)
sample
such
emissions,
(
E)
6
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical,
(
F)
submit
compliance
certifications,
and
(
G)
provide
such
other
information
as
he
may
reasonably
require.

In
the
Administrator's
judgment,
asbestos
emissions
from
the
demolition
and
renovation
of
asbestos­
containing
structures;
the
disposal
of
asbestos
waste;
waste
conversion;
asbestos
milling,

manufacturing,
and
fabricating;
the
use
of
asbestos
on
roadways;
the
use
of
asbestos
insulation
and
spray
materials;
cause
or
contribute
to
air
pollution
that
may
reasonably
be
anticipated
to
endanger
public
health
or
welfare.
Therefore,
NESHAP
were
promulgated
for
this
source
category
at
40
CFR
Part
61
Subpart
M.

2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
The
control
of
emissions
of
asbestos
from
the
regulated
sources
requires
not
only
the
installation
of
properly
designed
equipment,
but
also
the
operation
and
maintenance
of
that
equipment.
Emissions
of
asbestos
from
the
regulated
sources
are
the
result
of
operation
of
those
sources
(
milling,
manufacturing,
fabricating,
waste
disposal,
and
demolition
and
renovation).

These
standards
rely
on
the
capture
and
reduction
of
asbestos
emissions
by
air
cleaning
equipment
and
specified
work
practices.
The
required
notifications
are
used
to
inform
the
Agency
or
delegated
authority
when
a
source
becomes
subject
to
the
standard.
The
reviewing
authority
may
then
inspect
the
source
to
check
if
the
pollution
control
devices
are
properly
installed
and
operated,
the
work
practices
are
being
followed
and
the
standard
is
being
met.
Performance
test
reports
are
needed
as
these
are
the
Agency's
record
of
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
serve
as
a
record
of
the
operating
conditions
under
which
compliance
7
was
achieved.
Thereafter,
semi­
annual
reports,
if
required,
of
any
visible
emissions.
Waste
conversion
facilities
must
report
initial
testing
conditions
that
become
normal
operating
conditions
for
the
plant.
The
quarterly
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.
Notification
for
each
demolition
or
renovation
activity
allows
the
Agency
or
delegated
authority
to
plan
for
inspections
of
the
source
in
order
to
determine
compliance
with
the
work
practices.
Since
each
demolition
or
renovation
is
transitory
in
nature,
notification
must
be
made
for
each
activity
above
the
threshold
limits
specified
in
the
regulation.
The
information
generated
by
the
monitoring,
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
is
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
3(
a)
Nonduplication
The
recordkeeping
and
reporting
requested
is
required
under
40
CFR
Part
61
Subpart
M.

If
the
standard
has
not
been
delegated
the
information
is
sent
to
the
appropriate
EPA
Regional
Office.
Otherwise,
the
information
is
sent
directly
to
the
delegated
State
or
Local
Agency.
If
a
State
or
Local
Agency
has
adopted
their
own
similar
regulation
to
implement
the
Federal
Regulation,
a
copy
of
the
report
submitted
to
the
State
or
Local
agency
can
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
Federal
Standard.
Therefore,
no
duplication
8
exists.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
the
renewal
of
this
ICR
was
published
in
the
Federal
Register
on
June
20,
2002
beginning
on
page
41981.

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

Mr.
Frank
Sergi
Abcom
Environmental,
Inc
203­
776­
7583
Mr.
Michael
Lepi
Lepi
Enterprises,
Inc
740­
453­
2980
Ms.
Chris
Bockmann
Asbestos
Removers,
Inc.
402­
423­
6631
The
above
people
were
contacted
and
had
no
questions
about
the
notification,
reporting
or
recordkeeping
requirements.
They
had
no
issues
with
the
burden
for
complying
with
the
notification,
reporting
or
recordkeeping
requirements
for
this
regulation.

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

3(
e)
General
Guidelines
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
61
9
Subpart
M
or
otherwise
pertinent
to
this
request
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.6.

3(
f)
Confidentiality
The
required
information
consists
of
emissions
data
and
other
information
that
have
been
determined
not
to
be
private.
However,
any
information
submitted
to
the
Agency
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
the
Agency
policies
set
forth
in
Title
40,
Chapter
1,
Part
2,
Subpart
B
­
Confidentiality
of
Business
Information
(
see
40
CFR
2;
41
FR
36902,
September
1,
1976;
amended
by
43
FR
40000,
September
8,
1978;
43
FR
42251,

September
20,
1978;
44
FR
17674,
March
23,
1979).

3(
g)
Sensitive
Questions
None
of
the
reporting
or
recordkeeping
requirements
contained
in
40
CFR
Part
61
Subpart
M
or
otherwise
pertinent
to
this
request
contain
sensitive
questions.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
to
the
recordkeeping
and
reporting
requirements
are
as
follows:
10
Regulations
SIC
Codes
NAICS
Codes
40
CFR
260.142,
144
&
147
Mills,
Manufacture
and
Fabrication]
3292
(
asbestos
products)
2661
(
building
paper
and
board
mills)
3996
(
hard
surface
floor
coverings)
2812
(
alkalies
and
chlorine)
33634
(
Motor
Vehicle
Brake
System
Manufacturing)
327999
(
All
Other
Miscellaneous
Nonmetallic
Mineral
Product
Manufacturing)
23311
Land
Subdivision
and
Land
Development
326192
Resilient
Floor
Covering
Manufacturing
325181
Alkalies
and
Chlorine
Manufacturing
40
CFR
260.145
[
Renovation
and
Demolition]
1795
(
wrecking
and
demolition
work)
15
(
general
building
contractors)
16
(
heavy
construction
contractors)
17
(
special
trade
contractors)
6552
(
subdividers
and
developers)
23594
Wrecking
and
Demolition
Contractors
23321
Single
Family
Housing
Construction
23332
Commercial
and
Institutional
Building
Construction
23322
Multifamily
Housing
Construction
23331
Manufacturing
and
Industrial
Building
Construction
Regulations
SIC
Codes
NAICS
Codes
11
40
CFR
260.145
[
Renovation
and
Demolition],
cont.
1795
(
wrecking
and
demolition
work)
15
(
general
building
contractors)
16
(
heavy
construction
contractors)
17
(
special
trade
contractors)
6552
(
subdividers
and
developers)
23411
Highway
and
Street
Construction
23412
Bridge
and
Tunnel
Construction
23491
Water,
Sewer,
and
Pipeline
Construction
56291
Remediation
Services
23594
Wrecking
and
Demolition
Contractors
23571
Concrete
Contractors
23542
Drywall,
Plastering,
Acoustical,
and
Insulation
Contractors
23561
Roofing,
Siding,
and
Sheet
Metal
Contractors
23552
Floor
Laying
and
Other
Floor
Contractors
23543
Tile,
Marble,
Terrazzo,
and
Mosaic
Contractors
23311
Land
Subdivision
and
Land
Development
40
CFR
260.150
&
151
[
Waste
Disposal
Landfill]
4953
(
refuse
systems).
562212
Solid
Waste
Landfill
4(
b)
INFORMATION
REQUESTED
(
i)
Data
Items
All
data
in
this
ICR
that
is
recorded
and/
or
reported
is
required
by
40
CFR
Part
61
Subpart
M.
12
A
source
must
make
the
following
reports:

Reports
for
Regulatory
Citation
Construction
or
modification
application
61.07
61.155(
a)(
1)

Anticipated
start­
up
61.09(
a)(
1)

Actual
start­
up
61.09(
a)(
2)

Initial
performance
test
results
61.13(
f)

Initial
performance
test
61.13(
c)

Compliance
status
63.9(
h)

Physical
or
operational
change
61.15
Source
status
report
61.10(
a)

Asbestos
Mill­
visible
emission
report,
semi­
annual
61.142(
b)(
6)

Manufacturing­
visible
emission
report,
semi­
annual
61.144(
b)(
8)

Demolition
or
renovation
61.145(
b)

Spray­
on
application
61.146(
b)

Prior
to
excavating
asbestos
waste
61.151(
d)
61.154(
j).

Source
status
report
61.10(
a)

Maintenance
plan
61.142(
b)(
2)
61.144(
b)(
4)
61.147(
b)(
4)

Visible
emissions
(
quarterly)
61.142(
b)(
6)
61.144(
b)(
8)
61.147(
b)(
8)

Waste
shipment
record
not
received
61.149(
e)(
3)
61.150(
d)(
4)

Initial
startup
report
61.153(
a)

Initial
startup
report
61.153(
a)

Copy
of
records
when
landfill
is
closed
61.154(
h)
Reports
for
Regulatory
Citation
13
Analysis
of
samples
during
the
initial
90
days
61.155(
g)(
1)

Quarterly
operations
and
sample
analysis
61.155(
g)(
2)

A
source
must
maintain
the
following
records:

Recordkeeping
for
Regulatory
Citation
Emission
test
results
and
other
data
needed
to
determine
emissions
61.13(
g)

Records
are
required
to
be
retained
for
TWO
Years.
61.144(
b)(
7),
61.145(
c)(
7)(
iii)
61.147(
b)(
7)
61.149(
e)(
4)
61.150(
d)(
5)
61.155(
e)(
4)

Startup
and
initial
90
days
performance
test
61.155(
f)

Record
of
temperature
when
not
wetting
61.145(
c)(
7)
61.149(
c)(
1)(
iii)

Visible
emission
monitoring
and
air
cleaning
device
inspection
61.142(
b)(
3)
61.144(
b)(
5)
61.147(
b)(
5)

Training
61.145(
c)(
8)

Waste
shipment
record
61.149(
e)(
1)
61.150(
d)(
1)
61.154(
e)(
1)

Location,
volume,
etc.
of
asbestos
on
a
map
61.154(
f)

(
ii.)
Respondent
Activities
Respondent
Activities
Read
instructions.

Perform
initial
performance
test
[
Transmission
Electron
Microscopy]

Write
the
notifications
and
reports
listed
above.
Respondent
Activities
14
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
primary
reporting
and
recordkeeping
burden
under
NESHAP
Subpart
M
is
for
demolition
and
renovation
activities.
A
notice
must
be
submitted
before
each
demolition
or
renovation.
Most
of
the
information
contained
in
the
notification
is
information
required
by
the
abatement
contractor
to
bid
on
and
perform
the
demolition
or
renovation
activity.
This
ICR
minimizes
the
need
to
develop
new
information.
With
the
increasing
use
of
computers
and
electronic
form
software,
demolition
and
renovation
notifications
can
be
prepared
using
available
software
thus
minimizing
the
entry
of
information.
A
properly
completed
form
will
be
able
to
be
used
for
each
new
notification,
just
update
the
specifics
for
each
job.
However,
under
the
current
regulations,
only
a
paper
copy
is
acceptable
for
the
Notification
requirements.

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,
15
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
AIRS
(
Aerometric
Information
Retrieval
System)
Facility
Subsystem
(
AFS)
database.

5(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
determine
whether
the
pollution
control
devices
are
properly
installed
and
operated.

Performance
test
reports
are
used
by
the
Agency
to
discern
a
source's
initial
capability
to
comply
with
the
emission
standard,
and
note
the
operating
conditions
as
determined
during
the
test
under
which
compliance
was
achieved.
The
Agency
may
also
choose
to
inspect
active
demolition
or
renovation
sites
to
ensure
that
proper
work
practices
are
followed.
Data
and
records
maintained
by
the
respondents
are
tabulated
and
published
for
use
in
compliance
and
enforcement
programs.

The
quarterly
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
the
notification
is
entered
into
NARS,
information
contained
in
the
reports
is
entered
into
AFS
which
is
operated
and
maintained
by
EPA's
Office
of
Air
Quality
Planning
and
Standards.
NARS
is
EPA's
database
for
the
collection
and
tracking
of
asbestos
abatement
contractor
activity
and
compliance
record.
AFS
is
EPA's
database
for
the
collection,

maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
16
industrial
and
government­
owned
facilities.
EPA
uses
AIRS
for
tracking
air
pollution
compliance
and
enforcement
by
Local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
EPA
and
its
delegated
Authorities
can
edit,
store,
retrieve
and
analyze
the
data.

The
records
required
by
this
regulation
must
be
retained
by
the
owner
or
operator
for
two
years.

5(
c)
Small
Entity
Flexibility
The
recordkeeping
and
reporting
requirements
were
selected
within
the
context
of
this
specific
subpart
and
the
specific
process
equipment
and
pollutant(
s).
The
requirements
reflect
the
burden
on
small
businesses.
To
the
extent
that
larger
businesses
can
use
economies
of
scale
to
reduce
their
burden,
the
overall
burden
will
be
reduced.
Although
the
recordkeeping
and
reporting
requirements
are
the
same
for
small
and
larger
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.
In
fact,
for
demolition
and
renovation
activities,
this
sector
would
most
likely
not
exist
if
EPA
did
not
regulate
how
asbestos­
containing
material
(
material
containing
greater
than
1
percent
asbestos)
must
be
handled.
There
is
no
notification
required
for
renovations
that
involve
disturbing
less
than
160
square
feet
or
260
linear
feet
of
asbestoscontaining
material.

5(
d)
Collection
Schedule
The
specific
frequency
for
each
information
collection
activity
within
this
request
is
shown
on
Table
2.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Tables
1­
4
document
the
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
industry.
The
individual
burdens
are
expressed
under
standardized
17
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.
Section
112
of
the
Clean
Air
Act
as
Amended
provides
EPA
with
the
authority
for
NESHAP
Standards.
40
CFR
Part
61
Subpart
M
requires
the
collection
and
reporting
of
the
emissions
data/
work
practice
compliance.
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
342,249
person­
hours.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
Agency
knowledge
and
experience
with
the
NESHAP
program,
the
previously
approved
ICR,
and
any
comments
received.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
This
ICR
uses
labor
rates
of
$
55.34
for
technical
labor
and
$
35.64
for
clerical
labor.

These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,

March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rates
have
been
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

Technical
$
55.34($
26.35
+
110%)
Clerical
$
35.64($
16.97
+
110%)

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
18
The
only
type
of
industry
costs
associated
with
the
information
collection
activity
in
the
standards
are
labor
costs.
There
are
no
capital
or
operations
and
maintenance
costs.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
This
is
not
applicable
since
there
is
no
continuous
monitoring.

6(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.

Publication
and
distribution
of
the
information
are
part
of
the
NARS
and
AIRS
program.

Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
EPA's
overall
compliance
and
enforcement
program.

The
average
annual
Federal
Government
cost
during
the
3
years
of
the
ICR
is
estimated
to
be
$
1,786,653
based
on
the
average
hourly
labor
rate
at
a
GS­
12,
Step
1,
times
a
1.6
benefits
multiplication
factor
to
account
for
government
overhead
expenses
for
a
total
of
$
36.98.
Details
upon
which
this
estimate
is
based
appear
in
Table
1:
Agency
Burden.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
National
Emission
Standard
for
Asbestos
(
NESHAP
Subpart
M)
is
430
for
Milling,
Manufacturing
and
Fabricating,
984
for
Waste
Disposal
and
3,017
for
Demolition
and
Renovation.
The
number
of
new
sources
subject
to
National
Emission
Standard
for
Asbestos
(
NESHAP
Subpart
M)
is
0
for
Milling,
Manufacturing
and
Fabrication,
3
for
Waste
Disposal
(
with
3
closing
per
year)
and
92,790
(
85%
of
Notifications
are
initial
notifications).
The
total
annual
labor
costs
are
$
2,455,768
for
Milling,
Manufacturing
and
Fabricating,
$
12,676,608
for
Demolition
and
Renovation
and
$
1,481,233
for
Waste
Disposal
($
16,613,609
total).
Details
upon
which
this
estimate
is
based
appear
in
Table
1
­
4:
Industry
19
Burden.

6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables
See
Tables
1
­
4
6(
f)
Reasons
for
Change
in
Burden
While
there
was
no
new
regulatory
requirements
implemented
since
the
last
approved
ICR.
The
number
of
contractors
increased
by
1,143
(
7,200
in
FY
1999
to
8,343
in
FY
2001).

This
increase
is
due
to
new
businesses
being
formed
to
undertake
hazardous
materials
abatement,

e.
g.,
asbestos
and
lead.
The
number
of
waste
disposal
sites
decreased
due
to
more
accurate
numbers
of
municipal
waste
disposal
facilities
identified
by
the
Office
of
Solid
Waste.

6(
g)
Burden
Statement
Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
35
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.

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
20
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OECA­
2002­
0010,
which
is
available
for
public
viewing
at
the
Enforcement
and
Compliance
Docket
and
Information
Center
(
ECDIC)
Docket
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
(
ECDIC)
Docket
is
(
202)
566­
1514).
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.
Once
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
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OECA­
2002­
0010)
and
OMB
control
number
(
2060­
0101)
in
any
correspondence.

.

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

TABLE
1:
AVERAGE
ANNUAL
EPA
RESOURCE
REQUIREMENTS
RESULTING
FROM
NESHAP
SUBPART
M
21
(
A)
(
B)
(
C)
(
D)
(
E)
a
EPA
hours/
Occurrences/
respondents/
EPA
hours/
EPA
cost/

Occurrence
respondent/
yr
year
year
year
($)

(
AxBxC)

Activity
Report
Review
Visible
emission
Report
0.10
1
430
43
1,590
Control
device
maintenance
plan
0.25
1
43
11
407
Notification
of
intent
to
demolish
or
renovate
0.25
12
8,434
25,302
935,668
Re­
notification
due
to
change
0.25
2
8,434
4,217
155,945
Excepted
waste
shipment
report
from:

Milling,
mfg,
and
fabricating
0.5
1
430
215
7,951
Demolition
and
renovation
0.5
3
8,434
12,651
467,834
Waste
disposal
discrepancy
report
0.5
1
984
492
18,194
Improperly
contained
wastes
report
0.5
2
984
984
36,388
Maps
of
waste
sites
1.0
1
3
3
111
Asbestos
waste
conversion
processes
b
80.0
1
5
400
14,792
Disposal
site:
Application
to
construct
2
1
10
20
740
Notification
of
anticipated
startup
2
1
10
20
740
Notification
of
actual
startup
2
1
10
20
740
Source
reports
4
1
984
3,936
145,553
TOTAL
ANNUAL
BURDEN
47,330
$
1,786,653
a
Costs
are
based
on
the
rate
of
pay
of
GS
12
Step
1
$
23.11
times
1.6
for
benefits.
The
cost
per
hour
is
$
36.98.
OPM
General
Schedule
Salary,
2002.

b
An
estimated
1
respondent
will
apply
for
approval
each
year.
Between
40
and
120
hours,
or
an
average
of
80
hours,
per
occurrence
will
be
required
depending
on
whether
or
not
a
process
demonstration
is
necessary.

TABLE
2.
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
22
REQUIREMENTS
AS
A
RESULT
OF
THE
STANDARDS
For
Milling,
Manufacturing,
and
Fabricating
Occurrences/
Hours/
Cost
Hours
per
respondent/
respondent/
Respondents
Hours
per
Occurrence
year
year
per
year
per
year
year
a
(
A)
(
B)
(
C
=
A
*
B)
(
D)
(
E
=
C
*
D)
(
F)

1.
APPLICATIONS
____________________________________
Not
Applicable
_____________________________________________

2.
SURVEY
AND
STUDIES
____________________________________
Not
Applicable
_____________________________________________

3.
REPORTING
REQUIREMENTS
A.
Read
Instructions
1
1
1
430b
430
23,796
B.
Required
Activities
____________________________________
Not
Applicable
_____________________________________________

C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Not
applicablec
E.
Write
Report
Visible
Emissions
report
1
1d
1
430
430
23,796
Maintenance
plan
1e
1
1
43f
43
2,380
Excepted
waste
shipments
1
1
1
430
430
23,796
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Not
applicable
C.
Implement
Activities
Not
applicable
D.
Develop
Record
System
0g
n/
a
n/
a
n/
a
n/
a
n/
a
E.
Time
to
Enter
Information
Visible
Emissions
monitoring
0.1
638h
64
430
27,520
1,522,957
Weekly
inspection
0.25
120i
32
430
13,760
761,478
Waste
shipments
0.1
51j
5
430
2,150
118,981
Excepted
waste
shipment
0.1
1
0.1
430
43
2,380
F.
Train
Personnel
Not
applicable
(
unless
certification
for
Method
9
is
necessary)

G.
Audits
____________________________________
Not
Applicable
______________________________________________

TOTAL
ANNUAL
BURDEN
45,236
$
2,455,768
23
TABLE
2.
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
AS
A
RESULT
OF
THE
STANDARDS
For
Milling,
Manufacturing,
and
Fabricating,
cont.

a
This
ICR
uses
labor
rates
of
$
55.34
for
technical
labor.
These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,

"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rates
have
been
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
$
55.34
($
26.35
+
110%).

b
There
are
an
estimated
200
milling
and
manufacturing
sources.
The
total
number
of
fabricators
in
1981
was
estimated
at
273.
Based
on
the
rate
of
change
for
asbestos
consumption
by
manufacturers,
there
were
an
additional
230
fabricators
in
1989.
The
number
of
milling,
manufacturing,
and
fabricating
respondents
is
430
(
200
+
230).
Asbestos
milling,
manufacturing
and
fabricating
in
the
US
has
not
increased.
There
have
been
no
new
facilities.

c
Time
required
to
monitor
and
inspect
are
not
included
because
they
are
already
done
by
most
plants.

d
One
visible
emission
per
year.

e
The
three
year
average
burden
assumes
3
hours
to
develop
a
maintenance
plan
in
the
first
year
with
no
additional
time
requirements
in
the
second
and
third
years.

The
average
would
then
be
(
3+
0+
0)/
3
=
1
hour.

f
An
estimated
10
percent
of
respondents
would
submit
maintenance
plans.

g
Since
there
are
no
new
facilities,
there
is
no
need
to
develop
new
recordkeeping
systems.

h
Each
control
device
monitored
1/
day,
2.5
devices/
respondent,
255
days
per
year.

i
Each
control
device
inspected
1/
wk,
2.5
devices/
respondent,
51
wk/
year.

j
One
shipment
of
waste
per
week.
TABLE
3.
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
24
REQUIREMENTS
AS
A
RESULT
OF
THE
STANDARDS
For
Demolition
and
Renovation
Occurrences/
Hours/

Hours
per
respondent/
respondent/
Respondents
Hours
Cost
Occurrence
year
year
per
year
per
year
per
year
(
A)
(
B)
©
=
A
*
B)
(
D)
(
E
=
C
*
D)
(
F)

1.
APPLICATIONS
Not
Applicable
2.
SURVEY
AND
STUDIES
Not
Applicable
3.
REPORTING
REQUIREMENTS
A.
Read
Instructions
c
1
1
1
8,434
8,434
466,737
a
B.
Required
Activities
Not
Applicable
C.
Create
Information
Included
in
3E
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
Notification
of
intent
to
demolish
or
renovate
d
1
9
9
8,434
75,906
3,004,359
b
Renotification
due
to
changed
0.25
2
0.5
8,434
4,217
166,909
b
Excepted
waste
shipments
1
3
3
8,434
25,302
1,400,212
a
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Included
in
3B
C.
Implement
Activities
Included
in
3B
D.
Develop
Record
System
Not
Applicable
E.
Time
to
Enter
Information
Waste
shipments
0.1
29
e
2.9
8,434
24,459
1,353,561
a
Temperature
monitoring
0.1
15
f
1.5
8,434
12,651
700,106
a
Excepted
waste
shipments
0.1
3
0.3
8,434
2,530
140,010
a
F.
Train
Personnel
Time
to
train
contractors
in
NESHAP
provisions:

Initial
training
15.5
1
15.5
4,920g
76,260
4,220,228
a
Refresher
training
8
1
8
2,811h
22,488
1,224,486
a
G.
Audits
____________________________________
Not
Applicable
25
5.
TOTAL
ANNUAL
BURDEN
252,247
$
12,676,608
TABLE
3.
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
AS
A
RESULT
OF
THE
STANDARDS,
cont.

a
Assume
an
hourly
Technical
wage
of
$
55.34.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.
This
ICR
uses
labor
rates
of
$
55.34
for
technical
labor
and
$
35.64
for
clerical
labor.
These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,
"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rates
have
been
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
$
55.34
($
26.35
+
110%)
Clerical
$
35.64
($
16.97
+

110%)

b
Assume
20%
technical
and
80%
clerical
(
0.80
x
35.64
+
0.20
x
55.34)
=
$
39.58
c
Based
on
NARS,
FY
2001
the
year
most
recently
completed.
There
are
approximately
8,434
asbestos
contractors.

d
Based
on
NARS,
FY
2001,
there
were
a
total
of
92,790
notifications/
year.
Assume
85
percent
are
initial
notifications,
and
the
remaining
are
renotifications
On
average
there
are
9
notifications
per
respondent
[(
92,790
x
0.85)/
8434],
and
2
renotifications
per
respondent
[(
92,790
x
0.15)/
8434].

e
Waste
shipments
to
be
recorded
­
assume
4(
106)
yd3
per
year
and
20
yd3
per
load.
This
gives
200,000
loads
per
year
or
29
loads/
contractor.

f
Of
an
estimated
total
of
92,790
asbestos
jobs,
approximately
1%
or
9279
are
demolitions
involving
asbestos.
Approximately
15
percent
of
the
demolitions
are
performed
during
freezing
weather.
Taking
three
reading
per
day
with
demolition
jobs
lasting
an
average
of
30
days
each,
the
number
of
occurrences
per
respondent
per
year
would
be
as
follows:
(
9,279)(
0.15)(
3)(
30)/
8,434
=
15.

g
Number
of
respondents
is
3­
year
average
assuming
that
8,434
contractors
are
trained
in
the
first
year.
In
the
second
year
4,217
(
50
percent)
require
training
as
a
result
of
employee
turnover,
and
firms
entering
the
market
for
the
first
time,
and
existing
firms
that
were
not
involved
in
asbestos
removal
in
the
first
year.
In
the
third
year,
2109
(
50
percent
of
the
previous
year)
require
training.
The
three
year
average
is
calculated
as
follows:

(
8434
+
4217
+
2109)/
3
=
4920
contractors/
year.

h
Number
of
respondents
is
3­
year
average
assuming
that
8,434
contractors
would
receive
refresher
training
during
the
3­
year
period
as
follows:

8434/
3
=
2811
contractors/
year.
26
TABLE
4.
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
AS
A
RESULT
OF
THE
STANDARDS
For
Waste
Disposal
Occurrences/
Hours/
Cost
Hours
per
respondent/
respondent/
Respondents
Hours
per
Occurrence
year
year
per
year
per
year
year
a
(
A)
(
B)
©
=
A
*
B)
(
D)
(
E
=
C
*
D)
(
F)

1.
APPLICATIONS
Not
Applicable
2.
SURVEY
AND
STUDIES
Not
Applicable
3.
REPORTING
REQUIREMENTS
A.
Read
Instructions
1
1
1
984
b
984
54,455
B.
Required
Activities
Not
Applicable
C.
Create
Information
Map
location
and
quantity
of
waste
4
1
4
984
3,936
217,818
D.
Gather
Existing
Information
Included
in
3E
E.
Write
Report
Application
to
construct
0.5c
1
0.5
10
d
5
277
Notification
of
anticipated
Startup
0.5c
1
0.5
10
5
277
Notification
of
actual
startup
0.5c
1
0.5
10
5
277
Source
reporting
0.5c
1
0.5
984
492
27,227
Improperly
contained
waste
report
1
2
2
984
1,968
108,909
Discrepancy
report
1
1
1
984
984
54,455
4.
RECORDKEEPING
REQUIREMENTS
A.
Read
Instructions
Included
in
3A
B.
Plan
Activities
Not
applicable
C.
Implement
Activities
Not
applicable
D.
Develop
Record
System
Not
applicable
E.
Time
to
Enter
Information
File
and
mail
waste
shipment
Records
to
generator
1.5
12
18
984
17,712
980,182
File
and
mail
discrepancy
report
to
EPA
0.5
1
0.5
984
492
27,227
27
TABLE
4.
ANNUAL
BURDEN
OF
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
AS
A
RESULT
OF
THE
STANDARDS
For
Waste
Disposal,
cont.

Occurrences/
Hours/
Cost
Hours
per
respondent/
respondent/
Respondents
Hours
per
Occurrence
year
year
per
year
per
year
year
a
(
A)
(
B)
©
=
A
*
B)
(
D)
(
E
=
C
*
D)
(
F)

File
and
mail
application
to
construct
to
EPA
0.17e
1
0.17
10
2
111
File
and
mail
notice
of
anticipated
startup
0.17e
1
0.17
10
2
111
File
and
mail
notice
of
actual
startup
0.17e
1
0.17
10
2
111
File
and
mail
source
report
0.17e
1
0.17
984
167
9,242
Copy
and
send
maps
to
EPA
upon
closure
0.5
1
0.5
10
5
277
Make
record
on
deed
0.5
1
0.5
10
5
277
F.
Train
Personnel
Not
Applicable
G.
Audits
Not
Applicable
5.
TOTAL
ANNUAL
BURDEN
26,766
$
1,481,233
a
Assume
an
hourly
Technical
wage
of
$
55.34.
This
amount
was
multiplied
by
the
hours
per
year
in
Column
E.
This
ICR
uses
labor
rates
of
$
55.34
for
technical
labor
and
$
35.64
for
clerical
labor.
These
rates
are
from
the
United
States
Department
of
Commerce
Bureau
of
Labor
Statistics,
March
2000,

"
Table
10.
Private
industry,
by
occupational
and
industry
group."
The
rates
are
from
column
1,
"
Total
compensation."
The
wage
rates
have
been
increase
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.
Technical
$
55.34
($
26.35
+
110%)

b.
It
is
estimated
that
of
the
currently
operating
1,967
landfills,
approximately
one
half
will
handle
asbestos
waste.

c
The
3­
yr
average
burden
assumes
1.5
hours
to
write
reports
in
the
first
year
with
no
additional
time
requirements
in
the
second
and
third
years.
The
average
would
then
be
(
1.5+
0+
0)/
3
=
0.5hr.

d
It
is
estimated
that
5
percent
of
the
asbestos
landfills
will
close
each
year
and
that
the
number
of
landfills
that
open
each
year
will
be
approximately
equal
to
28
the
number
that
close.
(
984
*
0.01
=
10)
e
The
3­
yr
average
burden
assumes
0.5
hours
to
file
and
mail
reports
in
the
first
year
with
no
additional
time
requirements
in
the
second
and
third
years.
The
average
would
then
be
(
0.5+
0+
0)/
3
=
0.17
hr.
