SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, 

Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB 

and CCCCCC) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline 

Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and 

CCCCCC) (Renewal), EPA ICR Number 2237.04, OMB Control Number 2060-0620.

1(b) Short Characterization/Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source 

Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline 

Dispensing Facilities were proposed on January 8, 2007, promulgated on January 10, 2008, and 

most recently amended on January 24, 2011. The most recent amendment clarifies certain 

definitions and applicability provisions, but do not alter the intent, level of control, nor the 

environmental impacts of the regulations. These regulations apply to existing and new gasoline 

distribution facilities that are area sources of hazardous air pollutants (HAP). New facilities 

include those that commenced construction or reconstruction after the date of proposal. This 

information is being collected to assure compliance with 40 CFR Part 63, Subparts BBBBBB 

and CCCCCC.

In general, all NESHAP standards require initial notifications, performance 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 NESHAP. 

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least five 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 directly to the United 

States Environmental Protection Agency (EPA) regional office.

Approximately 350,000 sources are currently subject to these standards, with the gasoline 

dispensing facility segment alone accounting for about 340,000 of these facilities. However, a 

large percentage of these facilities are already complying with this standard as a result of their 

compliance with applicable State and local rules. We have minimized or eliminated the 

reporting and recordkeeping requirements under this rule for most of those sources. Therefore, 

the total estimated number of affected sources expected to incur reporting and recordkeeping 
2

costs under this rule is about 19,120. Also, there are no new or reconstructed facilities expected 

within the larger, bulk segment of the industry and new gasoline dispensing facilities are 

expected to be subject to State and local rules. Thus, we have estimated that no additional 

sources will become subject to the regulation and therefore, we expect that only existing sources 

will be subject to the reporting and recordkeeping requirements of the rule. We have, however, 

included a description of the notifications that would be required if new affected sources are 

constructed.

The Office of Management and Budget (OMB) approved the currently active ICR 

without any “Terms of Clearance.”

None of the 350,000 facilities in the United States are owned by state, local, tribal or the 

Federal government. They are owned and operated by privately owned for-profit businesses. 

The burden to the “Affected Public” may be found in Table 1.1 – 1.6: Annual Respondent 

Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk 

Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts 

BBBBBB and CCCCCC) (Renewal). The “Federal Government” burden is attributed entirely to 

work performed by federal employees or government contractors and may be found in Table 2: 

Average Annual EPA Burden and Cost – NESHAP for Source Categories: Gasoline Distribution 

Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR 

Part 63, Subparts BBBBBB and CCCCCC) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under Section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction. 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, at 

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 Administrator may

reasonably require.
3

In the Administrator's judgment, HAP emissions from gasoline distribution bulk 

terminals, bulk plants, pipeline facilities, and gasoline dispensing facilities cause or contribute to 

air pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, 

the NESHAP were promulgated for this source category at 40 CFR Part 63, Subparts BBBBBB 

and CCCCCC. In total, this NESHAP will regulate 9 HAP compounds normally found in 

gasoline, including: benzene, ethylbenzene, hexane, toluene, xylenes, isooctane, naphthalene, 

cumene, and methyl tert-butyl ether.

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. Continuous emission monitors are used to 

ensure compliance with the standards at all times. 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 properly 

installed and operated, leaks are being detected and repaired, and the standards are being met. 

The performance test may also be observed.

The required semiannual reports are used to determine periods of excess emissions, 

identify problems at the facility, verify operation/maintenance procedures and for compliance 

determinations.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 63, Subparts 

BBBBBB and CCCCCC.

3(a) Nonduplication

If the subject standards have not been delegated, the information is sent directly to the 

appropriate 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. Therefore, no 

duplication exists.
4

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 (79 FR 30117) on May 27, 2014. No comments were received on the 

burden published in the Federal Register. 

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. The 

primary source of information as reported by industry, in compliance with the recordkeeping and 

reporting provisions in the standard, is Enforcement and Compliance History Online (ECHO)

which is operated and maintained by the EPA Office of Compliance. ECHO is the EPA database 

for the collection, maintenance, and retrieval of all compliance data. The growth rate for the 

industry is based on our consultations with the Agency’s internal industry experts.

Industry trade associations and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed. In developing 

this ICR, we contacted both ExxonMobil at (281) 870-6050 and the American Petroleum 

Institute (API) at (202) 682-8319.

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 first Federal Register notice.

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 frequently, the proper 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 by OMB under 5 CFR Part 1320, Section 1320.5.

These standards require the respondents to maintain all records, including reports and 

notifications for at least five years. This is consistent with the General Provisions as applied to 

the standards. EPA believes that the five year records retention requirement is consistent with 

the Part 70 permit program and the five year statute of limitations on which the permit program 

is based. The retention of records for five years allows EPA to establish the compliance history 

of a source, any pattern of non-compliance and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 
5

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records. 

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; 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 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 gasoline 

distribution bulk terminals, bulk plants, pipeline facilities, and gasoline dispensing facilities. The 

United States Standard Industrial Classification (SIC) code for the respondents affected by the 

standards, and the corresponding North American Industry Classification System (NAICS) code 

are listed in the table below. 

Standard (40 CFR Part 63, Subparts 

BBBBBB and CCCCCC)

SIC Codes NAICS Codes

Pipeline transportation of refined 

petroleum products 486910 4613

Bulk gasoline terminals and bulk plants 424710 5171

Gasoline stations with convenience stores 447110 5411

Gasoline stations without convenience 

stores 447190 5541

Hazardous materials trucking - local 484220 4214

Hazardous materials trucking – long 

distance 484230 4213

 

4(b) Information Requested

(i) Data Items
6

In this ICR, all the data that is recorded or reported is required by the NESHAP for 

Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and 

Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC). 

A source must make the following reports:

Notifications

Initial notifications, reports of startups, shutdowns, malfunctions, 

anticipated construction/reconstruction, and modification

63.5, 63.9(b)(2-5), 

63.10(d)(5), 

63.867(a)

Notification and report of performance test and results 63.7(a-b), 63.9(e), 

63.10(d)(2)

Notification of initial continuous monitoring system (CMS)/ 

continuous opacity monitoring system (COMS) demonstration

63.9(g), 63.867(a)

Notification and report of compliance status 63.9(h), 63.9(b)(2), 

63.11095(b).

A source must keep the following records:

Recordkeeping

Five years retention of records 63.10(b)(1), 

63.11094(a

Startup, shutdown, and malfunction plan 63.6(e)(3), 

63.866(a)

Records of startup, shutdown, and malfunction 63.6(e)(3)(iii)-(iv), 

63.10(b)(2)(i)-(v)

Records of performance tests 63.10(b)(2)(viii)

Documentation supporting initial notifications and notification of 

compliance status

63.10(b)(2)(xiv), 

63.11094(b)

Records of annual inspections 63.11094(a) and (e)

Record of operating parameter monitoring data, as well as specific 

records to ensure that the monitoring activities will provide an 

indication of the facility’s compliance, are to be kept pursuant to 

63.11094(b) and (f).

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 
7

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 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.

Install, calibrate, maintain, and operate CMS for opacity, or for pressure drop and liquid 

supply pressure for wet scrubber.

Perform initial performance test, Reference Method 18, 25, 271, 1A tests, and 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 

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.

Train personnel to be able to respond to a collection of information.

Transmit, or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way e.g., continuous parameter monitoring system. Although personnel at 

the source still need to evaluate the data, this type of monitoring equipment has significantly

reduced the burden associated with monitoring and recordkeeping. 

5. The Information Collected: Agency Activities, Collection Methodology, and 

Information Management
8

5(a) Agency Activities 

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Integrated Compliance Information System (ICIS) and 

ECHO. 

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 properly installed and operated. 

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard and note the operating conditions under which compliance was 

achieved. 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.

Information contained in the reports is entered is reported by state and local governments 

in the ICIS Air database which is operated and maintained by EPA's Office of Compliance. ICIS

is EPA’s database for the collection, maintenance, and retrieval of compliance data for industrial 

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

enforcement by 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 five

years.

5(c) Small Entity Flexibility

Since these regulations address area sources of HAP emissions (i.e., a source that emits 

less than 10 tons per year of any individual hazardous air pollutant (HAP) or less than 25 tons 

per year of any combination of HAP), the a majority of the respondents (i.e., owners or 

operators of gasoline dispensing facilities, bulk plants, bulk terminals, pipeline breakout 

stations, and pipeline pumping stations) are typically small facilities and many of them meet the 

definition of a small business entity (i.e., small business). Therefore, the impact on small entities 
9

(i.e., small businesses) was taken into consideration during the development of the regulation. 

Due to technical considerations involving the process operations and the types of control 

equipment employed, 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. Construction, 

modification, and reconstruction reports take very little time to complete and are filed only once. 

Equipment leak monitoring and storage tank inspection records are brief, and cargo tank vapor 

tightness documentation will be supplied primarily by independent cargo tank operators and kept 

at the gasoline distribution facility for each cargo tank and railcar that is to be loaded at the 

facility. 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 below Table 1.1 – 1.6: Annual Respondent Burden and Cost – NESHAP for Source 

Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline 

Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal).

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 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 Respondent Burden

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

and reporting requirements is estimated to be 175,308 (Total Labor Hours from Table 1). These 

hours are based on Agency studies and background documents from the development of the 

regulation, Agency knowledge and experience with the NESHAP program, the previously

approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 
10

Managerial $128.02 ($60.98 + 110%) 

Technical $101.05 ($48.12 + 110%)

Clerical $51.37 ($24.46 + 110%)

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

2014, “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 type of industry costs associated with the information collection activities in the 

subject standards are both labor costs which are addressed elsewhere in this ICR and the costs 

associated with continuous monitoring. The capital/startup costs are one time costs when a 

facility becomes subject to the regulation. The annual operation and maintenance costs are the 

ongoing costs to maintain the monitor(s) and other costs such as photocopying and postage.

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

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

(A)

Continuous 

Monitoring 

Device

(B)

Capital/Startup 

Cost for One 

Respondent

(C)

Number of 

New

Respondents 

(D)

Total 

Capital/Startup 

Cost, (B X C)

(E)

Annual O&M 

Costs for One 

Respondent

(F)

Number of 

Respondents 

with O&M

(G)

Total O&M,

(E X F)

CPMS for 

vapor 

processors

$0 0 $0 $1,000

110 ( 10% 

of Bulk 

Terminals)

$110,000

The total capital/startup costs for this ICR are $0. This is the total of column D in the 

above table. 

The total operation and maintenance (O&M) costs for this ICR are $110,000. This is the 

total of column G. 

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

industry over the next three years of the ICR is estimated to be $110,000.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs 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, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 
11

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

$1,085,741. 

This cost is based on the average hourly labor rate as follows:

Managerial $62.90 (GS-13, Step 5, $39.31 + 60%) 

Technical $46.67 (GS-12, Step 1, $29.17 + 60%)

Clerical $25.25 (GS-6, Step 3, $15.78 + 60%)

These rates are from the Office of Personnel Management (OPM), 2014 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 Table 2: Average Annual EPA Burden and Cost – NESHAP for Source 

Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline 

Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

19,120 existing respondents will incur a reporting or recordkeeping burden as a result of the 

NESHAP. This estimate consists of the following: 1,100 bulk terminals, 460 pipeline breakout 

stations, 1,800 pipeline pumping stations, 5,900 bulk plants, and 9,860 gasoline dispensing 

facilities. It is estimated that no additional respondents per year will become subject. The 

overall average number of respondents, as shown in the table below, is 19,120 per year. 

The number of respondents is calculated using the following table that 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 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 19,120 0 0 19,120

2 0 19,120 0 0 19,120

3 0 19,120 0 0 19,120
12

Number of Respondents

Average 0 19,120 0 0 19,120

1

New respondents include sources with constructed, reconstructed and modified affected facilities. 

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 19,120. 

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

Initial Notification 19,120 0 0 0

Initial Performance Test 14,695 0 0 0

Notification of Compliance 

Status 14,695 0 0 0

Storage Tank Inspections 1,560 1 0 1,560

Semiannual Compliance 

Report 1,714 2 0 3,428

Non-routine reports 1,912 1 0 1,912

Total 6,900

The number of Total Annual Responses is 6,900. 

The total annual labor costs are $17,163,140. Details regarding these estimates may be 

found below in Table 1.1 – 1.6: Annual Respondent Burden and Cost – NESHAP for Gasoline 

Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing 

Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC) (Renewal).

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, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 175,308. Details regarding these estimates may be found 

in Table 1.1 – 1.6: Annual Respondent Burden and Cost – NESHAP for Source Categories: 

Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline Facilities, and Gasoline Dispensing 
13

Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) (Renewal). 

Furthermore, the annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 25 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $110,000. The 

cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and Maintenance 

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

23,856 labor hours at a cost of $1,085,741. See Table 2: Average Annual EPA Burden and Cost 

– NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, Bulk Plants, Pipeline 

Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and 

CCCCCC) (Renewal).

6(f) Reasons for Change in Burden

The overall increase in burden from the most recently approved ICR is due to an 

adjustment to the labor rates, mathematical corrections, and corrections to the number 

respondents required for each burden item. The previous ICR contained several errors and did 

not correctly reflect the number of respondents subject to each reporting and recordkeeping 

requirement after the initial 3-year rule implementation period. Further, the burden estimates did 

not match the assumptions stated in the table footnotes. Specifically, the previous ICR did not 

account for the burden associated with equipment leak inspections. In this ICR, we have 

conducted a thorough review of the assumptions and updated all burden estimates, as 

appropriate. 

There is however, a small decrease in the Agency cost from the previous ICR due to a 

mathematical correction. The previous ICR incorrectly calculated and overestimated Agency

labor costs. This correction results in an apparent decrease in Agency cost. 

6(g) Burden Statement

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

is estimated to average 25 hours per response. Burden means the total time, effort, or financial 

resources expended by 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 systems 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 instructions 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.
14

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 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 EPA-HQ-OECA-2014-0095. 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 system, select “search,” then key in the docket ID number identified 

in this document. The documents are also available for public viewing at the Enforcement and 

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

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1927. Also, you can send comments to the Office of 

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

Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

Number EPA-HQ-OECA-2014-0095 and OMB Control Number 2060-0620 in any

correspondence. 

Part B of the Supporting Statement

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

information.
15

Table 1.1: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, 

Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC) 

(Renewal)

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 year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per 

year 

(Ex0.1)

(H) 

Total Cost 

per year b

1.1 Bulk Terminals

(a) Read and understand rule requirements c

6 1 6 0 0 0 0 0

(b) Prepare Initial Notification c

4 0 4 0 0 0 0 0

(c) Perform Initial Performance Test c

175 0 175 0 0 0 0 0

(d) Prepare Notification of Compliance Status c

4 0 4 0 0 0 0 0

(e) Perform annual storage tank inspection d

12 1 12 1,100 13,200 660 1,320 $1,486,161.60

(f) Perform equipment leak inspections d

2 12 24 1,100 26,400 1,320 2,640 2972323.2

(g) Keep records of performance tests, storage 

tank and equipment leak inspections, and cargo 

tank vapor tightness documentation

0.75 12 9 1,100 9,900 495 990 $1,114,621.20

(h) Submit semiannual compliance report

4 2 8 1,100 8,800 440 880 $990,774.40

Subtotal Reporting [(h)]

10,120 $990,774.40

Subtotal Recordkeeping [(e) - (g)]

56,925 $5,573,106.00

TOTAL

67,045 $6,563,880.40

Assumptions for Table 1.1:

a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 1,100 existing bulk 

terminals.

b This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2: Civilian Workers, by 

Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit 

packages available to those employed by private industry.

c Reading the rule, preparing Initial Notification, performing initial performance test, and preparing Notification of Compliance Status are one-time activities. 
16

d Assumed that all respondents are currently performing annual storage tank inspections; and, that all are currently performing equipment leak inspections at least 

once per month.
17

Table 1.2: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, 

Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC)

(Renewal)

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) 

Respondent

per year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Mgmt.

person 

hours per 

year 

(Ex0.05)

(G) 

Clerical 

person 

hours per 

year 

(Ex0.1)

(H) 

Total Cost 

per year b

1.2 Pipeline Breakout Stations

(a) Read and understand rule requirementsc

6 1 6 0 0 0 0 0

(b) Prepare Initial Notificationc

8 1 8 0 0 0 0 0

(c) Prepare Notification of Compliance Statusc

8 1 8 0 0 0 0 0

(d) Perform annual storage tank inspectiond

12 1 12 460 5,520 276 552 $621,485.76

(e) Perform equipment leak inspectionsd

2 12 24 460 11040 552 1104 1242971.52

(f) Keep records of storage tank and equipment leak 

inspectionsd16 1 16 460 7,360 368 736 $828,647.68

(g) Submit semiannual compliance report

4 2 8 460 3,680 184 368 $414,323.84

Subtotal Reporting [(g)]

4,232 $414,323.84

Subtotal Recordkeeping [(d) - (f)]

27,508 $2,693,104.96

TOTAL

31,740 $3,107,428.80

Assumptions for Table 1.2:

a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 460 existing pipeline 

breakout stations.

b This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2: Civilian Workers, by 

Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit 

packages available to those employed by private industry.

c Reading the rule, preparing Initial Notification, and preparing Notification of Compliance Status are one-time activities. 

d Assumed that all respondents are currently performing annual storage tank inspections; and, that all are currently performing equipment leak inspections at least 

once per month.
18

Table 1.3: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, 

Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC)

(Renewal)

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 year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per 

year 

(Ex0.1)

(H) 

Total Cost 

per year b

1.3 Pipeline Pumping Stations

(a) Read and understand rule requirements c

4 1 4 0 0 0 0 0

(b) Prepare Initial Notification c

1 1 1 0 0 0 0 0

(c) Prepare Notification of Compliance Status c

1 1 1 0 0 0 0 0

(d) Perform equipment leak inspections 1 12 12 1,800 21,600 1,080 2,160 $2,431,900.80

(e) Keep records of equipment leak inspections

d 0.1 12 1.2 1,800 2,160 108 216 $243,190.08

(f) Submit semiannual compliance report e

0.25 2 0.5 36 18 0.9 1.8 $2,026.58

Subtotal Reporting [(f)] 21 $2,026.58

Subtotal Recordkeeping [(d) - (e)] 27,324 $2,675,090.88

TOTAL 27,345 $2,677,117.46

Assumptions for Table 1.3:

a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 1,800 existing pipeline 

pumping stations.

b This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2: Civilian Workers, by 

Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit 

packages available to those employed by private industry.

c Reading the rule, preparing Initial Notification, and preparing Notification of Compliance Status are one-time activities. 

d Assumed that all respondents are currently performing equipment leak inspections at least once per month.

e Assumed that, on an annual average basis, 2 percent of facilities (36) will be required to submit a semiannual compliance report because of delays in repairing 

equipment leaks.
19

Table 1.4: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, 

Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC)

(Renewal)

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 year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per 

year 

(Ex0.1)

(H) 

Total Cost 

per year b

1.4 Bulk Plants

(a) Read and understand rule requirements (in 

States without submerged fill rules)c

4 1 4 0 0 0 0 0

(b) Read and understand rule requirements (in 

States with submerged fill rules)c

2 1 2 0 0 0 0 0

(c) Prepare Initial Notification c

2 1 2 0 0 0 0 0

(d) Prepare Notification of Compliance Status c

1 1 1 0 0 0 0 0

(e) Perform equipment leak inspections d

0.25 12 3 5,900 17,700 885 1,770 $1,992,807.60

(f) Keep records of equipment leak inspections d

0.1 12 1.2 5,900 7,080 354 708 $797,123.04

(g) Submit semiannual compliance report e

1 2 2 118 236 11.8 23.6 $26,570.77

Subtotal Reporting [(g)]

271 $26,570.77

Subtotal Recordkeeping [(e) - (f)]

28,497 $2,789,930.64

TOTAL

28,768 $2,816,501.41

Assumptions for Table 1.4:

a We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 5,900 existing bulk 

plants. 

b This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2: Civilian Workers, by 

Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit 

packages available to those employed by private industry.
20

c Reading the rule, preparing Initial Notification, and preparing Notification of Compliance Status are one-time activities. Note: 25% of the respondents are in 

States without bulk plant rules and 75% are in States with rules.

d Assumed that all respondents are currently performing equipment leak inspections at least once per month.

e Assumed that, on an annual average basis, 2 percent of facilities (118) will be required to submit a semiannual compliance report because of delays in repairing 

equipment leaks.
21

Table 1.5: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, 

Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC)

(Renewal)

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 year a

(E) 

Technical 

personhours per 

year 

(E=CxD)

(F) 

Management 

person hours 

per year 

(Ex0.05)

(G) 

Clerical 

person 

hours 

per 

year 

(Ex0.1)

(H) 

Total Cost 

per year b

1.5 Gasoline Dispensing Facilities

(a) Read and understand rule requirements (facilities 

>100k already in compliance) c 0.5 1 0.5 0 0 0 0 0

(b) Read and understand rule requirements (facilities 

<100k already in compliance)c 0.25 0.33 0.08 0 0 0 0 0

(c) initial vapor balance system testingc6 1 6 0 0 0 0 0

(d) Prepare Initial Notificationc1 1 1 0 0 0 0 0

(d) Prepare Notification of Compliance Statusc1 1 1 0 0 0 0 0

(e) vapor balance system testing d6 0.3 1.8 9,860 17,748 887.4 1,774.8 $1,998,211.82

Subtotal Reporting [(e)] 20,410 $1,998,211.82

Subtotal Recordkeeping [NA] 0 0

TOTAL 20,410 $1,998,211.82

Assumptions for Table 1.5:

a We expect no new affected sources the next 3 years of this ICR. Of the total 340,000 facilities, 243,587 facilities with throughputs of <100,000 gpm that are 

complying with a SLT submerged fill requirement, and for the 85,340 facilities with throughputs of >100,000 gpm that are complying with a state (SLT) vapor 

balancing requirement, there are no other reporting or recordkeeping requirements associated with this rule for this ICR. Therefore, the estimated number of 

respondents with recordkeeping and reporting requirements remains unchanged from the previous ICR as 11,073 gasoline dispensing facilities, of which 9,860 

install vapor balance system and 1,213 must add submerged filled as a result of this rulemaking. 

b This ICR uses the following labor rates: $128.02 per hour for Executive, Administrative, and Managerial labor; $101.05 per hour for Technical labor, and $51.37 

per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, March 2014, “Table 2: Civilian Workers, by 

Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit 

packages available to those employed by private industry.
22

c Reading the rule, preparing Initial Notification, conducting an initial vapor balance system test, and preparing Notification of Compliance Status are one-time 

activities. 

d Assume vapor balance pressure retesting require every three years. There are 9,860 gasoline dispensing facilities would have to retest. 

Table 1.6: Annual Respondent Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, 

Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC)

(Renewal)

Burden Item

Average 

Number of 

Respondents 

per year

Total personhours per 

year

Total Cost per 

year

Subtotal for Reporting Requirements

19,120

35,054 $14,179,557.90 

Subtotal for Recordkeeping Requirements 140,254 $2,983,582.00 

TOTAL LABOR BURDEN AND COST 175,308 $17,163,140 

Sector Number of 

Sources

Number of 

Responses

Reporting Burden 

(Hr)

Recordkeeping 

Burden (Hr)

Bulk Terminals 1,100 3,410 10,120 56,925

Pipeline Breakout Stations 460 1,426 4,232 27,508

Pipeline Pumping Stations 1,800 252 21 27,324

Bulk Plants 5,900 826 271 28,497

Gasoline Dispensing 

Facilities 9,860 986 20,410 0

Total 19,120 6,900 35,054 140,254
23

Table 2: Average Annual EPA Burden and Cost – NESHAP for Source Categories: Gasoline Distribution Bulk Terminals, 

Bulk Plants, Pipeline Facilities, and Gasoline Dispensing Facilities (40 CFR Part 63, Subparts BBBBBB and CCCCCC)

(Renewal)

Activity

(A) 

EPA 

personhours per 

occurrence

(B) 

No. of 

occurrences 

per plant 

per year

(C) 

EPA 

person 

hours per 

plant per 

year 

(AxB)

(D) 

Plants per 

year a 

(E) 

Technical 

personhours per 

year (CxD)

(F) 

Management 

personhours per 

year 

(Ex0.05)

(G) 

Clerical 

personhours per 

year 

(Ex0.1)

(H) 

Cost, $ b

Review of storage tank inspection reports 4 1 4 1,560 6,240 312 624 $326,601.60

Review semiannual compliance reports 2 2 4 1,714 6,856 342.8 685.6 $358,843.04

Review of other, non-routine reports c4 1 4 1,912 7,648 382.4 764.8 $400,296.32

TOTAL LABOR BURDEN AND COST 23,855.6 $1,085,740.96

(rounded) 23,856 $1,085,741

Assumptions for Table 2:

a Number of activities per year is the sum of the number of applicable respondents from Tables 1.1 through 1.5.

b This cost is based on the average hourly labor rate from the Office of Personnel Management (OPM) “2014 

General Schedule” which excludes locality rates of pay. 

c Assumed that 10 percent of affected facilities industry-wide will submit non-routine reports each year. (19,120 x 

10% = 1,912)