Pollution
Prevention
Compliance
Alternative;
Transportation
Equipment
Cleaning
(
TEC)
Point
Source
Category
(
40
CFR
PART
442)

March
19,
2001
U.
S.
Environmental
Protection
Agency
Office
of
Water
Office
of
Science
and
Technology
Engineering
and
Analysis
Division
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
D.
C.
20460
i
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Short
Characterization/
Abstract
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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2
2(
a)
Need/
Authority
for
the
Collection
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2
2(
b)
Practical
Utility/
Users
of
the
Data
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2
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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2
3(
a)
Nonduplication
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2
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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2
3(
c)
Consultations
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2
3(
d)
Effects
of
Less
Frequent
Collection
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3
3(
e)
General
Guidelines
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3
3(
f)
Confidentiality
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3
3(
g)
Sensitive
Questions
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3
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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4
4(
a)
Respondents
and
SIC
Codes
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4
4(
b)
Information
Requested
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4
4(
c)
Respondent
Activities
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6
5.
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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6
5(
a)
Agency
Activities
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6
5(
b)
Collection
Methodology
and
Management
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7
5(
c)
Small
Entity
Flexibility
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7
5(
d)
Collection
Schedule
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7
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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7
6(
a)
Estimating
Respondent
Burden
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7
6(
b)
Estimating
Respondent
Costs
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10
6(
c)
Estimating
Agency
Burden
and
Costs
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11
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
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11
6(
e)
Bottom
Line
Burden
Hours
and
Costs
Table
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13
6(
f)
Reasons
for
Changes
in
Burden
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13
6(
g)
Burden
Statement
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13
ii
LIST
OF
TABLES
1
Annual
Respondent
Burden
and
Cost
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8
2
Annual
Agency
Burden
and
Cost
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12
3
Summary
of
Burden
and
Cost
to
Respondents
and
EPA
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13
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
Pollution
Prevention
Compliance
Alternative;
Transportation
Equipment
Cleaning
(
TEC)
Point
Source
Category.
(
40
CFR
Part
442)
(
EPA
ICR
No.
2018.01).

1(
b)
Short
Characterization/
Abstract
EPA
issued
a
final
guideline
for
the
TEC
point
source
category
on
August
14,
2000.
This
final
rule
included
a
regulatory
compliance
option
which
allows
certain
facilities
to
develop
a
Pollutant
Management
Plan
in
lieu
of
meeting
numeric
standards.
Facilities
have
the
option
to
develop
this
plan
if
it
would
be
a
more
beneficial
compliance
alternative.
The
Pollutant
Management
Plan
is
only
available
for
PSES
and
PSNS
in
Subparts
A
and
B
of
the
TEC
regulation,
representing
a
potential
total
of
316
facilities.
Facilities
opting
to
comply
with
the
PMP
have
until
August
14,
2003
to
comply
with
the
regulations.

The
Pollutant
Management
Plan
includes
requirements
for
record
keeping
and
paperwork
that
were
not
previously
included
in
the
burden
estimate
for
the
TEC
industry.
This
new
Information
Collection
Request
(
ICR)
presents
estimates
of
the
burden
hours
and
costs
to
the
regulated
community
and
pretreatment
authorities
for
data
collection
and
recordkeeping
associated
with
implementing
the
pollution
prevention
compliance
option.

The
PMP
is
an
effective
alternative
method
of
reducing
pollutant
discharges
from
indirect
dischargers
in
Subparts
A
and
B
(
facilities
that
clean
tank
trucks,
intermodal
tank
containers,
and
rail
tank
cars
transporting
chemical
and
petroleum
cargos).
The
PMP
contains
10
components
that
must
be
considered
and
addressed
when
developing
the
Plan.
These
components
require
facilities
to
identify
and
segregate
incompatible
waste
streams
which
may
include
heels,
prerinse
or
prestream
wastewater,
and
spent
cleaning
solutions
from
wastewater
discharged
to
the
POTW.
The
PMP
also
requires
provisions
for
recycling
or
reuse
of
incompatible
waste
streams
and
for
minimizing
the
use
of
toxic
cleaning
agents.
Data
collection
and
recordkeeping
requirements
under
the
pollution
prevention
compliance
option
include
preparing
the
PMP
and
maintaining
records
to
demonstrate
compliance
with
the
procedures
and
provisions
of
the
PMP.
Records
will
be
stored
on
site,
and
there
are
no
reporting
requirements.
2
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
EPA
is
providing
an
alternative
pollution
prevention
compliance
option
to
reduce
pollutant
discharges
from
indirect
dischargers
in
Subparts
A
and
B
(
facilities
that
clean
tank
trucks,
intermodal
tank
containers,
and
rail
tank
cars
transporting
chemical
and
petroleum
cargos).

The
Transportation
Equipment
Cleaning
Effluent
Limitations
Guidelines
and
Standards
were
promulgated
under
the
authority
of
Sections
301,
304,
306,
307,
308,
402,
and
501
of
the
Clean
Water
Act,
33
U.
S.
C.
1311,
1314,
1316,
1317,
1342,
and
1361.

2(
b)
Practical
Utility/
Users
of
the
Data
The
primary
users
of
the
PMP
and
information
generated
as
required
by
the
PMPs
will
be
the
owners
and
operators
of
Subpart
A
and
B
facilities
that
choose
the
pollution
prevention
compliance
option.
These
data
will
be
used
to
demonstrate
compliance
with
the
regulation.

EPA
expects
that
the
PMP
and
recordkeeping
required
by
the
PMP
will
be
used
by
pretreatment
authorities
to
determine
compliance
with
the
procedures
and
provisions
required
by
the
PMP.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
EPA
has
examined
all
other
reporting
requirements
contained
in
the
Clean
Water
Act
and
40
CFR
Parts
122,
123,
124,
125,
501,
and
503.
The
Agency
has
also
consulted
other
sources
of
information
to
determine
if
similar
or
duplicative
information
is
available
elsewhere.
These
examinations
have
revealed
no
duplicative
reporting
requirements.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
EPA
is
amending
the
table
of
currently
approved
information
collection
request
(
ICR)
control
numbers
issued
by
OMB
for
various
regulations.
The
amendment
updates
the
table
to
list
those
information
collection
requirements
promulgated
under
the
Effluent
Limitations
Guidelines,
Pretreatment
Standards,
and
New
Source
Performance
Standards
for
the
Transportation
Equipment
Cleaning
Point
Source
Category,
which
appeared
in
the
Federal
Register
on
August
14,
2000
(
65
FR
4966).
The
affected
regulations
are
codified
at
40
CFR
parts
442.15,
442.16,
442.25,
and
442.26.
EPA
will
continue
to
present
OMB
control
numbers
in
a
consolidated
table
format
to
be
codified
in
40
CFR
part
9
of
the
Agency's
regulations,
and
in
each
CFR
volume
3
containing
EPA
regulations.
The
table
lists
CFR
citations
with
reporting,
recordkeeping,
or
other
information
collection
requirements,
and
the
current
OMB
control
numbers.
This
listing
of
the
OMB
control
numbers
and
their
subsequent
codification
in
the
CFR
satisfies
the
requirements
of
the
Paperwork
Reduction
Act
(
44
U.
S.
C.
3501
et
seq.)
and
OMB's
implementing
regulations
at
5
CFR
part
1320.
This
ICR
was
previously
subject
to
public
notice
and
comment
prior
to
OMB
approval.
Due
to
the
technical
nature
of
the
table,
EPA
finds
that
further
notice
and
comment
is
unnecessary.
As
a
result,
EPA
finds
that
there
is
"
good
cause"
under
section
553(
b)(
B)
of
the
Administrative
Procedure
Act,
5
U.
S.
C.
553(
b)(
B),
to
amend
this
table
without
prior
notice
and
comment.

3(
c)
Consultations
During
Interagency
review
for
the
final
TEC
guidelines,
EPA
discussed
the
pollution
prevention
alternative
with
the
Office
of
Management
and
Budget,
the
Small
Business
Administration
Office
of
Advocacy,
and
industry
stakeholders
who
supported
promulgation
of
PMP.
The
Association
of
Metropolitan
Sewerage
Agencies
has
also
indicated
its
support
for
effective
pollution
prevention
practices
as
an
alternative
to
numeric
limits
for
Subpart
A
and
B
facilities.

3(
d)
Effects
of
Less
Frequent
Collection
Data
collection
frequency
will
specified
in
each
site­
specific
PMP.
Facilities
must
provide
information
on
cleaning
agents
used
and
must
maintain
appropriate
records
of
heel
management
procedures,
prerinse/
presteam
management
procedures,
cleaning
agent
management
procedures,
operator
training,
and
proper
operation
and
maintenance
of
any
pretreatment
system.

Some
facilities
do
not
use
chemical
cleaning
agents
and
do
not
clean
tanks
or
containers
that
last
contained
cargos
which
are
likely
to
result
in
discharges
of
pollutants
that
would
be
incompatible
with
treatment
at
a
POTW.
These
facilities
will
have
minimal,
if
any,
recurring
data
collection
requirements
specified
in
their
site­
specific
PMPs.
In
contrast,
other
facilities
use
toxic
chemical
cleaning
agents
and
routinely
clean
tanks
or
containers
that
last
contained
cargos
which
are
likely
to
result
in
discharges
of
pollutants
that
would
be
incompatible
with
treatment
at
a
POTW.
Site­
specific
PMPs
prepared
by
these
facilities
will
likely
require
collection
of
daily
cleaning
agent
use
and
incompatible
waste
stream
management
information.
Because
these
facilities
can
and
do
generate
incompatible
waste
streams
at
any
time,
less
frequent
data
collection
would
not
provide
the
information
necessary
to
prevent
pass
through,
interference,
and
sludge
contamination
at
POTWs.

3(
e)
General
Guidelines
This
information
collection
is
consistent
with
OMB
guidelines
contained
in
5
CFR
1320.5,
1320.6,
1320.8,
and
1320.12.
4
3(
f)
Confidentiality
EPA
does
not
expect
that
any
confidential
business
information
or
trade
secrets
will
be
required
from
TEC
facilities
as
part
of
this
ICR.
If
information
submitted
in
conjunction
with
this
ICR
were
to
contain
confidential
business
information,
the
respondent
has
the
authority
to
request
that
the
information
be
treated
as
confidential
business
information.
All
data
so
designated
will
be
handled
by
EPA
pursuant
to
40
CFR
Part
2.
This
information
will
be
maintained
according
to
procedures
outlined
in
EPA's
Security
Manual
Part
III,
Chapter
9,
dated
August
9,
1976.

3(
g)
Sensitive
Questions
The
reporting
requirements
addressed
in
this
ICR
do
not
include
sensitive
questions.
5
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
SIC
Codes
The
respondents
for
this
ICR
will
be
a
maximum
of
an
estimated
286
facilities
in
Subpart
A
(
Tank
Trucks
and
Intermodal
Tank
Containers
Transporting
Chemical
and
Petroleum
Cargos)
and
30
facilities
in
Subpart
B
(
Rail
Tank
Cars
Transporting
Chemical
and
Petroleum
Cargos).
EPA
estimates
approximately
25%
of
facilities
in
these
Subparts
will
choose
the
pollution
prevention
compliance
option.
There
is
no
single
SIC
code
or
set
of
SIC
codes
that
specifically
identify
facilities
that
perform
TEC
operations.
Examples
of
common
SIC
codes
for
facilities
in
these
Subparts
include
SIC
7699
(
Repair
Ships
and
Related
Services,
Not
Elsewhere
Classified)
and
SIC
4741
(
Rental
of
Railroad
Cars).

4(
b)
Information
Requested
The
pollution
prevention
compliance
option
at
40
CFR
442.15,
442.16,
442.25,
and
442.26
include
the
following
major
components:
(
1)
prepare
and
submit
a
statement
of
intent,
(
2)
prepare
and
submit
a
pollutant
management
plan,
(
3)
collect
information
and
maintain
records,
and
(
4)
perform
operator
training.

(
1)
Prepare
and
submit
a
statement
of
intent
[
40
CFR
442.15(
b)(
2),
442.16(
b)(
2),
442.25(
b)(
2),
442.26(
b)(
2)]

Owners
or
operators
who
choose
the
pollution
prevention
compliance
option
will
prepare
and
submit
to
their
local
control
authority
a
statement
of
intent
to
implement
a
PMP,
certified
by
a
responsible
corporate
officer.

(
2)
Prepare
and
submit
a
PMP
[
40
CFR
442.15(
b)(
1),
442.15(
b)(
3),
442.16(
b)(
1),
442.16(
b)(
3),
442.25(
b)(
1),
442.25(
b)(
3),
442.26(
b)(
1),
and
442.26(
b)(
3)]

Central
to
the
pollution
prevention
compliance
option
is
the
preparation
and
implementation
of
a
PMP.
The
PMP
is
intended
to
contain
the
procedures
and
provisions
the
facility
will
implement
to
reduce
pollutant
discharges
and
prevent
pass
through,
interference,
and
sludge
contamination
at
POTWs.
The
PMP
will
be
enforceable,
meaning
it
will
be
included
in
the
facility's
individual
control
mechanism
or
POTW
permit.
Owners
and
operators
will
keep
a
copy
of
the
PMP
on
site
to
demonstrate
compliance
with
the
rule.

According
to
40
CFR
442,
the
PMP
(
Plan)
will
include
the
following
components:

(
i)
procedures
for
identifying
cargos,
the
cleaning
of
which
is
likely
to
result
in
discharges
of
pollutants
that
would
be
incompatible
with
treatment
at
the
POTW;
6
(
ii)
for
cargos
identified
as
being
incompatible
with
treatment
at
the
POTW,
the
Plan
shall
provide
that
heels
be
fully
drained,
segregated
from
other
wastewaters,
and
handled
in
an
appropriate
manner;

(
iii)
for
cargos
identified
as
being
incompatible
with
treatment
at
the
POTW,
the
Plan
shall
provide
that
the
tank
be
prerinsed
or
presteamed
as
appropriate
and
the
wastewater
segregated
from
wastewaters
to
be
discharged
to
the
POTW
and
handled
in
an
appropriate
manner,
where
necessary
to
ensure
that
they
do
not
cause
or
contribute
to
a
discharge
that
would
be
incompatible
with
treatment
at
the
POTW;

(
iv)
all
spent
cleaning
solutions,
including
interior
caustic
washes,
interior
presolve
washes,
interior
detergent
washes,
interior
acid
washes,
and
exterior
acid
brightener
washes
shall
be
segregated
from
other
wastewaters
and
handled
in
an
appropriate
manner,
where
necessary,
to
ensure
that
they
do
not
cause
or
contribute
to
a
discharge
that
would
be
incompatible
with
treatment
at
the
POTW;

(
v)
provisions
for
appropriate
recycling
or
reuse
of
cleaning
agents;

(
vi)
provisions
for
minimizing
the
use
of
toxic
cleaning
agents
(
solvents,
detergents,
or
other
cleaning
or
brightening
solutions);

(
vii)
provisions
for
appropriate
recycling
or
reuse
of
segregated
wastewaters
(
including
heels
and
prerinse/
presteam
wastes);

(
viii)
provisions
for
off­
site
treatment
or
disposal,
or
effective
pretreatment
of
segregated
wastewaters
(
including
heels,
prerinse/
presteam
wastes,
spent
cleaning
solutions);

(
ix)
information
on
the
volumes,
content,
and
chemical
characteristics
of
cleaning
agents
used
in
cleaning
or
brightening
operations;
and
(
x)
provisions
for
maintaining
appropriate
records
of
heel
management
procedures,
prerinse/
presteam
management
procedures,
cleaning
agent
management
procedures,
operator
training,
and
proper
operation
and
maintenance
of
any
pretreatment
system.

(
3)
Collect
information
and
maintain
records
[
40
CFR
442.15(
b)(
5)(
ix),
442.15(
b)(
5)(
x),
442.16(
b)(
5)(
ix),
442.16(
b)(
5)(
x),
442.25(
b)(
5)(
ix),
442.25(
b)(
5)(
x),
442.26(
b)(
5)(
ix),
and
442.26(
b)(
5)(
x)]

Components
(
ix)
and
(
x)
of
the
PMP
will
specify
information
collection
and
recordkeeping
to
demonstrate
compliance
with
the
procedures
and
provisions
required
by
the
PMP.
For
7
example,
facilities
may
develop
and
maintain
logs
documenting
cleaning
agents
use,
heel
removal
and
management,
prerinse/
presteam
management,
cleaning
agent
management,
operator
training,
and
proper
operation
and
maintenance
of
any
pretreatment
system.

(
4)
Perform
operator
training
[
40
CFR
442.15(
b)(
5)(
x),
442.16(
b)(
5)(
x),
442.25(
b)(
5)(
x),
and
442.26(
b)(
5)(
x)]

Owners
or
operators
will
prepare
and
perform
operator
training
on
the
data
collection
and
recordkeeping
specified
in
the
PMP.

4(
c)
Respondent
Activities
Respondent
activities
include
the
following:


Preparing
basic
information.
This
includes
reviewing
regulatory
requirements,
preparing
and
submitting
a
statement
of
intent,
preparing
and
submitting
a
PMP,
and
collecting
information
as
specified
by
the
PMP.


Maintaining
records.
The
PMP
will
specify
provisions
for
maintaining
appropriate
records
of
heel
management
procedures,
prerinse/
presteam
management
procedures,
cleaning
agent
management
procedures,
operator
training,
and
proper
operation
and
maintenance
of
any
pretreatment
system.
Owners
or
operators
must
also
maintain
records
on
the
volumes,
content,
and
chemical
characteristics
of
cleaning
agents
used
in
cleaning
and
brightening
operations.
Records
will
be
maintained
and
stored
on
site
for
the
length
of
time
specified
by
the
PMP,
but
no
more
than
three
years.


Training
operators.
The
PMP
will
specify
provisions
for
performing
operator
training
on
maintaining
appropriate
records
of
cleaning
agent
use,
heel
management
procedures,
prerinse/
presteam
management
procedures,
and
cleaning
agent
management
procedures,
and
wastewater
treatment
operations
and
maintenance.

5.
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
owner
or
operator
retains
essentially
all
of
the
information
generated
and
provides
only
the
statement
of
intent
and
PMP
to
the
pretreatment
authority;
there
are
no
additional
reporting
requirements.
Agency
activities
associated
with
the
pollution
prevention
compliance
option
are
therefore
limited
to
review
and
incorporation
of
the
PMP
into
the
facility's
individual
control
mechanism
or
POTW
permit,
and
compliance
reviews.
8
5(
b)
Collection
Methodology
and
Management
The
pretreatment
authority
will
review
the
PMP
and
will
retain
the
authority
to
recommend
additional
or
incremental
procedures
as
necessary
to
prevent
pass
through,
interference,
and
sludge
contamination
at
POTWs
and
to
ensure
that
implementation
of
the
PMP
is
consistent
with
Clean
Water
Act
requirements.

5(
c)
Small
Entity
Flexibility
Pursuant
to
Section
605(
b)
of
the
Regulatory
Flexibility
Act,
the
EPA
Administrator
certifies
that
this
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
The
number
of
small
businesses
affected
by
the
rule
is
relatively
low
and
the
impact
is
modest
for
most
of
the
affected
small
businesses.

5(
d)
Collection
Schedule
The
information
collection
activities
included
in
this
ICR
are
anticipated
to
occur
under
the
following
schedule:


Submittal
of
a
statement
of
intent
to
implement
a
PMP:
Due
prior
to
renewing
or
modifying
the
facility
individual
control
mechanism
or
POTW
permit.


Submittal
of
a
PMP:
Due
at
the
time
the
facility
applies
to
renew
or
modify
the
individual
control
mechanism
or
POTW
permit.


Collect
information
and
maintain
records:
Performed
on
a
continual
basis.


Perform
operator
training:
Performed
on
a
continual
basis.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
Table
1
presents
estimates
of
the
respondent
burdens
for
labor
hours
and
costs
associated
with
this
ICR.
A
brief
description
of
the
basis
for
the
burden
estimates
is
presented
below.
All
estimates
are
based
on
best
professional
judgement.

(
1)
Prepare
and
submit
a
statement
of
intent
Owners
and
operators
will
need
to
make
an
initial
choice
of
how
to
comply
with
the
regulation.
Facility
owners
or
operators
will
read
the
Federal
Register
(
65
FR
49665),
Technical
Development
Document
(
EPA­
821­
R­
00­
012),
and/
or
Permit
Guidance
Document
to
learn
the
requirements
of
the
pollution
prevention
compliance
option
to
make
an
9
Table
1
Annual
Respondent
Burden
and
Cost
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Corp
Capital/
Number
Officer
Legal
Manager
Operator
Clerical
Resp.
Labor
Startup
O&
M
of
Total
Total
Information
Collection
Activity
$
67.71/
hr
$
59.78/
hr
$
34.46/
hr
$
27.66/
hr
$
18.99/
hr
hr/
yr
$/
yr
$
$
Resp.
hr/
yr
$/
yr
Prepare
and
submit
a
statement
of
intent
Read
the
regulations
and
supporting
documents
0.7
0.7
$
45.14
$
0.00
$
16.67
316
210.7
$
19,530.91
Prepare
and
submit
statement
of
intent
0.3
0.3
0.3
1.0
$
48.83
$
0.00
$
1.67
79
79.0
$
3,988.97
Prepare
and
submit
a
PMP
Prepare
and
submit
a
PMP
0.7
0.7
22.2
1.3
24.8
$
874.18
$
0.00
$
3.33
79
1,961.8
$
69,323.29
Collect
information
and
maintain
records
Develop
records
format
and
content
5.3
5.3
$
183.79
$
0.00
$
1.67
79
421.3
$
14,650.81
Collect
information
and
maintain
records
186.5
186.5
$
4,992.61
$
0.00
$
25.00
79
14,733.5
$
396,390.80
Perform
operator
training
Operator
training
6.0
16.0
22.0
$
635.08
$
0.00
$
5.00
79
1,738.0
$
50,566.32
Subtotal
1.7
1.0
33.5
202.5
1.7
240.3
$
6,779.62
$
0.00
$
53.33
varies
19,144.3
$
554,451.10
10
informed
choice.
Those
owners
or
operators
that
choose
the
pollution
prevention
compliance
option
will
need
to
prepare
and
submit
of
a
statement
of
intent
to
implement
a
PMP,
certified
by
a
responsible
corporate
officer.

Reading
the
portions
of
the
regulations
and
supporting
documents
specific
to
the
pollution
prevention
compliance
option
requires
an
estimated
2
hours
for
a
corporate
officer.
Preparing
and
submitting
the
statement
of
intent
requires
an
estimated
1
hour
for
a
corporate
officer,
1
hour
for
legal
council,
and
1
hour
for
a
clerk.
Burden
estimates
for
these
activities
are
a
one­
time
initial
burden;
therefore,
these
estimates
are
divided
by
three
for
use
in
Table
1
to
provide
an
average
burden
on
an
annual
basis
over
the
three­
year
period
of
this
ICR.

(
2)
Prepare
and
submit
a
PMP
Those
owners
or
operators
that
choose
the
pollution
prevention
compliance
option
will
need
to
prepare
and
submit
a
PMP.
This
is
a
one­
time
initial
burden.

This
activity
requires
an
estimated
66.5
hours
for
an
manager
review
available
cargo
identification
records,
meet
with
POTW
representatives
to
learn
incompatible
pollutants,
and
write
the
ten
components
of
the
PMP.
This
estimate
represents
an
average
facility
burden
with
owners
and
operators
that
choose
to
operate
end­
of­
pipe
wastewater
treatment
of
incompatible
wastes
requiring
higher
than
average
burden
and
those
that
choose
not
to
operate
end­
of­
pipe
wastewater
treatment
of
incompatible
wastes
requiring
lower
than
average
burden.
An
estimated
25%
of
owners
or
operators
are
expected
to
choose
to
operate
end­
of­
pipe
wastewater
treatment
of
incompatible
wastes.
Internal
review
of
the
draft
PMP
will
require
2
hours
for
a
corporate
officer
and
2
hours
for
legal
council.
Preparation
and
submittal
of
the
final
PMP
will
requires
4
hours
for
a
clerk.

(
3)
Collect
information
and
maintain
records
Components
(
ix)
and
(
x)
of
the
PMP
will
specify
information
collection
and
recordkeeping
to
demonstrate
compliance
with
the
procedures
and
provisions
required
by
the
PMP.
Recordkeeping
is
assumed
to
include
the
maintenance
of
the
following
operating
logs:
cleaning
agents
use,
heel
management,
prerinse/
presteam
management,
spent
cleaning
agent
management,
wastewater
treatment
system
operation,
wastewater
treatment
system
maintenance
and
repair,
and
wastewater
treatment
system
inspection.

An
estimated
16
hours
for
a
manager
are
required
to
design
the
format
and
content
of
the
information
log
sheets.
This
is
a
one­
time
initial
burden.

Information
collection
and
record
maintenance
are
recurring
activities
assumed
to
be
performed
by
equipment
operators.
An
estimated
2
hours
per
month
are
required
to
collect
information
and
maintain
records
for
cleaning
agents
use.
An
estimated
one­
half
hour
per
day
is
required
to
collect
information
and
maintain
records
for
heel
management,
prerinse/
presteam
11
management,
and
spent
cleaning
agent
management.
This
estimate
assumes
that
20%
of
tanks
cleaned
at
an
average
facility
last
contained
cargos
that
would
cause
or
contribute
to
a
discharge
that
would
be
incompatible
with
treatment
at
the
POTW.
Finally,
an
estimated
one­
half
hour
per
day
is
required
to
collect
information
and
maintain
records
for
wastewater
treatment
for
the
estimated
25%
of
owners
or
operators
that
choose
to
operate
end­
of­
pipe
wastewater
treatment
of
incompatible
wastes.

(
4)
Perform
operator
training
Owners
or
operators
will
prepare
and
perform
operator
training
on
the
data
collection
and
recordkeeping
specified
in
the
PMP.
An
estimated
4
hours
per
year
for
a
manager
are
required
to
prepare
and
perform
the
training,
and
an
additional
2
hours
per
year
for
a
manager
are
required
to
maintain
operator
training
records.
An
estimated
16
hours
per
year
for
operators
are
required
to
attend
training.
This
estimate
includes
an
allowance
for
operator
staff
turnover.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
Labor
costs
presented
in
Table
1
were
estimated
by
multiplying
the
estimated
burden
(
hours)
by
labor
rates
for
corporate
officer,
legal,
manager,
operator,
and
clerical.
The
labor
rate
for
an
operator
was
obtained
from
the
TEC
cost
model
used
to
estimate
compliance
costs
for
the
promulgated
rule,
after
adjusting
the
rate
to
2000
using
the
Chemical
Engineering
Plant
Cost
Index.
Labor
rates
for
the
remaining
categories
were
obtained
from
the
Bureau
of
Labor
Statistics
(
BLS).
Specifically,
rates
are
based
on
the
BLS
average
hourly
earnings
for
private
industry
(
Source:
National
Compensation
Survey:
Occupational
Wages
in
the
United
States,
1998)
increased
by
30
percent
to
account
for
benefits,
and
then
adjusted
to
2000
using
the
BLS
Employment
Cost
Index.
Labor
rates
used
to
estimate
labor
costs
are
summarized
below:


Corporate
officer
­
$
67.71
per
hour;


Legal
­
$
59.78
per
hour;


Manager
­
$
34.46
per
hour;


Operator
­
$
27.66
per
hour;
and

Clerical
­
$
18.99
per
hour.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
No
capital
costs
are
required
for
the
data
collection
and
recordkeeping
requirements
under
the
pollution
prevention
compliance
option.
Minor
operating
and
maintenance
costs
are
required
for
each
activity
as
described
below.
Estimates
are
based
on
best
professional
judgement.
12
(
1)
Prepare
and
submit
a
statement
of
intent
Operating
and
maintenance
costs
for
this
activity
include
$
50
to
acquire
hard
copies
of
the
regulation
and
supporting
documents
and
$
5
for
copying
and
postage
of
the
statement
of
intent.
These
are
one­
time
initial
costs.

(
2)
Prepare
and
submit
a
PMP
Operating
and
maintenance
costs
for
this
activity
include
$
10
for
copying
and
postage
of
the
PMP.
This
is
a
one­
time
initial
cost.

(
3)
Collect
information
and
maintain
records
Operating
and
maintenance
costs
for
this
activity
include
$
25
for
copying.
This
is
a
recurring
cost.

(
4)
Perform
operator
training
Operating
and
maintenance
costs
for
this
activity
include
$
5
for
copying.
This
is
a
recurring
cost.

6(
c)
Estimating
Agency
Burden
and
Cost
Table
2
presents
estimates
of
the
Agency
burdens
for
labor
hours
and
costs
associated
with
this
ICR.
EPA
estimates
a
burden
to
state
pretreatment
authorities
of
10
hours
per
facility
to
review
and
incorporate
the
PMP
into
the
facility's
individual
control
mechanism
or
POTW
permit.
This
is
a
one­
time
initial
burden.
EPA
estimates
an
additional
pretreatment
authority
burden
of
2
hours
per
year
to
perform
periodic
(
e.
g.,
annual
or
semi­
annual)
compliance
reviews.

U.
S.
Department
of
Labor
average
annual
salary
for
state
and
local
employees
is
$
41,185.
At
2,080
available
labor
hours
per
year,
the
hourly
rate
is
$
19.80.
Overhead
costs
for
state
and
local
employees
are
estimated
to
be
60%
(
EPA
ICR
Handbook),
or
$
11.88
per
hour,
which
results
in
a
total
hourly
rate
of
$
31.68
per
hour.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
regulated
community
includes
approximately
286
indirect
discharging
facilities
in
Subpart
A
and
30
indirect
discharging
facilities
in
Subpart
B.
EPA
assumes
that
all
regulated
facilities
will
evaluate
the
alternative
pollution
prevention
compliance
option
to
determine
whether
it
would
be
less
costly
that
complying
with
numerical
limits.
Based
on
discussions
with
industry
stakeholders
and
pretreatment
authorities,
EPA
assumes
that
25%
of
these
facilities
will
select
the
pollution
prevention
compliance
option.
13
Table
2
Annual
Agency
Burden
and
Cost
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Labor
Agency
Costs
Number
of
Total
Total
Information
Collection
Activity
$
31.68/
hr
$/
yr
Respondent
s
hr/
yr
$/
yr
Implement
new
pretreatment
conditions
3.3
$
105.60
79
263.3
$
8,342.40
Annual
onsite
record
review
2.0
$
63.36
79
158.0
$
5,005.44
Subtotal
5.3
$
168.96
varies
421.3
$
13,347.84
14
Total
burden
and
costs
by
activity
are
shown
in
Tables
1
and
2
for
respondents
and
EPA
based
on
the
assumed
respondent
universe.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
Table
Table
3
presents
the
bottom
line
burden
hours
and
costs
for
respondents
and
EPA.

Table
3.
Summary
of
Burden
and
Costs
to
Respondents
and
EPA
Category
Total
Labor
Hours
Total
Costs
Respondents
(
Subpart
A
and
B)
19,144
$
554,451
EPA
421
$
13,349
6(
f)
Reasons
for
Changes
in
Burden
Since
this
is
a
new
information
collection,
there
is
no
change
in
burden
for
this
collection.

6(
g)
Burden
Statement
For
the
TEC
pollution
prevention
compliance
option,
the
burden
is
estimated
to
average
240.3
hours
per
respondent
per
year.
This
estimate
includes
time
for
preparing
and
submitting
the
statement
of
intent,
preparing
and
submitting
the
PMP,
collecting
information
and
recordkeeping,
and
operator
training.
Agency
burden
is
estimated
to
average
5.3
hours
per
respondent
per
year.
This
estimate
includes
time
to
review
and
incorporate
the
PMP
into
the
facility's
individual
control
mechanism
or
POTW
permit
and
to
perform
compliance
reviews.

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;
15

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
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
Chapter
15.
