SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG)

1.  Identification of the Information Collection

1(a)  Title of the Information Collection

NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG)

1(b)  Short Characterization/Abstract

The final rule for the National Emission Standards for Hazardous Air
Pollutants (NESHAP) Site Remediation was published in 40 CFR part 63,
subpart GGGGG, and promulgated on October 8, 2003.  These standards
apply to site remediation activities that use certain types of equipment
to clean up materials containing organics that potentially could be
released to the atmosphere as a hazardous air pollutant (HAP).  These
site remediation activities can potentially be conducted at any facility
where materials containing organic HAP currently are or have been
stored, processed, treated, or otherwise managed at the facility.  The
types of businesses most likely to be subject to the rule include, but
are not limited to, organic liquid storage terminals, petroleum
refineries, chemical manufacturing facilities, and manufacturing
facilities using organic materials.

A site remediation involves a clean up of hazardous substances in order
to protect human health and the environment.  These hazardous substances
could potentially contaminate soil, groundwater, and the air.  Owners
and operators of the facilities subject to part 63, subpart GGGGG are
required to perform this information collection.

Affected owners and operators subject to the rule are required to
install and operate air emission controls and meet certain work practice
standards.  To demonstrate initial and continuous compliance with the
rule requirements, affected owners and operators need to collect
information to meet specific monitoring, inspection, recordkeeping, and
reporting requirements.

The information collection requirements for the site remediation NESHAP
are summarized in Section 4(b).

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

	Based on our previous consultations with the industry, we estimate that
there are approximately 286 facilities subject to this regulation and
each facility has only one respondent (owner/operator).  The Agency
estimates that there has not been any growth in the industry since the
previous Information Collection Request (ICR).  The respondents submit
the reports to the permitting authority on a semiannual basis as
required by the regulation (the compliance report) and when a startup,
shutdown, and malfunction (SSM) report is required in case the facility
does not follow its approved SSM Plan (assumed twice a year) for a total
of four semiannual reports per year.

	During a previous renewal, information provided by the Office of Air
Quality Planning and Standards (OAQPS) was used to project industry
growth.  Based on an assessment of information from the EPA Resource
Conservation and Recovery Act (RCRA) reporting system, OAQPS did not
project any growth for the affected industry.

The active (previous) ICR had the following Terms of Clearance (TOC): 
“Under the terms of the Government Paperwork Elimination Act, EPA
should review this collection before resubmitting it for approval and
ensure that, to the extent practicable, the collection has been revised
to include electronic means of reporting.”  

	EPA has addressed each item of concern in the TOC by reviewing and
revising the collection, to the extent practicable, to include
electronic means of reporting.  See Section 4(b)(i).

During the current renewal of this ICR, EPA consulted with industry on
the accuracy of the burden estimates.  Details of the consultation may
be found in Section 3(c).  

The burden to the “Affected Public” may be found in Table 1: Annual
Respondent Burden and Cost, NESHAP for Site Remediation (40 CFR Part 63,
Subpart GGGGG).  The “Affected Public” burden includes respondent
burden for the private sector and state, local and tribal governments. 
The burden to the “Federal Government” is attributed entirely to
work performed by federal employees or government contractors; this
burden includes report review and respondent burden for the federal
government and may be found in Table 2: Average Annual EPA Burden,
NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG).  

The ICR associated with this original rule specifies that the primary
affected public category is the private sector; the ICR also anticipates
respondents from within the Federal government and state, local, or
tribal governments.  The most recent previous ICR renewal (2062.03)
estimates 10 percent of respondents are from the Federal government, and
5 percent of respondents are from state, local, or tribal governments. 
This ICR uses the same methodology to estimate 243 respondents from the
private sector, 14 from the state, local or tribal governments, and 29
from the Federal government.  

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 (CAA), 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, site remediation activities involve the
clean up of materials that could potentially emit volatile organic
hazardous air pollutants (VOHAP).  VOHAP emissions cause or contribute
to air pollution that may reasonably be anticipated to endanger public
health or welfare.  Therefore, the NESHAP standards were promulgated for
this source category at 40 CFR part 63, subpart GGGGG.

2(b)  Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards 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 standards. 
Continuous emission monitors are used to ensure compliance with the
standards at all times.  During the performance test, a record of the
operating parameters under which compliance was achieved may be recorded
and used to determine compliance in place of a continuous emission
monitor.

The notifications required in the standards 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 that the standards 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.

To minimize the burden, much of the information the EPA needs to
determine compliance is recorded and retained on-site at the facility. 
Such information will be reviewed by the enforcement personnel during an
inspection and will not need to be reported routinely to the EPA.  The
Agency requires respondents to report a minimal amount of information to
demonstrate compliance.  However, when a deviation occurs, additional
information must be reported that describes the cause of the deviation,
steps taken to correct the problem, and time required to return to
compliance.

3.  Nonduplication, Consultations, and Other Collection Criteria

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

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

3(c)  Consultations

It is our policy to review any comments received since the last ICR
renewal including those submitted in response to the first Federal
Register notice and respond appropriately.  It should be noted that
participants outside the EPA that were involved in the development of
the site remediation NESHAP include other Federal agencies, state air
regulatory agencies, trade associations, and private businesses.

The primary source of information was the industry and EPA data
including an assessment by the Office of Air and Radiation.  Information
provided by the industry is retained in the EPA Air Facility System
(AFS) database which is operated and maintained by the EPA Office of
Compliance.  AFS is the EPA database for the collection, maintenance,
and retrieval of all compliance data.  Approximately 286 respondents are
currently subject to the regulation.  The Agency estimates that there
will not be any industry growth in the next three years.

It should be noted that the industry trade associations and other
interested parties were provided an opportunity to comment on the burden
associated with the standard when it was proposed, and the standard was
previously reviewed to determine the minimum information needed for
compliance purposes.  No major problems regarding the rule monitoring,
recordkeeping, or reporting were identified during the public comment
period.

	For this renewal, EPA contacted representatives of industry trade
organizations to request a voluntary opinion as to the accuracy of the
burden estimates associated with this ICR and whether there is any way
to reduce the burden.  The American Chemistry Council, Lorraine
Gershman, telephone: 703-741-5219, did not identify any issues
associated with this ICR and had no comments on the estimates.

	EPA also contacted the American Petroleum Institute (API), Khary
Cauthen, telephone: 202-682-8209; no comments were received.

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

These reporting or recordkeeping requirements do not violate any of the
regulations promulgated by OMB under 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
with the Part 70 permit program 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 a source, any
pattern of non-compliance and to determine the appropriate level of
enforcement action.  EPA has found that the most flagrant violators have
violations extending beyond five years.  In addition, EPA would be
prevented from pursuing the violators due to the destruction or
nonexistence of essential records.  

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 reporting or recordkeeping requirements in the standard do not
include sensitive questions.

4.  The Respondents and the Information Requested

4(a)  Respondents/SIC Codes

Unlike a specific industry sector or type of business, the respondents
potentially affected by this ICR cannot be easily or definitively
identified.  Potentially, the site remediation NESHAP may be applicable
to any type of business or facility at which a site remediation is
conducted to clean up media contaminated with organic HAP, and the
remediation activities performed and the magnitude of the cleanup meets
the applicability criteria specified in the rule.  A site remediation
that is subject to this rule potentially may be conducted at any type of
privately owned or government-owned facility at which contamination has
occurred due to past events or current activities at the facility.  Site
remediations performed at sites where the facility has permanently
closed, the owner has gone out of business, or the facility has been
abandoned and there is no owner (in this latter case, a government
agency takes responsibility for the cleanup) are not subject to this
NESHAP in most cases.

The regulated sources under this NESHAP (i.e., the site remediation
activities) are not the predominant activity, process, operation, or
service conducted at the facility.  A comprehensive list of North
American Industry Classification System (NAICS) codes cannot be compiled
for the respondents who will potentially be regulated by this action due
to the nature of activities regulated by the source category.  The NAICS
code indicates a primary product produced or service provided at the
facility rather than the presence of a site remediation performed to
support the predominant function of the facility.  Some representative
NAICS codes for facilities where site remediations have been, or are
currently being, conducted at some (but not all) facilities under a
given code include: 325211, 325192, 325188, 32411, 49311, 49319, 48611,
42269, and 42271.  However, these codes are not necessarily
comprehensive as to the types of facilities at which site remediations
subject to the rule may be required in the future.

4(b)  Information Requested 

Each respondent to this information collection is required to submit to
the EPA a one-time notification of applicability of the respondent's
facility to the final NESHAP.  The respondents will be required to
perform an annual performance test for each control device used to
comply with the emission limitation standards and submit to the
EPA/permitting authority a report following the test.  Between
performance tests, the respondents will be required to monitor selected
operating parameters indicative of the control device performance and to
maintain records of the monitoring results.  Semiannually, the
respondent will be required to prepare and submit to the EPA a
compliance report describing any periods of control device operation
during which the monitored values of the control device operating
parameters deviated from the boundaries established during the most
recent performance test.

For the affected sources subject to work practice standards, the
respondents will be required to collect and maintain records of the air
pollution equipment inspections and repairs, as specified in the rule. 
In addition, the respondents will need to maintain records of initial
and subsequent determinations for any affected sources qualifying for an
exemption from control requirements under the rule.

Records and reports must be retained for a total of five years.  Records
must be kept on-site for two of the five years, and for three of the
years, records may be placed at an off-site location.  The files can be
maintained on microfilm, on computer or floppy disks, on magnetic tape
disks, or on microfiche.

(i)  Data Items

In this ICR, all the data that is recorded or reported is required by
the NESHAP for Site Remediation (40 CFR part 63, subpart GGGGG). 

A source must make the following reports:

Reports for 40 CFR part 63, subpart GGGGG

Requirement	40 CFR part 63 subpart GGGGG Citation	40 CFR part 63 subpart
A Citation

Notifications and Reports



Initial notification	63.7950(a), (c)	63.9(b)

Notification of performance tests	63.7950(a), (d)	63.7, 63.9(e)

Notification of compliance status	63.7950(a), (e)	63.9(h)

Performance test results	63.7950(a), (e)	63.10(d)(2)

Notification of alternative standard selection (if applicable)
63.7950(f)

	Semiannual compliance reports	63.7951(a), (b)	63.10(e)

Startup, shutdown, malfunction reports	63.7951(a), (b), (c)	63.10(d)(5)

Part 70 monitoring report	63.7951(d)

	

A source must maintain the following records:

Recordkeeping for 40 CFR part 63, subpart GGGGG

Requirement	40 CFR part 63 subpart GGGGG Citation	40 CFR part 63 subpart
A Citation	Retention Time

Copies of each notification and report submitted to comply with subpart
as listed above 	63.7952(a)(1)

5 years

Records related to startups, shutdowns, and malfunctions	63.7952(a)(2)
63.10(b)(2)	5 years

Records of performance tests	63.7952(a)(3)	63.10(b)(2)	5 years

Records of initial and subsequent determinations for affected sources
exempted from control requirements	63.7952(a)(4)	63.10(b)(2)	5 years

Records of control device operating parameter continuous monitoring
system (CMS) deviations, calibrations, and maintenance	63.7952(b)
63.10(b)(2)	5 years

Records to show continuous compliance with each emissions limitation,
work practice standard, and operation and maintenance requirement
63.7952(c), (d)	63.10(b)(2)	5 years



Respondents are using monitoring equipment that automatically records
parameter data.  Although personnel at the affected facility must still
evaluate the data, internal automation has significantly reduced the
burden associated with monitoring and recordkeeping at a plant site. 
Respondents will submit hard copy reports.  To minimize the burden, much
of the information the EPA needs to determine compliance will be
recorded and retained on-site at the facility. 

(ii)  Respondent Activities

Respondent Activities

Install, calibrate, maintain, operate continuous monitoring system for
VOHAP 

Perform initial performance test

Write the notification and reports listed above

Enter information required to be recorded above

Submit the required reports developing, acquiring, installing, and using
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 respond to a collection information

Transmit, or otherwise disclose the information



Electronic Reporting

Some of the respondents are using monitoring equipment that
automatically records parameter data.  Although personnel at the
affected facility must still evaluate the data, internal automation has
significantly reduced the burden associated with monitoring and
recordkeeping at a remediation 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 use
electronic reporting

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 initial notification

Review performance test notification

Conduct initial compliance determination

Review performance test reports

Review semiannual summary reports and any SSM reports

Audit facility records

Input, analyze, and maintain data in the Air facility Subsystem (AFS)
data base



5(b)  Collection Methodology and Management

Following notification of startup, the reviewing authority could 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 AFS which is
operated and maintained by the EPA 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

The rule places no requirement on any facility to initiate site
remediation activities.  The EPA anticipates that parties that undertake
site remediation generally do so voluntarily and that the impact of this
rule on those parties will not be significant.  Further, because states
and other parties decide whether to undertake site remediation
activities, predicting how many, or what types of small entities will
undertake such activities, is extremely difficult, if not impossible. 
Nonetheless, the rule is structured to avoid impacts on small
businesses.  

The rule specifically excludes from its scope remediations conducted at
gasoline stations, farm sites, and residential sites.  Moreover, the
rule applies only to remediation sites located at a facility that is a
major source under the CAA and at which is collocated one or more
non-remediation activities listed as a Maximum Achievable Control
Technology (MACT) major source category, pursuant to CAA section 112(c).
 Such sources tend to be large businesses.  The rule also contains
applicability emission thresholds that are likely to exclude many site
remediations conducted at small businesses.  For example, the rule
exempts sources where the total annual quantity of HAP contained in all
extracted remediation material at the facility is less than 1 megagram
per year.  For these reasons, the rule does not impose a significant
burden on a substantial number of small entities.

5(d)  Collection Schedule

The specific frequency for each information collection activity within
this request is shown in below Table 1: Annual Respondent Burden and
Cost, NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG).

6.  Estimating the Burden and Cost of the Collection

Tables 1 and 2 document the computation of individual burdens for the
recordkeeping and reporting requirements applicable to the affected
sources for the subpart included in this ICR.  The individual burdens
are expressed under standardized headings believed to be consistent with
the concept of burden under the Paperwork Reduction Act.  Where
appropriate, specific tasks and major assumptions have been identified. 
Responses to this information collection are mandatory.

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

6(a)  Estimating Respondent Burden

The average annual burden to industry (private sector and state, local
or tribal governments) over the next three years from these
recordkeeping and reporting requirements is estimated to be 112,349
hours (Total Labor Hours from Table 1).  The overall recordkeeping hours
shown in Table 1 are 85,621.  The overall reporting requirement hours
shown in Table 1 are 26,728.  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.

Estimating the number of respondents for the site remediation NESHAP is
more difficult than the other source categories for which the EPA
establishes NESHAP because of a unique set of considerations.  As
discussed earlier in Section 4(a), site remediations cannot be
categorized by a particular industry sector or group of industry
sectors.  Another consideration is the finite period for which a site
remediation is conducted.  The objective of a site remediation is to
mitigate a detected risk to public health or the environment by
successfully completing the cleanup of the area contaminated by a
hazardous substance.  For NESHAP source categories associated with
industrial processes or product distribution, a facility and its air
emission sources typically remain in operation for many years.  When an
existing source reaches the end of its useful service life, it is often
reconstructed or replaced with a new source.  In contrast, the air
emission sources associated with site remediations cease to exist once
the remediation cleanup criteria are achieved.  Depending on
site-specific facts such as the extent of the contamination and the type
of remediation activities needed, the “life span” of a given site
remediation may be a short period lasting several weeks to a more
extended period lasting several years.  Even for those site remediations
requiring a number of years to complete, it is important to recognize
that ultimately, the remediation activities at a facility will be
completed and the air emission sources will no longer exist.  Thus, at
any given time, the number of respondents will be changing since at some
facilities the site remediations are completed (i.e., subtracting
respondents from the total number), at other facilities the site
remediations are still on-going, and at some new facilities site
remediations are beginning (i.e., adding respondents to the total
number).

The annual burden estimates for reporting and recordkeeping presented in
Table 1 are based on an estimated total of 286 respondents, 243 of which
are from the private sector, 14 from state, local or tribal governments,
and 29 from the Federal government.  The respondent numbers used for the
estimates were derived from data used by EPA for estimating the
nationwide emission reduction and cost impacts of the final rule.  For
this total number of respondents, 26 respondents (9 percent) are
estimated to use an in-situ treatment process.  At each of these sites,
a control device is assumed to be required on the process vent.  The
other 260 respondents (91 percent) are assumed to use an on-site ex-situ
treatment process.  The vast majority of these sites use tanks for
storage and handling of contaminated media.  Although a rare practice at
existing sites, and not likely to be used at future sites, use of
surface impoundments at the ex-situ treatment sites is included in the
burden estimates by assuming that 5 of the 260 sites use a surface
impoundment in place of tanks.  Finally, the organic content of the
contaminated media extracted at most of the ex-situ treatment sites will
be below the 10 percent threshold level specified in the final rule for
implementation of a leak detection and repair (LDAR) program.  For the
burden estimates, it is assumed that 10 facilities will need to
implement an LDAR program.  Other assumptions are that 9 percent of the
respondents operating ex-situ treatment sites (26 respondents) choose to
exempt one source at the site from the air emission control requirements
according to the rule requirements, and an additional unit, an oil/water
separator, is used at five of the sites.

6(b)  Estimating Respondent Costs

(i)  Estimating Labor Costs 

 

This ICR uses the following labor rates: 

Managerial	$114.77 ($54.65 + 110%)   

Technical	$97.59 ($46.47 + 110%)

Clerical	$48.26 ($22.98 + 110%)

These rates are from the United States Department of Labor, Bureau of
Labor Statistics, March 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 type of industry costs associated with the information collection
activities in the subject standards are both labor costs which are
addressed elsewhere in this ICR and the costs associated with continuous
monitoring.  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 monitors and
other costs such as photocopying and postage.  

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

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

A

Monitoring Equipment	B

Startup Cost for One Affected Facility	C

Number of New Affected facilities to Startup	D

Total Startup Costs

(BxC)	E

Annual O&M Costs for One Affected Facility	F

Number of Affected Facilities with O&M	G

Total O&M

(ExF)

Parametric system	$10,000	0	0	$2,000	286	$572,000

Leak detection	$1,500	0	0	$1,000	10	$10,000

Total





$582,000



There are no capital/startup costs for this ICR.  The total operation
and maintenance (O&M) costs for this ICR are $582,000.  This is the
total of column G, which is the total costs for all 286
respondents—including 243 respondents from the private sector
($494,496 – rounded down), 14 respondents from the state, local or
tribal governments (28,490), and 29 respondents from the Federal
government (59,014). 

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 $582,000.  These are recordkeeping costs.  

6(c)  Estimating Agency Burden and Cost

The costs to the Agency are those costs associated with analysis of the
reported information.  Additionally, the Federal government incurs
burden (both labor costs and O&M) as respondents.  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 $1,555,772.  

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

	Managerial	$61.36 (GS-13, Step 5, $38.35 + 60%) 

	Technical	$45.52 (GS-12, Step 1, $28.45 + 60%)

	Clerical	$24.64 (GS-6, Step 3, $15.40 + 60%)

These rates are from the Office of Personnel Management (OPM), 2009
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
Site Remediation (40 CFR Part 63, Subpart GGGGG).  

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

Based on our research for this ICR, on average over the next three
years, approximately 286 existing respondents will be subject to the
standard.  It is estimated that no new respondents will become subject
to the standard.  

Respondent Universe and Total Burden and Cost

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	E

Number of Respondents That Keep Records but Do Not Submit Reports	F

Total Annual Responses

(AxB)+(CxD)+E

Semiannual reports	0	0	286	2	0	572

SSM reports when not in compliance with the SSM Plan	0	0	0	0	0	0



The number of Total Annual Responses is 572.  

The total annual labor costs to non-Federal-government respondents are
$10,796,331.  Details regarding these estimates may be found below in
Table 1: Annual Respondent Burden and Cost, NESHAP for Site Remediation
(40 CFR Part 63, Subpart GGGGG).  

The average annual Agency burden and cost over next three years is
estimated to be 18,398 labor hours at a cost of $1,496,758 (not
including startup and O&M costs).  See Table 2 below: Average Annual EPA
Burden, NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG).

The total annual capital/startup and O&M costs to the regulated entities
are $582,000.  The cost calculations are detailed in Section 6(b)(iii),
Capital/Startup vs. Operation and Maintenance (O&M) Costs.

The total annual respondent labor costs for all types of respondents is
$12,014,594.

6(e)  Bottom Line 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 respondent labor hours are 112,349 for the private
sector, state, local and tribal government respondents, and 12,678 for
Federal government respondents.  Details regarding these estimates may
be found in Table 1: Annual Respondent Burden and Cost, NESHAP for Site
Remediation (40 CFR Part 63, Subpart GGGGG) and Table 2: Average Annual
EPA Burden, NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG).
 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 $582,000.  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 18,398 labor hours at a cost of $1,496,758.  Including
O&M costs, the total cost is $1,555,772.  See Table 2: Average Annual
EPA Burden, NESHAP for Site Remediation (40 CFR Part 63, Subpart GGGGG)
(below).

6(f)  Reasons for Change in Burden

There is no change in the labor hours in this ICR compared to the
previous ICR.  This is due to two considerations.  First, the
regulations have not changed over the past three years and are not
anticipated to change over the next three years.  Secondly, the growth
rate for respondents is very low, negative, or non-existent.  Therefore,
the labor hours in the previous ICR reflect the current burden to the
respondents and are reiterated in this ICR.  There is a minor change to
the cost figures due to updates in labor rates and some minor
mathematical errors have been corrected.  The updated labor categories
and associated rates result in an increase to total labor cost.  

	There is also a change in the method of reporting in this ICR.  The
labor hours and costs are calculated separately for each respondent
type: “private sector,” “state, local or tribal governments,”
and “Federal government”.  There is no change in the total
respondent burden hours (comprising both industry and Federal government
respondents).  

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-2009-0545.  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 Avenue, 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
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, NW, Washington, DC 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OECA-2009-0545 and OMB Control Number 2060-0534 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 Site
Remediation (40 CFR Part 63, Subpart GGGGG)

Information Collection Activity	A	B	C	D	E	F	G	H

	Labor hours per Activity	Activities per Respondent per Year	Total
Number of Respondents	Manage-ment hours per year	Technical hours per
year	Clerical hours per year	Total Person Hours per Year	Total Cost per
Year

	Mngmt	Technical	Clerical	 	 	 	 	 	 	($)

Private Sector

1. Applications	NA	NA	NA	NA	NA	NA	NA	NA	NA	NA

2. Surveys and Studies	NA	NA	NA	NA	NA	NA	NA	NA	NA	NA

3. Parametric 	4	40	0	1	0	0	0	0	0	$0

Monitoring System











4. Reporting requirements	 	 	 	 	 	 	 	 	 	 

- Read instructions	8	16	0	1	0	0	0	0	0	$0

- Conduct performance test	16	120	0	1	0	0	0	0	0	$0

- Initial notification	8	0	2	1	0	0	0	0	0	$0

- Performance test notification	2	0	1	1	0	0	0	0	0	$0

- Initial compliance determination	8	40	8	1	0	0	0	0	0	$0

- Performance test report	8	80	16	1	0	0	0	0	0	$0

- Semiannual report	4	40	8	2	243	1944.00	19440	3888.00	25,272	$2,307,897

- SSM report	1	8	1	0	0	0	0	0	0	$0

Subtotal Reporting	 	 	 	 	 	25,272	25,272	$2,307,897

5. Recordkeeping requirements	 	 	 	 	 	 	 	 	 	 

- Read instructions	8	40	0	1	0	0	0	0	0	$0

- Plan activities	8	100	0	1	0	0	0	0	0	$0

- Prepare SSM plan	16	80	8	1	0	0	0	0	0	$0

- Prepare documentation for exempted sources	16	80	8	1	22.1	353.5	1767.3
176.7	2,297	$221,563

- In-situ process vents parametric monitoring	0	0.5	0	365	22.1	0	4031.6
0	4,032	$393,443

- Ex-situ process vents parametric monitoring	0	0.5	0	365	220.9	0
40315.9	0	40,316	$3,934,430

- Inspect tank covers	0	2	0	12	216.7	0	5199.9	0	5,200	$507,454

- Inspect container covers	0	0.5	0	12	220.9	0	1325.5	0	1,325	$129,351

- Inspect surface impoundment covers	0	2	0	12	4.2	0	102.0	0	102	$9,950

- Inspect separator covers	0	2	0	12	4.2	0	102.0	0	102	$9,950

- Inspect transfer system covers	0	0.5	0	12	220.9	0	1325.5	0	1,325
$129,351

- Leak detection and repair program	16	100	0	1	8.5	135.9	849.7	0	986
$98,520

- Develop record system	16	100	8	1	0	0	0	0	0	$0

- Enter information	0	2	0	52	243	0	25272	0	25,272	$2,466,294

- Personnel training	2	20	0	0	0	0	0	0	0	$0

Subtotal Recordkeeping	 	 	 	 	 	80,957	80,957	$7,900,306

Total for Private Sector	 	 	 	 	 	 	 	 	106,229	$10,208,204

State, Local or Tribal Government

1. Applications	NA	NA	NA	NA	NA	NA	NA	NA	NA	NA

2. Surveys and Studies	NA	NA	NA	NA	NA	NA	NA	NA	NA	NA

3. Parametric 	4	40	0	1	0	0	0	0	0	$0

Monitoring System











4. Reporting requirements	 	 	 	 	 	 	 	 	 	 

- Read instructions	8	16	0	1	0	0	0	0	0	$0

- Conduct performance test	16	120	0	1	0	0	0	0	0	$0

- Initial notification	8	0	2	1	0	0	0	0	0	$0

- Performance test notification	2	0	1	1	0	0	0	0	0	$0

- Initial compliance determination	8	40	8	1	0	0	0	0	0	$0

- Performance test report	8	80	16	1	0	0	0	0	0	$0

- Semiannual report	4	40	8	2	14	112	1120	224	1,456	$132,965

- SSM report	1	8	1	0	0	0	0	0	0	$0

Subtotal Reporting	 	 	 	 	 	1,456	1,456	$132,965

5. Recordkeeping requirements	 	 	 	 	 	 	 	 	 	 

- Read instructions	8	40	0	1	0	0	0	0	0	$0

- Plan activities	8	100	0	1	0	0	0	0	0	$0

- Prepare SSM plan	16	80	8	1	0	0	0	0	0	$0

- Prepare documentation for exempted sources	16	80	8	1	1.3	20.4	101.8
10.2	132	$12,765

- In-situ process vents parametric monitoring	0	0.5	0	365	1.3	0	232.3	0
232	$22,667

- Ex-situ process vents parametric monitoring	0	0.5	0	365	12.7	0	2322.7
0	2,323	$226,675

- Inspect tank covers	0	2	0	12	12.5	0	299.6	0	300	$29,236

- Inspect container covers	0	0.5	0	12	12.7	0	76.4	0	76	$7,452

- Inspect surface impoundment covers	0	2	0	12	0.2	0	5.9	0	6	$573

- Inspect separator covers	0	2	0	12	0.2	0	5.9	0.0	6	$573

- Inspect transfer system covers	0	0.5	0	12	12.7	0	76.4	0	76	$7,452

- Leak detection and repair program	16	100	0	1	0.5	7.8	49.0	0	57	$5,676

- Develop record system	16	100	8	1	0	0	0	0	0	$0

- Enter information	0	2	0	52	14	0	1456	0	1,456	$142,091

- Personnel training	2	20	0	0	0	0	0	0	0	$0

Subtotal Recordkeeping	 	 	 	 	 	4,664	4,664	$455,162

Total for State, Local or Tribal Government	 	 	 	 	 	 	 	 
6,120	$588,127

Overall Reporting	 	 	 	 	 	 	 	 	26,728	$2,440,863

Overall Recordkeeping	 	 	 	 	 	 	 	 	85,621	$8,355,468

OVERALL TOTAL	 	 	 	 	 	 	 	 	112,349	$10,796,331

Assumptions

Cost: managerial -$114.77/hr, technical - $97.59/hr, clerical -
$48.26/hr.

2) 243 respondents from the private sectors, 29 respondents from the
Federal government, and 14 respondents from state, local or tribal
governments.  (286 respondents total).

3) 26 out of 286 respondents (9 percent) are estimated to use an in-situ
treatment process.  At each of these sites, it is assumed that a control
device is required on the process vent.  

4) 260 out of 286 respondents (90 percent) are assumed to use an on-site
ex-situ treatment process.

5) 5 of the 260 sites use a surface impoundment in place of tanks.

6) 10 facilities implement an LDAR program.

7) 26 out of 286 respondents exempt one source at the site from the air
emission control requirements.

8) Oil/water separator is used at five of the sites.

9) Previous ICR allowed two SSM reports per year, but we determined that
these reports are typically included in the semiannual reports.

10) The relative proportions in assumptions (3) through (7) are applied
to each respondent type according to the breakdown explained in
Assumption (2).

Table 2:  Average Annual EPA Burden, NESHAP for Site Remediation (40
CFR Part 63, Subpart GGGGG).

Information Collection Activity	A	B	C	E	F	G	H	I

	Labor Hours per Activity per Labor Category	Activities per Respondent
per Year	Total Number of Respondents	Management hours per year	Technical
hours per year	Clerical hours per year	Total Person Hours per Year	Total
Labor Costs per Year

	Managerial	Technical	Clerical	 	 	 	 	 	 	($)

Report Review	 

 

 	 	 	 

 

a. Initial notification	1	4	0	0	0	0	0	0	0	$0

b. Performance test notification	1	2	0	0	286	0	0	0	0	$0

c. Initial compliance determination	4	24	0	0	0	0	0	0	0	$0

d. Performance test reports	4	24	0	0	286	0	0	0	0	$0

e. Semiannual report	2	8	0	2	286	1144	4576	0	5,720	$278,495

TOTAL for Report Review	 	 	 	 	 	 	5,720	$278,495

Respondent Burden - Federal Government

1. Applications	NA	NA	NA	NA	NA	NA	NA	NA	NA	NA

2. Surveys and Studies	NA	NA	NA	NA	NA	NA	NA	NA	NA	NA

3. Parametric 	4	40	0	1	0	0	0	0	0	$0

Monitoring System











4. Reporting requirements	 	 	 	 	 	 	 	 	 	 

- Read instructions	8	16	0	1	0	0	0	0	0	$0

- Conduct performance test	16	120	0	1	0	0	0	0	0	$0

- Initial notification	8	0	2	1	0	0	0	0	0	$0

- Performance test notification	2	0	1	1	0	0	0	0	0	$0

- Initial compliance 

  determination	8	40	8	1	0	0	0	0	0	$0

- Performance test 

  report	8	80	16	1	0	0	0	0	0	$0

- Semiannual report	4	40	8	2	29	232.00	2320	464.00	3,016	$275,428

- SSM report	1	8	1	0	0	0	0	0	0	$0

Subtotal Reporting	 	 	 	 	 	3,016	3,016	$275,428

5. Recordkeeping requirements	 	 	 	 	 	 	 	 	 	 

- Read instructions	8	40	0	1	0	0	0	0	0	$0

- Plan activities	8	100	0	1	0	0	0	0	0	$0

- Prepare SSM plan	16	80	8	1	0	0	0	0	0	$0

- Prepare 

  documentation for exempted sources	16	80	8	1	2.6	42.2	210.9	21.1	274
$26,442

- In-situ process vents 

parametric monitoring	0	0.5	0	365	2.6	0	481.1	0	481	$46,954

- Ex-situ process vents 

parametric monitoring	0	0.5	0	365	26.4	0	4811.4	0	4,811	$469,541

- Inspect tank covers	0	2	0	12	25.9	0	620.6	0	621	$60,560

- Inspect container 

covers	0	0.5	0	12	26.4	0	158.2	0	158	$15,437

- Inspect surface 

impoundment covers	0	2	0	12	0.5	0	12.2	0	12	$1,187

- Inspect separator 

covers	0	2	0	12	0.5	0	12.2	0	12	$1,187

- Inspect transfer system 

 covers	0	0.5	0	12	26.4	0	158.2	0	158	$15,437

- Leak detection and 

 repair program	16	100	0	1	1.0	16.2	101.4	0	118	$11,757

- Develop record 

 system	16	100	8	1	0	0	0	0	0	$0

- Enter information	0	2	0	52	29	0	3016	0	3,016	$294,331

- Personnel training	2	20	0	0	0	0	0	0	0	$0

Subtotal Recordkeeping	 	 	 	 	 	9,662	9,662	$942,835

Subtotal for Federal Government Respondent	 	 	 	 	 	 	 	 
12,678	$1,218,263

Total Labor Burden	 	 	 	 	 	 	 	 	18,398	$1,496,758

Startup and O&M









$59,014

Total Labor hours and Cost 







	18,398	$1,555,772



Assumptions for Report Review

1) Managerial labor - $61.36, technical labor-$45.52, clerical
labor-$24.64.  

Assumptions for Federal Government Respondent

Cost: managerial -$114.77/hr, technical - $97.59/hr, clerical -
$48.26/hr.

2) 243 respondents from the private sectors, 29 respondents from the
Federal government, and 14 respondents from state, local or tribal
governments.  (286 respondents total).

3) 26 out of 286 respondents (9 percent) are estimated to use an in-situ
treatment process.  At each of these sites, it is assumed that a control
device is required on the process vent.  4) 260 out of 286 respondents
(91 percent) are assumed to use an on-site ex-situ treatment process.

5) 5 of the 260 sites use a surface impoundment in place of tanks.

6) 10 facilities implement an LDAR program.

7) 26 out of 286 respondents exempt one source at the site from the air
emission control requirements.

8) Oil/water separator is used at five of the sites.

9) Previous ICR allowed two SSM reports per year, but we determined that
these reports are typically included in the semiannual reports.

10) The relative proportions in assumptions (3) through (7) are applied
to each respondent type according to the breakdown explained in
Assumption (2).

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