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.
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)