SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

	

NESHAP for Benzene Waste Operations (40 CFR part 61, subpart FF)
(Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Benzene Waste Operations (40 CFR part 61, subpart FF).

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for the regulations published at 40 CFR part 61, subpart FF were
proposed on September 14, 1989, and promulgated on March 7, 1990.  These
regulations apply to facilities that generate waste containing benzene,
such as chemical manufacturing plants, coke by-product recovery plants,
petroleum refineries, and those owners and operators of hazardous waste
treatment, storage, and disposal facilities (TSDF) which receive wastes
from the above facilities, commencing construction, modification or
reconstruction after the date of the proposal.  This information is
being collected to assure compliance with 40 CFR part 61, subpart FF.

In general, all NESHAP standards require initial notifications,
performance tests, and periodic reports.  Owners, or operators 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.  These notifications, reports, and records are essential in
determining compliance, and are required of all sources subject to
NESHAP.

Any owner, or operator subject to the provisions of this part will
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.  Facilities managing waste containing less than 1 megagram
(Mg) of benzene must certify to that effect and maintain documentation
to support their finding.  Facilities managing more than 1 Mg and less
than 10 Mg of benzene-containing waste must prepare an initial
certification, test annually to verify that their waste stream still
falls within this range, and maintain documentation to support these
findings.  Finally, facilities managing more than 10 Mg of waste must
submit quarterly and annual reports documenting the results of
continuous monitoring.  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 appropriate United
States Environmental Protection Agency (EPA) Regional Office.

Approximately 234 sources are currently subject to the regulation and
117 of those are estimated to have more than 10 Mg/yr of benzene in the
waste.  It is estimated that no additional sources will become subject
to the regulation in the next three years. To determine the size of the
regulated universe subject to NESHAP subpart FF, EPA contacted the
National Petroleum Refiners Association (NPRA) for any changes that may
have occurred since the last ICR was issued, and if any new sources
subject to NESHAP subpart FF were anticipated to come on-line over the
next three years.  NPRA confirmed that the regulated universe of
facilities subject to NESHAP subpart FF was expected to remain unchanged
over the next three years and that no new sources subject to these
standards are anticipated to come on-line in the next three years.  EPA
also conducted a search of the Integrated Data for Enforcement Analysis
system (IDEA) and the AIRS (Aerometric Information Retrieval System) Air
Facility Subsystem (AFS) to determine the number of sources subject to
this regulation and found that EPA data matched the information received
from the NPRA.  The respondent cost of this ICR will be $949,677.  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 Clean Air Act (Act) provides authority to the Agency to establish
standards to control air pollution and to ensure compliance with
promulgated regulations through adequate recordkeeping and reporting by
the affected industries (i.e., respondents).  The regulations include
the New Source Performance Standards (NSPS) under section 111 of the
Act, the National Emission Standards for Hazardous Air Pollutants (
NESHAP), which includes the original NESHAP standards and the more
recent Maximum Achievable Control Technology (MACT), or NESHAP-MACT
standards under section 112 of the Act, and emission guidelines for the
designated types of incinerators under section 129 of the Act.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard are used by
regulatory agencies, the public and the regulated community for a
variety of reasons, including the determination of the respondent’s
compliance status, analytical studies to demonstrate compliance trends,
and evaluations regarding the efficacy of the promulgated regulations.

The required recordkeeping and reporting also are used to: 1) certify
compliance with the regulations; 2) determine the respondent’s
compliance with the designated emission limitation(s); 3) notify
regulatory agencies when a standard is violated; 4) evaluate continuous
compliance through the use of emission, or operational parameter
monitors; and 5) ensure that plant personnel are following the required
procedures and are periodically trained, as indicated.

3.  Nonduplication, Consultations, and Other Collection Criteria

3(a)  Nonduplication

The standards do not require the duplication in the collection and
reporting of information.  If the subject standards have not been
delegated, the information is sent directly to the appropriate
Environmental Protection Agency (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.

 

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

It is our policy to carefully review any comments received since the
last ICR renewal including those submitted in response to the first
federal register notice and respond appropriately. In this case, no
comments were received.  The Agency’s internal industry experts have
been consulted.  The Agency’s internal data sources and any
projections of industry growth over the next three years also have been
considered.

The primary source of information as reported by industry, in compliance
with the recordkeeping and reporting provisions in the standard, is the
Air Facility Subsystem (AFS), which is operated and maintained by EPA's
Office of Compliance.  AFS is EPA’s database for the collection,
maintenance, and retrieval of all compliance data.  Approximately 234
respondents currently are subject to the regulation, and our
consultations with Agency industry experts regarding the growth rate for
the industry indicated that no additional respondents per year will
become subject to the regulation over the next three years.

It should be noted that the respondents, the industry trade
association(s) and other interested parties were provided an opportunity
to comment on the burden associated with the standard as it was being
developed and the standard has been previously reviewed to determine the
minimum information needed for compliance purposes.

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 proper operation
and maintenance of control equipment and the possibility of detecting
violations would be less likely.

3(e)  General Guidelines

Neither the reporting, nor the recordkeeping requirements violate the
regulations established by Office of Management and Budget (OMB) at 5
CFR Part 1320, Section 1320.5.  However, most NESHAP standards and a few
NSPS standards require records to be kept more than three years.  In
general, these standards require the respondents to maintain all
records, including reports and notifications, for five years.  The
five-year record retention requirement is consistent with the permit
program at 40 CFR part 70, and the five-year statute of limitations on
which the permit program is based.

The retention of records for five years allows EPA to establish the
compliance history of the respondent for purposes of determining the
appropriate level of enforcement action.  Historically, EPA notes that
the most flagrant violations have extended beyond a five-year period. 
If records are retained for less than five years, EPA would be deterred
from pursuing the most flagrant violations due to the destruction of
records documenting noncompliance.

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

The recordkeeping and reporting requirements do not contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
facilities which generate waste that contains benzene.  The SIC codes
for the respondents affected by the standards are the SIC (United States
Standard Industrial Classification) codes listed in the table below,
which correspond to the NAICS (The North American Industry
Classification System) codes also listed below.

Category	SIC code	NAICS code	Examples of regulated entities

Chemical manufacturing, Plastic product manufacturing	2800	325, 3261
Chemical products manufacturing 

Petroleum refineries	2911	32411	Petroleum refineries

Integrated iron and steel mills	3312	331111	Steel Works, Blast Furnaces
(Including Coke Ovens), and Rolling Mills (except coke ovens not
integrated with steel mills

Sanitary and waste management services	4959	56291, 562998	Remediation
services and all other miscellaneous waste management services 

Administration of Air and Water Resource and Solid Waste Management
Programs	9511	92411	Air, water, solid waste management



This table is not meant to be exhaustive, but rather provides a guide
for readers regarding the entities likely to be regulated by this
standard.  To determine whether the standard applies to a particular
entity, review the applicability provisions in the standard.

4(b)  Information Requested

(i)  Data Items

All data in this ICR that are recorded and/or reported are required by
40 CFR part 61, subpart FF- benzene waste operations.

A source must make the following reports:

Reports for 40 CFR part 61, subpart FF

Construction or modification application 	61.07

Anticipated startup 	61.09(a)(1)

Actual startup	61.09(a)(2)

Source reporting and request for waiver of compliance	61.10

Emission test and waiver of emission tests for flares and some waste  
incinerators	61.13

Initial performance test results	61.13(f)

Initial performance test	61.13(c)

Demonstration of continuous monitoring system	61.354(c)

Physical or operational change	61.15

Report that summarizes the regulatory status of each waste stream that
contain benzene 	61.357 (a)

Initial certification of necessary equipment and inspection tests	61.357
(d)(1)

Annual certification of benzene waste steams, benzene concentration, and
benzene quantity determination	61.357 (b), (c), (d)(2)

Notification of election to comply with alternative requirements and
certification of benzene waste steams, benzene concentration, and
benzene quantity determination	61.357(d)(4)-(5)

Quarterly reports certifying required inspections	61.357(d)(6)

Quarterly reports when monitored parameters are exceeded	61.357 (d)(7)

Initial and quarterly reports for inspections during which detectable
emissions or a problem is identified	61.357(d)(8)

Notification of election to comply with standard	61.357(e)

Initial and quarterly reports identifying all seal gap measurements that
are outside limits 	61.357(g)



A source must maintain the following records:

Monitoring and Recordkeeping for 40 CFR part 61, subpart FF

Monitoring requirements	61.14 

Monitoring of operation of treatment process or wastewater treatment 
61.354(a),(b)

Monitoring of alternative operational or process parameters	61.354(e)

Monitoring of affected facilities	61.343-349

Startups, shutdowns, malfunctions, periods where the continuous
monitoring system is inoperative	61.356	

Emission test results and other data needed to determine emissions
61.13(g)

All reports and notifications	63.10(b)

Record of applicability	63.10(b)(3)

Records for sources with continuous monitoring systems	63.10(3)

Records of off-site shipment of waste	61.356(c)

Record of control equipment engineering design	61.356(d) 

Records of engineering calculations, operating conditions, and
performance tests	61.356(e)

Records of detectable emissions from closed vent systems and control
devices	61.356(f)

Records of location, date, and corrective actions for problems found
during visual inspections	61.356(g)(l)

Records of location, date, and corrective actions for problems found
during visual inspections	61.356(g)(l)

Records for each test of no detectable emissions	61.356(h)

Operational records for each control device, treatment process, and
wastewater treatment system	61.356(i), (j)

Records are required to be retained for two years and they must be
retained at the facility	61.356(a)

Measurements and determinations of annual waste quantity, water content,
and benzene concentration	61.356(b)



Electronic Reporting

Some respondents use monitoring equipment that automatically records
parameter data.  Although personnel at the affected facility must
evaluate the data, internal automation has significantly reduced the
burden associated with monitoring and recordkeeping at the plant site.

Regulatory agencies, in cooperation with the respondents, also continue
to create reporting systems to transmit data electronically.  However,
electronic reporting systems still are not widely used.  At this time,
it is estimated that approximately 10 percent of the respondents use
electronic reporting.

(ii)  Respondent Activities	

Respondent Activities

Read instructions.

Perform initial performance test, Reference Method 21 tests, and repeat
performance tests as necessary.

Write the notifications and reports listed above.

Enter information required to be recorded listed 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.



5.  The Information Collected: Agency Activities, Collection
Methodology, and Information Management

5(a)  Agency Activities 

EPA conducts one or more of 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 AIRS (Aerometric Information
Retrieval System) Air Facility Subsystem (AFS) database.



5(b)  Collection Methodology and Management

The required data and reports can be evaluated on-site by conducting a
partial compliance evaluation, full compliance evaluation, or
inspection, or thru an off-site review of compliance monitoring records
and reports.  Evaluation reports and inspection results are maintained
by the Agency or delegated authority.

The results of these evaluations are entered into the Air Facility
Subsystem (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 delegated
authorities can retrieve and analyze the data.

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, attached.

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. 
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

The average annual burden to industry over the next three years from
these recordkeeping and reporting requirements is estimated to be 16,626
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 a Technical Labor Rate of $57.12 per hour.  This rate is
from the United States Department of Labor, Bureau of Labor Statistics,
March 2001, “Table 10. Private industry, by occupational and industry
group.”  The rates are from column 1, “Total compensation.”  The
wage rate of $27.20 has been increased by 110% to account for the
benefit packages available to those employed by private industry for a
labor rate of $57.12 per hour.

(ii)  Estimating Capital/Startup and Operation and Maintenance Costs

The only type of industry costs associated with the information
collection activity in the regulations is labor costs.  There are no
capital/startup, or operation and maintenance costs.  The
capital/startup costs are one-time costs when a facility becomes subject
to the regulation.  The annual operation and maintenance costs are the
ongoing costs to maintain the monitor and other costs, such as
photocopying and postage.

6(c)  Estimating Agency Burden and Costs

The only costs to the Agency are those 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 and the publication and distribution of collected
information.

The average annual Agency cost during the three years of the ICR is
estimated to be $50,939 (see Table 1 attached).  This cost is based on
the average hourly labor rate at a GS-12, Step 1, multiplied by a 1.6
benefits factor to account for government overhead expenses for a total
of $38.30.  These rates are from the Office of Planning and Management
(OPM) “2002 General Schedule”, which excludes locality rates of pay.
 Details upon which this estimate is based appear in Table 2, attached.

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

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	234	0	0	234

2	0	234	0	0	234

3	0	234	0	0	234

Average	0	234	0	0	234

1 New respondents include sources with constructed, reconstructed and
modified affected facilities.  [In this standard existing respondents
submit initial notifications.]

Column D is subtracted to avoid double-counting the number of
respondents.  The average Number of Respondents over the three-year
period of this ICR is shown in column D.  This number appears on the OMB
83-I form in block 13(a), Number of respondents.

The number of total respondents is 234.  This represents the number of
existing sources plus the number of new sources averaged over the
three-year period (i.e., number of new respondents per year multiplied
by three years divided by two).  It is shown in block 13(a), Number of
respondents, on the OMB 83-I form.

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

Total Annual Responses

(A)

Information Collection Activity	(B)

Number of Respondents	(C)

Number of Responses	(D)

Number of Existing Respondents That Keep Records But   Do Not Submit
Reports	(E)

Total Annual Responses 

E=(BxC)+D

Periodic reports	234	1	0	234



	Total	234



The number of Total Annual Responses is 234.  This is the number in
column E of the Respondent Universe and Number of Responses Per Year
table.  This number is shown in block 13(b), Total Annual Responses, on
the OMB 83-I form.

The total annual labor cost may be found in Table 1, Annual Respondent
Burden and Cost:  NESHAP for Benzene Waste Operations (40 CFR part 61,
subpart FF).  The total annual labor hours are 16,626.  This number is
not shown on the OMB 83-I form in block 13(c), Total hours requested. 
Only the burden hours are reflected in block 13(c).

 

There are no total annual capital and O&M costs to the regulated entity.
 This number is shown on the OMB 83-I form in block 14(c), “Total
annualized cost requested.”  These costs are detailed in section
6(b)(iii), Capital/Startup vs. Operating and Maintenance (O&M) Costs.

The average annual Agency burden and cost over next three years is shown
in Table 2, Annual Burden and Cost for The Federal Government: NESHAP
for Benzene Waste Operations (40 CFR part 61, subpart FF).

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.

(i) Respondent Tally

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). 
The annual labor cost is not shown on the OMB 83-I form.  Details
regarding these estimates may be found in Table 1.  Furthermore, the
annual public reporting and recordkeeping burden for this collection of
information is estimated to average 71 hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are 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) Cost.

(ii) The Agency Tally

The average annual Agency burden hours and cost over next three years is
shown in Table 2.

6(f)  Reasons for Change in Burden

There are no changes in the burden calculation for the renewal of this
ICR since we have assumed that there has been no change in the industry
burden since the last ICR was approved.

 6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 71 hours per response.  Burden
means the total time, effort, or financial resources expended by persons
to generate, maintain, retain, disclose, or provide information to, or
for a Federal agency.  This includes the time needed to review
instructions; to 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; to adjust the existing ways to comply with any
previously applicable instructions and requirements; to train personnel
to be able to respond to a collection of information; to search data
sources; to complete and review the collection of information; and to
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-HQ-OECA-2005-0020, which is available for public viewing at the
Enforcement and Compliance Docket and Information Center in the EPA
Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Avenue,
N.W., Washington, D.C.  The EPA Docket Center Public Reading Room is
open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal
holidays.  The telephone number for the Reading Room is (202) 566-1744,
and the telephone number for the Enforcement and Compliance Docket and
Information Center is (202) 566-1752.  An electronic version of the
public docket is available through 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-2005-0020 and OMB Control Number 2060-0183 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 REQUIREMENT  NESHAP Subpart FF 

	A	B	C	D	E	F

	EPA hours per occurrence	Occurrences per plant/yr	EPA                
hours/plant/yr     (A x B)	Plants/year	EPA           hours/year    (C x
D)	Total annual cost (E x $38.30)

Initial Performance Tests	............................not
applicable.........................  

Report Review	............................not
applicable.........................  

     New Plant







          Notification of construction	None expected

          Notification of anticipated startup
............................not applicable.........................  

          Notification of actual startup	............................not
applicable.........................  

          Initial Report (b)	............................not
applicable.........................  

          Notification of performance test
............................not applicable.........................  

     Existing Plant







          Quarterly reports	2	4	8	137	1,096	$41,977

          Annual Recertification	1	1	1	234	234	$8,962









TOTAL ANNUAL HOURS



	1,330	$50,939









Travel Expenses (d) (1 person x 0 plants/yr x 1 d/plant x $50 per diem)
+ ($250 round trip/plant x 0 plants/yr) = $0/yr 





	 	 

TOTAL ANNUAL COST	$50,939









 







a) A X B = C

b) C X D = E







d) Assume that as there will be no new sources, no new affected
facilities will be visited.



	e) Assume an hourly wage of a GS12, Step 1 employee rate times a 1.6
benefits multiplication factor to account for government overhead
expenses for a total of $38.30. This amount was multiplied by the hours
in each line of Column E to estimate the total annual cost per year.











TABLE 2.  ANNUAL BURDEN OF REPORTING AND RECORD KEEPING REQUIREMENTS AS
A RESULT OF THE STANDARDS NESHAP SUBPART FF

	A	B	C	D	E	F

Reporting and recordkeeping requirements	Person hours per occurrence
Annual occurrences per    respondent	Annual person hours/respondent    
(A x B)	Total number of respondents	Total annual person hours    (C x
D)	Total annual cost (E x $57.12)

1. APPLICATIONS	............................not
applicable.........................  

2. SURVEYS AND STUDIES	............................not
applicable.........................  

3. REPORTING REQUIREMENTS





    a. Read instructions	Included in 3C

     b. Required activites





	    c. Create information





	       i. Determine quantity of benzene in waste	done initially

       ii. Initial waste determination	done initially

      iii. Treatment performance evaluation	done initially

      iv. Annual waste determination (c)	2	1	2	234 (d)	468	$26,732

      v. Monthly treated waste analysis	1 (e)	12	12	13 (f)	156	$8,911

      vi.Treatment/control device monitoring	included in 4C

     vii. Initial visual inspection	done initially

    viii. Quarterly visual inspection	2	4	8	137 (g)	1,096	$62,604

     ix. Annual method 21 monitoring	6	1	6	137 (g) 	822	$46,953









D. Gather Existing Information













	E. Write report







       New Sources







          Notification of const/reconstruction 
........................not applicable......................... 

          Notification of ant/ act.startup	........................not
applicable......................... 

          Notification/Report of perf.test	........................not
applicable......................... 

       Existing sources





	          Initial report	........................not
applicable......................... 





          Quarterly emission report	4	4	16	137 (g) 	2,192	$125,207

          Annual report	1	1	1	234 (d)	234	$13,366

          Notification of offsite facility	2	12	24	13 (h)	312	$17,821









4. RECORD KEEPING REQUIREMENTS





    a. Read instructions	Included in 3A

     b. Plan Activites	Included in 4C

    c. Implement Activities





	        i. Filling and maintain records	78	1	78	137 (i)	10,686	$610,384

       ii. Concentration data	0.5	12	6	97 (k)	582	$33,244

      iii. Concentration data	0.5	12	6	13	78	$4,455

      iv. Waste quantity data	Done initially

    d. Develop Record System	Included in 4C

    e. Time to Enter Information	Included in 4C

    f. Train Personnel	........................not
applicable......................... 

    g. Audits	........................not
applicable......................... 









Total



	16,626	$949,677





	 	 

(a) estimate that there are 234 affected sources. No new sources are
expected over the next three years. Estimate that 117 sources have a TAB
between 1 Mg/yr and 10 Mg/yr and file an annual report of TAB. Estimate
that 117 sources have a TAB greater than 10 Mg/yr and have complied with
the control requirements and file quarterly reports. 

A total of 56 facilities has over 50 Mg/yr and are expected to have
installed controls without applying for exemptions.









(b) Estimate an hourly wage of $57.12 ($27.20 x 110% to account for the
benefit packages available to those employed by private industry). This
amount was multiplied by the hours in each line of Column E to estimate
the total annual cost.









(c) Based upon of knowledge of waste and initial tests for
determination.









	(d) All facilities above 1 Mg/yr must evaluate waste streams annually
TAB report (97+137 = 234).









(e) Based upon 0.5 hours for collection activities for all samples and
0.5 hours per sample for analysis for a total of 1 hour per sample. 









(f) Assumes that 90 percent of the 137 sources (124) monitor process
parameters; and 10 percent (13) must conduct monthly sampling.









(g) A total of 137 facilities are expected to be greater than 10 Mg per
year and must comply with the control requirements.









(h) Assumes that 10 percent of facilities (13) choose to ship their
waste offsite monthly for treatment.









(i) Recordkeeping requirements for the 137 sources which must install
controls.









	(k) Recordkeeping requirements for the 97 sources which repeat the
annual benzene quantity determination.









	234	sources





	0.975







0.975







136.5







234







55.575







151.125







117





	

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