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 Equip ment L eaks of VOC in Petroleum Refineries (40 CFR p art 60, s ubpart 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 appl y 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 con struction, 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 on e - time on ly reports: notification of the date of construction or reconstruction; notification of the actual date of startup; notification of an y ph ys ical or operational change to an existing facility which may increase the regulated pollutant emission rate; notific ation 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 an y startup, shutdown, or malfunction in the operation of an af

fected facility , or any

period during which the monitoring sy stem is inoperative. Monitoring requirements specific to Equipment Leaks of VOC in Petroleum Refineries provide information regarding which components are leaking VOCs. NSPS subpart GGG referen ces the compliance requirements of NSPS subpart VV. On a periodic basis, which varies depending on equipment ty

pe 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 b y 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 authorit y, the reports are sent directly to the EPA regional office. In the development of this Information Collection Request (ICR), we reviewed the Office2

of Management and Budget (OMB) “Terms of Clearance” (T OC) 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 report ing 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 sy stem 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 significantl y higher number of sources (100 more sources) being accounted for in the burden calculation for the renewal of this I CR 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 b y the affected industries (i.e., respondents). The regulations includ e 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 ty

pes 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 variet y of reasons including the determination of the respondent’s compliance status, analy tical studies to demonstrate compliance trends, and evaluations regarding the efficac y 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 wh en 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. Nonduplica tion, 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 appropriate3

Environmental Protection Agency (EPA) regional office. Otherwise, the information is sent directl y 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 cop y 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 peri od for the renewal of this I CR 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 an y 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 additi on, 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 regulati ons 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 ye ars. Less frequent information collection would d ecrease 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 frequentl y, the likelihood of detecting poor operation and maintenance of control equipment and noncompliance would decrease. **3(f) Confidentiality** Any information s ubmitted 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;4

amended b y 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 Info rmation Requested**  **4(a) Respondents/SIC Codes** The Standard Industrial Classification (SI C) codes and corresponding North American Industry Classification Sy stem (NAICS) for the respondents are listed below. **Regulation SIC Codes**  **NAICS Codes** NSPS fo r Equipment L eaks of VOC in Petroleum Refineries (40 CFR Part 60, subpart GGG) SI C 2911 NAI C 324110

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

to be regulated b y this standard. To det ermine 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 I CR that is recorded and/or reported is required b y 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 ph ys ical 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 pe rformance 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)5 **Reports** Semiannual reports 40 CFR 60.486, 40 CFR 60.487(a

- c) A source must maintain the following records: **Recordkeeping** Startup s, 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 ye ars 60.486(c) In formation pertaining to design requirements or closed vent sy stems and control devices 60.486(d)
In formation pertaining to all equipment 60.486(e) In formation pertaining to all valves 60.486(f) In formation pertaining to valves complying with alternative complian ce requirements 60.486(g) Design criteria and an y changes 60.486(h) Records for use in determining exemptions 60.486(i) In formation and data to demonstrate that a piece of equipment is not in VOC service 60.486(j)
Electronic Reporting At the present , man y 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 significantl y reduced the burden associated with monit oring and recordkeeping at the plant site. Also regulatory

agencies, in cooperation with the respondents, continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this tim e, 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 tes ts, and repeat performance tests6 **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 sy stems for the purpose of coll ecting, validating, and verifying information Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information Develop, acquire, install, and utilize technology and sy stems for the purpose of disclos ing and providing information Adjust the existing way s to comply with an y previously applicable instructions and requirements Train personnel to be able to respond to a collection of information Transmit or otherwise disclose the information
As refin ers replace/upgrade their monitoring equipment, they may choose to use sy stems 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 repor ts electronicall y. **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, analy sis, storage, and distributio n 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, anal yz e, and maintain data in the Aerometric Information Retrieval Sy stem (AIRS) database **5(b) Collection Methodology and Management** The required data and reports can be evaluated on

- site by condu cting 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 b y the Agency or delegated authority

.7

The r esults of these evaluations are ente red into the Air Facility Subsy stem (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 12 5,000 industrial and government

- owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA headquarters and EPA regional offices. EPA and delegated authorities can retrieve and anal yz e 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 co nsiderations 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 no t 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 economi es 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, the8

previously

appr oved IC R, and any

comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $97.46 ($46.41 + 110%) Technical $83.71 ($39.86 + 110%) Clerical $42.55 ($20.26 + 1 10%) 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 increase d 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 t ype of industry costs associated with the information collection activ ity 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 ru le 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 IC R 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 Secti on 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 Cost** s The only costs to the Agency

are those associated with analy sis of the reported information. EPA's overall compliance and enforcement program includes activities such as the examination of records maintained b y 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 hourl y labor rate as follows:9 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 ye ars covered b y this ICR. **Number of Respondents**

**Respond ents 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 Th**  **at 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 ne w 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 thr ee - ye ar period of this I CR 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 ye ar is calculated using the following table:
**Total Annual Responses (A)**  **Inform ation 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 0 010 **Total Annual Responses (A)**  **Inform ation 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 c alculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y. **(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 co sts 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 av erage annual Agency burden hours and cost over next three y ears is shown in Table 2. **6(f) Reasons for Change in Burden** The increase in labor burden to industry from the most recentl y approved ICR from 6,137 to 21,360 is due to an adjustment. The burd en 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 an y 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 rate11

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 I CR, 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 s ys tems. The Agency

burden increase is due to the review of semiannual reports for m ore 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 recordkeepin g burden for this collection of information is estimated to average 72 hours per response. Burden means the total time, effort, or financial resources expended b y 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 s ys tems for the purposes of collecting, validating and verifying information, processing and maintaining information, and disclosing and providing information; to adjust the existing way s to comply with an y 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 collecti on 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 Number s 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 I CR 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 B1 02, 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 holiday s. The telephone number for the Reading Room is (202) 5 66

- 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 sy stem, select “search,” then key in the Docket ID Numbe r 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 OEC A

-12

2005

- 001 8 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.13

**Table 1. Annual Respondent Burden and Cost: NS**  **PS for Equipment Leaks of VOC in Petroleum Refineries**  **(40 CFR Part 60, Subpart GGG)**

**Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per y**  **ear a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours per**  **year (Ex0.1)**  **(H)**

**Cost, $ b** 

1. Applications N/A 2. Survey and Studies N/A 3. Acquis ition, 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. Initi al 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 Inc luded in 4B and 5E E. Write report a, c14

**Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per y**  **ear a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours 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 transmit15

**Burden item (A)**  **Person**
  ** hours per** **occurrence (B)** 

**No. of occurrences**  **per respondent**  **per year (C)** 

**Person**
  ** hours per** **respondent per year**  **(C=AxB) (D)** 

**Respondents per y**  **ear a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Managem ent**  **person -**  **hours per year**  **(Ex0.05) (G)** 

**Clerical person**  **** **hours 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
TO TAL LABOR BURDEN AND COST 18,574.0 928.7 1,857.4 $1,724,343.77

TO TAL LABOR HOURS (Rounded) 21,360 $1,724,344

**Assu mptions:**  a We have assumed that all of the existing 14 8 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 ne w respondents subject to this rule over th e thr ee 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, A Table 2. Civilian Workers, by occupational and industry group. @ The rates are from column 1, A Total compensation. @ The rates have been increased by 110% to account for the benefit packages available to those em ploy ed 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) implement ation 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 sem i

- annual reports. f We have assumed that equipment leaks data will be recorded daily at an average of 18 minutes or 0. 3 hour s per day.16

**Table 2. Annual Burden and Cost for The Federal Government:**  **NSPS for Equipment Leaks of VOC in Petroleum Refinerie s** 

**(40 CFR Part 60, Subpart GGG )** 

**Activity (A)**  **EPA person**  **** **hours per occurrence**  **(B)**

**No. of occurrences**  **per plant per year**  **(C)**

**EPA person**  **** **hours per plant per**  **year (C=AxB)**  **(D)**

**Plants per**  **year a**  **(E)**

**Technical person**  **** **hours per year**  **(E=CxD) (F)** 

**Man agem**  **ent person**  **- hours**  **per year (Ex0.05)**  **(G)**

**Clerical person**  **** **hours 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

- annu al 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
TO TAL ANNUAL BURDEN AND COST (rounded) 1,362 $55,199

**Assu mptions:**  a We have assumed that all of the existing 14 8 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 ne w respondents subject to this rule over th e thr ee 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 w hich incorporates a 1.6 benefits mul tiplication 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 fro m the Office of Personnel Management (OPM) A 2005 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.17