SUPPORTING STATEMENT

	ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63,
Subpart DD) (Renewal)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Off-Site Waste and Recovery Operations (40 CFR Part 63,
Subpart DD) (Renewal),

EPA ICR Number 1717.07, OMB Control Number 2060-0313

1(b)  Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP)
for Off-Site Waste and Recovery Operations were proposed on October 13,
1994, and promulgated on July 1, 1996.  These standards apply to
hazardous air pollutant (HAP) emissions from selected facilities
involved in waste management and recovery operations that are not
subject to Federal air standards under other subparts in part 63, and
commencing construction, modification or reconstruction after the date
of proposal if the facility is a major source of HAP emissions, as
defined in general provisions to 40 CFR part 63.  In addition, subpart
DD cross-references control requirements to be applied to specific types
of affected sources: tanks-level 1; containers; surface impoundments;
individual drain systems; oil-water separators; organic water
separators; and loading, transfer, and storage systems.  This
information is being collected to assure compliance with 40 CFR part 63,
subpart DD.  Organic HAP emissions are the pollutants regulated under
this subpart.

Owners or operators of the affected facilities described must make
one-time-only notifications.  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. 
Semiannual reports of excess emissions, or reports certifying that no
exceedances have occurred, are required.  These notifications, reports,
and records are essential in determining compliance; and, in general,
are required of all sources subject to the NESHAP.

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
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.

There is an annual average of 236 respondents that will be subject to
the regulations.  Due to the nature of the industry, it is estimated
that no additional sources will become subject to the standard over the
next three years.  This information is based on discussions with EPA
personnel knowledgeable about the off-site waste and recovery
operations.  The average annual cost to industry over the next three
years of this Information Collection Request (ICR) is estimated to be
$14,681,368.

The Office of Management and Budget (OMB) approved the currently active
ICR without any “Terms of Clearance.”

The burden to the “Affected Public” may be found below in Table 1:
Annual Respondent Burden and Cost - NESHAP for Off-Site Waste and
Recovery Operations (40 CFR part 63, subpart DD) (Renewal).  The burden
to the “Federal government” is attributed entirely to work performed
by Federal employees or government contractors.  This burden may be
found below in Table 2: Average Annual EPA Burden - NESHAP for Off-Site
and Waste Recovery Operations (40 CFR part 63, subpart DD) (Renewal).

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

In the Administrator's judgment, HAP emissions from off-site waste and
recovery operations cause or contribute to air pollution that may
reasonably be anticipated to endanger public health or welfare. 
Therefore, the NESHAP was promulgated for this source category at 40 CFR
part 63, subpart DD.

2(b)  Practical Utility/Users of the Data

The control of emissions of pollutants from off-site waste and recovery
operations requires not only the installation of properly designed
equipment, but also the operation and maintenance of that equipment. 
Emissions of organic HAP from off-site waste and recovery operations are
the result of operation of the affected facilities.  The subject
standards are achieved by the reduction of organic HAP emissions using
control technology and/or leak detection and repair procedures.

The notifications required in the applicable regulations 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, that leaks are being detected and
repaired, and that the regulations are being met.  The semiannual
reports are used for problem identification, as a check on source
operation and maintenance, and for compliance determinations.

The information generated by the monitoring, recordkeeping and reporting
requirement described in this ICR is used by the Agency to ensure that
facilities affected by the NESHAP continue to operate the control
equipment in compliance with the regulation.  Adequate monitoring,
recordkeeping, and reporting are necessary to ensure compliance with the
applicable regulations, 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.  Non-duplication, Consultations, and Other Collection Criteria

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

3(a)  Non-duplication

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 their 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 (74 FR 38004) on July 30, 2009. 
No comments were received on the burden published in the Federal
Register.

3(c)  Consultations

Over the next three years, an average of 236 facilities per year will be
subject to the standard, with no additional sources per year becoming
subject to the standard.  We have also determined that approximately 33
percent of the respondents are reporting electronically.  In estimating
the affected number of sources and the growth rate of off-site waste and
recovery operations facilities subject to this standard during a
previous renewal, we contacted the Solid Waste Association of North
America (SWANA) Ms. Shannon Crawford, at (800) 467-9262, and Chartwell
Information, Mr. Grant Ferrier, (619) 295-7685.  For this renewal, we
contacted Environmental Business International (formerly Chartwell
Information), Mr. Grant Ferrier, (619) 295-7685, who did not refute
current estimates.  We referenced the most recent ICR, and used other
resources to obtain the most recent data available.  We reviewed
information available from the Online Tracking Information System (OTIS)
which is the primary source of information regarding the number of
existing sources.  OTIS data was used in conjunction with industry
consultation to verify the number of sources and the industry growth
rate. 

3(d)  Effects of Less Frequent Collection

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

3(e)  General Guidelines

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

 	

These standards require affected facilities 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
with 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

The required information has been determined not to be confidential. 
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 (CBI) (see 40 CFR 2; 41 FR
36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43
FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g)  Sensitive Questions

None of the reporting or recordkeeping requirements contain sensitive
questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are
off-site waste and recovery operations that store, treat, recycle,
reprocess, or dispose of wastes containing organic chemical compounds. 
The United States Standard Industrial Classification (SIC) codes, which
correspond to the North American Industry Classification System (NAICS)
codes, could be found in the following table:

Off-site Waste and Recovery Operations (40 CFR part 63, subpart DD)	SIC
Codes	NAICS Codes

Petrochemical Manufacturing	2869	325110

All Other Basic Inorganic Chemical Manufacturing	2869	325188

Cyclic Crude and Intermediate Manufacturing	2689	325192

Ethyl Alcohol Manufacturing	2689	325193

All Other Basic Organic Chemical Manufacturing	2689	325199

Industrial Gas Manufacturing	2689	325120

All Other Miscellaneous Chemical Product and Preparation Manufacturing
2689	325998

Plastic Materials and Resin Manufacturing	2821	325211

Explosives Manufacturing	2892	325920

Carbon Black Manufacturing	2816	325182

Inorganic Dye and Pigment Manufacturing	2816	325131

Semiconductor and Related Device Manufacturing	3674	334413

Petroleum Refineries	2911	324110

Aircraft Manufacturing	3721	336411

Aircraft (research and development not producing prototypes)	3721	541710

Other General Government Support	9199	921190

All Other Petroleum and Coal Products Manufacturing	3312	324199

Iron and Steel Mills	3312	331111

Rolled Steel Shape Manufacturing	3312	331221



4(b)  Information Requested

None of these reporting or recordkeeping requirements violate any of the
regulations established by OMB at 5 CFR part 1320, section 1320.5.

(i)  Data Items

All data in this ICR that is recorded and/or reported is required by
National Emission Standards for Hazardous Air Pollutants for Off-Site
Waste and Recovery Operations (40 CFR part 63, subpart DD).

A source must make the following reports:

Reports for 40 CFR part 63, subpart DD

Notification and application of construction/reconstruction	63.5(d)

Notification of initial startup	63.9(b)

Notification of initial performance test	63.7(b) and 63.9(e)

Rescheduled initial performance test	63.7(b)(2)

Demonstration of continuous monitoring system	63.9(g)

Compliance status	63.9(h)

Physical and operational change	63.10

Notification of performance tests	63.7(b), and 63.697(b)(1)

Performance test results	63.8(e)(5), and 63.697(b)(2)

Startup, shutdown, malfunction reports	63.697(b)(3)

Notification of tank floating roof inspection	63.686(b)(3)

Notification of oil/water separator floating roof inspection
63.687(d)(6)

Notification to tank refill	63.697(d)(1)

Notification of seal gap measurements	63.697(d)(2)



Reports

Initial performance test results	63.10(d)(2)

Opacity or visible emissions	63.10(d)(3)

Periodic startup, shutdown, malfunction reports	63.10(d)(5)(i)

Source status report	63.10(e)(3)

Excess emission reports	63.695(e)

Semiannual summary report	63.697(b)(4)



A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart DD

Startup, shutdown, malfunctions, periods where the continuous monitoring
system is inoperative.	63.10(b)(2)

All reports and notifications.	63.10(b)

Record of applicability.	63.10(b)(3)

Records of sources with continuous monitoring systems.	63.10(c)

Records of startup, shutdown, and malfunctions, and pollution control
system maintenance.	63.696(b)(1)

Records of applicability determinations.	63.696(b)(3)

Documentation of extension of tank emptying schedule.	63.696(c)

Records of results of seal gap measurements and description of repairs.
63.686(d)(3)

Record of sampling plan for determining volatile organic hazardous air
pollutant (VOHAP) concentration at point of treatment	63.694(c)

Record of sampling plan for determining maximum HAP vapor pressure in
tanks.	63.694(j)(2)(1)

Record of maximum HAP vapor pressure determinations for covered tanks
63.686(c)(5)

Records should be retained for 5 years.	63.10(b)(1)



Electronic Reporting

Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., leaks and spills of mercury. 
Although personnel at the source still need to evaluate the data, this
type of monitoring equipment has significantly reduced the burden
associated with monitoring and recordkeeping.  In addition, some
regulatory agencies are setting up electronic reporting systems to allow
sources to report electronically which is reducing the reporting burden.
 However, electronic reporting systems are still not widely used by the
regulatory agencies.  It is estimated that approximately 33 percent of
the respondents use electronic reporting.

(ii)  Respondent Activities

Respondent Activities

Determine the VOHAP concentration for off-site material at the
point-of-delivery and for the treated off-site material streams at the
point-of-treatment.

Determine the required HAP mass removal rate, actual HAP mass removal,
HAP reduction efficiency and HAP bio-degradation efficiency.

Determine the maximum organic HAP vapor pressure of the off-site
material in tanks and the process vent stream flow rate and total HAP
concentration.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

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

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

Transmit, or otherwise disclose the information.



 	Currently, sources are using monitoring equipment that provides
parameter data in an automated way, e.g., HAP vapor pressure.  Although
personnel at the source still need to evaluate the data, this type of
monitoring equipment has significantly reduced the burden associated
with monitoring and recordkeeping.

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

5(a)  Agency Activities

EPA conducts the following activities in connection with the
acquisition, analysis, storage, and distribution of the required
information.

Agency Activities

Observe initial performance tests and repeat performance tests if
necessary.

Review notifications and reports, including performance test reports,
excess emissions reports, startup, shutdown, malfunction plan, and
quality control plan for CMS 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 operational.  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 under which
compliance was achieved.  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 AFS which is
operated and maintained by the EPA Office of Compliance.  AFS is the EPA
database for the collection, maintenance, and retrieval of compliance
and annual emission inventory data for more than 100,000 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 or
operator for five years.

5(c)  Small Entity Flexibility

A majority of the affected facilities are primarily small entities
(e.g., small businesses).  According to the Off-Site Waste and Recovery
Operations NESHAP: Economic Impact Analysis,. (EPA-452/R-96-011, June
1996), EPA specifically identified 388 firms that own 621 potentially
affected facilities.  These 388 firms include 110 small businesses that
own 112 facilities Therefore, this ICR assumes approximately 18 percent
of the total facilities are small businesses, or 42 of 236 respondents.

The impact on small entities was taken into consideration during the
development of the regulation.  Due to technical considerations
involving the process operations and the type of control equipment
employed, the recordkeeping and reporting requirements are the same for
both small and large entities.  The Agency considers these requirements
the minimum needed to ensure compliance and, therefore, cannot reduce
them further for small entities.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown below in Table 1: Annual Respondent Burden and
Cost - NESHAP for Off-Site Waste and Recovery Operations (40 CFR part
63, subpart DD) (Renewal).

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.  Wherever appropriate,
specific tasks and major assumptions have been identified.  Responses to
this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid OMB Control Number.

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
155,212 (Total Labor Hours from Table 1).  These hours are based on
Agency studies and background documents from the development of the
regulation, Agency knowledge and experience with the NESHAP program, the
previously approved ICR, and any comments received.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

This ICR uses the following labor rates: 

Managerial	$114.49 ($54.52 + 110%)  

Technical	$98.20 ($46.76 + 110%)

Clerical	$48.53 ($23.11 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, September 2009, “Table 2. Civilian Workers, by
Occupational and Industry group.”  The rates are from column 1,
“Total compensation.”  The rates have been increased by 110 percent
to account for the benefit packages available to those employed by
private industry.

	

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

	The capital/startup costs are one-time costs when a facility becomes
subject to the standard.  Since this is based on no new sources over the
next three years, capital/startup costs associated with this ICR during
this period will be zero.  In addition, there is no significant
operation and maintenance costs associated with this ICR since sources
are not required to install continuous monitoring systems.  The only
operational cost that sources will incur is associated with photocopying
and postage which would be minimal based on a rate of $7.57 per
response.  There are approximately 708 responses per year (708 responses
x $7.57 = $5,359.56), for a total annual operation and maintenance (O&M)
cost of $5,360.

6(c)  Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of
the reported information.  The EPA 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 $106,353.  

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

		Managerial	$62.27 (GS-13, Step 5, $38.92 + 60%) 

		Technical	$46.21 (GS-12, Step 1, $28.88 + 60%)

		Clerical	$25.01 (GS-6, Step 3, $15.63 + 60%)

These rates are from the Office of Personnel Management (OPM), 2010
General Schedule, which excludes locality rates of pay.  The rates have
been increased by 60 percent to account for the benefit packages
available to government employees.  Details upon which this estimate is
based appear below in Table 2: Average Annual EPA Burden – NESHAP for
Off-Site Waste and Recovery Operations (40 CFR part 63, subpart DD)
(Renewal).

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

	

	Based on our research for this ICR, there are approximately 236
existing sources currently subject to the standard.  It is estimated
that no additional sources per year will become subject to the
regulation in the next three years.

	Number of respondents is calculated using the following table which
addresses the three years covered by this ICR.

Number of Respondents

Year	(A)

Number of New Respondents	(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	236	0	0	236

2	0	236	0	0	236

3	0	236	0	0	236

Average	0	236	0	0	236



To avoid double-counting respondents, column D is subtracted.  As shown
above, the average Number of Respondents over the three-year period of
this ICR is 236.

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

Respondent Universe and Number of Responses Per Year

Regulation Citation	(A)

Average Number of New Respondents per Year	(B)

Number of Reports for New Sources	(C)

Number of Existing Respondents	(D)

Number of Reports for Existing Sources	(F)

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

Total Annual Responses =

(AxB)+(CxD)+F

40 CFR part 63, subpart DD	0	0	236	3	0	708



The number of total respondents is 236.  This represents the number of
existing sources plus the number of new sources averaged over the
three-year period (i.e., the total of the number of new respondents over
the three-year period divided by three years).

The number of Total Annual Responses is 708.  This is the number in
column E of the Respondent Universe and Number of Responses per Year
table above.

The total annual labor costs are $14,681,368.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost - NESHAP for Off-Site Waste and Recovery Operations (40 CFR part
63, subpart DD) (Renewal).

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 (below),
respectively, and summarized below. 

(i)  Respondent Tally

The total annual labor hours are 155,212.  Details regarding these
estimates may be found below in Table 1: Annual Respondent Burden and
Cost – NESHAP for Off-Site Waste and Recovery Operations (40 CFR part
63, subpart DD) (Renewal).  Furthermore, the annual public reporting and
recordkeeping burden for this collection of information is estimated to
average 219 hours per response.

The total annual capital/startup and O&M costs to the regulated entity
are $5,000 (rounded).  The cost calculations are detailed in Section
6(c)(ii), Estimating Capital/Startup and Operation and Maintenance
Costs.

(ii)  The Agency Tally

The average annual Agency burden and cost over next three years is
estimated to be 2,360 labor hours at a cost of $106,353.  See below
Table 2: Average Annual EPA Burden – NESHAP for Off-Site Waste and
Recovery Operations (40 CFR part 63, subpart DD) (Renewal).

6(f)  Reasons for Change in Burden

There is no change in the calculation methodology for labor hours in
this ICR compared to the previous ICR.  This is due to two
considerations: (1) the regulations have not changed over the past three
years and are not anticipated to change over the next three years; and
(2) the growth rate for the respondents is very low, negative or
non-existent.  There is, however, an apparent increase of 906 hours in
respondent labor hours, due to a math error in the previous ICR. 

	Also, there is an increase in both Respondent and Agency costs
resulting from labor rate increases from 2003 to 2009.  In this ICR, the
labor burden and cost calculations in Tables 1 and 2 of this ICR were
expanded to include managerial and clerical labor rates, and the
previous ICR only provided a technical labor rate for 2003.  This ICR
has been updated to present the most recent available labor rates for
each of the three labor categories.

6(g)  Burden Statement

The annual public reporting and recordkeeping burden for this collection
of information is estimated to average 219 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 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-2009-0534. An electronic version of the public docket is
available at http://www.regulations.gov/ which may be used to obtain a
copy of the draft collection of information, submit or view public
comments, access the index listing of the contents of the 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 in this document.  The documents are
also available for public viewing at the Enforcement and Compliance
Docket and Information Center in the EPA Docket Center (EPA/DC), EPA
West, Room 3334, 1301 Constitution Ave., 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
docket center is (202) 566-1752.  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-2009-0534 and OMB Control Number 2060-0313 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: Annual Respondent Burden and Cost - NESHAP for Off-Site
Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal)

 

Assumptions:									

a)	This ICR uses the following labor rates: Managerial $114.49 ($54.52 +
110%); Technical $98.20 ($46.76 + 110%); and Clerical $48.53 ($23.11 +
110%).  These rates are from the United States Department of Labor,
Bureau of Labor Statistics, September 2009, “Table 2. Civilian
workers, by Occupational and Industry group.”  The rates are from
column 1, "Total compensation."  The rates have been increased by 110
percent to account for the benefit packages available to those employed
by private industry.  This ICR assumes that Managerial hours are 5
percent of Technical hours, and Clerical hours are 10 percent of
Technical hours.

b)	This activity is performed once during the year following
promulgation of the rule.

c)	It is assumed that it will take four hours to read instructions.

d)	It is assumed that it will take eight hours to gather existing
information.

e)	It is assumed that there will be no new sources.

f)	The burden of one annual summary report was included in the burden
estimate for the semiannual report.

g)	It is assumed that at 50 percent of the facilities, the owner or
operator manages, for a fee, off-site materials received from other
generators.

h)	It is assumed that 50 percent of the owners or operators accept the
off-site material at another location and ship it to the facility for
storage, treatment, or disposal.

i)	It is assumed that 20 percent of 236 facilities will perform
monitoring/repair.

Table 2: Average Annual EPA Burden - NESHAP for Off-Site Waste and
Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal)

 

Assumptions:									

a)	This ICR uses the following labor rates: Managerial $62.27 (GS-13,
Step 5, $38.92 + 60%); Technical $46.21 (GS-12, Step 1, $28.88 + 60%);
and Clerical $25.01 (GS-6, Step 3, $15.63 + 60%).  These rates are from
the Office of Personnel Management (OPM), 2010 General Schedule, which
excludes locality rates of pay.  The rates have been increased by 60
percent to account for the benefit packages available to government
employees.  This ICR assumes that Clerical hours are 10 percent of
Technical hours and Managerial hours are 5 percent of Technical hours.

b)	There will be no travel expenses associated with this ICR since we
have assumed that no new sources will become subject to this rule over
the three year period of this ICR.

c)	It is assumed that there will be no new sources (respondents) over
the 3-year period of this Information Collection Request. new or
reconstructed turbines per year.

d)	It is assumed that it will take 16 hours to review each performance
test report.

e)	It is estimated that the number of facilities subject to the rule is
236.

f)	It is assumed that two reports will be submitted by each of the 236
facilities on an annual basis.

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