When this ICR is renewed, EPA should review the respondent burden, universe, labor rates, and capital costs and ensure these estimates have been updated.
Inventory as of this Action
Requested
Previously Approved
07/31/2016
36 Months From Approved
07/31/2013
2,500
0
3,727
46,642
0
224,339
910,733
0
692,400
The affected entities are subject to the General Provisions of the NESHAP at 40 CFR part 63, subpart A, and any changes, or additions to the Provisions specified at 40 CFR part 63, subpart HH. Owners or operators of the affected facilities must submit initial notification, performance tests, and periodic reports and results. Owners or operators 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. Reports, at a minimum, are required semiannually.
This ICR combines the requirements from the existing regulations and the 2012 amendment, which are EPA ICR Number 1788.09 and 2440.02, respectively. The 2012 rule amended title 40, chapter I, part 63 subpart HH to include emission sources for which standards were not previously developed. This results in an increase in the number of affected major sources. The amendment did not affect the number of area sources.
Several changes were made to this ICR: 1) A correction in the estimated number of respondents based on recent data obtained during development of the 2012 rule amendment; 2) Inclusion of requirements associated with the 2012 amendment, including affirmative defense; and 3) Update to labor rates used in calculating burden estimates. The changes result in an overall decrease in the labor hours and costs and an increase in the total capital and O&M costs as currently identified in the OMB Inventory of Approved Burdens. The current OMB Inventory adds the burden from EPA ICR Number 1788.09 and 2440.02, double counting the burden associated with several requirements. This ICR has been updated to remove any duplicates and to correctly reflect the revised standard.
The EPA estimate for the required notification, reports and records, including the root cause analysis, associated with a single affirmative defense incident totals $3,261 and is based on the time and effort required for a source to review relevant data, interview plant employees, and document the events surrounding a malfunction that has caused an exceedance of an emission limit. The estimate also includes time to produce and retain records and reports for submission to the EPA. For the purpose of estimating the annual burden, the EPA is attributing a total of 39 instances of affirmative defense over a 3 year period across all sources in the category. The EPA is using this frequency because among the number of excess emission events reported by source operators, only a small number would be expected to result from a malfunction, and only a subset of excess emissions caused by malfunctions would result in the source choosing to assert affirmative defense. Thus we believe the number of instances in which source operators may be expected to avail themselves of the affirmative defense will be extremely small.
$244,404
No
No
No
No
No
Uncollected
Learia Williams 202 564-4113 williams.learia@epa.gov
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
1788ss10.docx
NESHAP for Oil and Natural Gas Production (40 CFR part 63, subpart HH)