1541ss12

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal), EPA ICR Number 1541.12, OMB Control Number 2060-0183.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Benzene Waste Operations (40 CFR Part 61, Subpart FF) were proposed on September 14, 1989, and promulgated on March 7, 1990. These regulations apply to existing facilities and new facilities that generate waste containing benzene, such as chemical manufacturing plants, coke by‑product recovery plants, petroleum refineries, and those owners and operators of hazardous waste treatment, storage, and disposal facilities (TSDF) that receive wastes from the above facilities. New facilities include those that either commenced construction or modification after the date of proposal. This information is being collected to assure compliance with 40 CFR Part 61, Subpart FF.

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

Any owner/operator subject to the provisions of this part shall maintain a file containing these documents, and retain the file for at least two years following the generation date of such maintenance reports and records. All reports are sent to the delegated state or local authority. If there is no such delegated authority, the reports are sent directly to the U.S. Environmental Protection Agency (EPA) regional office.

The ‘burden’ to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost – Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal). The Federal Government’s ‘burden’ is attributed entirely to work performed by either Federal employees or government contractors and may be found below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal). There are approximately 270 facilities, which are owned and operated by the benzene waste industry. None of the 270 facilities in the United States are owned by either state, local, tribal or the Federal government. They are all owned and operated by privately-owned, for-profit businesses. We assume that they will all respond to EPA inquiries.

Based on our consultations with industry representatives, there are an average of 270 affected facilities at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site).

Over the next three years, approximately 270 respondents per year will be subject to these standards, and no additional respondents per year will become subject to these same standards. Of the 270 sources, we estimate 135 sources have a total annual benzene (TAB) waste quantity greater than 10 MG/yr.

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

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory of major sources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of hazardous air pollutants and shall require the maximum degree of emission reduction. In addition, section 114(a) states that the Administrator may require any owner/operator subject to any requirement of this Act to:

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

In the Administrator's judgment, benzene emissions from benzene waste operations either cause or contribute to air pollution that may reasonably be anticipated to endanger public health and/or welfare. Therefore, the NESHAP were promulgated for this source category at 40 CFR Part 61, Subpart FF.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in these standards ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings.

Performance tests are required in order to determine an affected facility’s initial capability to comply with the emission standard. Continuous emission monitors are used to ensure compliance with the standards at all times. During the performance test a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor.

The notifications required in these standards are used to inform the Agency or delegated authority when a source becomes subject to the requirements of these regulations. The reviewing authority may then inspect the source to check if the pollution control devices are properly installed and operated, leaks are being detected and repaired, and the standards are being met. The performance test may also be observed.

The required quarterly and annual reports are used to determine periods of excess emissions, identify problems at the facility, verify operation/maintenance procedures and for compliance determinations.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 61, Subpart FF.

3(a) Non-duplication

If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency. If a state or local agency has adopted its own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published in the Federal Register (82 FR 29552) on June 29, 2017. No comments were received on the burden published in the Federal Register for this renewal.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the number of affected facilities and industry growth over the next three years. The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in these standards, is the Integrated Compliance Information System (ICIS). ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. The growth rate for the industry is based on our consultations with the Agency’s internal industry experts. Approximately 270 respondents will be subject to these standards over the three-year period covered by this ICR.

Industry trade association(s) and other interested parties were provided an opportunity to comment on the burden associated with these standards as they were being developed and these same standards has been reviewed previously to determine the minimum information needed for compliance purposes. In developing this ICR, we contacted Sage Environmental Consulting, at (866) 234-5768, and the American Fuel & Petrochemical Manufacturers (AFPM), at (202) 457-0480.

It is our policy to respond after a thorough review of comments received since the last ICR renewal, as well as to those submitted in response to the first Federal Register notice. In this case, no comments were received.

3(d) Effects of Less-Frequent Collection

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

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

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

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are gasoline distribution bulk terminals, bulk plants, pipeline facilities, and gasoline dispensing facilities. The United States Standard Industrial Classification (SIC) code for the respondents affected by the standards, and the corresponding North American Industry Classification System (NAICS) code are listed in the table below:

Standard (40 CFR Part 61, Subpart FF)	SIC Codes	NAICS Codes
Chemical Products Manufacturing	2812, 2813, 2816, 2819, 2821, 2822, 2823, 2824, 2833, 2834, 2835, 2836, 2841, 2842, 2843, 2844, 2851, 2861, 2865, 2869, 2873, 2874, 2875, 2879, 2891, 2892, 2893, 2895, 2899, 3087, 3861, 3952, 3999, 7389	325
Plastic Product Manufacturing	2671, 2673, 3069, 3081, 3082, 3083, 3084, 3085, 3086, 3088, 3089, 3996, 3999	3261
Petroleum Refineries	2911	32411
Iron and Steel Mills and Ferroalloy Manufacturing	3312, 3399	33111
Remediation Services	1799, 4959	56291
All Other Miscellaneous Waste Management Services	4959, 7699	562998
Administration of Air and Water Resource and Solid Waste Management Programs	9511	92411

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF).

A source must make the following reports:

Notifications/Reports
Notification and application of construction or modification.	§ 61.07
Notification of anticipated date of initial startup.	§ 61.09(a)(1)
Notification of actual startup.	§ 61.09(a)(2)
Source reporting and request for waiver of compliance	§ 61.10
Emission test and waiver of emission tests for flares and some waste incinerators	§ 61.13
Initial performance test results	§ 61.13(f)
Initial performance test	§ 61.13(c)
Demonstration of continuous monitoring system	§ 61.354(c)
Notification of physical or operational change which may increase the emission rate.	§ 61.15
Report that summarizes the regulatory status of each waste stream that contain benzene	§ 61.357(a)
Initial certification of necessary equipment and inspection tests	§ 61.357(d)(1)
Annual certification of benzene waste streams, benzene concentration, and benzene quantity determination	§ 61.357(b), (c), (d)(2)
Notification of election to comply with alternative requirements and certification of benzene waste streams, benzene concentration, and benzene quantity determination	§ 61.357(d)(4-5)
Quarterly reports certifying required inspections	§ 61.357(d)(6)
Quarterly reports when monitored parameters are exceeded	§ 61.357(d)(7)
Initial and quarterly reports of inspections during which detectable emissions or a problem is identified	§ 61.357(d)(8)
Notification of election to comply with standard	§ 61.357(e)
Initial and quarterly reports identifying all seal gap measurements that are outside limits	§ 61.357(g)

A source must keep the following records:

Recordkeeping
Monitoring requirements	§ 61.14
Monitoring of operation of treatment process or wastewater treatment	§ 61.354 (a), (b)
Monitoring of alternative operational or process parameters	§ 61.354(e)
Monitoring of affected facilities	§§ 61.343-349
Startup, shutdowns, malfunctions, periods where the continuous monitoring system is inoperative	§ 61.356(i), (j)
Emission test results and other data needed to determine emissions	§ 61.13(g)
Records of off-site shipment of waste	§ 61.356(c)
Records of control equipment engineering design	§ 61.356(d)
Records of engineering calculations, operating conditions, and performance tests	§ 61.356(e)
Records of detectable emissions from closed vent systems and control devices	§ 61.356(f)
Records of location, date and corrective actions for problems found during visual inspections	§ 61.356(g)
Records for each test of no detectable emissions	§ 61.356(h)
Operational records for each control device, treatment process, and wastewater treatment system	§ 61.356(i), (j)
Records are required to be retained for two years and they must be retained at the facility	§ 61.356(a)
Measurements and determinations of annual waste quantity, water content, and benzene concentration	§ 61.356(b)

Electronic Reporting

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

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate CMS for temperature, flow, concentration levels, or for pressure drop and liquid supply pressure for control device.

Perform initial performance test, Reference Method 18 and 21 test, and repeat performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

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

Transmit, or otherwise disclose the information.

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

5(a) Agency Activities

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

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) and ICIS.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properly installed and operated. Performance test reports are used by the Agency to discern a source’s initial capability to comply with the emission standards and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The annual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.

Information contained in the reports is reported by state and local governments in the ICIS Air database, which is operated and maintained by EPA's Office of Compliance. ICIS is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial and government-owned facilities. EPA uses ICIS for tracking air pollution compliance and enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. The EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for two years.

5(c) Small Entity Flexibility

The majority of the respondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the types of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced.

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is shown below in Table 1: Annual Respondent Burden and Cost – NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 below documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this ICR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of ‘Burden’ under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may neither conduct nor sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is estimated to be 19,500 hours (Total Labor Hours from Table 1 below). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $149.35 ($71.12 + 110%)

Technical $112.98 ($53.80 + 110%)

Clerical $54.81 ($26.10 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2017, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

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

The only costs to the regulated industry resulting from information collection activities required by the subject standard(s) are labor costs. There are no capital/startup or operation and maintenance costs.

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

The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported information. EPA's overall compliance and enforcement program includes such activities as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information.

The average annual Agency cost during the three years of the ICR is estimated to be $72,800.

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

Managerial $64.80 (GS-13, Step 5, $40.50 + 60%)

Technical $48.08 (GS-12, Step 1, $30.05 + 60%)

Clerical $26.02 (GS-6, Step 3, $16.26 + 60%)

These rates are from the Office of Personnel Management (OPM), 2017 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to Federal government employees. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately 270 existing respondents will be subject to these standards. It is estimated that no additional respondents per year will become subject to these same standards. The overall average number of respondents, as shown in the table below, is 270 per year.

The number of respondents is calculated using the following table that addresses the three years covered by this ICR:

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
Year	(A) Number of New Respondents 1	(B) Number of Existing Respondents	(C) Number of Existing Respondents that keep records but do not submit reports	(D) Number of Existing Respondents That Are Also New Respondents	(E) Number of Respondents (E=A+B+C-D)
1	0	270	0	0	270
2	0	270	0	0	270
3	0	270	0	0	270
Average	0	270	0	0	270

¹ New respondents include sources with constructed, reconstructed and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the average Number of Respondents over the three-year period of this ICR is 270.

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

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Annual report	270	1	0	270
Quarterly emission report 1	135	4	0	540
Notification of offsite facility 2	14	12	0	168
			Total	978

¹ It is estimated that 135 sources that have a total annual benzene (TAB) quantity waste between 1 Mg/yr and 10 Mg/yr must file an annual report. It is also estimated that 135 sources that have a TAB greater than 10 Mg/yr are required to comply with the control requirements and must also file quarterly reports.

² We have assumed that 10 percent of facilities (14) will choose to ship their waste offsite once a month for treatment.

The number of Total Annual Responses is 978.

The total annual labor costs are $2,130,000. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal).

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown below in Tables 1 and 2, respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 19,500 hours. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost – NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 20 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $0. The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 1,550 labor hours at a cost of $72,800; see below in Table 2: Average Annual EPA Burden and Cost – NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical tasks because the typical tasks for managers are to review and approve reports. Clerical burdens are assumed to take 10% of the time required for technical tasks because the typical duties of clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is an adjustment increase in the total estimated ‘burden’ as currently identified in the OMB Inventory of Approved Burdens. This increase is not due to any program changes, but reflects the addition of burden hours to account for the time spent by existing facilities to re-familiarize themselves annually with the rule requirements.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 20 hours per response. ‘Burden’ means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information either 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 neither conduct nor sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OECA-2014-0046. An electronic version of the public docket is available at http://www.regulations.gov/, which may be used to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. When in the system, select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the docket center is (202) 566-1752. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OECA-2014-0046 and OMB Control Number in any correspondence.

Part B of the Supporting Statement

This part is not applicable because no statistical methods were used in collecting this information.

Table 1: Annual Respondent Burden and Cost – NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal)

Burden item		(A) Person hours per occurrence			(B) No. of occurrences per respondent per year			(C) Person hours per respondent per year (AxB)			(D) Respondents per year a				(E) Technical person- hours per year (CxD)			(F) Management person hours per year (Ex0.05)				(G) Clerical person hours per year (Ex0.1)			(H) Total Cost Per year b
1. Applications		N/A
2. Surveys and studies		N/A
3. Reporting requirements
A. Familiarization with regulatory requirements		1			1			1			270				270			14				1			$32,387.72
B. Required activities		See 3C
C. Create information
i. Determine quantity of benzene in waste l		2			1			2			0				0			0				0			$0
ii. Initial waste determination l		2			1			2			0				0			0				0			$0
iii. Treatment performance evaluation l		2			1			2			0				0			0				0			$0
iv. Annual waste determination c, d		2			1			2			270				540			27				54			$67,661.19
v. Monthly treated waste analysis e, f		1			12			12			14				168			8.4				17			$21,050.15
vi. Treatment/control device monitoring		See 4C
vii. Initial visual inspection l		2			1			2			0				0			0				0			$0
viii. Quarterly visual inspection g		2			4			8			135				1,080			54				108			$135,322.38
ix. Annual method 21 monitoring h		6			1			6			135				810			40.5				81			$101,491.79
D. Gather existing information		See 3E
E. Write report
New source
Notification of const/reconstruction		N/A
Notification of anticipated/actual startup		N/A
Notification/report of performance test		N/A
Existing sources
Initial report		N/A
Quarterly emission report		4			4			16			135				2,160			108				216			$270,644.76
Annual report		1			1			1			270				270			13.5				27			$33,830.60
Notification of offsite facility i		2			12			24			14				336			16.8				33.6			$42,100.30
Subtotal for Reporting Requirements															6,453										$704,489
4. Recordkeeping requirements
A. Familiarization with regulatory requirements		See 3A
B. Plan activities		See 4C
C. Implement activities
i. Filing and maintain records j		78			1			78			135				10,530			526.5				1,053			$1,319,393.21
ii. Concentration data (annual benzene quantity determination) k		0.5			12			6			121				726			36.3				72.6			$90,966.71
iii. Concentration data		0.5			12			6			14				84			4.2				8.4			$10,525.07
iv. Waste quantity data l		1			1			1			0				0			0				0			$0
D. Develop record system		See 4C
E. Time to enter information		See 4C
F. Train Personnel		N/A
G. Audits		N/A
Subtotal for Recordkeeping Requirements															13,041										$1,420,885
TOTAL LABOR BURDEN AND COSTS (rounded): m															19,500										$2,130,000
TOTAL CAPITAL and O&M COST: m																									$0
GRAND TOTAL (rounded): m																									$2,130,000
	Assumptions:
	a We have assumed that the average number of respondents that will be subject to this rule will be 270. There will be no additional new sources that will become subject to the rule over the three-year period of the ICR. It is estimated that 135 sources that have a total annual benzene (TAB) quantity waste between 1 Mg/yr and 10 Mg/yr must file an annual report. It is also estimated that 135 sources that have a TAB greater than 10 Mg/yr required to comply with the control requirements must file quarterly reports.
	b This ICR uses the following labor rates: $149.35 per hour for Executive, Administrative, and Managerial labor; $112.98 per hour for Technical labor, and $54.81 per hour for Clerical labor. 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.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
	c We have assumed that it will take each respondent two hours once per year to create the annual waste determination.
	d We have assumed that all facilities above 1 Mg/yr must evaluate waste streams annually for TAB.
	e We have assumed that it will take one hour each month for each respondents to create the monthly treated waste analysis information (0.5 hours for collection activities for all samples and 0.5 hours per sample for analysis for a total of 1 hour per sample).
	f We have assumed that 90 percent of 135 sources (121) will monitor process parameters, and the remaining 10 percent (14) must conduct monthly sampling.
	g We have assumed that 135 facilities that are expected to be greater than 10 Mg per year must comply with the quarterly visual inspection requirements.
	h We have assumed that 135 respondents will each take six hours once per year to comply with the annual method 21 monitoring requirements.
	i We have assumed that 10 percent of facilities (14) will choose to ship their waste offsite once a month for treatment.
	j We have assumed that 135 respondents will take 78 hours once per year to comply with the record requirements.
	k We have assumed that 121 respondents will take 30 minutes twelve times per year to repeat the benzene quantity determination.
	l We have assumed that this is a one-time only activity.
	m Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.

Table 2: Average Annual EPA Burden and Cost – NESHAP for Benzene Waste Operations (40 CFR Part 61, Subpart FF) (Renewal)

Burden item	(A) Person hours per occurrence		(B) No. of occurrences per respondent per year		(C) Person hours per respondent per year (AxB)		(D) Respondents per year a		(E) Technical person- hours per year (CxD)		(F) Management person hours per year (Ex0.05)			(G) Clerical person hours per year (Ex0.1)		(H) Total Cost Per year b
Initial performance tests	N/A
Report Review	N/A
New Plant
Notification of construction c	2		1		2		0		0		0			0		$0
Notification of anticipated startup	N/A
Notification of actual startup	N/A
Initial report	N/A
Notification of performance test	N/A
Existing Plants
Quarterly reports d	2		4		8		135		1,080		54			108		$58,235.76
Annual recertification e	1		1		1		270		270		13.5			27		$14,558.94
TOTAL (rounded) f									1,550							$72,800
Assumptions:
a We have assumed that the average number of respondents that will be subject to this rule will be 270 and there will be no additional new sources that will become subject to the rule over the three-year period of the ICR. It is estimated that 135 sources that have a total annual benzene (TAB) quantity waste between 1 Mg/yr and 10 Mg/yr must file an annual report. It is also estimated that 135 sources that have a TAB greater than 10 Mg/yr and have complied with the control requirements must file quarterly reports.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: $62.80 for Managerial (GS-13, Step 5, $40.50 x 1.6), $48.08 for Technical (GS-12, Step 1, $30.05 x 1.6), and $26.02 Clerical (GS-6, Step 3, $16.26 x 1.6). These rates are from the Office of Personnel Management (OPM) “2015 General Schedule” which excludes locality rates of pay.
c We have assumed that this is a one-time activity for each new facility.
d We have assumed that the Agency will review quarterly reports for 135 respondents.
e It is assumed that it will take one hour per year to review the annual recertification from each respondent.
f Totals have been rounded to 3 significant values. Figures may not add exactly due to rounding.