**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY** 
**NSPS for**  **Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part**  **60 , Subpart**  **s GGG and GGGa** **) (Renewal) 1. Identification of the Information Collection**  **1(a) Title of the Information Collection**  NSPS for Equipment L eaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGG and GGGa) (Renewal) , EPA I CR Number 0983.1 4 , OMB Control Number 2060

- 0067 **1(b) Short Characterization/Abstract** This information collection request (ICR) is for the New Source Performance Standards (NSPS) for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGG and GGGa). The NSPS in subpart GGG were proposed on January 4, 1983 , and promulgated on May 30, 1984 , and was last

- amended June 2, 2008. 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 construction, modification or reconstruction after the date of proposal. Amendments that would have added new standards and compliance requirements to subpart GGG were proposed on November 7, 2006. In response to public comments, all new requirements were incorporated in a new subpart GGGa that applies to sources that commence construction, reconstruction, or modification after November 7, 2006. The final 2008 amendments to subpart GGG extends a stay of the definitions for process units and capital expenditure established at 40 CF R 60.480a(f) for NSPS subpart Vv a , and at 40 CFR 60.590a(e) for NSPS subpart GGGa. This information is being collected to assure compliance with 40 CFR p art 60 , subparts GGG and GGGa. In general, all NSPS standards require initial notification report s, p erformance tests, and periodic reports by

the owners/operators of the affected facilities. They 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. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NSPS

. Owners or operators subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least two years following the date of such measurements, maintenance reports, and 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 directl y to the U

. S

. Environmental Protection Agency (EPA) regional office. The Environmental Protection Agency ’s (EPA’s) databases show that approximately 130 refineries are currentl y s ubject to NSPS subpart GGG

. In addition, it is assumed that 30 of the2

13 0 refineries are also subject to NSPS subpart GGGa. There are no additional respondents per ye ar expected for these rules for the next three ye ars. The Off ice of Management and Budget (OMB) approved the currentl y active I CR without any

‘Terms of Clearance’. The “Affected Public” are owners and operators of petroleum refineries that have compressors and/or the group of equipment (e.g., valves, pumps, flanges, etc.) within a process unit in VOC service

. The “burden ” to the Affected Public may be found below in both Table s 1 a : Annual Respondent Burden and Cost

– NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGG) ( Renewal) and 1b: Annual Respondent Burden and Cost

– NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGGa) (Renewal). The “burden ” to the Federal Government is attributed entirely to work performed b y either F ederal employees or government contractors. This burden may be found below in both Table s 2a: Average Annual EPA Burden and Cost

– NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR P art 60, Subparts GGG) (Renewal) and 2b: Average Annual EPA Burden and Cost

– NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGGa) (Renewal).
**2. Need for and Use of the Collection 2(a) Need/Authority for the**  **Collection** The EPA is charged under Section 111 of the Clean Air Act (CAA), as amended, to establish standards of performance for new stationary sources that reflect:

**. . .** application of the best technological system of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality health and environmental impact and energy requirements) the Administrat or determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to this charge as selecting the best

- demonstrated technology (BDT). Section 111 also requires that the Administrator review and, if appropriate, revise such standards ev ery four years. In addition, section 114(a) states that the Administrator may require any

owner/operator subject to any

requirement of this Act to: (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at3 such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Admini strator may reasonabl y require. In the Administrator's judgment, VOC emissions from equipment leaks in petroleum refineries cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Theref ore, the NSPS were promulgated for this source category at 40 CFR part 60 , subpart s GGG and GGGa. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standards ensure compliance with the applicable regulations which were promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to determine an affected facility ’ s initial capability to comply

with the emission standards . During the performance test , a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standards are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewing authority may then inspect the source to check if the pollution control devices are p roperl y installed and operated and leaks are being detected and repaired and the standard s are being met. The performance test may also be observed. The required semiannual reports are use d to determine periods of excess emissions, identify problems at the facility , verify operation/maintenance procedures and for compliance determinations. Semiannual reports shall be submitted itemizing the information for each month.
**3. Non**
**- duplication, Consultations, and Other Collection Criteria**  The requested recordkeeping and reporting are required under 40 CFR part 60, subpart GGG and GGGa. **3(a) Non**
**- duplication**  If the subject standards have not been delegated, the information is sent directl y to the appropriate 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 repor t submitted to the state or local agency can4

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, duplication does not exist. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a p ublic comment period for the renewal of this I CR was published in the Federal Register (78 FR 35023) on June 11, 2013. No comments were received on the burden published in the Federal Register

. **3(c) Consultations** Consultations with the Agency’s industry experts were conducted to determine if there is any way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard s to make it easier to compl y. In developing this I CR, we contacted : 1) the American Petroleum Institute , at (202) 682

- 8000 ; and 2) the American Fuel and Petrochemical Refineries , at (202) 457

- 0480. It is our policy

to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the firs t Federal Register notice. In this case, no comments were received. **3(d) Effects of Less Frequent Collection** Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the 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 prop er operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines**
These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. **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

- Confid entiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).5

**3(g) Sensitive Questions**
The reporting or recordkeeping requirements in the standard do not include sensitive questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents to the recordkeeping and reporting requirements are petroleum refineries where the affected compressors or group of equipment within a process unit commenced construction, modification, or reconstruction after January 4, 1983 . The United States Standard Industrial Classification ( SI C ) code for the respond ents af fected b y the standards is SI C 2911, which corresponds to the North American Industry Classification S ys tem (NAI CS ) code 324110 for P etroleum Refineries

. **4(b) Information Requested (i) Data Items** 
In this ICR , all the data that is recorded or reported is required b y the NSPS for Equipment L eaks of VOC in Petroleum Refineries (40 CFR P art 60, S ubpart GGG and GGGa)

. NSPS Subpart GGG references the compliance requirements of NSPS subpart VV, and NSPS subpart GGGa references the compli ance requirements of NSPS subpart VVa. A source must make the following reports: **Notifications for 40 CFR Part 60, Subparts GGG and GGGa** Construction/reconstruction 60.7(a)(1) Anticipated startup 60.7(a)(2) Actual startup 60.7(a)(3) Phy sical or operational change 60.7(a)(4) Initial performance test 60.8(d) Alternative standard selected 60.487(d)

**Reports for 40 CFR Part 60, Subparts GGG and GGGa** Initial performance test results 60.8(a) Comply with the provisions of 60.487 60.592(e) Semiannual reports (subpart GGG) 60.486, 60.487(a

- c )6 **Reports for 40 CFR Part 60, Subparts GGG and GGGa** Semiannual reports (subpart GGGa) 60.486a, 60.487a(a

- c ) Performance test 60.8, 60.487(e) A source must keep the following records: **Recordkeeping 40 CFR Part 60, Subpart GGG**  All measurements, monitoring device, and performance testing measurements 60.7(e) Comply with the provisions of 60.486 60.592(e) The date and instrument reading of each monitored component must be recorded N/A
The following information for each detected leak shall be recorded in a log and kept for 2 years : description of leaking equipment, repair methods used to stop the leaks, and the dates of repair 60.486(c)

In formation pertaining to design requirements or closed vent sy stems and control devices 60.486(d) Equipment identification numbers and designations, and dates of performance tests 60.486(e) Dates and results of weekly visual inspections N/A In formation related to instrument calibrations and drift checks N/A In formation pertaining to valves and pumps that are designated as unsafe to monitor or difficult to monitor 60.486(f)

In formation pertaining to valves complying with alternative complian ce requirements 60.486(g) Design criteria and any 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) **40 CFR Part 60, Subpart GGGa** All measurements, monitoring device, and performance testing measurements 60.7(e) Comply with the provisions of 60.486a 60.592a(e)7 **Recordkeeping 40 CFR Part 60, Subpart GGG**  The date and instrument reading of each monitored component must be recorded 60.486a(a) Each detected leak shall be recorded in a log and kept for 2 ye ars 60.486a(c) In formation pertaining to design requirements or closed vent sy stems and control devices 60.486a(d) Equipment identification numbers and designations, and dates of performanc e tests 60.486(e)(1

- 5 ) Dates and results of weekly visual inspections 60.486a(e)(6) In formation related to instrument calibrations and drift checks 60.486a(e)(7) In formation pertaining to valves and pumps that are designated as unsafe to monitor or difficult to monitor 60.486a(f)

In formation pertaining to valves complying with alternative compliance requirements 60.486a(g) Design criteria and any changes 60.486a(h) Records for use in determining exemptions 60.486a(i) In formation and data to demonstrate that a piece of equipment is not in VOC service 60.486a(j)

Electronic Reporting Some of the respondents are using monitoring equipment that automatically records parameter data. Although personnel at the affected facility must still evaluate the data, internal automation has significantly reduced the burden associated with monitoring and recordkeeping at a plant site. Also, regulatory

agencies in cooperation with th e respondents continue to create reporting sy stems to transmit data electronically . However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 30 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions Perform initial performance test as per 40 CFR 60.485, Reference Meth od 21 and 22 test s , and8 **Respondent Activities** repeat performance tests if necessary 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 collecting, validating, and verifying information Develop, acquire, install, and utilize technology and sy stems for the purpose of process ing and maintaining information Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and providing information Adjust the existing way s to comply with any previously applicable instructions and requirements Train personnel to be able to respond to a collection of information Transmit, or oth erwise disclose the information Currently sources are using monitoring and reporting equipment that provide parameter data in an automated way ( e.g., continuous parameter monitoring s ys tem. ) Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y reduced the burden associated with monitoring and recordkeeping. As refiners replace/upgrade their monitoring equipm ent, they may choose to use sy stems that automatically log the results of monitoring which can be downloaded into a computer database. This database can be used to develop the required reports. **5. The Information Collected: Agency Activities, Collecti on Methodology, and**  **Information Management 5(a) Agency Activities**  EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information : **Agency Activities** Observe initial performance tests and repeat performance tests if necessary Review notifications and reports, including performance test reports, and excess emissions reports, required to be submitted by industry9 **Agency Activities** Audit facility

records Input, anal y

z e, and maintain data in the Online Tracking Information Sy stem (Otis). **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority could inspect the source to determine whether the pollution control devices are properl y installed and operated. Performance test reports are used b y the Agency to discern a source’s initial capability to comply with the emission standard. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS 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 OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analyze the data. The records required by

this regulation must be retained by the owner/operator for two ye ars. **5(c) Small Entity Flexibility** A majority

of the respondents are large entities (i.e., large businesses). We estimate only five sources within the respondent universe are s mall entities. However, the impact on small entities (i.e., small businesses) was taken into consideration during the development of this 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 entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. For sources that install “leakless” components, monitoring may not be required for those components. Monitoring and recordkeeping may be reduced for sources that maintain low percentages of leaking components. In addition, alternative means of emission limitation s are allowed after proper demonstration of their effectiveness to the Administrator.10

**5(d) Collection Schedule** The specific frequency

for each information collection activity within this request is shown below in both Table s 1a: Annual Respondent Burden and Cost

- NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGG) (Renewal) and 1b: Annual Respondent Burden and Cost

- NSPS for Equipment L eaks of VOC in Petroleum Refineries (40 CFR Part 60, S ubpart GGGa) (Renewal). **6. Estimating the Burden and Cost of the Collection** Both Table s 1 a and 1b , shown below , document the computation of individual burdens for the recordkeeping and reporting requirements applica ble to the industry for each of the subparts included in this ICR. 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 Resp ondent Burden**  The average annual burden to industry over the next three years from these recordkeeping and reporting requirement s is estimated to be 24,886 hours (Total Labor Hours from Table s 1a and 1 b below)

. These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NSPS program, the previously

- approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 2 3

. 04 ($5 8

. 59 + 110%) Technical $ 10 1

. 2 2 ($4 8

. 2 0 + 110%) Clerical $ 5 1

. 18 ($2 4

. 37 + 110%) These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2013 , “ Table 2. Civilian Workers, by occupational and industry group. ” The rates are from column 1, “ Total compensation. ” The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry

.11 **(ii) Estimatin g Capital/Startup and Operation and Maintenance Costs**  The only costs to the regulated industry resulting from information collection activities required b y the subje ct standards are labor costs. To the extent possible, the requirements of this standard are consistent with industry practices. VOC monitors used for leak detection are used ty picall y in the industry

for safety reasons and do not impose an additional cost to the respondents. Consequently , there are no capital/startup or operation and maintenance costs.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs** The only type of industry costs associated with the information collection activity in the regulations are labor costs. There are no capital/startup or operation and maintenan ce costs. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. EPA's overall compliance and enforcement program includes such activities as the examination of records maint ained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $66,335. This cost is based on the average hourl y labor rate as follows: Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 3 General Schedule , which excludes locality

rates of pay

. The rates have been increased by 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appear below in both Table 2 a : Average Annual EPA Burden and Cost

– NSPS for Equipment L eaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGG) (Renewal) and Table 2 b : Average Annual EPA Burden and Cost

– NSPS for Equipment L eaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGG a) (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs** Based on our research for this I CR, on average over the next three ye ars, approximately 130 existing respondents will be subject to subpart GGG. This number is not expected to change over the next three ye ars. Inaddition, 30 of the 130 refineries are also subject to NSPS subpart GGGa. The overall average number of respondents, as shown in the table below, is 130 per ye ar. The number of respondents is calculated using the following table that addresses the three12

ye ars covered b y this ICR : **Number of Respondents**

Respondents That Submit Reports Respondents That Do Not Submit Any Reports

Year (A) Number of Ne w Respondents 1 (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 0 130 0 0 130
2 0 130 0 0 130
3 0 130 0 0 130 **Average 0**  **130 0**  **0 130** 
C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 130

. The total number of annual responses per ye ar 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

Subpart GGG Semiannual Reports 130 2 0 260 Subpart GGGa Semiannual Reports 30 2 0 60

**Total 320**  The number of Total Annual Responses is 320. The total annual labor costs are $2,434,325

. Details regarding these estimates may be found below in both Table s 1a: Annual Respondent Burden and Cost

- NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGG) (Renewal) and 1b: Annual Respondent Burden and Cost

- NSPS for Equipment L eaks of VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGGa) (Renewal).13

**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 below in Tables 1 a, 1b, 2a and 2 b , respectivel y, and summarized below. **(i) Respondent Tally** The total annual labor hours are 24,886 hours at a cost of $2,434,325

. Details regarding these estimates may

be found below in both Table s 1 a : Annual Respondent Burden and Cost

– NSPS for Equipment L eaks of VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGG) (Renewal) and 1b: Annual Respondent Burden and Cost

- NSPS for Equipment L eaks of VOC in Petroleum Refineries (40 CFR Part 60, Subp art GGGa) (Renewal). Furthermore, the annual public reporting and recordkeeping burden for this collection of information is estimated to average 78 hours per response

. **Summary of Respondent Burden**

**Standard Reporting** 

**Burden (hr) Recordkeeping** 

**Burden (hr)**  **Total Burden**

**(hr) Total Cost ($)**  Subpart GGG 2,392 16,370 18,762 $1,835,274 Subpart GGGa 552 5,572 6,124 $599,051 **Total 24,886**  **$2,434,325**

**(ii) The Agency Tally** The average annual Agency burden and cost over next three years is estimated to be 1,472 labor hours at a cost of $66,335. See below both Table s 2a: Average Annual EPA Burden and Cost

– NSPS for Equipment L eaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGG) (Renewal) and 2 b : Average Annual EPA Burden and Cost

– NSPS for Equipment L eaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGG a) (Renewal)

. **Summary of Agency**  **Burden**

**Standard Total Burden** 

**(hr) Total Cost ($)**  Subpart GGG 1,196 $53,897 Subpart GGGa 276 $12,438 **Total 1,472**  **$66,335 6(f) Reasons for**  **Change in Burden** There are several changes to the estimated burden as currently identified in the OMB Inventory of Approved Burdens. Th ese differences are not due to any program changes. There14

is a decrease in the respondent and Agency burden for subpart GGG due to a correction of the number of respondents from 135 to 130. In addition, there is an increase in the respondent burden for subpart GGGa due to a mathematical correction. The previous ICR incorrectl y calculated the amount of time it would take to record operating parameters at large and small refineries for subpart GGGa. This I CR also updates all burden costs to reflect the current labor rates. These changes result in an overall increase in respondent burden and a decrease in Agency burden fo r both subparts combined. **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 78 hours per response (rounded

. ) “ Burden ” means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . This includes : the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously

applicable instruc tions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and 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 regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for th is 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 EPA

- HQ

- OECA

- 2013

- 0303. An electronic version of the public docket is available at http://www.regulations.gov/ , which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the 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 number identified in this document. The documents are also available for public viewing at th e Enforcement and Compliance Docket and Information Center in the EPA Docket Center (EPA/DC), WJC West, Room 3334 , 1301 Constitution Ave., NW, Washington, DC. 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) 566

- 1744, and the telephone number for the docket center i s (202) 566

- 1752

. Also, you can send comments to the Office of In formation and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include th e EPA Docket ID Number EPA

- HQ

- OECA

- 2013

- 0303 and OMB Control Number 2060

- 0067 in any correspondence.15

**Part B of the Supporting Statement** This part is not applicable because no statistical methods were used in collecting this information.16

**Table 1 a**  **: Annual Respondent Burden and Cost**

**– NSPS for**  **Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part**  **60 ,**  **Subpart GGG** **) (Renewal) a** 

**Activity (A)**  **Persons Hours per**  **Occurrence (B)** 

**Number of Occurrences**  **per Respondent**  **per Year**

**(C) Hours per**  **Respondent per Year**  **(C=A x B) (D)** 

**Number of Respondents**  **per Year (E)** 

**Technical Hours per**  **Year @ $101.22**  **(E=C x D) (F)** 

**Managem ent**  **Hours per Year**  **@ $123.04 (F= E x 0.05)**  **(G)**

**Clerical Hours per**  **Year @ $51.18**  **(G= E x 0.1) (H)** 

**Total Labor Costs per**  **Year a** 

1. Applications N/A 2. Survey and studies N/A 3. Report requirements A
**.** Read Instructions 1 1 1 0 0 0 0 $ 0 B. Required Activities Initial performance test 24 1 24 0 0 0 0 $ 0 Repeat performance test b 24 1 24 0 0 0 0 $ 0 C. Create Information See 3B D. Gather Existing Information See 3E E. Write Report Notification of construction or reconstruction e 2 1 2 0 0 0 0 $ 0 Notification of anticipated startup e 2 1 2 0 0 0 0 $ 0 Notification of actual startup e 2 1 2 0 0 0 0 $ 0 Notification of initial performance test e 2 1 2 0 0 0 0 $0 Report of performance test See 3B Semiannual work practice reports c , f 8 2 16 13 0 2,080 104 208 $ 233,979.20 **Subtotal for Reporting Requirements 2,392**  **$ 233,979.20**  4. Recordkeeping Requirements A. Read Instructions See 3A B. Plan Activities See 3B C. Implement Activities See 3B D. Develop Record System N/A17

**Activity (A)**  **Persons Hours per**  **Occurrence (B)** 

**Number of Occurrences**  **per Respondent**  **per Year**

**(C) Hours per**  **Respondent per Year**  **(C=A x B) (D)** 

**Number of Respondents**  **per Year (E)** 

**Technical Hours per**  **Year @ $101.22**  **(E=C x D) (F)** 

**Managem ent**  **Hours per Year**  **@ $123.04 (F= E x 0.05)**  **(G)**

**Clerical Hours per**  **Year @ $51.18**  **(G= E x 0.1) (H)** 

**Total Labor Costs per**  **Year a** 

E. Time to Enter Information Records of operating parameters c , d 0.30 365 109.5 13 0 14,235 711.75 1,423.50 $1,601,295.15 F. Train Personnel N/A G. Audits N/A **Subtotal for Recordkeeping Requirements**  **16, 370**  **$ 1,601,295.15**  **TOTAL LABOR BURDEN AND COST (rounded)**  **18,762 $1,835,274** 

**Assu mptions:** 
**a** NSPS GG G o nly includes facilities that commenced construction, reconstruction, or modification prior to November 7, 2006. All new faci lities and facilities that commence construction, reconstruction, or modification after November 7, 2006 are subject to subpart GGGa

. **b** Assume 20 percent of initial performance tests must repeat due to failure.
**c** Assume that average number of affected facilities over the next thre e years is equal to the c urrent number of facilities (130 ) because affected facilities after November 7, 2006 will be subject to subpart GGGa instead of subpart GGG. These affected facilities under subpart GGG (i.e., that were either new, reconstructed, o r modified affected source prior to November 16, 2007) are not required to comply with the requirements of subparts Vva/GGGa until EPA takes final action to require compliance and publishes a document in the Federal Register (see 60.480a(f)(2) of subpart Vva). Therefore, we have assumed that these facilities are complying with subparts VV/GGG even when many new sources may have opted already to comply with the subparts Vva/GGGa standards for the purpose of this burden estimate. **d** Although monitoring of th e various components may be required on a weekly, monthly, quarterly, semiannual or annual basis, given the number of compone nts that must be monitored at any facility, monitoring overall is essentially occurring daily. Therefore, it is assumed that the average recordkeeping time for each day’s worth of monitoring for both subpart GGG and subpart GGGa is 0.30 hours and that monitoring is done 365 days a year.
**e** Owners or operators of the affected facilities must make one

- time

- only notifications

. f The time to prepare reports is estimated to be the same as subpart GGGa, because the information in the new records must be maintained on

- site, but it does not have to be reported.18

**Table 1 b**  **: Annual Respondent Burden and Cost**

**– NSPS for Equipment Leaks of**  **VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGG**  **a ) (Renewal)**  **a**

**Burden Item (A)**  **Respondent Hours per**  **Occurrence (B)** 

**Number of Occurrences**  **per Respondent**  **per Year**

**(C) Hours per**  **Respondent per Year**  **(C=A x B) (D)** 

**Number of Respondents**  **per Year**

**(E) Technical**  **Hours per Year**  **@ $101.22 (E=C x D)**  **(F)**

**Managem ent**  **Hours pe r**  **Year @ $123.04**  **(F= E x 0.05) (G)** 

**Clerical Hours per**  **Year @ $51.18**  **(G= E x 0.1) (H)** 

**Total Labor Costs per**  **Year a** 

1. Applications N/A 2. Survey and studies N/A 3. Report requirements A. Read Instructions 1 1 1 0 0 0 0 $ 0 B. Required Activities Initial performance test 24 1 24 0 0 0 0 $ 0 Repeat performance test b 24 1 24 0 0 0 0 $ 0 C. Create Information See 3B D. Gather Existing Information See 3E E. Write Report Notification of construction or reconstruction 2 1 2 0 0 0 0 $ 0 Notification of anticipated startup 2 1 2 0 0 0 0 $ 0 Notification of actual startup 2 1 2 0 0 0 0 $ 0 Notification of initial performance test 2 1 2 0 0 0 0 $0 Report of performance test See 3B Semiannual work practice reports c 8 2 16 30 480 24 48 $53,995.20 **Subtotal for Reporting Requirements 552**  **$ 53,995**  4. Recordkeeping Requirements A. Read Instructions See 3A B. Plan Activities See 3B C. Implement Activities See 3B D. Develop Record System N/A19

**Burden Item (A)**  **Respondent Hours per**  **Occurrence (B)** 

**Number of Occurrences**  **per Respondent**  **per Year**

**(C) Hours per**  **Respondent per Year**  **(C=A x B) (D)** 

**Number of Respondents**  **per Year**

**(E) Technical**  **Hours per Year**  **@ $101.22 (E=C x D)**  **(F)**

**Managem ent**  **Hours pe r**  **Year @ $123.04**  **(F= E x 0.05) (G)** 

**Clerical Hours per**  **Year @ $51.18**  **(G= E x 0.1) (H)** 

**Total Labor Costs per**  **Year a** 

E. Time to Enter Information Records of operating parameters at large refineries c , d , e 0.44 365 160.6 26.25 4,215.75 210.79 421.58 $474,229.72 Records of operating parameters at small refineries c , d , e 0.46 365 167.9 3.75 629.63 31.48 62.96 $70,826.52 F. Train Personnel N/A G . Audits N/A **Subtotal for Recordkeeping Requirements 5,572**  **$ 545,056**  **TOTAL LABOR BURDEN and**  **COST (rounded)**  **6,124 $**  **599,051**

**Assu mptions:** 
**a** There are approximately 30 existing refineries (respondents that were reconstructed, or modified affected sources after November 16, 2007) subject to the subparts NSPS GGGa/VVa standard s
. **b** Assume 20 percent of initial performance tests must repeat due to failure.
**c** Assume that most facilities need an additional 0.14 hours per day to complete the tasks required by the new standards (0.30 + 0.15 = 0.44) T hese tasks include: collecting and maintaining records of all instrument readings (3 minutes per day); daily instrument calibrations and drift checks (3 minutes per day); and weekly pum p inspections (15 minutes per week). Instrument readings are assumed to be collected electronically; thus, the additional time is for downloading additional data and organizing it for storage. Smaller facilities may record instrument readings manually and an additional 0.02 hours per day are needed for small refineri es with manual recordkeeping of instrument readings (0.44 + 0.02 = 0.46).For a facility with a manual process, an average of 0.02 hours per day is estimated to prepare and print recordkeeping forms and to manually record the instrument readings on the forms. This includes 2 hr/yr to prepare and print recordkeeping forms and 10 seconds to record each reading for 9 pumps monitored monthly and 452 valves monitored semiannually. **d** Although monitoring of the various components may be required on a weekly, monthly, quarterly, semiannual or annual basis, given the number of components that must be monitored at any facility, monitoring overall is essentially occurring daily. Therefore, it is assumed that monitoring is done 365 days a year.
**e** Assume that 25 percent of the process units are located at small refineries and half of those use manual recordkeeping of instrument readings (30 x 25% x 0.5 = 3.75) and that 75 percent of the process units are located at large refineries (30 x 75% = 22.5) and thus the number of pr ocess units that do not need additional time for manual recordkeeping is (3.75 + 22.5 = 26.25) f Owners or operators of the affected facilities must make one

- time

- only notifications g The time to prepare reports is estimated to be the same as subpart GGG because the information in the new records must be maintained on

- site, but it does not20

have to be reported.21

**Table 2a: Average**  **Annual EPA**  **Burden and Cost**
**- NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part**  **60, Subparts GGG) (Renewal)** 

**Burden Item (A)**  **EPA Hours per**  **Occurrence (B)** 

**Number of Occurrences**  **per Plant per Year**  **(C)**

**EPA Hours per Year**  **(C=A x B) (D)** 

**Plants per Year**  **(E)**

**Technical Hour**  **s per Year**  **@ $46.21 (E=C x D)**  **(F)**

**Managem ent**  **Hours per Year**  **@ $62.27 (F= E x 0.05)**  **(G)**

**Clerical Hours per**  **Year @ $25.01**  **(G= E x 0.1) (H**  **)**

**Costs per Year**  **a**

Performance Test Report Review (New Process Units ) a 4 1.2 4.8 0 0 0 0 $ 0 Notification of construction 2 1 2 0 0 0 0 $ 0 Notification of anticipated startup 0.5 1 0.5 0 0 0 0 $ 0 Notification of actual startup 0.5 1 0.5 0 0 0 0 $ 0 Notification of initial test 0.5 1.2 0.6 0 0 0 0 $ 0 Revie w test results 8 1.2 9.6 0 0 0 0 $ 0 Report Review (Existing Plants) 4 2 8 130 1,04 0 52 104 $ 5 3,897.48 **TOTAL ANNUAL BURDEN and COST (rounded)**  **1, 196**  **$5 3,897** 
**Assu mptions:** 
**a** Assume that 20 percent of the respondents will repeat the performance test at ne w process units.

.22

**Table 2b: Average**  **Annual EPA**  **Burden and Cost**
**- NSPS for Equipment Leaks of VOC in Petroleum**  **Refineries (40 CFR Part 60, Subparts GGGa) (Renewal)** 

**Burden Item (A)**  **EPA Hours per**  **Occurrence (B)** 

**Number of Occurrences**  **per Plant per Year**  **(C)**

**EPA Hours per**  **Year (C=A x B)**  **(D)**

**Plants per Year**  **(E)**

**Technical Hours per**  **Year @ $46.21**  **(E=C x D) (F)** 

**Managem ent**  **Hours per Year**  **@ $62.27 (F= E x 0.05)**  **(G)**

**Clerical Hours per**  **Year @ $25.01**  **(G= E x 0.1) (H**  **)**

**Costs per Year**  **a**

Performance Test Report Review (New Process Units ) a 4 1.2 4.8 0 0 0 0 $ 0 Notification of construction 2 1 2 0 0 0 0 $ 0 Notification of anticipated startup 0.5 1 0.5 0 0 0 0 $ 0 Notification of actual startup 0.5 1 0.5 0 0 0 0 $ 0 Notification of initial test 0.5 1.2 0.6 0 0 0 0 $ 0 Revie w test results 8 1.2 9.6 0 0 0 0 $ 0 Report Review (Existing Plants) 4 2 8 30 240 12 24 $12,437.88 **TOTAL ANNUAL BURDEN and COST**  **(rounded) 276**  **$ 12,438** 
**Assu mptions:** 
**a** Assume that 20 percent of the respondents will repeat performance tests at ne w process units. We have assumed no new respondents

.