1

SF-83 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Equipment Leaks of VOC in Petroleum Refineries

(40 CFR Part 60, Subpart GGG)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR part 60, subpart 

GGG)

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Equipment Leaks of VOC (Volatile 

Organic Compound) in Petroleum Refineries were proposed on January 4, 1983, and promulgated 

on May 30, 1984. These standards apply to the following facilities in petroleum refineries: 

compressors and the group of all equipment (e.g., valves, pumps, flanges, etc.) within a process 

unit in VOC service, commencing construction, modification or reconstruction after the date of 

proposal. This information is being collected to assure compliance with 40 CFR part 60, subpart 

GGG.

Owners or operators of the affected facilities described must make the following one-time 

only reports: notification of the date of construction or reconstruction; notification of the actual 

date of startup; notification of any physical or operational change to an existing facility which may

increase the regulated pollutant emission rate; notification of the date of the initial performance 

test; and the results of the initial performance test. 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. 

Monitoring requirements specific to Equipment Leaks of VOC in Petroleum Refineries provide 

information regarding which components are leaking VOCs. NSPS subpart GGG references the 

compliance requirements of NSPS subpart VV. On a periodic basis, which varies depending on 

equipment type and leak history, owners or operators are required to record: 1) information 

identifying leaking equipment and 2) repair methods used to stop the leaks, and 3) dates of repair. 

Semiannual reports are required to measure compliance with the standards of NSPS subpart VV as 

referenced by NSPS subpart GGG. In general, these notifications, reports and records are required 

of all sources subject to NSPS.

Any owner or operator subject to the provisions of this part will maintain a file of these 

records, and retain the file for at least two years following the date of such records. All reports are 

sent to the delegated state or local authority. In the event that there is no such delegated authority, 

the reports are sent directly to the EPA regional office.

In the development of this Information Collection Request (ICR), we reviewed the Office 
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of Management and Budget (OMB) “Terms of Clearance” (TOC) section on the active ICR. 

There were no comments in the TOC section.

We have determined that there are approximately 148 petroleum refiners would have at 

least one process unit (affected facility) subject to the monitoring, recordkeeping and reporting 

requirements of NSPS subpart GGG/VV. Due to consolidation of several industry refiners, we 

have further assumed that no new sources are expected to become subject to the standard over the 

next three years. These assumptions were made based on information available on EPA’s database 

system and consultation with the industry sector leads at the Office of Air Quality Planning and 

Standards (OAQPS) and the National Petroleum Refiners Association. This research resulted in a 

significantly higher number of sources (100 more sources) being accounted for in the burden 

calculation for the renewal of this ICR and, therefore, reflects a more accurate estimate.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The Clean Air Act (Act) provides authority to the Agency to establish standards to control 

air pollution and to ensure compliance with promulgated regulations through adequate 

recordkeeping and reporting by the affected industries (i.e., respondents). The regulations include 

the New Source Performance Standards (NSPS) under section 111 of the Act, the National 

Emission Standards for Hazardous Air Pollutants ( NESHAP) which includes the original 

NESHAP standards and the more recent Maximum Achievable Control Technology (MACT) or 

NESHAP-MACT standards under section 112 of the Act, and emission guidelines for the 

designated types incinerators under section 129 of the Act.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard(s) are used by regulatory

agencies, the public and the regulated community for a variety of reasons including the 

determination of the respondent’s compliance status, analytical studies to demonstrate compliance 

trends, and evaluations regarding the efficacy of the promulgated regulations.

The required recordkeeping and reporting are also used to: 1) certify compliance with the 

regulations; 2) determine the respondent’s compliance with the designated emission limitation(s); 

3) notify regulatory agencies when a standard is violated; 4) evaluate continuous compliance 

through the use of emission or operational parameter monitors; and 5) ensure that plant personnel 

are following the required procedures and are periodically trained, as indicated.

3. Nonduplication, Consultations, and Other Collection Criteria

3(a) Nonduplication

The standards do not require the duplication in the collection and reporting of information. 

If the subject standards have not been delegated, the information is sent directly to the appropriate 
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Environmental Protection Agency (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.

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 (70 FR 24020) on May 6, 2005. No comments were received on the burden 

published in the Federal Register.

3(c) Consultations

We have reviewed our internal data sources and discussed the industry growth rate with the 

rule contacts for this industry category at the EPA’s Office of Air Quality Planning and Standards 

(OAQPS) and Norbert Dee of the National Petrochemical and Refiners Association in Washington, 

D.C., at (202) 457-0480. In addition, the Agency has initiated additional reviews on the sector to 

evaluate any residual risk from this regulation and determine if there is a need to change any of the 

monitoring, recordkeeping and reporting requirements of this rule.

3(d) Effects of Less Frequent Collection

The effect of less frequent collection would be a decrease in the margin of assurance that 

facilities are achieving the emission reductions mandated by the CAA through the promulgation of 

the applicable regulations. In addition, the likelihood of detecting the poor operation and 

maintenance of control equipment decreases and the detection of noncompliance becomes 

problematic.

3(e) General Guidelines

Neither the reporting nor recordkeeping requirements violate the regulations established by

Office of Management and Budget (OMB) at 5 CFR part 1320, section 1320.5. This NSPS 

standard requires respondents to maintain all records, including reports and notifications, for two 

years. Less frequent information collection would decrease the margin of assurance that facilities 

are continuing to meet the required 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 likelihood of detecting poor operation and maintenance of control 

equipment and noncompliance would decrease.

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 (see 40 CFR 2; 41 FR 36902, September 1, 1976; 
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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 recordkeeping and reporting requirements do not contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The Standard Industrial Classification (SIC) codes and corresponding North American 

Industry Classification System (NAICS) for the respondents are listed below.

Regulation SIC Codes NAICS Codes

NSPS for Equipment Leaks of 

VOC in Petroleum Refineries (40 

CFR Part 60, subpart GGG)

SIC 2911 NAIC 324110

This table is not meant to be exhaustive, but rather provides a guide for readers regarding the 

entities likely to be regulated by this standard. To determine whether the standard applies to a 

particular entity, review the applicability provisions in the standard.

4(b) Information Requested

(i) Data Items

All data in this ICR that is recorded and/or reported is required by 40 CFR part 60, subpart 

XX Bulk Gasoline Terminals.

A source must make the following reports:

Notification Reports

Notification of construction or reconstruction 40 CFR 60.7(a)(1)

Notification of anticipated date of initial startup 40 CFR 60.7(a)(2)

Notification of actual date of initial startup 40 CFR 60.7(a)(3)

Notification of physical or operational change 40 CFR 60.7(a)(4)

Maintain records of startups, shutdowns or malfunctions. 40 CFR 60.7(b)

Notification of performance test. 40 CFR 60.8(d)

Reports

Report of performance tests 40 CFR 60.8(a), 

40 CFR 487(e)

Comply with the provisions of NSPS subpart VV at 40 CFR 60.487 40 CFR 60.592(e)
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Reports

Semiannual reports 40 CFR 60.486, 40 

CFR 60.487(a-c)

A source must maintain the following records:

Recordkeeping 

Startups, shutdowns, malfunctions 60.7(b)

All measurements, monitoring device, and performance testing 

measurements

60.7(e)

Comply with the provisions of 60.486 60.592(e)

Each detected leak shall be recorded in a log and kept for 2 years 60.486(c)

Information pertaining to design requirements or closed vent systems 

and control devices

60.486(d)

Information pertaining to all equipment 60.486(e)

Information pertaining to all valves 60.486(f)

Information pertaining to valves complying with alternative 

compliance requirements

60.486(g)

Design criteria and any changes 60.486(h)

Records for use in determining exemptions 60.486(i)

Information and data to demonstrate that a piece of equipment is not in 

VOC service

60.486(j)

Electronic Reporting

At the present, many respondents to CAA standards use monitoring equipment that 

automatically records parameter data. Although personnel at the affected facility must evaluate the 

data, this internal automation has significantly reduced the burden associated with monitoring and 

recordkeeping at the plant site.

Also regulatory agencies, in cooperation with the respondents, continue to create reporting 

systems to transmit data electronically. However, electronic reporting systems are still not widely

used. At this time, it is estimated that approximately 10 percent of the respondents use electronic 

reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions

Perform initial performance test as per 40 CFR 60.485, Reference Method 21 and 22 tests, and 

repeat performance tests
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Respondent Activities

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

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

Transmit or otherwise disclose the information

As refiners replace/upgrade their monitoring equipment, they may choose to use systems 

that automatically log the results of monitoring, which can then be downloaded into a computer 

database. This database can then be used to develop and submit the required reports electronically.

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 information required under NSPS subpart GGG:

Agency Activities

Observe initial performance tests and repeat performance tests if necessary

Review notifications and reports, including performance test reports, and other reports, 

required to be submitted by industry

Audit facility records

Input, analyze, and maintain data in the Aerometric Information Retrieval System (AIRS) 

database

5(b) Collection Methodology and Management

The required data and reports can be evaluated on-site by conducting a partial compliance 

evaluation, full compliance evaluation or inspection, or thru an off-site review of compliance 

monitoring records and reports. Evaluation reports and inspection results are maintained by the 

Agency or delegated authority.
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The results of these evaluations are entered into the Air Facility Subsystem (AFS) 

which is operated and maintained by EPA's Office of Compliance. AFS is EPA’s database for the 

collection, maintenance, and retrieval of compliance data for approximately 125,000 industrial and 

government-owned facilities. EPA uses the AFS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA headquarters and EPA regional offices. 

EPA and delegated authorities can retrieve and analyze the data.

5(c) Small Entity Flexibility

A majority of the affected facilities by this regulation are large businesses. However, the 

impact on small businesses was taken into consideration during development of the regulation. 

Due to technical considerations involving the process operations and leak detection and repair 

programs, the recordkeeping and reporting requirements are the same for both small and large 

businesses. However, for sources that install “leakless” components, monitoring may not be 

required for those components. Therefore, the monitoring and recordkeeping may also be reduced 

for sources that maintain low percentages of leaking components. Additionally, alternative means 

of emission limitation are allowed after proper demonstration of their effectiveness to the 

Administrator.

The Agency considers these requirements to be the minimum needed to ensure compliance 

and, therefore, cannot reduce them further for small businesses. 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 

in Table 1, attached.

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry. 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 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.

6(a) Estimating Respondent Burden

The average annual burden to industry over the next three years from these recordkeeping 

and reporting requirements is estimated at 21,360 person-hours, as shown in Table 1, attached. 

The labor hours in Table 1 are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the standard, the 
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previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $97.46 ($46.41 + 110%)

Technical $83.71 ($39.86 + 110%)

Clerical $42.55 ($20.26 + 110%)

These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 19, 

2005, “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 type of industry costs associated with the information collection activity in the 

standards are labor costs. There are no capital/startup and operation and maintenance costs 

associated with the leak detection and repair requirements for this rule. Costs associated with 

equipment for VOC leaks cannot be attributed to this rule since these are used by industry as part 

of their normal operations for safety reasons and do not involve the use of continuous monitors.

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

The average annual costs for capital/startup and operation and maintenance costs to 

industry over the next three years of the ICR is zero because no continuous monitoring equipment 

is required under the leak detection and repair program of this regulation. This is shown on the 

OMB 83-I form in Section 14 as follows: block 4(a), Total annualized capital/startup costs; block 

14(b), Total annual costs (O&M); block 14(c), Total annualized cost requested. The numbers in 

block 14 of the OMB 83-I form are rounded to show the cost in thousands of dollars.

6(c) Estimating Agency Burden and Costs

The only costs to the Agency are those associated with analysis of the reported information. 

EPA's overall compliance and enforcement program includes activities such as the examination of 

records maintained by the respondents and the publication and distribution of collected 

information.

The average annual Agency cost during the three years of the ICR is estimated to be 

$55,199, as shown in Table 2, attached.

This cost is based on the average hourly labor rate as follows:
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Managerial $56.02 (GS-13, Step 5, $35.01 x 1.6)

Technical $41.57 (GS-12, Step 1, $25.98 x 1.6)

Clerical $22.50 (GS-6, Step 3, $14.06 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2005 General Schedule” which 

excludes locality rates of pay.

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

Number of respondents is calculated using the following table which 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

(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 0 148 0 0 148

2 0 148 0 0 148

3 0 148 0 0 148

Average 0 148 0 0 148

1 New respondents would typically include sources with constructed, reconstructed and modified affected 

facilities. However, for this industry category a new source would be required to comply with more recent equipment 

leaks standards and not this standard.

To avoid double-counting respondents column D is subtracted. The average Number of 

Respondents over the three-year period of this ICR is shown in column D. This number appears 

on the OMB 83-I form in block 13(a), Number of respondents.

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

Semiannual Reports 148 2 0 296

Initial Notifications 0 4 0 0

Report of Performance Report 0 1 0 0
10

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

Total 296

The number of Total Annual Responses is shown in column E. This number is shown on 

the OMB 83-I form in block 13(b), Total annual responses.

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). The total 

annual labor cost may be found in Table 1.

The average annual Agency burden and cost over next three years is shown in Table 2.

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 in Tables 1 and 2, respectively.

(i) Respondent Tally

The Total Hours Requested is shown on the OMB 83-I form in block 13(c). The annual 

labor costs are not shown on the OMB 83-I form. Details regarding these estimates may be found 

in Table 1. Furthermore, the annual public reporting and recordkeeping burden for this collection 

of information is estimated to average 72 hours (rounded) per response.

The total annual capital/startup and O&M costs to the regulated entity are shown on the 

OMB 83-I form in block 14(c), Total annualized cost requested. The cost calculations are detailed 

in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance (O&M) Cost.

(ii) The Agency Tally

The average annual Agency burden hours and cost over next three years is shown in Table 

2.

6(f) Reasons for Change in Burden

The increase in labor burden to industry from the most recently approved ICR from 6,137 

to 21,360 is due to an adjustment. The burden change resulted from an increase from 48 to 148 on 

the number of sources subject to the standard which is based on recent Agency data available on 

the sector and consultation with industry, as discussed in Section 3 of this report. We also 

removed any burden associated with new sources complying with the initial rule requirements due 

to the assumption that there will be no industry growth. The total industry cost also increased from 

$631,983 to $1,724,344 as a result of these changes, and the use of an updated technical labor rate 
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and the addition of the Management and Clerical labor hours associated with the 

standards.

There were no capital/startup and operation and maintenance costs associated with 

continuous emission monitoring for the renewal of the ICR, therefore, there is no change in this 

burden category. This is based on the fact that this regulation does not require the use of 

continuous emission monitoring systems.

The Agency burden increase is due to the review of semiannual reports for more number of 

sources, as discussed above, and the use of updated higher labor rates which did not offset the 

decrease in burden associated with new sources submitting initial reports.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 72 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, disclose, or provide information to or 

for a Federal agency. This includes the time needed to review instructions; to 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; to 

adjust the existing ways to comply with any previously applicable instructions and requirements; 

to train personnel to be able to respond to a collection of information; to search data sources; to 

complete and review the collection of information; and to 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 valid OMB Control Number. The OMB Control 

Numbers for EPA’s 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 OECA-2005-0018, which is available for public viewing at the Enforcement and 

Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, 

Room B102, 1301 Constitution Avenue, NW, Washington, D.C. 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 Enforcement and Compliance Docket and Information Center Docket is (202) 566-

1752. 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, to access the 

index listing of the contents of the public 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 above. You can also send comments to the Office of Information 

and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, 

D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number OECA-
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2005-0018 and OMB Control Number 2060- 0067 in any correspondence.

Part B of the Supporting Statement

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

information.
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Table 1. Annual Respondent Burden and Cost: NSPS for Equipment Leaks of VOC in Petroleum Refineries

(40 CFR Part 60, Subpart GGG)

Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year 

a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, Installation, 

and Utilization of Technology 

and Systems

N/A

4. Reporting Requirements

 A. Read instructions 1 1 1 0 0.0 0.0 0.0 $0.00

 B. Required activities:

 i. Initial Performance tests c  24 1 24 0 0.0 0.0 0.0 $0.00

 ii. Repeat Performance tests c  24 0.2 4.8 0 0.0 0.0 0.0 $0.00

 

 iii. Monitoring of operations 

and equipment: d

D. Gather Existing Information Included in 4B and 5E

E. Write report a, c
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Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year 

a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

 i. Notification of actual 

startup

2 1 2 0 0.0 0.0 0.0 $0.00

 ii. Notification of 

construction/ modification a

2 1 2 0 0.0 0.0 0.0 $0.00

 iii. Notification of 

Performance Test 

2 1 2 0 0.0 0.0 0.0 $0.00

 iv. Reports of performance 

test results

Included in 4B

 v. Semi-annual reports e 8 2 16 148 2,368.0 118.4 236.8 $219,840.38

5. Recordkeeping Requirements

A. Read instructions Included in 4A

B. Plan activities Included in 4B

C. Implement activities Included in 4B

D. Develop record system N/A

E. Time to enter and transmit 
15

Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year 

a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

information: Monitoring of 

operations include leak detection 

records f

0.3 365 109.5 148 16,206.0 810.3 1,620.6 $1,504,503.39

F. Time to train personnel N/A

G. Time for audits N/A

TOTAL LABOR BURDEN AND 

COST 

18,574.0 928.7 1,857.4 $1,724,343.77

TOTAL LABOR HOURS 

(Rounded)

21,360 $1,724,344

Assumptions:

a

 We have assumed that all of the existing 148 refineries in the United States (i.e., respondents) would have at least one process unit (affected facility) subject to the

requirements of NSPS subpart GGG. We have further assumed that there will be no new respondents subject to this rule over the three year period of this ICR since any 

new petroleum refining process unit would be required to comply with recent equipment leaks standards which are more stringent. 

b

 This ICR uses the following labor rates: $97.46 per hour for Executive, Administrative, and Managerial labor; $83.71 per hour for Technical labor, and $42.55 per hour 

for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 19, 2005, ATable 2. Civilian Workers, by occupational 

and industry group.@ The rates are from column 1, ATotal compensation.@ The rates have been increased by 110% to account for the benefit packages available to those 

employed by private industry.

c

 We have assumed that all sources are in compliance with initial rule requirements including the initial performance test and notification requirements . We have assumed 

that usually 20 percent of the sources would repeat performance tests due to failure. 

d

 Monitoring of operations includes: 1) implementation of Standard Operating Procedures (SOP) for operation and maintenance of control equipment; 2) records of 

tank identification numbers; and monthly leak detection inspection of control equipment. 

e The rule requires existing sources to submit semi-annual reports.

f We have assumed that equipment leaks data will be recorded daily at an average of 18 minutes or 0.3 hours per day. 
16

Table 2. Annual Burden and Cost for The Federal Government: 

NSPS for Equipment Leaks of VOC in Petroleum Refineries

(40 CFR Part 60, Subpart GGG)

Activity

(A)

EPA 

personhours per

occurrence

(B)

No. of

occurrences

per plant

per year

(C)

EPA 

personhours per

plant per

year

(C=AxB)

(D)

Plants

per

year 

a

(E)

Technical

personhours

per year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours per

year

(Ex0.1)

(H)

Cost, $ b

Initial Notifications c 2 1 2 0 0 0 0 $0.00

Reports of performance test 

results c

8 1.2 9.6 0 0 0 0 $0.00

Semi-annual reports d 4 2 8 148 1,184 59.2 118.4 $55,199.26

Subtotal Burden and Cost 1,184 59.2 118.4 $55,199.26

TOTAL ANNUAL BURDEN 

AND COST (rounded)

1,362 $55,199

Assumptions:

a We have assumed that all of the existing 148 refineries in the United States (i.e., respondents) would have at least one process unit (affected facility) subject to the

requirements of NSPS subpart GGG. We have further assumed that there will be no new respondents subject to this rule over the three year period of this ICR since 

any new petroleum refining process unit would be required to comply with recent equipment leaks standards which are more stringent. 

b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate 

of $56.02 (GS-13, Step 5, $35.01 x 1.6), Technical rate of $41.57 (GS-12, Step 1, $25.98 x 1.6), and Clerical rate of $22.50 (GS-6, Step 3, $14.06 x 1.6). These rates 

are from the Office of Personnel Management (OPM) A2005 General Schedule@ which excludes locality rates of pay. 

c We have assumed that all existing sources are in compliance with the initial rule requirements. 

d The rule requires existing sources to submit semi-annual reports. 
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