SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Publicly Owned Treatment Works (40 CFR part 63, subpart VVV)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

	NESHAP for Publicly Owned Treatment Works (40 CFR part 63, subpart VVV)

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the regulations published at 40 CFR part 63, subpart VVV were
proposed on December 1, 1998, and promulgated on October 26, 1999. 
These regulations apply to existing and new publicly owned treatment
works (POTWs) located at a major source of hazardous air pollutants, or
industrial POTWs that are either area, or major sources.  Affected
sources must develop and implement a pretreatment program defined by 40
CFR 403.8, or meet the general criteria for development and
implementation of a pretreatment program.  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 VVV

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

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

Approximately six respondents are currently subject to the regulation,
and it is estimated that no new respondents per year will become subject
to the regulation during 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

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, hazardous air pollutant emissions from
POTWs 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
VVV.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard(s) ensure
compliance with the applicable regulations which where promulgated in
accordance with the Clean Air Act.  The collected information is also
used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected
facility’s initial capability to comply with the emission standard(s).
 Continuous emission monitors are used to ensure compliance with the
standard(s) at all times.

The notifications required in the standard(s) are used to inform the
Agency, or delegated authority, when a source becomes subject to the
requirements of the regulations.  The reviewing authority may then
inspect the source to check if the pollution control devices are
properly installed and operated and/or leaks are being detected and
repaired and the standard(s) are being met.  The performance test may
also be observed.

The required semiannual reports are used to determine periods of excess
emissions, identify problems at the facility, verify
operation/maintenance procedures and for compliance determinations.

3.  Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR part
63, subpart VVV.

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 (70 FR 24020) on May 6, 2005.  No
comments were received on the burden published in the Federal Register.

3(c)  Consultations

 	Consultations were made with the National Association of Clean Water
Agencies (NACWA), which represents municipalities that own and operate
large publicly owned treatment works (POTWs).  The contact at NACWA was
Chris Hornback, Director of Regulatory Affairs, at (202) 833-2672. 
Consultations were also made with Robert Lucas, the staff lead for
developing subpart VVV in the Office of Air Quality Planning and
Standards.  In addition, the EPA Online Targeting and Information System
(OTIS) was used to verify the estimated number of sources.

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 violates 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

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 contains sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
sewerage systems operators.  The SIC code for the respondents affected
by the standards is SIC (United States Standard Industrial
Classification) 4952 which corresponds to the NAICS (The North American
Industry Classification System) 221320 for sewerage treatment
facilities.

4(b)  Information Requested 

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
the NESHAP for Publicly Owned Treatment Works (40 CFR part 63, subpart
VVV).

Sources may be required to submit the following notifications and submit
the following reports listed below:

Notifications

Initial Notification 	63.1591(b), 63.9(b)

Request for Extension of Compliance	63.9(c)

Notification of Special Compliance Requirements	63.9(d)

Notification of Initial Performance Tests	63.9(e), 63.7(b)

Additional Notification Requirements for Sources with CMS	63.9(g)

Notification of Compliance Status	63.9(h)

Notification of Adjustments to Time Periods for Submitting Required
Communications	63.9(i)

Notification of Changes to Information Provided	63.9(j)



Reports

Initial Performance Test Report	63.1590(f), 63.10(d)

Startup, Shutdown, Malfunction Report	63.1590(f)

Inspection and Monitoring Plan	63.1588(c)

Semiannual Report	63.1590(f)

Excess Emissions Report	63.10(e)

Initial Report on Compliance Approach	63.1590(g)



Sources may be required to maintain the following records for the
specified sections that apply to the source:

Recordkeeping

Records of Annual Inspections	63.1589(a)(1)

Records of Defects Detected 	63.1589(a)(2)

Records of Defect Repair Delays	63.1589(a)(3)

Records of Control Devices Covered by Other NESHAPS	63.1589(a)(4)

Records of Methods Used to Calculate Annual HAP Emissions	63.1589(b)(1)

Record of Methods and Data Used to Determine if POTW Meets Fraction
Emitted Standard	63.1589(b)(2)

Records of Methods and Data the Demonstrates POTW is in Continuous
Compliance 	63.1589(b)(3)

Maintain Records for Five Years	63.10(b)(1)

Records of Startups, Shutdowns, and Malfunctions	63.10(b)(2)



Electronic Reporting

	At the present, respondents are using monitoring equipment that
automatically records parameter data.  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.  At this time,
it is estimated that approximately 10 percent of the respondents who are
required to submit reports would use electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Read instructions.

Write the notifications and reports listed above.

Prepare required plans and perform initial performance test, if
required.

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.

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.

Audit facility records.

Input, analyze, and maintain data in the Air Facility System (AFS).



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.  Data and records maintained by the respondents are
tabulated and published for use in compliance and enforcement programs. 
The semiannual reports are used for problem identification, as a check
on source operation and maintenance, and for compliance determinations.

Information contained in the reports is entered into the Air Facility
System (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.

5(c)  Small Entity Flexibility

	There are no small entities (i.e., 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 Burden of Reporting and
Recordkeeping Requirements, NESHAP for Publicly Owned Treatment Works
(40 CFR part 63, subpart VVV).

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.

6(a)  Estimating Respondent Burden

We have estimated that there are six (6) “existing” affected sources
subject to subpart VVV.  We also estimated that no new sources will
startup in the next three years.  Subpart VVV requires existing sources
to comply with the requirements specified by other applicable NESHAPs. 
Therefore, the only recordkeeping and reporting requirement for existing
sources subject to Subpart VVV is a semiannual report.  The average
annual burden to industry over the next three years from submitting the
semiannual report is 13.8 hours.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates: 

Managerial	$97.46   ($46.41 + 110%)

Technical	$83.71   ($39.86 + 110%)

Clerical	$42.55   ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 19, 2005, Table 2. Civilian Workers, 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

There are no capital/startup or operation and maintenance costs
associated with this ICR.

(iii)  Capital/Startup vs. Operation and Maintenance (O&M) Costs

Per 40 CFR 63.1583, emissions and control requirements for existing
sources are covered by other existing NESHAP standards.  Since there are
no new sources subject to this subpart, we can assume that the
capital/startup costs associated with the monitoring devices are already
included in the ICRs for the other NESHAP standards that apply to these
sources.  Therefore the costs associated with capital/startup are $0 as
shown on the OMB 83-I form in block 14(a), Total annualized
capital/startup costs.

Operation and maintenance costs associated with these monitoring devices
would also be included in the ICRs for the other NESHAP standards that
apply to these sources.  Therefore, the estimated total operation and
maintenance (O&M) costs for this ICR are also $0 as shown on the OMB
83-I form in block 14(b), Total annual costs (O&M).

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 as shown on the OMB 83-I form in block
14(c), Total annualized cost requested.

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 $559 (rounded).

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

		Managerial	$56.02  (GS-13, Step 5, $35.01 x 1.6)

		Technical	$41.57  (GS-12, Step 1, $25.98 x 1.6)

		Clerical	$22.50  (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) (2005
General Schedule( which excludes locality rates of pay.  Details upon
which this estimate is based appear in Table 2: Average Annual EPA
Resource Requirement, NESHAP for Publicly Owned Treatment Works (40 CFR,
Part 63, Subpart VVV) below.

6(d)  Estimating the Respondent Universe and Total Burden and Costs

Based on our research for this ICR, there are six “existing” sources
that are subject to Subpart VVV.  No new sources will becomes subject to
this ICR over the next three years.  Therefore, the Number of
Respondents over the three year period of this ICR is six.  This number
appears on the OMB 83-I form in block 13(a), Number of respondents.

	Existing sources are only required to submit semiannual reports.  Thus,
the number of Total Annual Responses is 12.  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). 
Since there are no requirements for “existing” sources under Subpart
VVV, the total annual labor costs are $1,114 (rounded).  The annual
labor costs are not shown on the OMB 83-I form.  Details regarding these
estimates may be found in Table 1: Annual Burden of Reporting and
Recordkeeping Requirements, NESHAP for Publicly Owned Treatment Works
(40 CFR part 63, subpart VVV).

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 13.8 hours at a cost of $559.45.  See Table 2: Average
Annual EPA Resource Requirement, NESHAP for Publicly Owned Treatment
Works (40 CFR, part 63, subpart VVV).

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 $1,114.  The annual labor costs are not
shown on the OMB 83-I form.  Details regarding these estimates may be
found in Table 1: Annual Burden of Reporting and Recordkeeping
Requirements, NESHAP for Publicly Owned Treatment Works (40 CFR part 63,
subpart VVV).  Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 1.15 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 13.8 hours at a cost of $559.  See Table 2: Average
Annual EPA Resource Requirement, NESHAP for Publicly Owned Treatment
Works (40 CFR, part 63, subpart VVV).

6(f)  Reasons for Change in Burden

The decrease in burden from the most recently approved ICR is due to a
correction.  It has been determined that there are six affected
“existing” sources subject to Subpart VVV.  According to Subpart
VVV, the only requirements for “existing” sources are those required
by other NESHAPs that may apply.  For the purpose of this ICR, we assume
that the burden associated with complying with the requirements of the
other NESHAPs will be included in the ICR for those NESHAPs.  Therefore,
the only burden associated with this ICR is semiannual reporting.

The previous ICR assumed there were additional recordkeeping costs
associated with control device monitoring and inspection.  The previous
ICR also assumed costs associated with a design analysis and trading. 
These costs are erroneous and have been removed from this ICR.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 1.15 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
EPA-OECA-2005-0035, 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 is (202)
566-1752.  

	An electronic version of the public docket is available through the
Federal Docket Management System (FDMS) at http://www.regulations.gov. 
Use FDMS 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, N.W.,
Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OECA-2005-0035 and OMB Control Number
2060-0428 in any correspondence.	

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in
collecting this information.

TABLES

Table 1

TABLE 1















NESHAP FOR PUBLICLY OWNED TREATMENT WORKS (40 CFR PART 63, SUBPART VVV)



















	REPORTING/RECORDKEEPING REQUIREMENT	Hours/Occurence     (A)
Occurences/Year              (B)	Hours/Year (C=A*B)            (C)
Respondents/Year                  (D)	Technical Hours/Year (E)
Management Hours/Year (E*0.05)	Admin. Hours/Yr.   (E*0.1)	Hours/Year    
    (F)	Costs/Year                  (G)

1.	APPLICATIONS	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

2.	SURVEY AND STUDIES	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

3.	REPORTING REQUIREMENTS











a.	Read Instructions	4	1	4	0	0	0.0	0.0	0.0	$0.00

	b.	Required Activities













Initial Notification	2	1	2	0	0	0.0	0.0	0.0	$0.00



	Notification of Compliance Status	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

	c.	Create Information

------------------------Included in 3b------------------------





d.	Gather Existing Information

------------------------Included in 3e------------------------





e.	Write Report













Request for Extension of Compliance	2	1	2	0	0	0.0	0.0	0.0	$0.00



	Notification of Special Compliance Requirements	2	1	2	0	0	0.0	0.0	0.0
$0.00



	Notification of Initial Performance Test	N/A	N/A	N/A	N/A	N/A	N/A	N/A
N/A	N/A



	Additional Notification Requirements for Sources with CMS	2	1	2	0	0	0.0
0.0	0.0	$0.00



	Notification of Adjustments to Time Periods	2	1	2	0	0	0.0	0.0	0.0	$0.00



	Notification of Changes to Information Provided	2	1	2	0	0	0.0	0.0	0.0
$0.00



	Initial Performance Test Report	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A



	Inspection and Monitoring Plan	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A



	Startup, Shutdown, and Malfunction Plan	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
N/A



	Semiannual Report	1	2	2	6	12	0.6	1.2	13.8	$1,114.06



	Startup, Shutdown, Malfunction Report	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A
N/A



	Excess Emissions Report	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A



	Initial Report on Compliance Approach	2	1	2	0	0	0.0	0.0	0.0	$0.00

4.	RECORDKEEPING REQUIREMENTS











a.	Read Instructions	 	------------------------Included in
3e------------------------	 	 	 	 

	b.	Plan Activities

------------------------Included in 3e------------------------





c.	Implement Activities

------------------------Included in 3e------------------------





d.	Develop Record System

------------------------Included in 3e------------------------



















REPORTING/RECORDKEEPING REQUIREMENT	Hours/Occurence     (A)
Occurences/Year              (B)	Hours/Year (C=A*B)            (C)
Respondents/Year                  (D)	Technical Hours/Year (E)
Management Hours/Year (E*0.05)	Admin. Hours/Yr.   (E*0.1)	Hours/Year    
    (F)	Costs/Year                  (G)

	e.	Time to Enter Information













Records of Annual Inspections	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A



	Records of Treatment Unit Inspections, Defects Detected, Defect Repair
Delays, Control Devices	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A



	Methods and Data Used to Determine HAP Emissions, Compliance with
Fraction Emitted Standard, and Continuous Compliance	N/A	N/A	N/A	N/A	N/A
N/A	N/A	N/A	N/A

	f.	Time to Transmit or Disclose Information	N/A	N/A	N/A	N/A	N/A	N/A	N/A
N/A	N/A

	g.	Train Personnel	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

	h.	Audits	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A















	TOTAL ANNUAL BURDEN



	 	 	 	 	$1,114.06































	Assumptions













Number of affected facilities	6











Number of new facilities (per year)	0











Time required to read instructions, submit notifications, and reports
(hours)	2











Management labor rate	$97.46











Technicial labor rate	$83.71











Adminstrative labor rate	$42.55

























This ICR assumes all six affected sources are "existing" facilities. 
There are no emission limits or control requirements under Subpart VVV
for existing sources subject to this ICR.  Compliance with Subpart VVV
is demonstrated by operating treatment and control devices which meet
all requirements specified in the appropriate industrial NESHAP(s).  40
CFR Section 63.1586. The recordkeeping and reporting burden associated
with the other NESHAP(s) is included in the ICRs for the other
NESHAP(s).



	Performance testing, plan development, and reporting are only required
for "new" sources subject to Subpart VVV.  Therefore, these requirements
as shown above are "not applicable."



Table 2

TABLE 2	AVERAGE ANNUAL EPA RESOURCE REQUIREMENT









	NESHAP FOR PUBLICLY OWNED TREATMENT WORKS (40 CFR, PART 63, SUBPART
VVV)

















REPORTING/RECORDKEEPING REQUIREMENT	EPA Hours/Occurence      (A)
Occurences/Plant/Year       (B)	EPA Hours/   Year (C=A*B)  (C)
Plants/Year       (D)	Technical Hours/Year (E)	Management Hours/Year
(E*0.05)	Admin. Hours/Year (E*0.1)	EPA     Hours/ Year (E=C*D)       
(F)	Cost/ Year 

INITIAL PERFORMANCE TESTS	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

 











REPEAT PERFORMANCE TEST	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A













REPORT REVIEW











Initial Notification	2	1	2	0	0	0	0	0	0

	Notification of Compliance Status      	2	1	2	0	0	0	0	0	0

	Request for Extension of Compliance	2	1	2	0	0	0	0	0	0

	Notification of Special Compliance Requirements	2	1	2	0	0	0	0	0	0

	Notification of Initial Performance Test	2	1	2	0	0	0	0	0	0

	Additional Notification Requirements for Sources with CMS	2	1	2	0	0	0	0
0	0

	Notification of Adjustments to Time Periods for Submitting Required
Communications	2	1	2	0	0	0	0	0	0

	Notification of Changes to Information Provided	2	1	2	0	0	0	0	0	0

	Initial Performance Test Report	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

	Inspection and Monitoring Plan 	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

	Semi Annual Report	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

	Startup, Shutdown, Malfunction Report	1	2	2	6	12	0.6	1.2	13.8	$559.46

	Excess Emissions Report	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A

	Initial Report on Compliance Approach	2	1	2	0	0	0	0	0	0













TOTAL ANNUAL HOURS







       13.8	$559.46













	Assumptions











Number of new facilities	0









	Time require to review notifications and initial compliance approach
(hours)	2









	EPA Management labor rate	$56.02









	EPA Technical labor rate	$41.57









	EPA Clerical labor rate	$22.50





































































	This ICR assumes all six affected sources are "existing" facilities. 
There are no emission limits or control requirements under Subpart VVV
for existing sources subject to this ICR.  Compliance with Subpart VVV
is demonstrated by operating treatment and control devices which meet
all requirements specified in the appropriate industrial NESHAP(s).  40
CFR Section 63.1586. The recordkeeping and reporting burden associated
with the other NESHAP(s) is included in the ICRs for the other
NESHAP(s).

	Performance testing, plan development, and reporting are only required
for "new" sources subject to Subpart VVV.  Therefore, these requirements
shown in the table above are "not applicable."



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