SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction 

or Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 

60, Subpart K) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction or 

Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, 

Subpart K) (Renewal), EPA ICR Number 1797.07, OMB Control Number 2060-0442. 

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Storage Vessels for Petroleum 

Liquids for Which Construction, Reconstruction or Modification Commenced After June 11, 

1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K were proposed on June 11, 1973,

and promulgated on March 8, 1974. These regulations apply to existing facilities that store 

petroleum liquids in storage vessels with a storage capacity greater than 151,416 liters (40,000 

gallons), including: storage vessels with capacity greater than 151,416 liters (40,000 gallons), 

but not exceeding 246,052 liters (65,000 gallons), and where construction or modification 

commenced after March 8, 1974, and prior to May 19, 1978; and storage vessels that have a 

capacity greater than 246,052 liters (65,000 gallons), and where construction or modification 

commenced after June 11, 1973, and prior to May 19, 1978. Facilities that are not subject to 

these standards are storage vessels of petroleum or condensate stored, processed, and/or treated 

at a drilling and production facility prior to custody transfer. This information is being collected 

to assure compliance with 40 CFR Part 60, Subpart K.

In general, all NSPS standards require initial notification reports, 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 NSPS.

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

documents, and retain the file for at least two years following the generation date of such 

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 U.S.

Environmental Protection Agency (EPA) regional office.

The petroleum liquid storage vessels are owned and operated by the private industry (the 

“Affected Public”). None of these storage vessels are owned by either state, local, tribal or the 

Federal government. They are all owned and operated by privately-owned, for-profit businesses.
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We assume that they will all respond to EPA inquiries. The “burden” to the “Affected Public” 

may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for Storage 

Vessels for Petroleum Liquids for Which Construction, Reconstruction or Modification 

Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) 

(Renewal). The “burden” to the Federal Government is attributed entirely to work performed by 

either Federal employees or government contractors, and may be found below in Table 2: 

Average Annual EPA Burden and Cost – NSPS for Storage Vessels for Petroleum Liquids for 

Which Construction, Reconstruction or Modification Commenced After June 11, 1973 and Prior 

to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal).

Based on the findings of the EPA 2011 Petroleum Refinery Information Collection 

Request, there are approximately 149 refineries, of which 69 facilities had a total of 432 storage 

vessels subject to NSPS Subpart K. Therefore, we estimate that an average of 6.3 storage vessels

at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the 

plant site).

Over the next three years, approximately 69 respondents per year will be subject to these

standards. No additional respondents per year will become subject to the standard because 

Subpart K does not apply to new sources.

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

without any “Terms of Clearance”.

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 

Administrator determines has been adequately 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 every 

eight years.

In addition, section 114(a) states that the Administrator may require any owner/operator 

subject to any requirement of this Act to: 
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(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.

In the Administrator's judgment, volatile organic compounds (VOCs) emissions from 

storage vessels for petroleum liquids either cause or contribute to air pollution that may 

reasonably be anticipated to endanger public health and/or welfare. Therefore, the NSPS were 

promulgated for this source category at 40 CFR Part 60, Subpart K.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard 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 these 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 standard 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 standard are being met. 

The performance test may also be observed.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR Part 60, 

Subpart K.

3(a) Non-duplication

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 
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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, duplication does 

not exist.

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 (80 FR 32116) on June 5, 2015. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency has consulted industry experts and internal data sources to project the 

number of affected facilities and industry growth over the next three years. The primary source 

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

provisions in the standard, is the Integrated Compliance Information System (ICIS). ICIS is 

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

and government-owned facilities. 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 these standards as they were being developed and these

standards have been reviewed previously to determine the minimum information needed for 

compliance purposes. In developing this ICR, we contacted: 1) the American Petroleum Institute 

(API), at (202) 682-8000; and 2) the Western States Petroleum Association (WSPA), at (916) 

498-7750. No comments were received from the consultations. However, we obtained 

information on the number of facilities from the Agency’s 2011 Petroleum Refinery ICR. 

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. 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 frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.
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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.

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 (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).

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 facilities that have 

petroleum liquid storage vessels meeting the rule criteria. The United States Standard Industrial 

Classification (SIC) codes and the corresponding North American Industry Classification System 

(NAICS) codes for such facilities can be found in the following table:

Standard (40 CFR Part 60, Subpart K) SIC Codes NAICS Codes

Petroleum refineries 2911 32411

Asphalt paving mixture and block manufacturing 2951 324121

Asphalt shingle and coating materials manufacturing 2952 324122

Petroleum lubricating oil and grease manufacturing 2992 324191

All other petroleum and coal products manufacturing 2999 324199

4(b) Information Requested

(i) Data Items

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

Vessels for Petroleum Liquids for Which Construction, Reconstruction or Modification 

Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) 

(Renewal).
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A source must make the following reports:

Notifications

Notification of construction/reconstruction. 60.7(a)(1)

Notification of physical or operational change. 60.7(a)(4)

A source must keep the following records:

Recordkeeping

Records are required to be retained for two years. 60.7(f)

Owner/Operator shall maintain a record of the petroleum liquid stored, 

the period of storage, and the maximum true vapor pressure of that 

liquid during the respective storage period.

60.113(a)

Maintain records of the occurrence and duration of any startup, 

shutdown, or malfunction.

60.7(b)

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.

(ii) Respondent Activities

Respondent Activities

Familiarization with the regulatory requirements.

Install, calibrate, maintain, and operate floating roof or vapor recovery system.

Perform initial performance test, according to manufacturers’ instructions, 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.
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Respondent Activities

Develop, acquire, install, and utilize technology and systems for the purpose of processing and 

maintaining information.

Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and 

providing information.

Adjust the existing ways to comply with any previously applicable instructions and 

requirements.

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

Transmit or otherwise disclose the information.

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

Management

5(a) Agency Activities

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

storage, and distribution of the 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 industry.

Audit facility records.

Input, analyze, and maintain data in the Enforcement and Compliance History Online (ECHO) 

and ICIS.

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 to 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 
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determinations.

Information contained in the reports 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 two

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). However, the 

impact on small entities (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. 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 below in Table 1: Annual Respondent Burden and Cost – NSPS for Storage Vessels for 

Petroleum Liquids for Which Construction, Reconstruction or Modification Commenced After 

June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) (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 the subpart 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 
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and reporting requirements is estimated to be 321 (Total Labor Hours from Table 1 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 previouslyapproved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $129.93 ($61.87+ 110%)

Technical $103.97 ($49.51 + 110%)

Clerical $51.79 ($24.66 + 110%)

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

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 only costs to the regulated industry resulting from information collection activities 

required by the subject standards are labor costs. 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 maintenance costs.

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. 

The average annual Agency cost during the three years of the ICR is estimated to be $72.

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%)
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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 – NSPS for Storage 

Vessels for Petroleum Liquids for Which Construction, Reconstruction or Modification 

Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) 

(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 

69 existing respondents will be subject to the standard. Of these respondents, only one percent 

will have reporting requirements. 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 69

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 0.69 68.31 0 69

2 0 0.69 68.31 0 69

3 0 0.69 68.31 0 69

Average 69

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 69. 

The total number of annual responses per year is calculated using the following table: 
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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

Notification of physical or 

operational change 0.69 1 68.31 69

Total 69

The number of Total Annual Responses is 69.

The total annual labor costs are $32,200. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost – NSPS for Storage Vessels for 

Petroleum Liquids for Which Construction, Reconstruction or Modification Commenced After 

June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) (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 (below), respectively, and summarized below.

(i) Respondent Tally

The total annual labor hours are 321. Details regarding these estimates may be found 

below in Table 1. Annual Respondent Burden and Cost – NSPS for Storage Vessels for 

Petroleum Liquids for Which Construction, Reconstruction or Modification Commenced 

After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

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

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

There are no annual capital/startup and O&M costs to the regulated entity. The cost 

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

(O&M) Costs.
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(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 2

labor hours at a cost of $72. See below in Table 2: Average Annual EPA Burden and Cost –

NSPS for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction or 

Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, 

Subpart K) (Renewal).

We assume that burdens for managerial tasks take 5% of the time required for technical 

tasks because the typical tasks for managers are to review and approve reports. Clerical burdens 

are assumed to take 10% of the time required for technical tasks because the typical duties of 

clerical staff are to proofread the reports, make copies and maintain records.

6(f) Reasons for Change in Burden

There is a substantial decrease in burden from the previous ICR due to a decrease in the 

number of sources. Many storage vessels have been modified and become subject to Subpart 

Kb. Based on information obtained from the Agency’s 2011 Petroleum Refinery ICR, the 

number of facilities subject to this regulation has decreased from 220 to 69. The update in 

source count results in a decrease in the labor hours, labor costs, and number of responses. 

6(g) Burden Statement

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

is estimated to average five 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.

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-2012-0677. 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 
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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), 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 

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

number for the docket center is (202) 566-1752. 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-2012-0677 and OMB Control Number 2060-0442 in any 

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NSPS for Storage Vessels for Petroleum Liquids for Which Construction, 

Reconstruction or Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K)

 (Renewal)

Burden Item

(A)

Technical 

personhours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Technical 

personhours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E) 

Technical 

person 

hours per 

year

(E=CxD)

(F)

Management

hours per 

year

(F=Ex0.05)

(G) 

Clerical 

hours per 

year

(G=Ex0.1)

(H) 

Total Cost 

per year 

($) b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

A. Familiarize with regulatory 

requirements c 1 1 1 69 69 3.45 6.9 $7,979.54 

B. Required activities: See 3D

 i. Monitoring of operations 

and emissions d See 3D

C. Gather existing information See 3D and 

4E

D. Write notification

 i. Notification of 

reconstruction/modification N/A

 ii. Notification of physical or 

operational change e 4 1 4 0.69 2.76 0.138 0.276 $319.18 

Subtotal for Reporting 

Requirements 83 $8,299

4. Recordkeeping requirements

A. Familiarize with regulatory 

requirements c See 3A

B. Plan activities See 3E
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C. Implement activities See 3E

D. Develop record system N/A

E. Time to enter and transmit 

information: 

 i. Records of startup, 

shutdown, or malfunction 1 1 1 69 69 3.45 6.9 $7,979.54 

 ii. Record petroleum liquid 

stored 0.5 1 0.5 69 34.5 1.725 3.45 $3,989.77 

 iii. Record of storage 

performance tests 0.5 1 0.5 69 34.5 1.725 3.45 $3,989.77 

 iv. Record true vapor pressure 

of liquid stored 1 1 1 69 69 3.45 6.9 $7,979.54 

F. Time to train personnel N/A

G. Time for audits N/A

Subtotal for Recordkeeping 

Requirements 238 $23,939

TOTAL ANNUAL BURDEN 

AND COST (rounded) f 321 $32,200

TOTAL CAPITAL AND O&M 

COST (rounded) f $0

GRAND TOTAL (rounded) f $32,200

Assumptions:

a

 We assume there are approximately 69 sources currently subject to the standard, and that there will be no new sources over the three-year period of this ICR. 

We assumed there is approximately 6.3 petroleum liquids storage vessels per plant site. b

 This ICR uses the following labor rates: $103.97 for technical, $129.93 for managerial, and $51.79 for clerical labor. These rates are from the United States 

Department of Labor, Bureau of Labor Statistics, June 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. c

 This ICR assumes all respondents will take 1 hour to familiarize with regulatory requirements. d

 Monitoring and recordkeeping operations include maintaining records of the petroleum liquid stored, the period of storage, and the maximum true vapor 

pressure of that liquid during the respective storage period, unless the affected facility is equipped with a vapor recovery and return or disposal system in 

accordance with the requirements in 40 CFR 60.112, or stores liquid with a Reid vapor pressure of less than 6.9 kPa (1.0 psia), provided the true vapor pressure 

does not exceed that value.

e

 We assume only one percent of respondents (i.e., 0.01 of 69, or 0.69 respondents) will make physical or operational changes to their tanks in such way that will 

trigger reporting requirements under the standard.
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f Figures have been rounded 3 significant figures. Figures may not add exactly due to rounding.
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Table 2: Average Annual EPA Burden and Cost – NSPS for Storage Vessels for Petroleum Liquids for Which Construction, 

Reconstruction or Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K)

(Renewal)

Burden Item

(A)

Technical 

personhours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C)

Technical 

personhours per 

respondent 

per year

(C=AxB)

(D)

Respondents 

per year a

(E) 

Technical 

person 

hours per 

year

(E=CxD)

(F)

Management 

hours per 

year

(F=Ex0.05)

(G) 

Clerical 

hours per 

year

(G=Ex0.1)

(H) 

Total Cost 

per year 

($) b

Notification of 

reconstruction/modification N/A

Notification of physical or 

operational change c 2 1 2 0.69 1.38 0.07 0.14 $72.23

TOTAL ANNUAL 

BURDEN AND COST 

(rounded) d

2 $72

Assumptions:

a

 We assume there are approximately 69 sources currently subject to the standard, and that there will be no new sources over the three-year period of this ICR. b

 This ICR uses the following labor rates: $46.67 for technical, $62.90 for managerial, and $25.25 for clerical labor. 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.

c

 We assume only one percent of respondents (i.e., 0.01 of 69, or 0.69 respondents) will make physical or operational changes to their tanks in such way that will 

trigger reporting requirements under the standard.

d

 Figures have been rounded 3 significant figures. Figures may not add exactly due to rounding.