                             SUPPORTING STATEMENT
                                  APPENDIX A 
                                       
Table 1. Annual Respondent Burden and Cost  -  National Emission Standards for Hazardous Air Pollutants for Asbestos (40 CFR Part 61, Subpart M) (Renewal)

Table 2. Average Annual EPA Burden and Cost  -  National Emission Standards for Hazardous Air Pollutants for Asbestos (40 CFR Part 61, Subpart M) (Renewal)
Table 1. Annual Respondent Burden and Cost  -  National Emission Standards for Hazardous Air Pollutants for Asbestos (40 CFR Part 61, Subpart M) (Renewal)
Burden item
                                       A
                                       B
                                       C
                                       D
                                       E
                                       F
                                       G
                                       H

                          Person-hours
per occurrence
                       Annual occurrences
per respondent
                  Person-hours
per respondent
per year (AxB)
                           Respondents
per year [a]
                        Technical hours per
year (CxD)
                      Management hours per year (Ex0.05)
                       Clerical hours
per year
(Ex0.10)
                              Annual cost
($) [b]
1.  Applications
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
2.  Surveys and studies
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
3.  Reporting requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
A.  Read instructions
                                       1
                                       1
                                       1
                                      66
                                      66
                                      3.3
                                      6.6
                                                                       7,632.60
B.  Required activities including monitoring or operations
                                    See 3D
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
C.  Gather existing information
                                  See 3D, 4E
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
D.  Write reports
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
i.  Asbestos converting operations
 
 
 
 
 
 
 
 
Notification and application for construction
                                      80
                                       1
                                      80
                                       0
                                       0
                                       0
                                       0
                                                                              0
Report on sample analyses performed during initial 90 days of operation
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                                                              0
Quarterly operations and monthly sample analysis report
                                       2
                                       4
                                       8
                                       2
                                      16
                                       1
                                       2
                                                                          1,850
ii.  Spraying operations [c]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Notification of commencement of operations using materials containing >1% asbestos
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Excepted waste shipment report [d]
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
iii.  Demolition/renovation
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Notification  by US Mail of intent to demolish or renovate
                                       1
                                       6
                                       6
                                     8,413
                                    50,478
                                   2,523.90
                                    5,047.8
                                                                   5,837,553.55
Renotification due to change
                                     0.25
                                       2
                                      0.5
                                     8,413
                                    4,206.5
                                    210.33
                                    420.65
                                                                     486,462.80
Electronic notification
                                     0.25
                                       3
                                      0.8
                                      200
                                     150.0
                                     7.50
                                     15.00
                                                                      17,346.83
Excepted waste shipment report [d]
                                       1
                                       3
                                       3
                                     8,621
                                    25,863
                                   1,293.15
                                    2,586.3
                                                                   2,990,939.57
Malfunction report if using CTPS AWP
                                       2
                                       2
                                       4
                                      22
                                      88
                                     4.40
                                      8.8
                                                                      10,176.80
iv.  Milling, manufacturing, and fabricating
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Control device maintenance plan [e]
                                       1
                                       1
                                       1
                                      40
                                      40
                                       2
                                       4
                                                                       4,625.82
Semiannual visible emissions report
                                       1
                                       2
                                       2
                                      400
                                      800
                                      40
                                      80
                                                                       92,516.4
Excepted waste shipment report [d]
                                      0.1
                                       1
                                      0.1
                                      400
                                      40
                                       2
                                       4
                                                                       4,625.82
New source report
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                                                              0
v.  Asbestos-containing waste disposal sites
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
New source report
                                       1
                                       1
                                       1
                                      10
                                      10
                                      0.5
                                       1
                                                                       1,156.46
Waste generator reports
                                     0.67
                                       1
                                     0.67
                                      560
                                     375.2
                                     18.76
                                     37.52
                                                                      43,390.19
Waste disposal discrepancy report [f]
                                      1.5
                                       1
                                      1.5
                                      560
                                      840
                                      42
                                      84
                                                                      97,142.22
Improperly contained waste report [g, h]
                                     1.17
                                       2
                                     2.34
                                      560
                                    1,310.4
                                     65.52
                                    131.04
                                                                     151,541.86
Notification of excavation of asbestos materials [i]
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                                                              0
Facility closure report
                                       2
                                       1
                                       2
                                      10
                                      20
                                       1
                                       2
                                                                       2,312.91
Reporting Subtotal
                                       
                                       
                                       
                                       
                                    96,949
                                                                     $9,749,274
4.  Recordkeeping requirements
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
A.  Read instructions
                                    See 3A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
B.  Plan activities
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
C.  Implement activities
                                    See 3B
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
D.  Develop record system
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
E.  Time to enter and transmit information
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
i.  Asbestos converting operations
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Records of startup performance testing and initial 90 days of operations
                                      0.1
                                       1
                                      0.1
                                       0
                                       0
                                       0
                                       0
                                                                              0
Waste shipment records
                                      0.1
                                      12
                                      1.2
                                       2
                                      2.4
                                     0.12
                                     0.24
                                                                         277.55
ii.  Spraying operations [c]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Waste shipment records
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Excepted waste shipment report [d]
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
iii.  Demolition/renovation
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Waste shipment records [j]
                                      0.1
                                      24
                                      2.4
                                     8,621
                                   20,690.4
                                   1,034.52
                                   2,069.04
                                                                   2,392,751.65
Cold weather temperature monitoring [k]
                                      0.1
                                      147
                                     14.7
                                       0
                                       0
                                       0
                                       0
                                                                              0
Excepted waste shipment report [d]
                                      0.1
                                       3
                                      0.3
                                     8,621
                                    2,586.3
                                     129.3
                                    258.63
                                                                     299,093.96
iv.  Milling, manufacturing, and fabricating
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Cold weather temperature monitoring [k]
                                      0.1
                                      147
                                     14.7
                                       0
                                       0
                                       0
                                       0
                                                                              0
Daily visible emissions [l]
                                      0.1
                                     637.5
                                     63.75
                                      400
                                    25,500
                                     1,275
                                     2,550
                                                                   2,948,960.25
Weekly inspection of air cleaning devices [l]
                                     0.25
                                     127.5
                                     31.88
                                      400
                                    12,750
                                     637.5
                                     1,275
                                                                   1,474,480.13
Waste shipment records
                                      0.1
                                      51
                                      5.1
                                      400
                                     2,040
                                      102
                                      204
                                                                     235,916.82
Excepted waste shipment report [d]
                                      0.1
                                       1
                                      0.1
                                      400
                                      40
                                       2
                                       4
                                                                       4,625.82
v.  Asbestos-containing waste disposal sites
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Time to file and mail waste generator reports
                                    See 3D
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Waste shipment records
                                      1.5
                                      12
                                      18
                                      560
                                    10,080
                                      504
                                     1,008
                                                                   1,165,706.64
Waste management data retention until landfill closure
                                      0.5
                                       1
                                      0.5
                                      10
                                       5
                                     0.25
                                      0.5
                                                                         578.23
Record of deed OR utility record notation (if using CTPS AWP) once inactive
                                      0.5
                                       1
                                      0.5
                                      10
                                       5
                                     0.25
                                      0.5
                                                                         578.23
F.  Time to train personnel
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
i.  Asbestos converting operations
                                      N/A
 
 
 
 
 
 
 
ii.  Spraying operations [c]
                                      N/A
 
 
 
 
 
 
 
iii.  Demolition/renovation (refresher training) [m]
                                       8
                                       1
                                       8
                                     8,649
                                    69,192
                                    3,459.6
                                    6,919.2
                                                                   8,001,743.44
iv.  Milling, manufacturing, and fabricating [n]
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
v.  Asbestos-containing waste disposal sites [o]
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
G.  Time for audits
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
Recordkeeping Subtotal
                                       
                                       
                                       
                                       
                                    164,325
                                                                    $16,524,713
TOTAL ANNUAL BURDEN AND COST (ROUNDED)
                                       
                                       
 
                                       
                                    261,273
                                                                    $26,273,987
TOTAL ANNUAL CAPITAL AND O&M COST (SEE SECTION 6(b)(iii))
                                       
                                       
 
                                       
                                       
                                       
                                       
                                                                              0
GRAND TOTAL (LABOR, CAPITAL, AND O&M)
                                       
                                       
 
                                       
                                       
                                       
                                       
                                                                    $26,273,987
Assumptions:
[a]  EPA estimates an average of 9,575 existing sources will be subject to the rule over the next 3 years. On average during this period, 38 new sources per year will become subject, while 10 existing sources per year will close and will cease to be subject to the rule. The net total is 9,603 sources per year (9,575 + 38 - 10 = 9,603). The following is a detailed breakdown of the four source categories:
      Two existing asbestos converting sources. No new sources are expected.
      8,613 existing asbestos demolition/renovation sources. EPA assumes an increase of 28 new sources per year.
      Of these demolition/renovation sources, we estimate electronic notifications will begin in 2018, and increase over the next 3 years to average about 10 percent, or 800 electronic notifications annually.
      Of these demolition/renovation sources, we estimate that malfunction reports for the CTPS AWP may be required twice per year for each company conducting ACPRPs using the new AWP. 
      400 existing asbestos milling, manufacturing, and fabricating sources. No new sources are expected.
      1,119 municipal/Subtitle D landfills nation-wide, of which 50 percent, or 560 sources, will receive asbestos-containing wastes subject to the rule. No net growth will occur because an estimated 10 sites will close annually, while an estimated 10 sites will become subject to the rule by commencing acceptance of asbestos-containing wastes.

[b]  This ICR uses the following labor rates: $103.97 (technical), $129.93 (managerial), and $51.79 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2014, "Table 2. Civilian Workers, by Occupational and Industry Group." The rates are from column 1, "Total compensation." They have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
[c]  EPA does not expect any spray operation sources will become subject to the rule over the next 3 years.
[d]  Report notifying EPA that waste shipment records signed by owners/operators of disposal sites were not received by waste generators within 45 days of the date of waste acceptance by initial transporters.
e  The rule requires sources to submit a control device maintenance plan for any air cleaning devices that cannot be inspected on a weekly basis. EPA assumes 10 percent of sources will submit such maintenance plans.
[f]  Sources are required to submit reports if discrepancies between designated waste shipment and actual received quantities are not resolved with waste generators.
[g]  Active waste disposal sites are required to report the presence of improperly enclosed or uncovered waste, or any asbestos-containing waste material not sealed in leak-tight containers, and submit the waste shipment record.
[h]  EPA assumes respondents will submit reports for improperly contained waste twice per year.
[i]  EPA assumes asbestos-containing waste will not be excavated at any disposal site.
[j]  EPA assumes approximately 4 million cubic yards of waste shipments will be recorded annually for all demolition/renovation contractors, and that each load will be about 20 cubic yards. This would result in approximately 200,000 loads annually (4 million cubic yards/20 cubic yards per load). Averaged out over all 8,613 contractors, we estimate approximately 23 loads per contractor per year (200,000 loads/8,613 contractors = 23.2 loads per contractor, or 24 after rounding up to the nearest whole integer).
[k]  Based on Agency experience with the rule, operations generally cease from late fall into winter. We, thus, assume the burden for this activity will be negligible.
[l]  EPA assumes sources will have an average of 2.5 control devices requiring monitoring, and that will operate for 255 days over 51 weeks, annually.
[m]  EPA assumes all existing contractors (8,613) and new contractors entering the market for the first time (28) will spend resources annually on training due to employee turnover and new hires.
[n]  EPA anticipates there will be no direct costs to respondents to train inspectors for Method 9 certification for daily visible emissions monitoring.
[o]  EPA anticipates there will be no burden for waste disposal-related training.
Table 2. Average Annual EPA Burden and Cost  -  National Emission Standards for Hazardous Air Pollutants for Asbestos (40 CFR Part 61, Subpart M) (Renewal)
Burden item
                                       A
                                       B
                                       C
                                       D
                                       E
                                       F
                                       G
                                       H

                        EPA
person-hours
per occurrence
                       Annual occurrences
per respondent
                EPA
person-hours
per respondent
per year (AxB)
                           Respondents
per year [a]
                        Technical hours
per year
(CxD)
                      Management
hours per year
(Ex0.05)
                       Clerical hours
per year
(Ex0.10)
                              Annual cost
($) [b]
1.  Asbestos converting operations
 
 
 
 
 
 
 
 
A.  Notification and application for construction
                                      80
                                       1
                                      80
                                       0
                                       0
                                       0
                                       0
                                                                              0
B.  Report on sample analyses performed during initial 90 days of operation
                                       1
                                       1
                                       1
                                       0
                                       0
                                       0
                                       0
                                                                              0
C.  Quarterly operations and monthly sample analysis report
                                      0.5
                                       4
                                       2
                                       2
                                       4
                                      0.2
                                      0.4
                                                                         209.36
2.  Spraying operations [c]
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
A.  Notification of commencement of operations using materials containing >1 percent asbestos
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
B.  Excepted waste shipment report
                                      N/A
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
3.  Demolition/renovation
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
A.  Notification by U.S. mail of intent to demolish or renovate
                                     0.25
                                       6
                                     1.50
                                     8,413
                                   12,619.50
                                    630.98
                                   1,261.95
                                                                     660,504.63
B. Electronic Notification
                                      0.1
                                       3
                                     0.25
                                      200
                                     50.00
                                     2.50
                                     5.00
                                                                       2,617.00
C.  Renotification due to change
                                     0.25
                                       2
                                      0.5
                                     8,413
                                    4,206.5
                                    210.33
                                    420.65
                                                                     220,168.21
D.  Excepted waste shipment report
                                      0.5
                                       3
                                      1.5
                                     8,621
                                   12,931.5
                                    646.58
                                   1,293.15
                                                                     676,834.71
E.  CTPS AWP Malfunction report
                                     0.25
                                       2
                                      0.5
                                      22
                                     11.0
                                     0.55
                                     1.10
                                                                         575.74
4.  Milling, manufacturing, and fabricating
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
A.  Control device maintenance plan
                                     0.25
                                       1
                                     0.25
                                      40
                                      10
                                      0.5
                                       1
                                                                          523.4
B.  Semiannual visible emissions report
                                      0.1
                                       2
                                      0.2
                                      400
                                      80
                                       4
                                       8
                                                                        4,187.2
C.  Excepted waste shipment report
                                      0.5
                                       1
                                      0.5
                                      400
                                      200
                                      10
                                      20
                                                                         10,468
D.  New source report
                                      0.5
                                       1
                                      0.5
                                       0
                                       0
                                       0
                                       0
                                                                              0
5.  Asbestos-containing waste disposal sites
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                                                              
A.  New source report
                                      0.5
                                       1
                                      0.5
                                      10
                                       5
                                     0.25
                                      0.5
                                                                          261.7
B.  Waste generator reports
                                       4
                                       1
                                       4
                                      560
                                     2,240
                                      112
                                      224
                                                                      117,241.6
C.  Waste disposal discrepancy report
                                      0.5
                                       1
                                      0.5
                                      560
                                      280
                                      14
                                      28
                                                                       14,655.2
D.  Improperly contained waste report
                                      0.5
                                       2
                                       1
                                      560
                                      560
                                      28
                                      56
                                                                       29,310.4
E.  Notification of excavation of asbestos materials
                                       2
                                       1
                                       2
                                       0
                                       0
                                       0
                                       0
                                                                              0
F.  Facility closure report
                                       1
                                       1
                                       1
                                      10
                                      10
                                      0.5
                                       1
                                                                          523.4
TOTAL ANNUAL BURDEN AND COST (ROUNDED)
                                    38,189
                                                                     $1,738,081

Assumptions:
[a]  EPA estimates an average of 9,575 existing sources will be subject to the rule over the next 3 years. On average during this period, 38 new sources per year will become subject, while 10 existing sources per year will close and will cease to be subject to the rule. The net total is 9,603 sources per year (9,575 + 38 - 10 = 9,603). The following is a detailed breakdown of the four source categories:
 Two existing asbestos converting sources. No new sources are expected.
 8,613 existing asbestos demolition/renovation sources. EPA assumes an increase of 28 new sources per year.
 400 existing asbestos milling, manufacturing, and fabricating sources. No new sources are expected.
 1,119 municipal/Subtitle D landfills nation-wide, of which 50 percent, or 560 sources, will receive asbestos-containing wastes subject to the rule. No net growth will occur because an estimated 10 sites will close annually, while an estimated 10 sites will become subject to the rule by commencing acceptance of asbestos-containing wastes.
 
[b]  This ICR uses the following labor rates: $46.67 (technical), $62.90 (managerial), and $25.25 (clerical). These rates are from the Office of Personnel Management (OPM), 2014 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.
[c]  EPA does not expect any spray operation sources will become subject to the rule over the next 3 years.
