Pursuant to 5
CFR 1320.11 the proposed revision of this collect- ion of
information is not approved. Prior to submission of the final rule,
EPA should clarify whether the respondent burden that will be borne
by contractors and outside consultants is con- tained in burden
hours or is monetized and included in operation and maintenance
cost. Burden that is borne by respondents' con- tractors should be
monetized and included as part of total annual costs, and not
included in the total hour burden. Also, EPA should provide written
clarification of the reduction in bur- den associated with plan
modification under section 112.5(a) that is attributed to the
proposed rule, both with respect to the average plant and in the
aggregate, and specifically address why this burden reduction
should apply to new sources. The ICR should support the assumption
that the proposed reduction in plan review frequency will yield a
proportionate reduction in burden under this section. In addition,
EPA should specifically address whether SPCC ICR requirements apply
to facilities containing oil-filled elec- trical equipment through
its revision of this ICR and in the final rule. OMB remains
concerned that application of SPCC requirements to such equipment
may lack practical utility. EPA is also reminded of OMB's request,
expressed in its 11/4/96 terms of clearance, that EPA consider
expanding the exemption from SPCC applicability to underground
storage tanks up to 84,000 gallons in order to avoid to duplicative
regulatory requirements under 40 CFR 280 and 40 CFR 112.
Inventory as of this Action
Requested
Previously Approved
10/31/1998
05/31/1998
10/31/1998
488,730
0
488,730
2,557,194
0
0
7,203,000
0
0
The oil pollution prevention
regulation requires certain regulated facilities to prepare and
maintain SPCC plans in order to prevent oil discharges and control
discharges when they occur.
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.