Information
Collection
Request
Supporting
Statement
for
Pollution
Prevention
Compliance
Alternative;
Transportation
Equipment
Cleaning
(
TEC)
Point
Source
Category
(
40
CFR
Part
442)

EPA
ICR
No.
2018.02
OMB
No.
2040­
0235
November
3,
2004
U.
S.
Environmental
Protection
Agency
Office
of
Water
1200
Pennsylvania
Avenue,
N.
W.
Washington,
D.
C.
20460­
0001
i
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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3
3(
a)
Nonduplication
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3
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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3
3(
c)
Consultations
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3
3(
d)
Effects
of
Less
Frequent
Collection
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3
3(
e)
General
Guidelines
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4
3(
f)
Confidentiality
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4
3(
g)
Sensitive
Questions
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4
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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4
4(
a)
Respondents
and
NAICS/
SIC
Codes
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4
4(
b)
Information
Requested
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5
(
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)]
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5
(
2)
Prepare
and
submit
a
Pollutant
Management
Plan
[
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)]
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5
(
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)]
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6
(
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)]
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7
4(
c)
Respondent
Activities
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7
5.
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
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8
5(
a)
Agency
Activities
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8
5(
b)
Collection
Methodology
and
Management
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8
5(
c)
Small
Entity
Flexibility
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8
5(
d)
Collection
Schedule
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8
ii
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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9
6(
a)
Estimating
Respondent
Burden
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9
(
1)
Prepare
and
submit
a
statement
of
intent
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9
(
2)
Prepare
and
submit
a
Pollutant
Management
Plan
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9
(
3)
Collect
information
and
maintain
records
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10
(
4)
Perform
operator
training
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10
(
5)
Pretreatment
Control
Authority
Implementation
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11
6(
b)
Estimating
Respondent
Costs
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11
6(
c)
Estimating
Agency
Burden
and
Cost
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12
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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12
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
TABLES
1.
Annual
Burden
and
Cost
for
Transportation
Equipment
Cleaning
Respondents
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15
2.
Annual
Pretreatment
Control
Authority
Burden
and
Cost
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16
3.
Summary
of
Burden
and
Costs
to
Respondents
and
Pretreatment
Control
Authorities
.
16
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
Information
Collection
Rule:
Pollution
Prevention
Compliance
Alternative;
Transportation
Equipment
Cleaning
Point
Source
Category
(
40
CFR
Part
442)
(
EPA
ICR
No.
2018.02
and
OMB
Control
Number
2040­
0235).

1(
b)
Short
Characterization/
Abstract
The
U.
S.
Environmental
Protection
Agency
(
EPA)
issued
a
final
guideline
for
the
Transportation
Equipment
Cleaning
(
TEC)
point
source
category
on
August
14,
2000
(
at
65
FR
49666).
An
initial
Information
Collection
Rule
(
ICR)
was
published
on
March
19,
2001.
This
document
serves
as
a
renewal
ICR
for
the
Pollution
Prevention
Compliance
Alternative.

The
final
TEC
rule
established
technology­
based
effluent
limitations
guidelines,
new
source
performance
standards,
and
pretreatment
standards
for
the
discharge
of
pollutants
into
waters
of
the
United
States
and
into
publicly
owned
treatment
works
by
existing
and
new
facilities
that
perform
transportation
equipment
cleaning
operations.
TEC
facilities
are
defined
as
those
facilities
that
generate
wastewater
from
cleaning
the
interior
of
tank
trucks,
closed­
top
hopper
trucks,
rail
tank
cars,
closed­
top
hopper
rail
cars,
intermodal
tank
containers,
tank
barges,
closedtop
hopper
barges,
and
ocean/
sea
tankers
used
to
transport
materials
or
cargos
that
come
into
direct
contact
with
the
tank
or
container
interior.
Facilities
that
do
not
engage
in
cleaning
the
interior
of
tanks
are
outside
the
scope
of
the
rule.

The
final
rule
included
a
regulatory
compliance
option
that
allows
certain
facilities
to
develop
a
Pollutant
Management
Plan
(
PMP)
in
lieu
of
meeting
numeric
standards.
The
PMP
is
only
available
to
indirect
dischargers
identified
under
Subparts
A
and
B
of
the
rule.
Subpart
A
covers
tank
trunks
and
intermodal
tank
containers,
while
Subpart
B
covers
rail
tank
cars.
EPA
estimates
approximately
10
new
facilities
per
year
(
9
in
Subpart
A
and
1
in
Subpart
B)
over
the
initial
rulemaking
estimate
of
316
facilities
that
transport
chemical
and
petroleum
cargos
(
i.
e.,
326
facilities
in
year
one,
336
facilities
in
year
two,
and
346
facilities
in
year
three
­
for
an
average
of
336
facilities
over
the
three
year
period
covered
by
this
ICR).
As
noted
in
Chapter
6,
approximately
25
percent
of
the
existing
316
facilities
(
79
facilities)
and
all
of
the
20
new
facilities
covered
by
Subparts
A
and
B
are
impacted
by
this
rule
(
for
a
total
of
99
facilities)
and
hence
are
included
in
this
ICR
supporting
statement.
EPA
estimates
that
15
of
these
new
facilities
will
only
incur
the
initial
burden
of
reading
and
understanding
the
regulations.
EPA
believes
that
development
and
implementation
of
a
PMP
is
an
effective,
alternative
method
of
reducing
pollutant
discharges
from
indirect
dischargers
in
these
subcategories.
Facilities
that
already
have
extensive
treatment
in
place,
however,
may
find
it
more
cost­
effective
to
comply
with
numeric
limits,
whereas
facilities
already
using
good
pollution
prevention
practices
may
find
the
PMP
compliance
alternative
more
cost­
effective.
2
The
PMP
includes
requirements
for
record
keeping
and
paperwork
that
were
not
previously
included
in
the
burden
estimate
for
the
TEC
industry.
The
initial
ICR
presented
estimates
of
the
burden
hours
and
costs
to
the
regulated
community
and
pretreatment
control
authorities
for
data
collection
and
recordkeeping
associated
with
implementing
the
pollution
prevention
compliance
option.

The
TEC
rule
requires
facilities
to
address
10
components
when
developing
a
PMP.
Facilities
must
identify
and
segregate
incompatible
waste
streams
which
might
include
heels
(
i.
e.,
tank
or
container
residuals),
pre­
rinse
or
pre­
stream
wastewater,
and
spent
cleaning
solutions
from
wastewater
discharged
to
a
publicly
owned
treatment
works
(
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.
Records
are
to
be
stored
on
site,
and
there
are
no
reporting
requirements.

This
ICR
also
estimates
burden
and
costs
for
pretreatment
control
authorities
(
i.
e.,
States
and
local
POTWs)
responsible
for
incorporating
these
PMP
requirements
into
discharge
permits
and
performing
routine
on­
site
reviews
of
applicable
procedures
and
records.
A
total
of
84
pretreatment
control
authorities
are
included.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
EPA
has
provided
an
alternative
pollution
prevention
compliance
option
to
reduce
pollutant
loadings
from
indirect
discharges
under
Subparts
A
and
B
(
facilities
that
clean
tank
trucks,
intermodal
tank
containers,
and
rail
tank
cars
transporting
chemical
and
petroleum
cargos).

The
Effluent
Limitations
Guidelines,
Pretreatment
Standards,
and
New
Source
Performance
Standards
for
the
Transportation
Equipment
Cleaning
Point
Source
Category
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,
1318,
1342,
and
1361.

2(
b)
Practical
Utility/
Users
of
the
Data
Subpart
A
and
B
dischargers
who
choose
to
develop
PMPs
as
a
compliance
option
will
be
the
primary
users
of
the
Plan
and
related
data
generated.

State
or
federal
pretreatment
approval
authorities
will
likely
use
the
PMP
and
related
records
when
making
compliance
determinations.
3
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
duplicate
information
is
available
elsewhere.
These
examinations
have
revealed
no
duplicate
reporting
requirements.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
Paperwork
Reduction
Act
(
44
U.
S.
C.
3501
et
seq),
EPA
solicited
comments
on
the
proposed
information
collection
in
the
Federal
Register
prior
to
submitting
this
renewal
ICR
to
the
Office
of
Management
and
Budget
(
69
FR
52883,
August
30,
2004).
No
comments
were
received.

3(
c)
Consultations
EPA
discussed
the
pollution
prevention
alternative
with
the
following
organizations:

$
Office
of
Management
and
Budget
$
Small
Business
Administration
Office
of
Advocacy
$
Association
of
Metropolitan
Sewerage
Agencies
$
Other
industry
stakeholders.

3(
d)
Effects
of
Less
Frequent
Collection
The
frequency
of
data
collection
is
site­
specific
and
is
to
be
articulated
in
each
PMP.
Facilities
must
provide
information
on
cleaning
agents
used
and
must
maintain
appropriate
records
of
heel
management
procedures,
pre­
rinse/
pre­
steam
management
procedures,
cleaning
agent
management
procedures,
operator
training,
and
proper
operation
and
maintenance
of
any
pretreatment
system.
Facilities
that
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
will
have
minimal,
if
any,
recurring
data
collection
requirements
specified
in
their
PMPs.
In
contrast,
facilities
that
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
will
have
more
significant
monitoring
and
reporting
requirements
in
their
PMPs.
For
example,
they
will
be
required
to
collect
information
on
daily
cleaning
agent
use
and
incompatible
waste
stream
management.
History
has
shown
that
these
facilities
may
generate
incompatible
waste
streams
at
any
time;
therefore,
less
frequent
data
collection
might
result
in
pass­
through,
interference
and
sludge
contamination
at
POTWs.
4
3(
e)
General
Guidelines
This
information
collection
is
consistent
with
Office
of
Management
and
Budget
guidelines
contained
in
5
CFR
1320.5,
1320.6,
1320.8,
and
1320.12.

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
may
request
that
the
information
be
treated
as
such.
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.
Pursuant
to
Section
308(
b)
of
the
CWA,
effluent
data
may
not
be
treated
as
confidential.

3(
g)
Sensitive
Questions
The
reporting
requirements
addressed
in
this
ICR
do
not
include
sensitive
questions.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents
and
NAICS/
SIC
Codes
The
regulated
community
includes
approximately
304
Subpart
A
facilities
(
Tank
Trucks
and
Intermodal
Tank
Containers
Transporting
Chemical
and
Petroleum
Cargos)
and
32
Subpart
B
facilities
(
Rail
Tank
Cars
Transporting
Chemical
and
Petroleum
Cargos),
for
a
total
of
336
facilities.
EPA
assumes
that
all
regulated
facilities
will
evaluate
the
alternative
pollution
prevention
compliance
option
to
determine
whether
it
would
be
less
costly
than
complying
with
numerical
limits.
Based
on
discussions
with
industry
stakeholders
and
pretreatment
control
authorities,
EPA
estimates
that
approximately
25
percent
of
these
facilities
will
select
the
pollution
prevention
compliance
option.
There
is
no
single
NAIC/
SIC
code
or
set
of
NAIC/
SIC
codes
that
specifically
identify
facilities
that
perform
TEC
operations.
Examples
of
common
SIC
codes
for
facilities
in
these
Subparts
include
SIC
4741
(
Rental
of
Railroad
Cars)
and
SIC
7699
(
Repair
Shops
and
Related
Services,
Not
Elsewhere
Classified).
There
are
no
directly
correlating
codes
under
the
North
American
Industrial
Classification
System
(
NAICS).
For
the
two
examples
provided
above,
SIC
4741
has
two
NAICS
codes
(
488211
and
532411)
associated
with
it
while
SIC
7699
has
20
NAICS
codes
associated
with
it.

In
addition,
this
ICR
estimates
84
pretreatment
control
authorities
are
covered,
including
activities
under
SIC
Code
4952
with
a
corresponding
NAICS
Code
of
221320.

4(
b)
Information
Requested
5
The
pollution
prevention
compliance
option
at
40
CFR
442.15,
442.16,
442.25,
and
442.26
includes
the
following
major
action
items:
(
1)
prepare
and
submit
a
statement
of
intent,
(
2)
prepare
and
submit
a
PMP,
(
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)]

Prior
to
renewing
or
modifying
its
individual
control
mechanism
or
pretreatment
agreement,
the
discharger
is
to
notify
the
local
control
authority
of
its
intent
to
achieve
the
pollution
prevention
option
through
implementation
of
a
PMP
by
submitting
a
certification
statement
signed
by
a
responsible
corporate
officer.

(
2)
Prepare
and
submit
a
Pollutant
Management
Plan
[
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
is
enforceable,
meaning
it
shall
be
included
in
the
facility's
individual
control
mechanism
or
POTW
permit.
Dischargers
are
to
maintain
a
copy
of
the
PMP
on­
site
to
demonstrate
compliance.

According
to
40
CFR
442,
the
PMP
is
to
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;

(
ii)
for
cargos
identified
as
being
incompatible
with
treatment
at
the
POTW,
procedures
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,
procedures
that
the
tank
be
pre­
rinsed
or
pre­
steamed
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)
procedures
that
all
spent
cleaning
solutions,
including
interior
caustic
washes,
interior
pre­
solve
washes,
interior
detergent
washes,
interior
acid
washes,
and
exterior
acid
brightener
washes
be
segregated
from
other
wastewaters
and
handled
6
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
pre­
rinse/
pre­
steam
wastes);

(
viii)
provisions
for
off­
site
treatment
or
disposal,
or
effective
pretreatment
of
segregated
wastewaters
(
including
heels,
pre­
rinse/
pre­
steam
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,
pre­
rinse/
pre­
steam
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)]

Dischargers
are
to
obtain
information
and
maintain
records
for
compliance
purposes
and
as
stipulated
under
components
(
ix)
and
(
x)
of
the
PMP.
As
noted
above,
facilities
may
develop
and
maintain
logs
documenting
the
use
of
cleaning
agents,
heel
management
procedures,
prerinse
pre­
steam
management
procedures,
cleaning
agent
management
procedures,
operator
training,
and
proper
operation
and
maintenance
of
any
pretreatment
system.
7
(
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)]

Dischargers
are
to
train
operators
on
the
data
collection
and
recordkeeping
requirements
specified
in
the
PMP.

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


Preparing
basic
information.
This
step
includes
reviewing
regulatory
requirements,
preparing
and
submitting
a
statement
of
intent,
preparing
and
submitting
a
PMP,
and
collecting
related
information.
These
activities
are
required
from
all
new
sources
subject
to
Subparts
A
and
B.


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


Training
operators.
Through
the
PMP,
the
discharger
is
to
specify
provisions
for
performing
operator
training
on
maintaining
appropriate
records
of
cleaning
agent
use,
heel
management
procedures,
pre­
rinse/
pre­
steam
management
procedures,
and
cleaning
agent
management
procedures,
and
wastewater
treatment
operations
and
maintenance.
These
activities
are
required
from
all
new
sources
subject
to
Subparts
A
and
B
opting
for
the
PMP
alternative.


Pretreatment
control
authority
implementation.
Pretreatment
control
authorities
(
i.
e.,
POTWs
or
States)
are
responsible
for
reviewing
and
incorporating
the
PMP
into
the
facility's
individual
control
mechanism
or
POTW
permit
and
for
conducting
compliance
reviews.
8
5.
THE
INFORMATION
COLLECTED:
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Dischargers
included
in
this
ICR
retain
most
of
the
information
generated
under
the
compliance
alternative
option
and
provide
only
a
Statement
of
Intent
and
PMP
to
pretreatment
control
authorities;
there
are
no
additional
reporting
requirements.
Therefore,
there
are
no
Agency
activities
necessary
beyond
any
existing
oversight
responsibilities
as
detailed
in
the
NPDES
Compliance
Assessment/
Certification
ICR
(
EPA
ICR
No.
1427.07,
OMB
Control
No.
2040­
0110).

5(
b)
Collection
Methodology
and
Management
The
pretreatment
control
authority
has
responsibility
for
reviewing
a
discharger's
PMP,
ensuring
that
its
implementation
is
consistent
with
Clean
Water
Act
requirements,
and
recommending
additional
or
incremental
procedures,
as
necessary,
to
prevent
pass
through,
interference,
and
sludge
contamination
at
POTWs.

5(
c)
Small
Entity
Flexibility
Pursuant
to
Section
605(
b)
of
the
Regulatory
Flexibility
Act,
the
EPA
Administrator
certified
as
part
of
the
rulemaking
that
this
rule
did
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
according
to
the
following
schedule:


Submit
Statement
of
Intent
to
implement
a
PMP:
Due
by
discharger
prior
to
having
its
individual
control
mechanism
or
POTW
permit
renewed
or
modified.


Submit
a
PMP:
Due
by
discharger
when
applying
to
renew
or
modify
its
individual
control
mechanism
or
POTW
permit.


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


Perform
operator
training:
Performed
by
discharger
on
a
continual
basis.
1These
documents
are
available
at
http://
www.
epa.
gov/
waterscience/
guide/
teci/.

9

Incorporate
PMP
requirements
into
control
mechanism:
Performed
by
pretreatment
control
authority
on
a
one
time
basis.


Perform
on­
site
records
review:
Performed
by
pretreatment
control
authority
on
a
regular
basis
(
annually
or
semi­
annually).

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
Table
1
presents
estimates
of
burden
and
costs
for
transportation
equipment
cleaning
respondents
associated
with
this
ICR.
Table
2
presents
estimates
of
pretreatment
control
authority
burden
for
burden
and
costs
associated
with
this
ICR.
A
brief
description
of
the
basis
for
these
estimates
is
presented
below.
All
estimates
are
based
on
best
professional
judgement.

(
1)
Prepare
and
submit
a
statement
of
intent
As
a
first
step,
dischargers
need
to
decide
how
they
are
going
to
comply
with
the
overall
regulations
for
the
TEC
point
source
category.
They
will
learn
of
the
requirements
and
those
of
the
pollution
prevention
compliance
option
through
a
review
of
the
Federal
Register
(
65
FR
49665),
EPA's
Technical
Development
Document
(
EPA­
821­
R­
00­
012,
June
2000)
and/
or
Permit
Guidance
Document
(
EPA­
821­
R­
01­
021,
March
2001).
1
Those
dischargers
choosing
the
pollution
prevention
compliance
option
will
need
to
prepare
and
submit
of
a
Statement
of
Intent
to
implement
a
PMP.
The
statement
needs
to
be
certified
by
a
responsible
corporate
officer.

EPA
estimates
it
will
require
2
hours
for
all
new
sources
(
20
respondents)
to
have
a
corporate
officer
read
the
applicable
portions
of
the
regulations
and
supporting
documents
specific
to
the
pollution
prevention
compliance
option.
For
the
25
percent
of
these
new
users
(
5
respondents)
that
select
this
option,
an
additional
burden
of
three
hours
(
one
hour
each
for
a
corporate
officer,
legal
council,
and
a
clerk)
will
be
required
to
prepare
and
submit
the
Statement
of
Intent.

(
2)
Prepare
and
submit
a
Pollutant
Management
Plan
Those
dischargers
that
choose
the
pollution
prevention
compliance
option
must
prepare
and
submit
a
PMP.
This
is
an
initial,
one­
time
burden.
This
activity
will
require
a
manager
66.5
hours
to
review
available
cargo
identification
records,
meet
with
POTW
representatives
to
learn
about
incompatible
pollutants,
and
write
the
10
components
of
the
Plan.
This
estimate
represents
an
average
facility
burden
of
(
1)
dischargers
who
choose
to
operate
end­
of­
pipe
wastewater
treatment
of
incompatible
wastes
which
require
higher
than
average
burden
and
(
2)
those
who
choose
not
to
operate
end­
of­
pipe
wastewater
treatment
of
incompatible
wastes
which
require
10
lower
than
average
burden.
An
estimated
25
percent
of
these
dischargers
are
expected
to
choose
to
operate
end­
of­
pipe
wastewater
treatment
of
incompatible
wastes.
EPA
estimates
that
it
will
require
a
corporate
officer
and
legal
council
2
hours
each
to
conduct
an
internal
review
of
the
draft
PMP,
and
it
will
require
a
clerk
4
hours
to
prepare
and
submit
the
final
Plan.
This
results
in
a
initial
one­
time
burden
of
74.5
hours
for
each
new
source
(
5
respondents)
opting
to
implement
the
PMP
alternative.

(
3)
Collect
information
and
maintain
records
Components
(
ix),
information
on
cleaning
agents,
and
(
x),
recordkeeping,
of
the
PMP
are
to
specify
provisions
that
enable
the
discharger
to
demonstrate
compliance.
Recordkeeping
is
assumed
to
include
the
maintenance
of
the
following
operating
logs:
cleaning
agent
use,
heel
management,
pre­
rinse/
pre­
steam
management,
spent
cleaning
agent
management,
wastewater
treatment
system
operation,
wastewater
treatment
system
maintenance
and
repair,
and
wastewater
treatment
system
inspection.

EPA
estimates
that
16
hours
will
be
required
by
a
manager
to
design
the
format
and
content
of
the
information
log
sheets.
This
estimate
is
a
one­
time
initial
burden
(
5
respondents).

Information
collection
and
record
maintenance
are
recurring
activities
assumed
to
be
performed
by
equipment
operators.
EPA
estimates
that
it
will
take
2
hours
per
month
for
dischargers
to
collect
information
and
maintain
records
for
cleaning
agent
use,
while
an
estimated
one­
half
hour
per
day
will
be
required
to
collect
information
and
maintain
records
for
heel
management,
pre­
rinse/
pre­
steam
management,
and
spent
cleaning
agent
management.
These
estimates
assume
that
20
percent
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,
EPA
estimates
that
one­
half
hour
per
day
will
be
required
to
collect
information
and
maintain
records
for
wastewater
treatment
for
the
estimated
25
percent
of
dischargers
who
to
operate
end­
of­
pipe
wastewater
treatment
of
incompatible
wastes.
This
results
in
an
annual
burden
of
186.5
hours
for
each
new
and
existing
source
(
79
existing
respondents
and
5
new
respondents)
opting
to
implement
the
PMP
alternative.

(
4)
Perform
operator
training
Dischargers
are
to
train
operators
on
the
data
collection
and
recordkeeping
requirements
specified
in
the
PMP.
EPA
estimates
that
this
task
will
require
a
manager
4
hours
per
year
to
prepare
and
perform
the
training
and
an
additional
2
hours
per
year
to
maintain
operator
training
records.
EPA
further
estimates
that
operators
will
require
16
hours
per
year
to
attend
training.
This
latter
estimate
includes
an
allowance
for
operator
staff
turnover.
This
results
in
an
annual
burden
of
22
hours
for
each
source
(
79
respondents)
opting
to
implement
the
PMP
alternative.

(
5)
Pretreatment
Control
Authority
Implementation
2National
Compensation
Survey:
Occupational
Wages
in
the
United
States,
1998,
U.
S.
Bureau
of
Labor
Statistics.

3
"
Table
6:
Employment
Cost
Index
(
Wages
&
Salaries
Only),
Private
Industry
Workers
By
Occupation
and
Industry
Group
(
Not
Seasonally
Adjusted),"
in
Employment
Cost
Index:
Historical
Listing,
July
29,
2004,
U.
S.
Bureau
of
Labor
Statistics,
available
at
http://
stats.
bls.
gov/
web/
echistry.
pdf.

11
EPA
estimates
a
burden
to
pretreatment
control
authorities
of
10
hours
per
new
source
(
5
respondents)
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
control
authority
burden
of
2
hours
per
year
to
perform
periodic
(
e.
g.,
annual
or
semi­
annual)
compliance
reviews
for
each
new
and
existing
source
opting
to
implement
the
PMP
alternative
(
84
respondents).

6(
b)
Estimating
Respondent
Costs
This
ICR
only
includes
labor
costs
associated
with
any
respondent
activities
as
EPA
has
determined
that
any
capital
or
operation
and
maintenance
costs
are
negligible.
Labor
costs
presented
in
Table
1
were
estimated
by
multiplying
the
estimated
burden
(
hours)
by
labor
rates
for
the
following
employment
categories:
corporate
officer,
legal,
manager,
operator,
and
clerical.
In
the
initial
ICR
(
2001),
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
U.
S.
Bureau
of
Labor
Statistics
(
BLS).
Specifically,
rates
were
based
on
BLS's
average
hourly
earnings
for
private
industry2
increased
by
30
percent
to
account
for
benefits
and
then
adjusted
to
2000
using
BLS's
Employment
Cost
Index.

For
the
current
version
of
the
ICR,
labor
rates
were
updated
to
2004
using
BLS's
Employment
Cost
Index.
3
The
BLS
has
changed
how
they
organize
and
report
occupational
data
since
the
previous
ICR.
They
now
organize
according
to
NAICS
codes
as
opposed
to
SIC
codes.
While
two
general
SIC
codes
were
identified
as
being
associated
with
the
TEC
rulemaking,
these
codes
do
not
directly
correspond
to
any
NAICS
codes.
Some
20
NAICS
codes
are
potentially
applicable
when
viewing
the
crosswalks
between
the
SIC
and
NAICS
documents.
For
the
purposes
of
this
ICR,
it
seemed
more
prudent
to
simply
escalate
the
rates
from
2000
to
2004
using
BLS's
Employment
Cost
Index.
A
summary
of
the
revised
labor
rates
is
provided
below:


Corporate
officer
­
$
75.46
per
hour;


Legal
­
$
66.62
per
hour;


Manager
­
$
38.40
per
hour;


Operator
­
$
30.83
per
hour;


Clerical
­
$
21.16
per
hour.
4"
Supplementary
Table
3.2:
State
and
Local
Government,
Selected
Occupations:
Mean
Hourly
Earnings
and
Percentiles,
Full­
time
Workers,"
National
Compensation
Survey:
Occupational
Wages
in
the
United
States,
July
2003,
U.
S.
Bureau
of
Labor
Statistics,
available
at
http://
stats.
bls.
gov/
ncs/
ocs/
sp/
ncbl0636.
pdf.

12
The
Bureau
of
Labor
Statistics
estimates
the
average
hourly
rate
for
all
full­
time
white
collar
state
and
local
employees
(
excluding
sales
personnel)
to
be
$
25.44.4
At
2,080
hours
per
year,
this
equates
to
an
average
annual
salary
of
$
52,915.
Overhead
costs
for
state
and
local
employees
are
estimated
to
be
60
percent
(
EPA
ICR
Handbook),
or
$
15.26
per
hour,
which
results
in
a
total
hourly
rate
of
$
40.70
per
hour.

6(
c)
Estimating
Agency
Burden
and
Cost
There
is
no
Agency
burden
or
costs
related
to
the
activities
detailed
in
this
ICR.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
potential
regulated
community
includes
approximately
304
(
286
existing
and
18
new)
indirect
discharging
facilities
in
Subpart
A
and
32
(
30
existing
and
2
new)
indirect
discharging
facilities
in
Subpart
B.
EPA
assumes
that
all
new
regulated
facilities
will
evaluate
the
alternative
pollution
prevention
compliance
option
to
determine
whether
it
would
be
less
costly
than
complying
with
numerical
limits.
Based
on
discussions
with
industry
stakeholders
and
pretreatment
control
authorities,
EPA
estimates
that
25
percent
of
these
facilities
will
select
the
pollution
prevention
compliance
option
for
a
total
of
84
facilities
(
79
existing
sources
and
5
new
sources)
implementing
the
PMP
alternative.
In
addition,
all
20
new
facilities
will
incur
an
initial
burden
for
reading
and
understanding
the
regulations.
A
comparable
number
of
pretreatment
control
authorities
(
i.
e.,
84)
are
also
included
based
on
the
requirement
to
incorporate
appropriate
language
into
individual
control
mechanisms
(
i.
e.,
permits)
and
perform
routine
on­
site
reviews
of
procedures
and
records.

Total
burden
and
costs
by
activity
are
shown
in
Tables
1
and
2
for
transportation
equipment
cleaning
respondents
and
pretreatment
control
authorities
based
on
the
assumed
respondent
universe.
13
6(
e)
Bottom
Line
Burden
Hours
and
Costs
Table
Table
3
presents
the
bottom
line
burden
hours
and
costs
for
transportation
equipment
cleaning
respondents
and
pretreatment
control
authorities.

6(
f)
Reasons
for
Changes
in
Burden
Below
is
a
summary
of
the
changes
in
burden
between
the
previous
ICR
(
March
19,
2001)
and
this
revised
edition:

The
overall
annual
burden
and
costs
for
transportation
equipment
cleaning
respondents
decreased
from
19,144
hours
and
$
554,451
in
the
2001
ICR
to
17,684
hours
and
$
551,014
in
this
renewal,
for
a
total
decrease
of
1,460
hours
and
$
3,437.
This
decrease
was
due
primarily
to
the
reduction
in
number
of
new
facilities
required
to
evaluate
the
PMP
alternative
and
if
appropriate,
develop
a
PMP.
Annual
burdens
associated
with
each
facility
to
implement
the
PMP
(
i.
e.,
collect
information,
maintain
records,
and
train
operators)
is
consistent
with
the
previous
ICR.

The
overall
annual
pretreatment
control
authority
burden
and
costs
increased
from
zero
hours
in
the
2001
ICR
to
185
hours
and
$
7,515
in
this
renewal.
This
increase
accounts
for
burden
identified
in
the
2001
ICR
as
Agency
burden
that
is
actually
local
pretreatment
control
authority
respondent
burden.
It
is
these
local
pretreatment
control
authorities
that
are
responsible
for
incorporating
these
provisions
into
a
control
mechanism
(
i.
e.,
a
discharge
permit).

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
98
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
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.

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
No.
OW­
2004­
0029,
which
is
available
for
public
viewing
at
the
Water
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
14
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
Water
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OW­
2004­
0029)
and
OMB
control
number
(
2040­
0235)
in
any
correspondence.
5Many
of
the
burden
estimates
reflect
a
one­
time,
initial
burden
that
have
been
divided
by
three
for
purposes
of
the
table
to
provide
an
average
burden
on
an
annual
basis
over
the
three­
year
period
of
this
ICR.
Collecting
information,
maintaining
records,

and
operator
training
reflect
actual
annual
burdens.
15
Table
1
Annual
Burden
and
Cost
for
Transportation
Equipment
Cleaning
Respondents
2004
to
2007
Hours
and
Costs
Per
Respondent5
Total
Hours
and
Costs
Corp
Number
Officer
Legal
Manager
Operator
Clerical
Resp.
Labor
of
Total
Total
Information
Collection
Activity
$
75.46/
hr
$
66.62/
hr
$
38.40/
hr
$
30.83/
hr
$
21.16/
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
$
52.82
20
14
$
1,056
Prepare
and
submit
statement
of
intent
0.33
0.33
0.34
1
$
54.08
5
5
$
270
Prepare
and
submit
a
PMP
Prepare
and
submit
a
PMP
0.7
0.7
22.2
1.3
24.9
$
979.44
5
125
$
4,897
Collect
information
and
maintain
records
Develop
records
format
and
content
5.3
5.3
$
203.52
5
27
$
1,018
Collect
information
and
maintain
records
186.5
186.5
$
5,749.80
84
15,666
$
482,983
Perform
operator
training
Operator
training
6
16
22
$
723.68
84
1,848
$
60,789
Subtotal
1.73
1.03
33.5
202.5
1.64
240.4
$
7,763.34
99
17,684
$
551,014
16
Table
2
Annual
Pretreatment
Control
Authority
Burden
and
Cost
Hours
and
Costs
Per
Respondent
Total
Hours
and
Costs
Labor
Burden
Costs
Number
of
Total
Total
Information
Collection
Activity
$
40.70/
hr
$/
yr
Respondents
hr/
yr
$/
yr
Implement
new
pretreatment
conditions
3.33
$
135.53
5
16.65
$
677.66
Annual
onsite
record
review
2
$
81.40
84
168
$
6,837.60
Subtotal
5.33
$
216.93
84
184.65
$
7,515.26
Table
3.
Summary
of
Burden
and
Costs
to
Respondents
and
Pretreatment
Control
Authorities
Category
No.
Respondents
Total
Labor
Hours
Total
Costs
Respondents
(
Subpart
A
and
B)
99
17,684
$
551,014
Pretreatment
Control
Authorities
84
184.65
$
7,515.26
Total
183
17868.65
$
558,529.26
