SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

The Consolidated Air Rule (CAR) for the Synthetic Organic Chemical Manufacturing 

Industry (SOCMI) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

The Consolidated Air Rule (CAR) for the Synthetic Organic Chemical Manufacturing Industry 

(SOCMI) (Renewal), EPA ICR Number 1854.09, OMB Control Number 2060-0443.

1(b) Short Characterization/Abstract

The Consolidated Federal Air Rule (CAR) for the Synthetic Organic Chemical 

Manufacturing Industry (SOCMI) at 40 CFR part 65 was promulgated on December 14, 2000. 

The CAR is an optional alternative compliance approach for plant sites that must comply with 

existing subparts in the Code of Federal Regulations (CFR). The CAR is a consolidation of 

major portions of 14 different New Source Performance Standards (NSPS) and National 

Emission Standards for Hazardous Air Pollutants (NESHAP) pertaining to storage vessels, 

process vents, transfer racks, equipment leaks, and the general provisions for the three applicable 

parts (40 CFR parts 60, 61, and 63). These subparts from 40 CFR parts 60, 61, and 63 are 

referred to as “referencing subparts” because they have been amended to refer to the CAR as a 

compliance alternative. The referencing subparts include 40 CFR part 60, subparts Ka, Kb, VV, 

VVa, DDD, III, NNN, and RRR; 40 CFR part 61, subparts BB, Y, and V; 40 CFR part 63, 

subparts F, G, H, and I.

This information collection request (ICR) is for the CAR and its referencing subparts. 

The burden estimates in this ICR reflect the addition of the Direct Final Rule for Revisions to the 

CAR (72 FR 48938; August 27, 2007); other burden estimates are consistent with the most 

recently approved ICR for the CAR. This information is being collected to assure compliance 

with 40 CFR part 65.

Compliance with the CAR is a voluntary alternative. Sources may continue to comply

with existing applicable rules or may choose to comply with the consolidated rule. All existing 

sources must be in compliance with the requirements of the CAR and/or its referencing subparts 

within three years of the effective date (i.e., promulgation date) of the appropriate standard for 

the affected source. All new sources must be in compliance with the requirements of the CAR 

and/or its referencing subparts upon startup or the promulgation date of standards for an affected 

source, whichever is later. 

When preparing renewals for the CAR, or the referencing subparts, estimates are made of 

the percentage of existing sources that will opt to comply with the CAR in lieu of the referencing 

subparts. It is estimated that 25 percent of non-Hazardous Organic NESHAP (HON) sources 

will opt to comply with the CAR if the per-source burden of complying with the CAR is less 

than the per-source burden of complying with the referencing subpart. For those referencing 
2

subparts for which the per-source burden of complying with the CAR is higher than the persource burden of complying with the referencing subpart (subparts Ka, Kb, Y, VV, VVa, III, 

NNN, RRR, and DDD), it is estimated that 5 percent of sources will opt to comply with the 

CAR. It is assumed that all new sources will initially comply with the appropriate referencing 

subpart. Based on these assumptions, we estimate the consolidated collection will involve 4,618

respondents. The number of respondents under each referencing subpart that will opt to comply

with the CAR is detailed in Table 4: Estimated Number of Sources Subject to Referencing 

Subparts that Will Opt to comply with the CAR. 

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

without any “Terms of Clearance.”

The “Affected Public” are owners or operators of synthetic organic chemical 

manufacturing facilities. The “burden” to the Affected Public may be found below in Table 8: 

Summary of Respondent and Agency Burden and Cost for Referencing Subparts and the CAR. 

The “burden” to the “Federal Government” is attributed entirely to work performed by either 

Federal employees or government contractors and also may be found below in Table 8: 

Summary of Respondent and Agency Burden and Cost for Referencing Subparts and the CAR.

The CAR (Consolidated Air Rule)

In general, the NSPS, NESHAP, CAR, and maximum achievable control technology

(MACT) 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 the standard. 

The Direct Final Rule for Revisions to the CAR includes direct final amendments to the 

General Provisions of the CAR which allow source owners and operators to petition the 

Administrator for an extension of the regulatory deadline to conduct performance tests during 

force majeure events. A force majeure event is an event caused by circumstances beyond the 

control of the affected facility, its contractors, or any entity controlled by the affected facility that 

resulted in not meeting the regulatory requirement to conduct performance tests within the 

specified timeframe despite the affected facility’s best efforts to fulfill the obligation. Examples 

of such events are acts of nature, acts of war, terrorism, equipment failure, or safety hazard 

beyond the control of the affected facility. The source owner or operator must provide to the 

Administrator a written description of the event and a rationale for attributing the delay in testing 

beyond the regulatory deadline to the force majeure; describe the measures taken or to be taken 

to minimize the delay; and identify a date by which the performance test would be conducted.

NSPS subpart Ka: Storage Vessels for Petroleum Liquids

The NSPS for subpart Ka were proposed on May 18, 1978, and promulgated on April 4, 
3

1980, and was last amended on December 14, 2000. These standards apply to storage vessels of 

petroleum liquids that have a storage capacity greater than 151,416 (40,000 gallons), and for 

which construction, reconstruction, or modification commenced after May 18, 1978 and prior to 

July 23, 1984. There is a de minimis exemption located at §60.110a(b). The regulated pollutants 

are volatile organic compounds (VOC). The universe of sources subject to NSPS subpart Ka is 

closed. Any new sources will be subject to NSPS subpart Kb, the most recent VOC standard 

applicable to storage vessels. This information is being collected to assure compliance with 40 

CFR part 60, subpart Ka.

NSPS subpart Kb: Volatile Organic Liquid (VOL) Storage Vessels

The NSPS for subpart Kb were proposed on July 23, 1984, and promulgated on April 8, 

1987, and was last amended on October 15, 2003. These standards apply to each storage vessel 

with a capacity greater than or equal to 40 cubic meters that is used to store volatile organic 

liquids, for which construction, reconstruction, or modification commenced after July 23, 1984. 

There are exemptions for specific storage vessels listed in §§60.110b(b), 60.110b(c), and 

60.110b(d). The standards include visual inspection, leak detection, and repair for equipment 

configurations including fixed and floating roofs. The regulated pollutants are VOC. This 

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

NSPS subpart VV: Equipment Leaks of VOC in the SOCMI Industry

The NSPS for Emissions of VOC from Equipment Leaks in the SOCMI Industry were 

proposed on January 5, 1981, and promulgated on October 18, 1983, and was last amended on 

June 2, 2008. They apply to specific pieces of equipment contained within a process unit in the 

synthetic organic chemicals manufacturing industry which was constructed, modified, or 

reconstructed after the date of proposal and on or before November 7, 2006, and which produce 

as an intermediate or final product, one or more of the chemicals listed in §60.489. These 

include pumps in light liquid service, compressors, pressure relief devices in gas/vapor service, 

sampling connection systems, open-ended valves or lines, valves in gas/vapor service and light 

liquid service, pumps and valves in heavy liquid service, pressure relief devices in light liquid or 

heavy liquid service, flanges, and other connectors. The regulated pollutants are VOC. The 

universe of sources subject to NSPS subpart VV is closed. Any new sources will be subject to 

NSPS subpart VVa, the most recent VOC standard applicable to equipment leaks. This 

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

NSPS subpart VVa: Equipment Leaks of VOC in the SOCMI Industry

NSPS subpart VVa is a standard that applies to equipment contained within a SOCMI

process unit that is constructed, modified, or reconstructed after November 7, 2006, and was last 

amended on June 2, 2008. The regulated pollutants are VOC. This information is being 

collected to assure compliance with 40 CFR part 60, subpart VVa.
4

NSPS subpart DDD: VOC Emissions from the Polymer Manufacturing Industry

The NSPS for the polymer manufacturing industry were proposed on both September 30, 

1987 and January 10, 1989, and promulgated on December 11, 1990, and was last amended on 

December 14, 2000. These standards apply to facilities involved in the manufacture of 

polypropylene, polystyrene, or poly (ethylene terephthalate) commencing construction, 

modification, or reconstruction after the date of proposal or after January 10, 1989, depending on 

the process section. The affected facilities include: 1) For polypropylene and polyethylene 

manufacturing: each raw material preparation section, each polymerization reaction section, each 

material recovery section, each product finishing section, and each product storage; 2) For 

polystyrene manufacturing processes: each material recovery section; and 3) For polyethylene 

(terephthalate) manufacturing: each polymerization reaction section. For equipment leaks, the 

affected facilities are each group of fugitive emissions equipment within any process unit. The 

regulated pollutants are VOC. This information is being collected to assure compliance with 40 

CFR part 60, subpart DDD.

NSPS subpart III: VOC Emissions from SOCMI Air Oxidation Unit Processes

The NSPS for the SOCMI Air Oxidation Unit Processes were proposed on October 21, 

1983, and promulgated on June 29, 1990, and was last amended on December 14, 2000. These 

standards apply to the following facilities for which construction, modification or reconstruction 

is commenced after the date of proposal: 1) Each air oxidation reactor not discharging its vent 

stream into a recovery device; 2) Each combination of an air oxidation reactor and the recovery

system into which its vent stream is discharged; and 3) Each combination of two or more air 

oxidation reactors and the common recovery system into which their vent streams are 

discharged. The standards apply to the affected facility which produces one or more of the 

chemicals listed in §60.617 as a product, co-product, byproduct, or intermediate. The regulated 

pollutants are VOC. This information is being collected to assure compliance with 40 CFR part 

60, subpart III.

NSPS subpart NNN: VOC Emissions from SOCMI Distillation Operations

The NSPS for the SOCMI Distillation Operations were proposed on December 30, 1983, 

and promulgated on June 29, 1990, and was last amended on December 14, 2000. These 

standards apply to the following facilities for which construction, modification or reconstruction 

is commenced after the date of proposal: 1) Each distillation unit not discharging its vent stream 

into a recovery device; 2) Each combination of a distillation unit and the recovery system into 

which its vent stream is discharged; and 3) Each combination of two or more distillation units 

and the common recovery system into which their vent streams are discharged. The standards

apply to affected facilities producing one or more of the chemicals listed in §60.667 as a product, 

co-product, by-product, or intermediate. The regulated pollutants are VOC. This information is 

being collected to assure compliance with 40 CFR part 60, subpart NNN.
5

NSPS subpart RRR: VOC Emissions from SOCMI Reactor Processes

The NSPS for the synthetic organic chemical manufacturing industry (SOCMI) Reactor 

Processes were proposed on June 29, 1990, and promulgated on August 31, 1993, and was lastamended on December 14, 2000. These standards apply to affected facilities commencing 

construction, modification or reconstruction after the date of proposal: (1) Each reactor process 

not discharging its vent stream into a recovery system; (2) Each combination of a reactor 

processes and the recovery system into which its vent stream is discharged; (3) Each 

combination of two or more reactor processes and the common recovery system into which their 

vent streams are discharged. The standard applies to affected facilities producing one or more of 

the chemicals listed in §60.707 as a product, co-product, by-product, or intermediate. The 

regulated pollutants are VOC. This information is being collected to assure compliance with 40 

CFR part 60, subpart RRR.

NESHAP subpart BB: Benzene Emissions from Benzene Transfer Operations

The National Emission Standards for Benzene Emissions from Benzene Transfer 

Operations were proposed on September 14, 1989, and promulgated on March 7, 1990, and was 

last-amended on December 14, 2000. The affected facility to which this subpart applies is the 

total of all loading racks handling a liquid containing 70 weight-percent or more benzene, at 

which benzene is loaded into tank trucks, railcars, or marine vessels at each benzene production 

facility and each bulk terminal. However, specifically exempted from this regulation are loading 

racks at which only the following are loaded: benzene-laden waste (covered under subpart FF of 

part 61), gasoline, crude oil, natural gas liquids, petroleum distillates (i.e., fuel oil, diesel, or 

kerosene), or benzene-laden liquid from coke by-product recovery plants. In addition, any

affected facility which loads only liquid containing less than 70 weight-percent benzene or 

whose annual benzene loading is less than 1.3 million liters of 70 weight-percent or more 

benzene is exempt from the control requirements except for the recordkeeping and reporting 

requirements in §61.305(i). Marine vessels were given a one-year industry wide waiver of 

compliance, which was later extended to July 23, 1991, in order to allow for concurrent 

compliance with United States Coast Guard regulations. The regulated pollutant is benzene. 

This information is being collected to assure compliance with 40 CFR part 61, subpart BB.

NESHAP subpart Y: Benzene Emissions from Benzene Storage Vessels 

The NESHAP for Benzene Emissions from Storage Vessels were proposed in 1980, and 

re-promulgated in 1989 (54 FR 38077) as 40 CFR part 61, subpart Y, and was last-amended on 

December 14, 2000. Entities affected by this action are those owners and operators of benzene 

storage vessels that store benzene having a specific gravity within the range of specific gravities 

as specified in ASTM D 4734-98 for Refined Benzene-545. Storage vessels with a design 

storage capacity less than 38 cubic meters (10,000 gallons) are exempt from the provisions of the

subpart. Similarly, storage vessels used for storing benzene at coke by-product facilities or 

vessels permanently attached to motor vehicles, such as trucks, rail cars, barges, ships, or 

pressure vessels designed to operate in excess of 204.9 kPa and without emissions to the 

atmosphere, are also exempt from this subpart. The regulated pollutant is benzene. This 
6

information is being collected to assure compliance with 40 CFR part 61, subpart Y.

NESHAP subpart V: National Emission Standard for Equipment Leaks (Fugitive Emission 

Sources)

The NESHAP for National Emission Standard for Equipment Leaks (Fugitive Emission 

Sources) was promulgated on June 6, 1984 (49 FR 23573), and was last-amended on December 

14, 2000. Affected facilities include the following sources that are intended to operate in volatile 

hazardous air pollutant (HAP) service: pumps, compressors, pressure relief devices, sampling 

connection systems, open-ended valves or lines, valves, flanges and other connectors, product 

accumulator vessels, and control devices or systems. The standards for this subpart are leak 

detection and repair (LDAR). The regulated pollutants are volatile HAPs. This information is 

being collected to assure compliance with 40 CFR part 61, subpart V.

NESHAP subparts F, G, H, and I: The HON

The MACT standards for the HON were proposed on December 31, 1992, and 

promulgated on April 22, 1994. These standards apply to chemical manufacturing process units 

(CMPU’s) in the SOCMI industries, which manufacture as a primary product one or more of the 

chemicals listed in Table 1 of 40 CFR part 63, subpart F; use as a reactant or manufacture as a 

product, by-product, or co-product, one or more of the organic HAPs listed in Table 2 of subpart 

F; and are located at a plant site that is a major source as defined in section 112(a) of the Act. 

Additionally, styrene-butadiene rubber production, pesticide production, polybutadiene 

production, chlorinated hydrocarbon use in the production of chemicals, pharmaceutical 

production, and miscellaneous butadiene use are subject to the negotiated regulations affecting 

equipment leaks promulgated under subpart I. The emission points include transfer racks, 

storage tanks, wastewater systems, process vents and equipment leaks. The regulations apply to 

existing sources as well as new sources commencing construction or reconstruction after the date 

of proposal. Hazardous air pollutants are the pollutants regulated under these subparts. This 

information is being collected to assure compliance with 40 CFR part 63, subparts F, G, H, and I.

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).
7

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

four years.

The EPA also 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.

In the Administrator's judgment, emissions from storage vessels, process vents, transfer 

racks, and equipment leaks associated with the SOCMI cause or contribute to air pollution that 

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

NESHAP were promulgated for this source category at 40 CFR parts 60, 61, and 63 referencing 

subparts.

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 pollution control devices are properly installed 

and operated, if leaks are being detected and repaired, and that the standards are being met. The 
8

performance test may also be observed.

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

at the facility, verify operation/maintenance procedures and for compliance determinations.

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

The requested recordkeeping and reporting are required under 40 CFR parts 60, 61, and

63 referencing subparts.

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 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 (78 FR 35023) on June 11, 2013. 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 the Online Tracking Information System (OTIS) 

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

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

Consultations with industry representatives (i.e., respondents) were conducted to 

determine if there is anyway for EPA to reduce the recordkeeping and reporting burden or 

improve the language in the standard to make it easier to comply. In developing this ICR, we 

contacted: 1) the Society of Chemical Manufacturers and Affiliates (SOCMA), at (202) 721-

4143; and 2) the American Fuel & Petrochemical Manufacturers (AFPM), 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 first Federal Register notice. In this 

case, no comments were received. 

 
9

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

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 

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 (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 owners or operators 

of synthetic organic chemical manufacturing facilities. The United States Standard Industrial

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

(NAICS) codes associated with this ICR are provided in the following table:
10

All Referenced Subparts SIC Codes NAICS Codes

Plastics Material and Resin 

Manufacturing

2821 325211

Non-cellulosic Organic Fiber 

Manufacturing

2824 325222

Paint and Coating Manufacturing 2851 325510

Petrochemical, Synthetic Organic Dye 

and Pigment, and Cyclic Crude and 

Intermediate Manufacturing

2865 325110, 325132, 325192

Petrochemical, Ethyl Alcohol, and All 

Other Basic Organic Chemical 

Manufacturing

2869 325110, 325193, 325199

Petrochemical and All Other Basic 

Organic Chemical Manufacturing 2899 325110, 325199

Petroleum Refineries 2911 324110

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

Solid, Hazardous, and Other Waste

Collection; General Freight Trucking, 

Local; and Used Household and Office 

Goods Moving

4212 562111, 562112, 562119, 

48411, 48421, 48422

General Freight Trucking, Long-Distance

(Truckload and Less Than Truckload); 

Used Household and Office Goods 

Moving; and Specialized Freight (except 

Used Goods) Trucking, Long-Distance

4213 484121, 484122, 48421, 

48423

General Freight Trucking; Used 

Household and Office Goods Moving; 

and Specialized Freight (except Used 

Goods) Trucking, Local

4214 48411, 48421, 48422
11

All Referenced Subparts SIC Codes NAICS Codes

Couriers and Express Delivery Services

and Local Messengers and Local Delivery 4215 49211, 49221

Farm Product Warehousing and Storage 4221 49313

Refrigerated Warehousing and Storage 4222 49312

General Warehousing and Storage and 

Lessors of Mini-warehouses and SelfStorage Units

4225 49311, 53113

Refrigerated, General, and Other 

Warehousing and Storage 4226 49312, 49311, 49319

Other Support Activities for Road 

Transportation 4231 48849

Deep Sea Freight Transportation 4412 483111

Coastal and Great Lakes Freight 

Transportation 4424, 4432 483113

Inland Water Freight Transportation 4449 483211

Deep Sea and Coastal and Great Lakes 

Passenger Transportation 4481 483112, 483114

Coastal and Great Lakes and Inland Water 

Passenger Transportation 4482 483114, 483212

Inland Water Passenger Transportation 

and Scenic and Sightseeing 

Transportation, Water

4489 483212, 48721

Port and Harbor Operations and Marine 

Cargo Handling 4491 48831, 48832

Navigational Services to Shipping 4492 48833

Marinas 4493 71393

Commercial Air, Rail, and Water 

Transportation Equipment Rental and 

Leasing; Port and Harbor Operations; 

Navigational Services to Shipping; and 

Other Support Activities for Water 

Transportation

4499 532411, 48831, 48833, 

48839

Travel Agencies 4724 56151

Tour Operators 4725 56152

All Other Support Activities for 4729 488999, 561599
12

All Referenced Subparts SIC Codes NAICS Codes

Transportation and All Other Travel 

Arrangement and Reservation Services

Process, Physical Distribution, and 

Logistics Consulting Services and Freight 

Transportation Arrangement

4731 541614, 48851

Commercial Air, Rail, and Water 

Transportation Equipment Rental and 

Leasing and Support Activities for Rail 

Transportation

4741 532411, 48821

Packing and Crating 4783 488991

Other Support Activities for Water and 

Road Transportation 4785 48839, 48849

All Other Support Activities for 

Transportation; Scenic and Sightseeing 

Transportation, Land; Food Service 

Contractors; and Support Activities for 

Rail Transportation

4789 488999, 48711, 72231, 

48821

 

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

the entities likely to be regulated by these standards. To determine whether these standards

apply to a particular entity, please see the applicability provisions in the standards.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by The Consolidated Air 

Rule (CAR) for the Synthetic Organic Chemical Manufacturing Industry (SOCMI).

Attachment A lists the recordkeeping and reporting requirements for the CAR and its 

referencing subparts.

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 the respondents continue to create reporting 
13

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

widely used. At this time, it is estimated that approximately 20 percent of the respondents use 

electronic reporting.

(ii) Respondent Activities

The respondent activities required by the CAR and its referencing subparts are identified 

in the following table.

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate CPMS for the appropriate control device.

Perform initial performance test and repeat performance tests if necessary.

Write the notifications and reports listed in Attachment A.

Enter information required to be recorded in Attachment A.

Submit the required reports developing, acquiring, installing, and utilizing technology and 

systems for the purpose of collecting, validating, and verifying information.

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

maintaining information.

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

providing information.

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

requirements.

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

Transmit, or otherwise disclose the information.

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. 
14

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

Information Management

5(a) Agency Activities

Agency activities associated with the CAR are presented below in Table 1: Agency

Activities; Agency activities associated with the CAR provisions are presented below in Table 2: 

Average Annual EPA Burden and Cost for the CAR Provisions; Agency activities associated 

with the CAR direct final standards are presented below in Table 3: Average Annual EPA 

Burden and Cost for the CAR Direct Final Standards; and Agency activities associated with the 

referencing subparts are shown below in Tables F-1 through F-12: Average Annual EPA Burden 

and Cost for the referencing subparts, respectively. EPA conducts one or more of these activities 

in connection with the acquisition, analysis, storage, and distribution of the required information.

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. 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 into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS 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 OTIS 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

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.
15

5(d) Collection Schedule

The specific frequency for each information collection activity within this request is 

shown below in Table 5: Basis for Annual Respondent Burden and Cost for the CAR, and Tables 

G-1 through G-13: Annual Respondent Burden and Cost for the referencing subparts, 

respectively.

6. Estimating the Burden and Cost of the Collection

For the referencing subparts that document the computation of individual burdens for the 

recordkeeping and reporting requirements applicable to the industry for each of the subparts 

included in this ICR, see below: Table 6: Annual Respondent Burden and Cost for the CAR 

Provisions; Table 7: Annual Respondent Burden and for the Direct Final Standards; and Tables 

G-1 through G-13: Annual Respondent Burden and Cost. The individual burdens are expressed 

under standardized headings believed to be consistent with the concept of “burden” under the

Paperwork Reduction Act. Wherever 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 2,130,669 hours (Total Labor Hours from Table 8

below). These hours are based on Agency studies and background documents from the 

development of the regulation, Agency knowledge and experience with the NSPS and NESHAP 

programs, the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates:

Managerial $123.04 ($58.59+ 110%)

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 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 by 110 percent to account for 

the benefit packages available to those employed by private industry.
16

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

Because we assume that no new sources will opt to comply with the CAR at startup over 

the next 3 years, there is no capital/startup cost associated with the CAR. Facilities that comply 

with the CAR are assumed to have already purchased any equipment needed to comply with the 

referencing subpart. There is no capital/startup cost associated with the Direct Final Rule for 

Revisions to the CAR. Both Capital/startup and O&M costs for the referencing subparts are 

summarized below in Table 8: Summary of Respondent and Agency Burden and Cost for 

Referencing Subparts and the CAR.

Details of the capital/startup and O&M costs, as taken from the most recently approved 

ICR for the CAR and referencing subparts, are detailed in Appendix J.

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

The total capital/startup costs for this ICR are $3,371,800. This is the total of column J in 

Table 8: Summary of Respondent and Agency Burden and Cost for Referencing Subparts and the 

CAR. 

The total operation and maintenance (O&M) costs for this ICR are $97,905,200. This is 

the total of column I in Table 8. 

The average annual cost for both capital/startup and O&M costs to industry over the next 

three years of the ICR is estimated to be $101,277,000. These are recordkeeping 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 burden and cost during the three years of the ICR is 

estimated to be $1,330,635. Details upon which this estimate is based appear below in Table 2: 

Average Annual EPA Burden and Cost for the CAR Provisions; Table 3: Average Annual EPA 

Burden and Cost for the Direct Final Standards; and Tables F-1 through F-12: Average Annual 

EPA Burden and Cost for the referencing subparts, and is summarized overall in Table 8: 

Summary of Respondent and Agency Burden and Cost for Referencing Subparts and the CAR.

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

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)
17

These rates are from the Office of Personnel Management (OPM), 2013 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.

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, the total number 

of respondents is 4,618. For the CAR, the direct final rule for revisions to the CAR, and the 

referencing subparts, the calculation of respondents is summarized in Column (A) of Table 8: 

Summary of Respondent and Agency Burden and Cost for Referencing Subparts and the CAR.

The number of Total Annual Responses is 12,229 responses. For the CAR, the direct 

final rule for revisions to the CAR, and the referencing subparts, the calculation of responses is 

summarized below in Column (B) of Table 8: Summary of Respondent and Agency Burden and 

Cost for Referencing Subparts and the CAR. A detailed breakdown of the Total Annual 

Responses specifically associated with the CAR, the direct final rule for revisions to the CAR, 

and the referencing subparts is provided below in Table 9: Summary of Total Annual Responses 

for Referencing Subparts and the CAR.

The total annual labor costs are $208,415,801. Details regarding these estimates may be 

found below in the following tables: Table 8: Summary of Respondent and Agency Burden and 

Cost for Referencing Subparts and the CAR; Table 6: Annual Respondent Burden and Cost for 

the CAR Provisions; Table 7: Annual Respondent Burden and Cost for the Direct Final 

Standards; and Tables G-1 through G-13: Annual Respondent Burden and Cost for the 

referencing subparts.

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 summarized below in Table 8: Summary of Respondent and Agency Burden and 

Cost for Referencing Subparts and the CAR, and are detailed, respectively, in Tables 2: Average 

Annual EPA Burden and Cost for the CAR Provisions and 6: Annual Respondent Burden and 

Cost for the CAR Provisions, plus Tables: 3: Average Annual EPA Burden and Cost for the 

Direct Final Standards and 7: Annual Respondent Burden and Cost for the Direct Final 

Standards; and in both Tables F-1 through F-12: Average Annual EPA Burden and Cost for the 

referencing subparts and Tables G-1 through G-13: Annual Respondent Burden and Cost for the 

referencing subparts. 

(i) Respondent Tally

The total annual labor hours are 2,130,669 hours at a cost of $208,415,801. Details 

regarding these estimates may be found below in: Table 6: Annual Respondent Burden and Cost 

for the CAR Provisions; Table 7: Annual Respondent Burden and Cost for the Direct Final 

Standards; and Tables G-1 through G-13: Annual Respondent Burden and Cost for the 

referencing subparts, respectively.
18

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

information is estimated to average 174 hours per response.

The total annual capital/startup and O&M costs to the regulated entity are $101,277,000. 

The cost calculations are detailed above 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 

29,526 labor hours at a cost of $1,330,635. See below: Table 8: Summary of Respondent and 

Agency Burden and Cost for Referencing Subparts and the CAR and detailed in Table 2: 

Average Annual EPA Burden and Cost for the CAR Provisions; Table 3: Average Annual EPA 

Burden and Cost for the Direct Final Standards; and Tables F-1 through F-12: Average Annual 

EPA Burden and Cost for the referencing subparts.

6(f) Reasons for Change in Burden

There is an increase in the total estimated respondent labor burden and associated labor, 

capital/startup, and O&M costs. Overall, the change in burden from the most recently-approved 

ICR is due to an increase in the number of sources subject to the standard, and is not due to any

program changes. The number of sources has been increased to reflect industry growth, which in 

turn increased the cost of those subparts where growth is expected.

There is a further overall increase in respondent burden costs from the most recently 

approved ICR due to the use of updated labor rates. This ICR references labor rates from the 

Bureau of Labor Statistics to calculate respondent burden costs. Note that this ICR also 

references labor rates from OPM to calculate Agency costs; however, the update did not affect 

Agency costs since the rates are identical between this and the most recently approved ICR.

Specific changes to the burden tables include:

Table 8: since this is a summary table, the appropriate entries were updated according to 

changes made in Tables F-1 through F-12 and G-1 through G-13.

Tables F-2 and G-2 (i.e., subpart Kb): the tables were updated to account for industry

growth. Also, we have revised the O&M cost to reflect both new and existing sources. 

The most recently approved ICR erroneously reflected O&M costs for new sources only.

Tables F-4 and G-4 (i.e., subpart VVa): the table was updated to account for industry

growth. Also, we have revised the respondent labor burden to reflect both new and 

existing sources. The most recently approved ICR erroneously reflected the respondent 

labor burden for new sources only.
19

Tables F-5 and G-5 (i.e., subpart DDD): the tables were updated to account for industry

growth. We also have updated the total O&M cost accordingly. In addition, we have 

revised Table G-5 to account for the labor burden associated with preparing repeat 

performance test notifications, and to make it consistent with the related burden presented 

in Table F-5 for Agency review of these notifications.

Tables F-6 and G-6 (i.e., subpart III): the tables were updated to account for industry

growth. We also have updated the total O&M cost accordingly.

Tables F-7 and G-7 (i.e., subpart NNN): the tables were updated to account for industry

growth. We also have updated the total O&M cost accordingly.

Tables F-8 and G-8 (i.e., subpart RRR): the tables were updated to account for industry

growth. We also have updated the total O&M cost accordingly.

Tables F-11 and G-11 (i.e., subpart V): the tables were updated to account for industry

growth.

Tables F-12, G-12, and G-13 (i.e., the HON): the tables were updated to account for 

industry growth.

6(g) Burden Statement

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

is estimated to average 174 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-2013-0350. 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 
20

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-2013-0350 and OMB Control Number 2060-0443 in any

correspondence. 

Part B of the Supporting Statement

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

information.
21

Table 1: Agency Activities

Performance Tests

 - Initial

 - Repeat

Review Reports

 - Notification of Initial Startup

 - Notification of Performance Test

 - Initial Compliance Status

 - Startup, Shutdown, Malfunction Plans

 - Periodic Reports

Table 2: Average Annual EPA Burden and Cost for the CAR Provisions

Burden item

A B C D E F

Average 

hours per 

activity

Number of 

activities 

per year

Estimated 

Technical 

hours 

per year

(AxB)

Estimated 

Managerial 

hours 

per year

(Cx0.05)

Estimated 

Clerical 

hours 

per year

(Cx0.10)

Annual cost 

per year 

($) a

Report review 

1. Initial notification of part 65 

applicability, Title V 

modification b

2 27 54 2.7 5.4 $2,798.52

2. Review equipment leak 

monitoring c

5 636 3,180 159 318 $164,801.91

3. Review periodic reports d4 80 320 16 32 $16,583.84

TOTAL ANNUAL BURDEN AND COST (rounded) 4,087 $184,184

Assumptions:

a. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. 

These rates are from the Office of Personnel Management (OPM) 2013 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.

b. Estimate all CAR sources must submit an initial notification. We estimate 1/3 of sources will submit initial 

notification in each of the three years covered by this ICR. This equates to 27 per year (80/3) during each of the 

three years following promulgation.

c. Estimate 318 equipment leak sources will comply with the CAR (240 from the HON, 59 from subpart VV and 19 

from subpart V - see Table 4). Reports for equipment leaks will be submitted semiannually (318 x 2 = 636 per 

year). See Attachment C for assumptions and further description of activities.

d. Estimate 25 percent of the 320 SOCMI facilities, which equals 80 facilities, will opt to comply with the CAR and 

must submit periodic reports each year.
22

Table 3: Average Annual EPA Burden and Cost for the Direct Final Standards

Burden item

A B C D E F G H

Technical 

person-hours 

per occurrence

No. of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year

(AxB)

Respondents 

per year

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($) a

Report review/filing 1 1 1 6 6 0.3 0.6 $310.95

TOTAL ANNUAL BURDEN AND COST (rounded) 7 $311

Assumptions:

a. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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.
23

Table 4: Estimated Number of Sources Subject to Referencing Subparts that Will Opt to

 Comply with the CAR

Referencing subpart Estimated number of sources 

complying with the CAR a, b

Storage Vessels

Ka 458

Kb 382

Y 0

Transfer Racks

BB 0

Equipment Leaks

V 19

VV 59

VVa 0

Process Vents

III 1

NNN 71

RRR 8

DDD 5

HON F & G - Storage Vessels 800

HON F & G - Transfer Racks 320

HON H &I -- Equipment Leaks 240

HON F & G - Process Vents 640

Assumptions:

a.

 This table provides estimates on a per-source basis, rather than a per-facility basis. 

Therefore, estimates correlate to (as described in the footnote to the appropriate 

Table), but do not match, facility entries in the reference subpart burden tables (Tables 

F-1 through F-12, and G-1 through G-13). For the purposes of this ICR, a source is 

defined as:

-One storage vessel (subparts Ka, Kb, Y, and G);

-One process vent (subparts DDD, III, NNN, RRR, and G);

-The collection of subject equipment for one process unit (subparts VV, VVa, V, and 

H and I); or

-One transfer rack (subparts BB and G).

b.

 From the most recently approved ICR.
24

Table 5: Basis for Annual Respondent Burden and Cost for the CAR

Burden Item

Annual Burden in Technical Hours

Process Vents Storage Vessels Transfer Racks

Equipment Leaks

Inventory Total With Connectors d

Without 

Connectors a

Per 

source b

Total c Per 

source b

Total c Per 

source b

Total c Per 

source b

Total c Per 

source b

Total c Per 

source

b

Total c

1. Read rule and instructions 2.9 2,103 1.1 1,804 1.1 352 2.5 600 1 78 1.8 144 5,081

2. Plan activities 2.1 1,523 1.7 2,788 0.85 272 0.57 137 0.23 18 4.5 360 5,098

3. Training 1.3 943 0.5 820 0.5 160 0 0 0 0 0 0 1,923

4. Creation, testing, research and 

development

28 20,300 16 26,240 16 5,120 380 91,200 155 12,090 0 0 154,950

5. Gather information, monitor/ 

inspect

14 10,150 17 27,880 17 5,440 263 63,120 108 8,424 54 4,320 119,334

6. Process/compile and review 0 0 0 0 0 0 0 0 0 0 18 1,440 1,440

7. Complete forms 9 6,525 5.4 8,856 5.4 1,728 57 13,680 23 1,794 5.4 432 33,015

8. Record/disclose 28 20,300 2.8 4,592 2.8 896 4.7 1,128 1.9 148 9 720 27,784

9. Store/file 3 2,175 1.25 2,050 1.25 400 2.75 660 0.9 70 1.58 126 5,481

TOTAL 88 64,019 46 75,030 45 14,368 711 170,525 290 22,622 94 7,542 354,106

Assumptions:

a.

 The HON, the basis for the CAR burden estimate, requires connector monitoring. Sources originally complying with subpart V or VV will not be required to 

perform connector monitoring. Connector monitoring for these facilities is the average of the per source burden for subparts V and VV. The average for 

subparts V and VV is 294 hours, 40.9 percent less than the HON-based estimate. Per-source estimates for each burden item were estimated by multiplying 

the HON-based estimate by 40.9 percent.

b.

 From the most recently approved CAR ICR.
25

c.

 Total burden for each source type is the product of the per-source burden and the total number of sources estimated to opt to comply with the CAR. The 

estimated numbers of sources to comply with the CAR is from the most recently approved ICR and are detailed in Table 4:

-process vents - 725

-storage vessels - 1,640

-transfer racks - 320

- equipment leaks with connector monitoring - 240

- equipment leaks without connector monitoring - 78

-facilities (used for inventory estimate) - 80

d.

 Total burden for each burden item is the sum of totals for each source type. This burden represents technical hours only and is the basis for determining total 

burden in Table 6.
26

Table 6: Annual Respondent Burden and Cost for the CAR Provisions

Burden item

A B C D E F G

Average 

hours 

per activity

Estimated 

number 

of activities 

per year 

per respondent

Technical 

hours 

per year 

per respondent

Estimated 

technical 

hours 

per year

Estimated 

managerial 

hours 

per year

Estimated 

clerical hours

per year

Annual cost 

per year 

($)

1. Read rule and instructions 2.76 23 63.51 5,081 254.05 508.1 $571,559.91

2. Plan activities 4.9 13 63.73 5,098 254.9 509.8 $573,472.24

3. Training 6.01 4 24.04 1,923 96.15 192.3 $216,317.6

4. Creation, testing, research, and development 19.56 99 1,936.88 154,950 7,747.5 15,495 $17,430,271.27

5. Gather information, monitor/inspect 2.2 677 1,491.68 119,334 5,966.7 11,933.4 $13,423,839.89

6. Process/compile and review 18 1 18 1,440 72 144 $161,985.1

7. Complete forms 82.54 5 412.69 33,015 1,650.75 3,301.5 $3,713,845.79

8. Record/disclose 13.36 26 347.3 27,784 1,389.2 2,778.4 $3,125,412.44

9. Store/file 1.96 35 68.51 5,481 274.05 548.1 $616,555.77

TOTAL ANNUAL BURDEN AND COST (rounded) 407,222 $39,833,260

Assumptions:

Following is a brief explanation of each column. A more detailed description is provided in Attachment E.

(a) Average hours per activity are back-calculated by dividing (c) by (b).

(b) Number of activities per year is based on the estimate of number of activities per year for the HON, with a reduction to reflect the consolidation of 

activities achieved through the CAR.

(c) Technical hours per year per respondent are the total technical hours for a burden item as estimated in Table 5, divided by 80 facilities.

(d) Estimated technical hours per year are the total technical hours for all facilities for each burden item, as estimated in Table 4.

(e) Estimated managerial hours per year are assumed to be 5 percent of technical hours.

(f) Estimated clerical hours per year are assumed to be 10 percent of technical hours.

(g) Annual Cost is the sum of costs for technical, managerial, and clerical hours. This ICR uses the following labor rates: $101.22 for technical, $123.04 

for managerial, and $51.18 for clerical labor. 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 

by 110 percent to account for the benefit packages available to those employed by private industry.
27

Table 7: Annual Respondent Burden and Cost for the Direct Final Standards

Burden item

A B C D E F G H

Technical 

person-hours 

per occurrence

No. of 

occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year (AxB)

Respondents 

per year

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)a

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, installation, and utilization 

of technology and systems

N/A

4. Reporting requirements

A. Read instructions b0.5 1 0.5 6 3 0.15 0.3 $337.47

B. Required activities N/A

C. Create information N/A

D. Gather existing information N/A

E. Write report b0.5 1 0.5 6 3 0.15 0.3 $337.47

Subtotal for Reporting Requirements 7 $674.94

4. Recordkeeping requirements

A. Read instructions N/A

Subtotal for Recordkeeping Requirements 0 0

TOTAL ANNUAL BURDEN AND COST (rounded) 7 $675

Assumptions:

a.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

b.

 This is a one-time event for six respondents per year.
28

Table 8: Summary of Respondent and Agency Burden and Cost for Referencing Subparts and the CAR

Subpart

A B C D E F G H I J

Number 

of

respondents

Total 

annual 

responses a

Respondent 

reporting 

burden 

hours a

Respondent 

recordkeeping 

burden 

hours a

Respondent 

burden 

hours a

Respondent 

burden 

Costs a

Agency 

burden 

hours b

Agency 

burden 

costs b

O&M

Costs c

Capital/

Startup 

costs c

NSPS Ka 174 194 522 45,931 46,453 $4,543,907 115 $5,182 $0 $0

NSPS Kb 728 2,299 25,515 77,173 102,688 $10,044,651 1,093 $49,244 $585,900 $27,000

NSPS VV 436 872 4,011 40,112 44,123 $4,316,003 2,006 $90,382 $0 $0

NSPS VVa 380 852 6,403 35,423 41,826 $4,091,339 2,327 $104,882 $0 $4,200

NSPS DDD 130 284 5,870 1,415 7,284 $712,509 708 $31,924 $910,000 $300,000

NSPS III 15 32 186 163 349 $34,141 82 $3,711 $20,250 $13,500

NSPS NNN 2,053 4,495 28,794 22,399 51,192 $5,007,477 11,394 $513,477 $2,771,550 $2,389,500

NSPS RRR 235 514 3,278 2,563 5,841 $571,307 1,302 $58,665 $117,500 $500,000

NESHAP BB 54 216 7,600 4,844 12,444 $1,217,251 497 $22,388 $0 $0

NESHAP Y 4 8 55 9 64 $6,299 9 $415 $0 $0

NESHAP V 63 137 4,318 4,023 8,341 $815,921 316 $14,262 $0 $0

NESHAP F, G, H, and I 260 1,920 1,201,302 201,532 1,402,833 $137,221,062 5,583 $251,608 $71,500,000 $137,600

CAR 80 400 368,967 38,255 407,222 $39,833,260 4,087 $184,184 $22,000,000 $0

CAR Revisions d6 6 7 0 7 $675 7 $311 $0 $0

TOTAL 4,618 12,229 1,656,828 473,841 2,130,669 $208,415,801 29,526 $1,330,635 $97,905,200 $3,371,800

Assumptions:

a. From Tables G-1 through G-13.

b. From Tables F-1 through F-12.

c. From Appendix J.

d. From Tables 3 and 7.
29

Table 9: Summary of Total Annual Responses for Referencing Subparts and the CAR

A B C D E

Information Collection Activity

Number of 

Respondents

Number 

of 

Responses

Number of Existing 

Respondents

That Keep Records But

Do Not Submit Reports

Total Annual 

Responses

E = (BxC) + D

NSPS Ka

Notification of construction 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of gap measurement 188 1 0 188

Report of seal gap excess 6 1 0 6

Subtotal 194

NSPS Kb

Notification of construction 37 1 0 37

Notification of actual startup 37 1 0 37

Notification of IFR internal inspection 28 1 0 28

Notification of EFR gap measurement 7 1 0 7

IFR internal inspection report 28 1 0 28

EFR 1st seal gap measurement 7 1 0 7

EFR 2nd seal gap measurement 7 1 0 7

CVS operating plan report 2 1 0 2

Report of IFR failure 55 1 0 55

Notification of IFR delay of repair/emptying 6 1 0 6

EFR 1st seal gap measurement report 691 1 0 691

EFR 2nd seal gap measurement report 691 1 0 691

Notification of refill 703 1 0 703

Subtotal 2,299

NSPS VV

Notification of construction 0 1 0 0

Notification of reconstruction/modification 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of initial/repeat performance test 0 1 0 0

Semiannual report 436 2 0 872

Subtotal 872

NSPS VVa

Initial performance test report 38 1 0 38

Repeat performance test report 8 1 0 8

Notification of construction 23 1 0 23

Notification of reconstruction/modification 15 1 0 15

Notification of actual startup 38 1 0 38
30

A B C D E

Information Collection Activity

Number of 

Respondents

Number 

of 

Responses

Number of Existing 

Respondents

That Keep Records But

Do Not Submit Reports

Total Annual 

Responses

E = (BxC) + D

Notification of initial/repeat performance test 46 1 0 46

Semiannual report 342 2 0 684

Subtotal 852

NSPS DDD

Initial performance test report 10 1 0 10

Repeat performance test report 2 1 0 2

Notification of construction/modification 10 1 0 10

Notification of actual startup 10 1 0 10

Notification of initial/repeat performance test 12 1 0 12

Semiannual report 120 2 0 240

Subtotal 284

NSPS III

Initial performance test report 1 1 0 1

Repeat performance test report 0 1 0 0

Notification of construction/modification 1 1 0 1

Notification of actual startup 1 1 0 1

Notification of initial/repeat performance test 1 1 0 1

Semiannual report 14 2 0 28

Subtotal 32

NSPS NNN

Initial performance test report 177 1 0 177

Repeat performance test report 35 1 0 35

Notification of construction/modification 177 1 0 177

Notification of actual startup 177 1 0 177

Notification of initial/repeat performance test 177 1 0 177

Semiannual report 1,876 2 0 3,752

Subtotal 4,495

NSPS RRR

Initial performance test report 20 1 0 20

Repeat performance test report 4 1 0 4

Notification of construction/modification 20 1 0 20

Notification of actual startup 20 1 0 20

Notification of initial/repeat performance test 20 1 0 20

Semiannual report 215 2 0 430

Subtotal 514
31

A B C D E

Information Collection Activity

Number of 

Respondents

Number 

of 

Responses

Number of Existing 

Respondents

That Keep Records But

Do Not Submit Reports

Total Annual 

Responses

E = (BxC) + D

NESHAP BB

Initial emission test 0 1 0 0

Monitoring performance test 0 1 0 0

Notification of construction 0 1 0 0

Notification of anticipated startup 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of emission test 0 1 0 0

Report of emission test 0 1 0 0

Notification of performance test 0 1 0 0

Report of performance test 0 1 0 0

Report facilities below cut-off 0 1 0 0

Quarterly parameter excesses 54 4 0 216

Subtotal 216

NESHAP Y

Annual IFR internal inspections and EFR seal gap 

measurements

4 1 0 4

Notification of construction/reconstruction 0 1 0 0

Notification of anticipated startup 0 1 0 0

Notification of actual startup 0 1 0 0

Notification of emission test 0 1 0 0

Report of emission test 0 1 0 0

Notification of control installation and refill at 1st 

IFR degassing

0 1 0 0

Annual inspection report 4 1 0 4

Supplemental delay report 0 1 0 0

Quarterly emission report 0 4 0 0

Subtotal 8

NESHAP V

Initial performance test 2 1 0 2

Reference method 21/22 test 2 1 0 2

Repeat performance test 2 0.2 0 0.4

Notification of construction/reconstruction 2 1 0 2

Notification of anticipated startup 2 1 0 2

Notification of actual startup 2 1 0 2

Notification of initial performance test 2 1 0 2

Application for alternative 1 1 0 1
32

A B C D E

Information Collection Activity

Number of 

Respondents

Number 

of 

Responses

Number of Existing 

Respondents

That Keep Records But

Do Not Submit Reports

Total Annual 

Responses

E = (BxC) + D

Initial report 2 1 0 2

Semiannual report 61 2 0 122

Subtotal 137

NESHAP F, G, H, and I 

Complete reports (new respondents; see Table G-12) 5 49 0 245

Complete reports (existing respondents; see Table G-13) 5 335 0 1,675

Subtotal 1,920

CAR Provisions

Complete forms (see Table 6) 80 5 0 400

Subtotal 400

CAR Direct Final Standards

Write report (see Table 7) 6 1 0 6

Subtotal 6

Total responses

(all subparts)

12,229
A-1

Attachment A

Part 1: Recordkeeping and Reporting under the Consolidated Air Rule

1. General Records

• Maintain notifications, records, and reports as specified in §65.4(a) and §65.4(c).

2. Storage Vessel Records

• Storage vessel records where emissions are controlled by a fixed roof and internal 

floating roof (IFR), external floating roof (EFR), or EFR converted into an IFR as 

specified in §65.47.

• Storage vessel records where emissions are controlled by a control device as specified 

in §65.159 for flare compliance determination and §65.163 for closed vent systems.

• Storage vessel records where emissions are routed to a fuel gas system or process as 

specified in §65.163.

3. Process Vent Records

• General process vent records as specified in §§65.66, 65.63, and 65.160.

• Process vent records where emissions are controlled by a control device as specified 

in §65.159 for flare compliance determination records and §§65.162 and 65.163.

• Process vent records where recovery devices are used to maintain the total resource 

effectiveness (TRE) index value above 1.0 as specified in §65.160.

4. Transfer Rack Records

• General Transfer Rack Records as specified in §§65.83, 65.87, and 65.160.

• Transfer Rack Records where emissions are controlled by a control device (except for 

low-throughput transfer operations) as specified in §§65.159, 65.162, and 65.163.

• Low-throughput transfer operation records where emissions are controlled by a 

control device as specified in §§65.159 and 65.163.

5. Equipment Leak Records

• General equipment leak records as specified in §§65.103, 65.104, and 65.105. 

Specific equipment leak records where equipment leak emissions are not controlled 

by a control device or routed to a process or fuel gas system as specified in §§65.106, 

65.109, 65.111, and 65.120.

• Equipment leak records where emissions are controlled by a control device as 

specified in §§65.159 and 65.163.

6. Notification of Initial Startup

• Submit Notification of Initial Startup as specified in §65.5(a), (b), (f), and (g) and 

65.48(a).

• Submit Initial Notification for Part 65 Applicability as specified in §65.5(a), (c), (f), 

and (g).
A-2

7. Initial Compliance Status Report

• Submit Initial Compliance Status Report as specified in §65.5(a), (d), (f), and (g).

• Storage vessels as specified in §§65.163 and 65.164.

• Process vents as specified in §§65.63, 65.67, 65.160, 65.164, and 65.165.

• Low-volume transfer racks as specified in §§65.164 and 65.165.

• High-volume transfer racks as specified in §§65.83, 65.164, and 65.165.

• Equipment leaks as specified in §§65.117, 65.118, 65.119, and 65.120.

8. Periodic Reports

• Submit Periodic Reports as specified in §65.5(a), (e), (f), and (g) and §65.6(c).

• Storage vessel records where emissions are controlled by an IFR, EFR, or EFR 

converted into an IFR as specified in §65.48.

• Storage vessels where emissions are controlled by a control device as specified in 

§65.166.

• Process vents as specified in §§65.67 and 65.166.

• Low-volume transfer racks as specified in §65.166.

• High-volume transfer racks as specified in §65.166.

• Equipment leaks as specified in §65.120.

• Closed vent systems as specified in §§65.143 and 65.166.

• Flares as specified in §65.166.

9. Other Notification and Reports

• Request for alteration of time periods or postmarks as specified in §65.5(h).

• Submit Startup, Shutdown, and Malfunction Report as specified in §65.5(a) and 

§65.6(c) (can be included with a periodic report).

• Application for waiver of recordkeeping or reporting requirements as specified in 

§65.7.

• Request for approval of alternative monitoring or recordkeeping provisions as 

specified in §65.7.

• Storage vessel refilling notification as specified in §65.48.

• Storage vessel seal gap measurement notification as specified in §65.48.

• Process vent Group 2A without a recovery device monitoring and recordkeeping and 

reporting plan as specified in §65.63.

• Process vent report of a process change if not included with the periodic report as 

specified in §65.67.

• Intent to conduct a performance test as specified in §65.67.

• Process vent report according to the plan for Group 2A process vents without a 

recovery device as specified in §65.67.

• Equipment leaks written request for alternative means of emission limitation as 

specified in §65.102.

Part 2: Burden for NSPS Sources Not Electing to Comply with the CAR

• Initial notifications as specified in §60.7.

• Provide notification of construction or reconstruction as specified in §60.7(a)(1).

• Provide notification of anticipated startup as specified in §60.7(a)(2).
A-3

• Provide notification of actual startup as specified in §60.7(a)(3).

• Provide notification of physical or operational change as specified in §60.7(a)(4).

• Demonstration of continuous monitoring system as specified in §60.7(a)(5).

• Performance test as specified in §60.8.

• Report on initial performance test results as specified in §60.8(a).

• Provide notification of initial performance test as specified in §60.8(d).

Requirements Specific to NSPS Subpart Ka

• Submit information prior to construction on vapor recovery and return or disposal 

system including emissions data, operations design specifications, and maintenance 

plan as specified in §60.113a(a)(2)(i-iv).

• Submit notification 30 days prior to seal gap measurement as specified in 

§60.113a(a)(1)(iv).

• Report within 60 days when a seal gap measurement exceeds the limits of §60.112a 

as specified in §60.113a(a)(1)(i)(E).

• Record gap measurements: Secondary seals every year and Primary seals every five 

years as specified in §60.113a(a)(1)(i)(D).

• Record whenever the liquid is changed, stored, period of storage, and maximum true 

vapor pressure as specified in §60.115a(a).

Requirements Specific to NSPS Subpart Kb

• Notification 30 days prior to re/filling vessel for (a)(1) and (a)(4) IFR inspections as 

specified in §60.113b(a)(5).

• Notification 30 days prior to seal gap measurements as specified in §60.113b(b)(5).

• Notification 30 days prior to re/filling vessel for (b)(6) EFR inspections as specified 

in §60.113b(b)(6).

• Submit operating plan for closed vent or exempt control device as specified in 

§60.113b(c).

• Report describing control equipment and IFR control certification as specified in 

§60.115b(a)(1).

• Record of each inspection required at §60.113b(a), as specified in 60.115b(a)(2).

• Report of visual defects as specified in §60.115b(a)(3).

• Report of seal holes/tears as specified in §60.115b(a)(4).

• Report describing control equipment and EFR control certification as specified in 

§60.115b(b)(1).

• Report results of seal gap measurements required at §60.113b(b)(1) within 60 days, as 

specified in §60.115b(b)(2).

• Record of each gap measurement required at §60.113b(b), as specified in 

60.115b(b)(3).

• Report gaps exceeding limits within 30 days of inspection required by 

§60.113b(b)(4), as specified in §60.115b(b)(4).

• Records kept on closed-vent system as specified in §60.115b(c).

• Report of flare measurements as specified in §60.115b(d)(1).

• Records kept on flare as specified in §60.115b(d)(2).
A-4

• Report semiannually periods of pilot flame absent from flare as specified in 

§60.115b(d)(3).

• Records of dimensions and capacity of vessel as specified in §60.116b(b).

• Record of VOL stored, period of storage, and maximum true vapor pressure of lower 

kPa vessels as specified in §60.116b(c).

• Record of VOL stored, period of storage, and maximum true vapor pressure of higher 

kPa vessels as specified in §60.116b(d).

Requirements Specific to NSPS Subpart VV and VVa

• Recordkeeping as specified in §§60.486 and 60.486a.

• Semiannual reporting as specified in §§60.487(a) through (c) and 60.487a(a) through 

(c).

• Notification of alternative standard selected as specified in §§60.487(d) and 

60.487a(d).

• Report Performance tests as specified in §§60.487(e) and 60.487a(e).

Requirements Specific to NSPS Subpart DDD

• Initial performance test results or specified alternative reports as specified in §60.565.

• Semiannual reports of deviations from monitoring parameters, monitoring 

exceedances, changes in process operations, and periods during which control device 

is inoperative as specified in §60.565(k).

• Records of periods when flow monitor indicates emission stream is being diverted 

away from the control device as specified in §60.565(b).

• Records of monitoring parameters as specified in §60.565(c), (d), (e), (f), (g), (h).

• Results of monitoring during performance tests, including the vent system used to 

vent each affected stream to the control device; evidence of compliance with 

incineration requirements; evidence of compliance with boiler or process heater 

operation, and records from flare or pilot light flame heat sensing monitoring and 

periods of operation when the flare or pilot flame is absent as specified in §60.565(a), 

(b), (c), (d), (e), (f).

• Changes in production capacity, feedstock type, or catalyst type or replacement, or 

removal or addition of product recovery equipment as specified in §60.565(g).

• Evidence of compliance with elected alternative provisions, and all periods of 

operation during which the performance boundaries are exceeded as specified in 

§60.565(h).

Requirements Specific to NSPS Subpart III

• Notification of the specific provisions of the standards for which the owner has 

elected to comply as specified in §60.615(a).

• Record data measured during each performance test as specified in §§60.615(b) and 

60.615(h)(3).

• Continuously record equipment operating parameters as specified in §§60.615(c) and 

60.615(g).
A-5

• Record periods of operation during which the performance boundaries established 

during the most recent performance test are exceeded as specified in §§60.615(c) and 

60.615(g).

• Continuously record the indication of vent stream flow to the control device as 

specified in §60.615(d).

• Record all periods of operation of a boiler or process heater as specified in 

§60.615(e).

• Record results of flare pilot flame monitoring and all periods of operations in which 

the pilot flame is absent as specified in §60.615(f).

• Record changes in production capacity, feedstock type, catalyst type, or replacement, 

removal, or addition of recovery equipment or an air oxidation reactor as specified in 

§60.615(h)(1).

• Record any recalculation of the TRE index value as specified in §60.615(h)(2).

• Written report of initial performance test results as specified in §§60.8 and 60.615(b).

• For the semiannual report, exceedances of parameter boundaries established during 

the most recent performance test as specified in §60.615(j)(1).

• For the semiannual report, all periods when the vent stream is diverted from the 

control device or has no flowrate as specified in §60.615(j)(2).

• For the semiannual report, all periods when the boiler or process heater was not 

operated as specified in §60.615(j)(3).

• For the semiannual report, all periods in which the flare pilot flame was absent as 

specified in §60.615(j)(4).

• For the semiannual report, any recalculation of the TRE index value as specified in 

§60.615(j)(5).

Requirements Specific to NSPS Subpart NNN

• Notification of the specific provisions of the standards for which the owner has 

elected to comply as specified in §60.665(a).

• Record data measured during each performance test as specified in §§60.665(b) and 

60.665(h)(3).

• Continuously record equipment operating parameters as specified in §§60.665(c) and 

60.665(g).

• Record periods of operation during which the performance boundaries established 

during the most recent performance test are exceeded as specified in §§60.665(c) and 

60.665(g).

• Continuously record the indication of vent stream flow to the control device as 

specified in §60.665(d).

• Record all periods of operation of a boiler or process heater as specified in 

§60.665(e).

• Record results of flare pilot flame monitoring and all periods of operations in which 

the pilot flame is absent as specified in §60.665(f).

• Record changes in production capacity, feedstock type, catalyst type, or replacement, 

removal, or addition of recovery equipment or an air oxidation reactor as specified in 

§60.665(h)(1).

• Record any recalculation of the TRE index value as specified in §60.665(h)(2).
A-6

• Record data showing that the vent stream flowrate is less than 0.008 m3/min and any 

change in equipment or process operation that increases the operating vent stream 

flowrate, including a measurement of the new flowrate, as specified in §60.665(i).

• Record any change in equipment or process operation that increases the design 

production capacity of the process unit as specified in §60.665(j).

• Written report of performance test results as specified in §§60.8 and 60.665(b).

• For demonstrating compliance with the low capacity exemption levels, a report 

detailing the design production capacity of the process unit as specified in §60.665(n).

• For demonstrating compliance with the low flow exemption level, a report of the 

flowrate measurement as specified in §60.665(o).

• For the semiannual report, exceedances of parameter boundaries established during 

the most recent performance test as specified in §60.665(l)(1).

• For the semiannual report, all periods when the vent stream is diverted from the 

control device or has no flowrate as specified in §60.665(l)(2).

• For the semiannual report, all periods when the boiler or process heater was not 

operated as specified in §60.665(l)(3).

• For the semiannual report, all periods in which the flare pilot flame was absent as 

specified in §60.615(j)(4).

• For the semiannual report, any change in equipment or process operation that 

increases the operating vent stream flowrate above the low flow exemption level as 

specified in §60.665(l)(5).

• For the semiannual report, any change in equipment or process operation that 

increases the design production capacity above the low capacity exemption level as 

specified in §60.665(l)(6).

• For the semiannual report, any recalculation of the TRE index value as specified in 

§60.665(l)(7).

Requirements Specific to NSPS Subpart RRR

• Notification of the specific provisions of the standards for which the owner has 

elected to comply as specified in §60.705(a).

• Exceedances of parameter boundaries established during the most recent performance

test as specified in §60.705(l)(1).

• All periods when the vent stream is diverted from the control device as specified in 

§60.705(l)(2).

• All periods in which the flare pilot flame was absent as specified in §60.705(l)(3).

• For the semiannual report, any changes in equipment or process operation that 

increases the operating vent stream flowrate above the low flow exemption level as 

specified in §60.705(l)(4).

• For the semiannual report, any change in equipment or process operation that 

increases the design production capacity above the low capacity exemption level as 

specified in §60.705(l)(5).

• For the semiannual report, any recalculation of the TRE index value as specified in 

§60.705(l)(6).

• For the semiannual report, all periods recorded in which the seal mechanism is broken 

or the bypass line valve position has changed. A record of the serial number of the 
A-7

car-seal or a record to show that the key to unlock the bypass line valve was checked 

out must be maintained to demonstrate the period, the duration, and frequency in 

which the bypass line was operated as specified in §60.705(l)(7).

• For the semiannual report, any change in equipment or process operation that 

increases the vent stream concentration above the low concentration exemption level, 

including a measurement of the new vent stream concentration as specified in 

§60.705(l)(8).

• For the initial report, written report of performance test results as specified in §§60.8 

and 60.705(b).

• Record data measured during each performance test as specified in §§60.705(b) and 

60.705(g)(3).

• Continuously record equipment operating parameters as specified in §60.705(c).

• Records of diversion of vent stream from the control device as specified in 

§60.705(d)(1).

• For seal mechanisms, records of monthly visual inspections and of all periods where

the mechanism is broken or there are bypass line valve position, serial number, or key

configuration changes as specified in §60.705(d)(2).

• Record results of flare pilot flame monitoring and all periods of operations in which 

the pilot flame is absent as specified in §60.705(e).

• Record periods of operation during which the performance boundaries established 

during the most recent performance test are exceeded as specified in §60.705(f).

• Record changes in production capacity, feedstock type, catalyst type, or replacement, 

removal, or addition of recovery equipment or reactors as specified in §60.705(g)(1).

• Record any recalculation of the TRE index value as specified in §60.705(g)(2).

• Records to indicate that the vent stream flowrate is less than 0.011 scm/min and of 

any change in equipment or process operation that increases the operating vent stream 

flowrate, including measurement of the new vent stream flowrate as specified in 

§60.705(h).

• For demonstrating compliance with the design production capacity provision, records 

of any change in equipment or process operation that increases design production 

capacity of the process unit as specified in §60.705(i).

• For demonstrating compliance with the low concentration exemption, records of any 

change in equipment or process operation that increases the concentration of the vent 

stream as specified in §60.705(j).

For demonstrating compliance with the low capacity exemption levels, a report detailing 

the design production capacity of the process unit as specified in §60.665(n).

• For demonstrating compliance with the low flow exemption level, a report of the 

flowrate measurement as specified in §60.665(o).

Part 3: Burden for 40 CFR Part 61 NESHAP Sources Not Electing to Comply with the 

CAR

• Construction or modification application as specified in §61.07.

• Provide notification of anticipated startup as specified in §61.09(a)(1). 

• Provide notification of actual startup as specified in §61.09(a)(2).

• Source status report as specified in §61.10(a).
A-8

• Initial performance test as specified in §61.13.

• Provide notification of initial performance test as specified in §61.13.

• Report on initial performance test results as specified in §61.13(f).

• Provide notification of physical or operational change as specified in §61.15 .

Requirements Specific to NESHAP Subpart BB

• Obtain vapor tightness documentation at §61.305(h) every 12 months as specified in 

§61.302(d).

• Maintain vapor-tightness file on each affected facility as specified in §§61.302(d) and 

(e).

• Record of measurements during each performance test as specified in §61.305(a).

• Engineering report as specified in §61.305(a)(5).

• Record of monitoring equipment parameters and excess emissions as specified in 

§61.305(b).

• Record vent valves status and maintain for at least two years as specified in 

§61.305(c).

• Records of periods of operation of steam generator or process heater kept up-to-date 

as specified in §61.305(d).

• Records of flare operation and monitoring kept up-to-date as specified in §61.305(e).

• Quarterly report by sources subject to §61.302 as specified in §61.305(f).

• Documentation of vapor-tightness required under §§61.302(d) and (e) on permanent 

file as specified in §61.305 (g).

• Documentation of vapor-tightness renewed at least once per year as specified in 

§61.305(h).

• Record and report information when exempt under §§61.300(b) and 61.305(i).

• Record of closed-vent system annual leak inspection required at §§61.242-11(e) and 

(f) and 61.302(k), as specified in §61.246(d).

Requirements Specific to NESHAP Subpart Y

• Initial source report as specified in §61.274.

• Report of annual and periodic inspections for IFR as specified in §61.275(a).

• Supplemental annual periodic report for IFR as specified in §61.275(a)(3).

• Report of 5- or 10-year internal inspections for IFR as specified in §61.275(b).

• Report of annual seal gap measurements for EFR as specified in §61.275(d).

• Report of 5 year seal gap measurements for EFR as specified in §61.275(d).

• Supplemental annual periodic report for EFR as specified in §61.275(d)(2).

• Quarterly report of excess emissions for closed vent systems with control devices as 

specified in §61.275(e).

• Record of storage vessel design capacity as specified in §61.276(b).

• Record of information on closed vent systems with control devices as specified in 

§61.276(c).
A-9

Requirements Specific to NESHAP Subpart V

• Application for alternative means of emissions limitation as specified in §61.244.

• Recordkeeping as specified in §61.246.

• Reporting as specified in §61.247.

Part 4: Burden for 40 CFR Part 63 NESHAP Sources Not Electing to Comply with the 

CAR (MACT Subparts F, G, H and I: The HON)

1. Notifications

• Notification of construction or reconstruction as specified in §§63.5, 63.9, 63.100, 

63.151, 63.182, and 63.192.

• Notification of anticipated date of initial startup as specified in §§63.5, 63.9, 63.151, 

63.182, and 63.192.

• Notification of actual date of initial startup as specified in §§63.9, 63.151, 63.182, 

and 63.192.

• Notification of process changes as specified in §§63.100, 63.118, 63.146, 63.151, 

63.152, 63.182, and 63.192.

• Notification of performance test as specified in §63.103.

• Notification for storage tanks as specified in §63.192.

2. Reporting - Initial and Notification of Compliance Status

• Initial report requirements as specified in §§63.117, 63.122, 63.129, 63.146, 63.151, 

63.182, and 63.192.

• Reporting of operating parameter levels as specified in §§63.117, 63.120, 63.122, 

63.129, 63.130, 63.146, 63.151, 63.182, and 63.192.

• Statement of compliance/noncompliance as specified in §§63.117, 63.120, 63.122, 

63.127, 63.128, 63.129, 63.151, 63.152, 63.182, and 63.192.

3. Reporting - Periodic and Event Triggered

• Startup, shutdown and malfunction as specified in §§63.6, 63.10, 63.103, and 63.105.

• Exceedance of parameter boundaries established during the most recent performance 

test as specified in §§63.118, 63.122, 63.130, 63.146, 63.148, 63.151, 63.152, 63.182, 

and 63.192.

• Any change in equipment or process operation that increases emission levels above 

requirements in the standard as specified in §§63.103, 63.104, 63.122, 63.130, 

63.146, 63.148, 63.151, 63.152, 63.182, and 63.192.

• Written report of performance tests as specified in §§63.117, 63.120, 63.122, 63.129, 

63.146, 63.151, 63.152, 63.182, and 63.192.

• Delay of repair as specified in §§63.104, 63.122, 63.182, and 63.192.

4. Recordkeeping

• General Recordkeeping as specified in §63.103.

• Record of data measured during each performance test as specified in §§63.117, 

63.118, 63.123, 63.129, 63.130, 63.147, 63.148, 63.151, 63.152, 63.181, and 63.192.

• Record of periods of operation during which the performance boundaries established 
A-10

in the Notification of Compliance Status are exceeded as specified in §§63.118, 

63.120, 63.123, 63.130, 63.147, 63.148, 63.151, and 63.152.

• Records of Monthly visual inspections as specified in §§63.118, 63.130, 63.147, 

63.148, 63.181, and 63.192.

• Records of Annual visual inspections as specified in §§63.123, 63.147, 63.148, 

63.181 and 63.192.

• TRE records for process vents as specified in §63.117.

• Monitoring records as specified in §§63.118 and §63.123.

• Records of process changes for process vents as specified in §63.118.

• Records of delay of repair as specified in §§63.120 and §63.123.

• Record of storage vessel size as specified in §63.123.

• Record of vent system configuration for transfer racks as specified in §63.129.

• Record of design criteria for equipment leaks as specified in §63.118.

• Record of startup, shutdown and malfunction as specified in §§63.6, 63.103, 63.105, 

and 63.152.

• Records of continuous monitoring systems as specified in §63.103.
B-1

Attachment B

Purposely left blank.
C-1

Attachment C

Assumptions and Item Descriptions for Table 2

Assumptions:

Assumptions are the same as Attachment E, and:

(A) That there are 318 total sources (240 from the HON, 59 from Subpart VV, 0 from 

Subpart VVa, and 19 from Subpart V) that must submit semiannual reports from equipment 

leak detection and repair programs as well as semiannual periodic reports. This equates to 

636 EPA activities (318 * 2) during each of the three years following promulgation.

(B) That all sources must submit an initial notification of part 65 applicability or submit the 

corresponding information in a modification to their Title V permits. This equates to 80 

EPA activities, or 27 per year (80/3) during each of the three years following promulgation.

Item descriptions:

(a) Average hours per activity are estimates of the specific activities and are the basis for 

estimating the overall burden.

(b) Number of activities per year represents the number of reports expected to be reviewed 

and other related activities during the course of the year, based upon assumptions (A) and (B), 

above.

(c) Estimated technical hours per year is the product of (a) and (b).

(d) Estimated managerial hours per year is 5 percent of (c).

(e) Estimated clerical hours per year is 10 percent of (c).

(f) Annual cost per year is the total cost of technical, managerial, and clerical hours and 

overhead using this formula:

(Ht x $46.21/hour) + (Hm x $62.27/hour) + (Hc x $25.01/hour) = (H)

Where:

Ht is (c), or technical hours,

Hm is (d), or managerial hours, and

Hc is (e), or clerical hours.

These rates are from the Office of Personnel Management (OPM), 2013 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-2

Report Review:

1) Initial notification of part 65 applicability, Title V modification represents the EPA 

review of either the initial notification of part 65 applicability report or the source’s Title V 

modification through which the source notifies EPA that it intends to comply with the CAR. As 

noted in the supporting statement text, the EPA does not expect any new sources to elect to 

comply with the CAR during the 3-year period following promulgation.

2) Review equipment leak monitoring represents the review and screening of periodic 

reports received as a result of the equipment leaks standard.

3) Review periodic reports represents the EPA review of periodic reports from new and 

existing sources.

TOTAL ANNUAL BURDEN AND COST (ROUNDED) is the sum of columns (c), (d), and (e), 

and of (f), respectively.
D-1

Attachment D

Purposely left blank.
E-1

Attachment E

Assumptions and Item Descriptions for Table 6 

Assumptions:

(A) That there are 320 existing facilities, of which 25 percent (80) chose to comply with the 

CAR.

(B) That the average representative source will consist of a variety of sources. The total 

number of sources expected to comply with the CAR includes (from Table 4):

• 1,640 storage vessels;

• 320 transfer racks;

• 240 collections of subject equipment, including connectors;

• 78 collections of subject equipment, not including connectors; 

• 80 facility wide inventories of emission points; and

• 725 process vents.

(C) That there are 5 percent (0.05) managerial and 10 percent (0.10) clerical hours required 

for every technical hour.

(D) That some activities necessary to generate reports involve creating records in the 

process, and that these activities are assumed to be reports activities alone, to avoid double 

counting these as records activities as well. Therefore, only items 8 and 9 are considered 

records burdens directly.

Item descriptions:

(a) Average hours per activity is back-calculated by dividing (b) into (c). Since the 

activities within each burden category can vary significantly, it is too inaccurate to assume 

an average to use to calculate (c). Estimated activity technical hours are calculated in Table 

5 and entered into column (d); (a) is then back-calculated with an estimated (b).

(b) Estimated number of activities per year per source represents the assumed typical 

number of separate activities a source may encounter during one year. This number may

vary from facility to facility depending on consolidation of activities, co-located readings, 

etc. Since so much variability exists, it is important to note that this is an estimate. This 

number was only used to back-calculate (a). The numbers are based on the number of 

activities per year estimated for complying with the HON. The numbers have been reduced 

to reflect the consolidation of activities achieved through the CAR.

(c) Technical hours per year per respondent is the total technical hours for a burden item, as 

estimated in Table 5, divided by 80 facilities. Because of the variability in the number and 

combination of sources at a facility, this value could vary widely.
E-2

(d) Estimated technical hours per year is the sum of total technical hours for all sources for 

each burden item, as estimated in Table 5.

(e) Estimated managerial hours per year is 5 percent of (d).

(f) Estimated clerical hours per year is 10 percent of (d).

(g) Annual cost per year is the total cost of technical, managerial, and clerical hours and 

overhead using this formula:

(Ht x $101.22/hour) + (Hm x $123.04/hour) + (Hc x $51.18/hour) = (G)

Where:

Ht is (d), or technical hours,

Hm is (e), or managerial hours, and

Hc is (f), or clerical hours.

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 by 110 percent 

to account for the benefit packages available to those employed by private industry.

Report Review:

1) Read rule and instructions consists of the activities, less training, which involve 

comprehending the provisions in the standard and understanding how they apply to the 

respective points at a facility.

2) Plan activities represents such burdens as design, redesign, and scheduling, as well as 

selecting methods of compliance.

3) Training represents the portion of activities from 1) Read rule and instructions for 

which an average facility would elect to provide class room instruction. The standard 

does not require specific training itself.

4) Creation, testing, research, and development are the activities involving testing, 

retesting, establishing operating ranges for parameters, and analyzing point by point 

applicability. Monitor-related refit, calibration, and maintenance activities also are 

included under this heading.

5) Gather information, monitor/inspect are the activities involving physical inspections of 

equipment, collection of monitored data, and other related activities.
E-3

6) Process/compile and review are the activities that involve analysis of the collected

information for accuracy and compliance, as well as appropriate records and reports 

required as a result.

7) Complete forms represents the activities normally associated with filling out forms. 

Since the standard requires no standard forms, these activities relate to the preparing of 

formal reports and cover letters.

8) Record/disclose are solely recordkeeping activities which occur once the appropriate 

report information has been extracted; see assumption, (D) above. These activities 

involve software translation, duplication, or archival processes normally associated with 

data management and storage common to this industry.

9) Store/file are activities which are solely recordkeeping which occur once the 

appropriate report information has been extracted; see assumption (D), above. These 

activities involve the management life cycle of records, from the time they are filed and 

boxed up, to the time they are disposed.

TOTAL ANNUAL BURDEN AND COST (rounded) is the sum of columns (d), (e), (f), and of 

(g), respectively.
F-1

Attachment F: Average Annual EPA Burden and Cost for Referencing Subparts

 Table F-1: Average Annual EPA Burden and Cost for Subpart Kaa

Burden item

A B C D E F G H

Technical 

person-hours 

per 

occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

Report review: New plant 

Vapor recovery c N/A

Report review: Existing plant

Notification of reconstruction 2 1 2 0 0 0 0 $0

Notification of modification 2 1 2 0 0 0 0 $0

Notification of seal gap measurement d0.5 1 0.5 188 94 4.7 9.4 $4,871.50

Report of gap excesses d, e1 1 1 6 6 0.3 0.6 $310.95

TOTAL ANNUAL BURDEN AND COST (rounded) 115 $5,182

Assumptions:

a.

 Assume no new sources subject to this regulation. All similar new sources will be subject to subpart Kb.

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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.

 Required only at start of construction. Any new storage vessel being constructed would be subject to NSPS subpart Kb.

d.

 Assume 90 percent of storage vessels will use a floating roof system and will be subject to seal gap measurement. The remaining 10 percent will use a 

closed vent system.

e.

 Assume that 3 percent of respondents submitting a notification of either primary or secondary gap measurement (188) will have excessive seal gaps 

(primary or secondary) requiring that a single report be filed once a year.
F-2

Table F-2: Average Annual EPA Burden and Cost for Subpart Kb

Burden item

A B C D E F G H

Person-hours 

per 

occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

Report review: New plant 

Notification of construction 2 1 2 37 74 3.7 7.4 $3,835.01

Notification of anticipated startup 1 1 1 37 37 1.85 3.7 $1,917.51

Notification of actual startup 1 1 1 37 37 1.85 3.7 $1,917.51

Notification of initial inspection 1 1 1 37 37 1.85 3.7 $1,917.51

Report review: Existing plant 

IFR failure report

c

1 1 1 55 55 2.75 5.5 $2,850.35

Notification of IFR delay of 

repair/emptying d

1.2 1 1.2 6 7.2 0.36 0.72 $373.14

Notification of refill e1 1 1 703 703 35.15 70.3 $36,432.62

TOTAL ANNUAL BURDEN AND COST (rounded) 1,093 $49,244

Assumptions:

a.

 We estimate 691 existing respondents with an average of 8,642 regulated vessels in service will be subject over the next three years. We also estimate 75 

percent (6,482) of vessels have an internal floating roof (IFR), 20 percent (1,728) have an external floating roof (EFR), and 5 percent (432) have a closed vent 

system (CVS). For new sources, we estimate 37 respondents per year will become subject to subpart Kb, and assume a distribution similar to that of existing 

respondents; therefore, 28 new respondents have an IFR, 7 have an ERF, and 2 have a CVS. These estimates do not include sources subject to both subpart 

Kb and the HON, which we assume will comply with the HON instead. 

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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.

 Estimate 10 percent failure rate for the 553 respondents choosing annual visual inspections, yielding 55 reports.

d.

 Estimate 10 percent of failed IFRs either are delayed in repair or are emptied, yielding 6 notifications.

e.

 Assume all 6,482 IFR tanks will be serviced routinely through a shutdown, and degassed once every ten years. One tenth of these tanks will be degassed each 

year, for an annual average of 648 per year. This number was added to the estimated 55 visual inspection failures that would lead to internal inspections, for a 

total estimate of 703 notifications of refill.
F-3

Table F-3: Average Annual EPA Burden and Cost for Subpart VV

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

Report review: New plant 

Notification of construction 8 1 8 0 0 0 0 $0

Notification of reconstruction/

modification

2 1 2 0 0 0 0 $0

Notification of actual startup 0.5 1 0.5 0 0 0 0 $0

Notification of initial/repeat test 0.5 1 0.5 0 0 0 0 $0

Review test results 2 1 2 0 0 0 0 $0

Report review: Existing plant 

Semiannual emission report 2 2 4 436 1,744 87.2 174.4 $90,381.93

TOTAL ANNUAL BURDEN AND COST (rounded) 2,006 $90,382

Assumptions:

a.

 All new sources are subject to subpart VVa. There are an average of 436 existing sources per year that will be subject to subpart VV over the next three years. 

These estimates do not include sources subject to both subpart VV and the HON, which we assume comply with the HON instead.

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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.
F-4

Table F-4: Average Annual EPA Burden and Cost for Subpart VVa

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

Report review: New plant 

Notification of construction c8 1 8 23 184 9.2 18.4 $9,535.71

Notification of reconstruction/

modification c

2 1 2 15 30 1.5 3 $1,554.74

Notification of actual startup 0.5 1 0.5 38 19 0.95 1.9 $984.67

Notification of initial/repeat test d0.5 1 0.5 46 23 1.15 2.3 $1,191.96

Review test results d2 1 2 46 92 4.6 9.2 $4,767.85

Report review: Existing plant 

Semiannual emission report 2.45 2 4.9 342 1,675.8 83.79 167.58 $86,847.5

TOTAL ANNUAL BURDEN AND COST (rounded) 2,327 $104,882

Assumptions:

a.

 Assume there will be an average of 38 new, modified, or reconstructed facilities each year and an average of 342 existing facilities over the next 3 years. The 

number of existing sources assumes constant industry growth at a rate of 38 sources per year starting in the second year after promulgation (2007) and ending 

in 2015 (the midpoint of this ICR). Since subpart VVa is more stringent than the HON and MON, no sources are assumed to be complying with the HON or 

MON instead of subpart VVa.

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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. Estimate 23 sources will be new due to construction while 15 will be due to reconstruction or modification.

d.

 Assume 20 percent of initial performance tests must be repeated due to failure.
F-5

Table F-5: Average Annual EPA Burden and Cost for Subpart DDD

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

Report review: New plant 

Notification of construction/

modification

2 1 2 10 20 1 2 $1,036.49

Notification of actual startup 2 1 2 10 20 1 2 $1,036.49

Initial performance test 8 1 8 10 80 4 8 $4,145.96

Repeat performance test c8 1 8 2 16 0.8 1.6 $829.19

Report review: Existing plant 

Semiannual report 2 2 4 120 480 24 48 $24,875.76

TOTAL ANNUAL BURDEN AND COST (rounded) 708 $31,924

Assumptions:

a.

 Assume 10 new affected sources per year and an average of 120 existing affected sources over the next three years.

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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.

 Assume 20 percent of initial performance tests must be repeated due to failure.
F-6

Table F-6: Average Annual EPA Burden and Cost for Subpart III

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

Report review: New plant 

Notification of construction/

modification

2 1 2 1 2 0.1 0.2 $103.65

Notification of anticipated startup 2 1 2 1 2 0.1 0.2 $103.65

Notification of actual startup 2 1 2 1 2 0.1 0.2 $103.65

Initial performance test 8 1 8 1 8 0.4 0.8 $414.60

Repeat performance test c8 1 8 0.2 1.6 0.08 0.16 $82.92

Report review: Existing plant

Semiannual report 2 2 4 14 56 2.8 5.6 $2,902.17

TOTAL ANNUAL BURDEN AND COST (rounded) 82 $3,711

Assumptions:

a.

 Assume 1 new affected source per year and an average of 14 existing affected sources over the next three years. This does not include sources subject to both 

subpart III and the HON, which are assumed to be complying with the HON.

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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.

 Assume 20 percent of initial performance tests must be repeated due to failure.
F-7

Table F-7: Average Annual EPA Burden and Cost for Subpart NNN

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost per 

year ($)b

Report review: New plant 

Notification of construction/

modification

2 1 2 177 354 17.7 35.4 $18,345.87

Notification of actual startup 2 1 2 177 354 17.7 35.4 $18,345.87

Initial performance test 8 1 8 177 1,416 70.8 141.6 $73,383.49

Repeat performance test c8 1 8 35 280 14 28 $14,510.86

Report review: Existing plant

Semiannual report 2 2 4 1,876 7,504 375.2 750.4 $388,891.05

TOTAL ANNUAL BURDEN AND COST (rounded) 11,394 $513,477

Assumptions:

a.

 Assume 177 new affected sources per year subject to subpart NNN and not the HON, and 1,876 existing affected sources over the next three years. These 

estimates do not include sources subject to both Subpart NNN and the HON, which are assumed to be complying with the HON.

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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.

 Assume 20 percent of initial performance tests must be repeated due to failure.
F-8

Table F-8: Average Annual EPA Burden and Cost for Subpart RRR

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical hours 

per year 

(Ex0.10)

Total cost per 

year ($)b

Report review: New plant 

Notification of construction/

modification

2 1 2 20 40 2 4 $2,072.98

Notification of actual startup 2 1 2 20 40 2 4 $2,072.98

Initial performance test 8 1 8 20 160 8 16 $8,291.92

Repeat performance test c8 1 8 4 32 1.6 3.2 $1,658.38

Report review: Existing plant

Semiannual report 2 2 4 215 860 43 86 $44,569.07

TOTAL ANNUAL BURDEN AND COST (rounded) 1,302 $58,665

Assumptions:

a. Assume 20 new affected sources per year subject to subpart RRR and not the HON, and 215 existing affected sources over the next three years. These 

estimates do not include sources subject to both Subpart RRR and the HON, which are assumed to be complying with the HON.

b. This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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. Assume 20 percent of initial performance tests must be repeated due to failure.
F-9

Table F-9: Average Annual EPA Burden and Cost for Subpart BB

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost per 

year ($)b

Report review: New plant 

Notification of construction 0.5 1 0.5 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

Initial report 8 1 8 0 0 0 0 $0

Notification of emission test 0.5 1 0.5 0 0 0 0 $0

Report of emission test 4 1 4 0 0 0 0 $0

Notification of performance test 0.5 1 0.5 0 0 0 0 $0

Report of performance test 8 1 8 0 0 0 0 $0

Review test results 8 1 8 0 0 0 0 $0

Report review: Existing plant

Quarterly report 2 4 8 54 432 21.6 43.2 $22,388.18

TOTAL ANNUAL BURDEN AND COST (rounded) 497 $22,388

Assumptions:

a.

 We estimate an averge of 54 existing facilities will be subject to the standard, and that no new sources will become subject over the next three years. We 

estimate 3 tank truck/railcars and 131 marine vessels are subject to the standards. We assume 50 percent of marine vessels (66) operate at negative pressure 

and do not conduct annual vapor-tightness tests. We also assume all other transfer racks subject to subpart BB are complying with the HON.

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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.
F-10

Table F-10: Average Annual EPA Burden and Cost for Subpart Y

Burden item

A B C D E F G H

Person-hours per 

occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year (AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost per 

year ($)b

Report review: New plant 

Notification of construction See NSPS Kb

Notification of anticipated startup See NSPS Kb

Notification of actual startup See NSPS Kb

Notification of performance test N/A

Report of performance test N/A

Notification of control installation 

and refill at 1st IFR degassing c

1 1 1 0 0 0 0 $0

Report review: Existing plant

Annual IFR internal inspection and 

EFR seal gap measurement

2 1 2 4 8 0.4 0.8 $414.6

Supplemental delay report d1 1 1 0 0 0 0 $0

Quarterly emission report e N/A

TOTAL ANNUAL BURDEN AND COST (rounded) 9 $415

Assumptions:

a.

 Estimate there will be 4 existing sources not covered by the HON. The burden for all new sources is included in the NSPS subpart Kb regulation for storage 

vessels at 40 CFR Part 60.

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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 believe that all vessels have been degassed and that all controls have been installed, as they were to be installed within 10 years of promulgation.

d.

 Estimate two percent of existing sources will request delay of repair in the annual report.

e.

 Assume no sources will select the option to have a fixed roof vented to a control device, and thus have no quarterly reports of excess emissions.
F-11

Table F-11: Average Annual EPA Burden and Cost for Subpart V

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. of 

occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours per 

year 

(Ex0.10)

Total cost per 

year ($)b

Report review: New plant 

Notification of construction 2 1 2 2 4 0.2 0.4 $207.3

Notification of anticipated startup 2 1 2 2 4 0.2 0.4 $207.3

Notification of actual startup 2 1 2 2 4 0.2 0.4 $207.3

Initial performance test 8 1 8 2 16 0.8 1.6 $829.19

Repeat performance test c8 0.2 1.6 2 3.2 0.16 0.32 $165.84

Semiannual report 2 2 4 61 244 12.2 24.4 $12,645.18

TOTAL ANNUAL BURDEN AND COST (rounded) 316 $14,262

Assumptions:

a.

 Assume 2 new sources per year and 55 existing sources subject to subpart V, but not the HON.

b.

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of 

Personnel Management (OPM) 2013 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.

 Assume 20 percent of initial performance tests must be repeated due to failure.
F-12

Table F-12: Average Annual EPA Burden and Cost for Sources Subject to the HON

Burden item

A B C D E F

Average 

hours 

per activity

Number

of activities 

per year

Estimated 

Technical hours 

per year

(AxB)

Estimated 

Managerial hours 

per year

(Cx0.05)

Estimated Clerical 

hours 

per year

(Cx0.10)

Annual cost 

per year ($)

Report review 

1. Initial 2 5 10 0.5 1 $518.25

2. Implementation plan or permit 20 5 100 5 10 $5,182.45

3. Compliance status 40 5 200 10 20 $10,364.9

4. Review equipment leak monitoring 7 255 1,785 89.25 178.5 $92,506.73

5. Notification of construction/reconstruction 2 5 10 0.5 1 $518.25

6. Notification of anticipated startup 2 5 10 0.5 1 $518.25

7. Notification of actual startup 2 5 10 0.5 1 $518.25

8. Notification of performance test 2 5 10 0.5 1 $518.25

9. Review of test results 8 5 40 2 4 $2,072.98

10. Review periodic reports 4 670 2,680 134 268 $138,889.66

TOTAL ANNUAL BURDEN AND COST (rounded) 5,583 $251,608

See Attachment H for assumptions and further description of activities.
G-1

Attachment G: Annual Respondent Burden and Cost for Referencing Subparts

Table G-1: Annual Respondent Burden and Cost for Subpart Ka a

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions See 3B

B. Required activities

Vapor recovery information 20 1 20 0 0 0 0 $0

Measure seal gap See 4E

C. Create information See 3B

D. Gather existing information 1 1 1 157 157 7.85 15.7 $17,660.88

E. Write report

Notification of construction 2 1 2 0 0 0 0 $0

Notification of actual startup 2 1 2 0 0 0 0 $0

Notification of gap measurement c1.5 1 1.5 188 282 14.1 28.2 $31,722.08

Report of seal gap excess d2.5 1 2.5 6 15 0.75 1.5 $1,687.34

Information on vapor recovery See 3B

Subtotal for Reporting Requirements 522 $51,070

4. Recordkeeping requirements

A. Read instructions See 3B

B. Plan activities See 3B

C. Implement activities See 3B
G-2

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

D. Develop record system N/A

E. Time to enter information

New tank seal gap measurements 250 1 250 0 0 0 0 $0

Secondary seal gap measurements c, d, e250 1 250 157 39,250 1,962.5 3,925 $4,415,218.76

Primary seal gap measurements c, d, f100 0.2 20 31 620 31 62 $69,743.58

Fill/refill record g, h2 1 2 35 70 3.5 7 $7,874.28

Subtotal for Recordkeeping Requirements 45,931 $4,492,837

TOTAL ANNUAL BURDEN AND COST (rounded) 46,453 $4,543,906.92

Assumptions:

a.

 Assume that there will be no new source subject to the requirements of this regulation. Similar new sources will be subject to NSPS subpart Kb. There are 

174 existing sources with an average of 50 tanks per facility.

b.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c.

 Estimate that 10 percent of respondents (17) will use a vapor recovery control system and 90 percent (157) will use a floating roof system. Respondents using 

vapor recovery control are not required to do seal gap measurements. All tanks using floating roof system (157) will perform a secondary seal gap 

measurement. Twenty percent (31) will conduct a primary seal gap measurement. Total respondents submitting a notification of either primary or secondary 

gap measurement: 157 + 31 = 188.

d.

 Assume that 3 percent of respondents submitting a notification of either primary or secondary gap measurement (188) will have excessive seal gaps (primary 

or secondary) requiring that a single report be filed once a year.

e.

 Estimate five hours to conduct secondary seal gap measurements annually for the average 50 tanks per respondent.

f.

 Estimate two hours to conduct primary seal measurements every five years for the average 50 tanks per respondent.

g.

 During any one year, a respondent would change liquid at approximately 20 percent of all facilities (35).

h.

 Estimate 0.2 hours per tank to record a liquid change at 20 percent of the average of 50 tanks per facility (10).
G-3

Table G-2: Annual Respondent Burden and Cost for Subpart Kb

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions 1 1 1 37 37 1.85 3.7 $4,162.12

B. Required activities

One-time-only requirements

Notification of construction 2 1 2 37 74 3.7 7.4 $8,324.23

Notification of actual startup 2 1 2 37 74 3.7 7.4 $8,324.23

Notification of physical/ operational 

changes c

N/A

Notification of malfunction c N/A

Notification of initial inspection

IFR internal inspection 2 1 2 28 56 2.8 5.6 $6,299.42

EFR gap measurement 2 1 2 7 14 0.7 1.4 $1,574.86

Initial inspection report

IFR internal inspection report 12 1 12 28 336 16.8 33.6 $37,796.52

EFR 1st seal gap measurement 12 1 12 7 84 4.2 8.4 $9,449.13

EFR 2nd seal gap measurement 8 1 8 7 56 2.8 5.6 $6,299.42

CVS operating plan report 8 1 8 2 16 0.8 1.6 $1,799.83

Repeat requirements

Internal IFR inspection d12 1 12 138 1,656 82.8 165.6 $186,282.86

Visual IFR inspection d8 1 8 553 4,424 221.2 442.4 $497,654.21

Report of IFR failure e2 1 2 55 110 5.5 11 $12,373.86
G-4

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

Notification of IFR delay of 

repair/emptying f

4 1 4 6 24 1.2 2.4 $2,699.75

EFR 1st seal gap measurement report 12 1 12 691 8,292 414.6 829.2 $932,764.18

EFR 2nd seal gap measurement report 8 1 8 691 5,528 276.4 552.8 $621,842.79

Notification of refill g2 1 2 703 1,406 70.3 140.6 $158,160.45

Subtotal for Reporting Requirements 25,515 $2,495,808

4. Recordkeeping requirements

A. Read instructions 1 1 1 37 37 1.85 3.7 $4,162.12

B. Gather and record information

Vessel volumes, liquid vapor pressures, 

flares 8 1

8

691

5,528 276.4 552.8 $621,842.79

113b(a) inspection 12 1 12 691 8,292 414.6 829.2 $932,764.18

113b(b) gap measurement 12 1 12 691 8,292 414.6 829.2 $932,764.18

C. Develop record system 10 1 10 3 30 1.5 3 $3,374.69

D. Time to enter information

CVS parameter records 2 52 104 432 44,928 2,246.4 4,492.8 $5,053,935

E. Train personnel N/A

F. Audits N/A

Subtotal for Recordkeeping Requirements 77,173 $7,548,843

TOTAL ANNUAL BURDEN AND COST (rounded) 102,688 $10,044,651

Assumptions:

a.

 We estimate 691 existing respondents with an average of 8,642 regulated vessels in service will be subject over the next three years. We also estimate 75 

percent (6,482) of vessels have an internal floating roof (IFR), 20 percent (1,728) have an external floating roof (EFR), and 5 percent (432) have a closed vent 

system (CVS). For new sources, we estimate 37 respondents per year will become subject to subpart Kb, and assume a distribution similar to that of existing 

respondents; therefore, 28 new respondents have an IFR, 7 have an ERF, and 2 have a CVS. These estimates do not include sources subject to both subpart Kb 

and the HON, which we assume comply with the HON instead.
G-5

b.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c

. The General Provision notifications of modification or malfunction will be covered by other notifications within the subpart.

d.

 For each of the 6,482 IFRs associated with the 691 existing respondents, 80 percent (553) will conduct an annual visual inspection, while 20 percent (138) will 

conduct an internal inspection. These activities are required to generate the information for the IFR failure report and EFR primary and secondary seal gap 

reports, but do not require response.

e.

 Estimate 10 percent failure rate for the 553 respondents choosing annual visual inspections, yielding 55 reports.

f.

 Estimate 10 percent of failed IFRs either are delayed in repair or are emptied, yielding 6 notifications.

g.

 Assume all 6,482 IFR tanks will be serviced routinely through a shutdown, and degassed once every ten years. One tenth of these tanks will be degassed each 

year, for an annual average of 648 per year. This number was added to the estimated 55 visual inspection failures that would lead to internal inspections, for a 

total estimate of 703 notifications of refill.
G-6

Table G-3: Annual Respondent Burden and Cost for Subpart VV

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions 1 1 1 0 0 0 0 $0

B. Required activities

Initial performance test report 48 1 48 0 0 0 0 $0

Repeat performance test report c48 1 48 0 0 0 0 $0

C. Create information See 3B

D. Gather existing information See 3E

E. Write report

Notification of construction 2 1 2 0 0 0 0 $0

Notification of 

reconstruction/modification

2 1 2 0 0 0 0 $0

Notification of actual startup 2 1 2 0 0 0 0 $0

Notification of initial/repeat 

performance test

2 1 2 0 0 0 0 $0

Semiannual report 4 2 8 436 3,488 174.4 348.8 $392,363.9

Subtotal for Reporting Requirements 4,011 $392,364

4. Recordkeeping requirements

A. Read instructions See 3A

B. Plan activities See 4C

C. Implement activities See 3B

D. Develop record system N/A
G-7

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

E. Time to enter information

Records of operating parameters 80 1 80 436 34,880 1,744 3,488 $3,923,638.99

F. Train personnel N/A

G. Audits N/A

Subtotal for Recordkeeping Requirements 40,112 $3,923,639

TOTAL ANNUAL BURDEN AND COST (rounded) 44,123 $4,316,003

Assumptions:

a.

 All new sources are subject to subpart VVa. There are an average of 436 existing sources per year that will be subject to subpart VV over the next three years. 

These estimates do not include sources subject to both subpart VV and the HON, which we assume comply with the HON instead.

b.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c.

 Assume 20 percent of performance tests must be repeated.
G-8

Table G-4: Annual Respondent Burden and Cost for Subpart VVa

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours per 

year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost per 

year 

($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions 1 1 1 38 38 1.9 3.8 $4,274.61

B. Required activities

Initial performance test report 48 1 48 38 1,824 91.2 182.4 $205,181.12

Repeat performance test report c48 1 48 8 384 19.2 38.4 $43,196.03

C. Create information See 3B

D. Gather existing information See 3E

E. Write report

Notification of construction d2 1 2 23 46 2.3 4.6 $5,174.52

Notification of 

reconstruction/modification d

2 1 2 15 30 1.5 3 $3,374.69

Notification of actual startup 2 1 2 38 76 3.8 7.6 $8,549.21

Notification of initial/repeat 

performance test c

2 1 2 46 92 4.6 9.2 $10,349.05

Semiannual report 4.5 2 9 342 3,078 153.9 307.8 $346,243.14

Subpart for Reporting Requirements 6,403 $626,342

4. Recordkeeping requirements

A. Read instructions See 3A

B. Plan activities See 4C

C. Implement activities See 3B
G-9

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours per 

year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost per 

year 

($)b

D. Develop record system N/A

E. Time to enter information

Records of operating parameters -

average facilities e

89.5 1 89.5 308 27,566 1,378.3 2,756.6 $3,100,889.69

Records of operating parameters -

small facilities e

95.2 1 95.2 34 3,236.8 161.84 323.68 $364,106.5

F. Train personnel N/A

G. Audits N/A

Subtotal for Recordkeeping Requirements 35,423 $3,464,996

TOTAL ANNUAL BURDEN AND COST (rounded) 41,826 $4,091,339

Assumptions:

a.

 Assume there will be an average of 38 new, modified, or reconstructed facilities each year and an average of 342 existing facilities over the next 3 years. The 

number of existing sources assumes constant industry growth at a rate of 38 sources per year starting in the second year after promulgation (2007) and ending 

in 2015 (the midpoint of this ICR). Since subpart VVa is more stringent than the HON and MON, no sources are assumed to be complying with the HON or 

MON instead of subpart VVa.

b.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c.

 Assume 20 percent of initial performance tests must be repeated due to failure.

d.

 Estimate 23 sources will be new due to construction while 15 will be due to reconstruction or modification. 

e.

 Assume 10 percent are small facilities that will record instrument readings manually while the other 90 percent use automated equipment to capture instrument 

readings electronically.
G-10

Table G-5: Annual Respondent Burden and Cost for Subpart DDD

Burden item

A B C D E F G H

Personhours per 

occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions 1 1 1 10 10 0.5 1 $1,124.9

B. Required activities

Initial performance test report 360 1 360 10 3,600 180 360 $404,962.74

Repeat performance test report c360 1 360 2 720 36 72 $80,992.55

C. Write report

Notification of 

construction/modification

2 1 2 10 20 1 2 $2,249.79

Notification of actual startup 1 1 1 10 10 0.5 1 $1,124.9

Notification of initial/repeat 

performance test

2 1 2 12 24 1.2 2.4 $2,699.75

Semiannual report 3 2 6 120 720 36 72 $80,992.55

Subtotal for Reporting Requirements 5,870 $574,147

4. Recordkeeping requirements

Records of operating parameters for 

control devices

1 12 12 10 120 6 12 $13,498.76

Records of operating conditions 

exceeding last performance test

1 8 8 120 960 48 96 $107,990.06
G-11

Burden item

A B C D E F G H

Personhours per 

occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

Records of startup, shutdown, 

malfunction, etc.

0.25 5 1.25 120 150 7.5 15 $16,873.45

Subtotal for Recordkeeping Requirements 1,415 $138,362

TOTAL ANNUAL BURDEN AND COST (rounded) 7,284 $712,509

Assumptions:

a.

 Assume 10 new affected sources per year and an average of 120 existing affected sources over the next three years.

b.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c.

 Assume 20 percent of initial performance tests must be repeated due to failure.
G-12

Table G-6: Annual Respondent Burden and Cost for Subpart III

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours per 

year 

(Ex0.10)

Total cost 

per year 

($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions 1 1 1 1 1 0.05 0.1 $112.49

B. Required activities

Initial performance test report 60 1 60 1 60 3 6 $6,749.38

Repeat performance test report c60 1 60 0.2 12 0.6 1.2 $1,349.88

C. Write report

Notification of 

construction/modification

2 1 2 1 2 0.1 0.2 $224.98

Notification of actual startup 1 1 1 1 1 0.05 0.1 $112.49

Notification of initial/repeat 

performance test

2 1 2 1 2 0.1 0.2 $224.98

Semiannual report 3 2 6 14 84 4.2 8.4 $9,449.13

Subtotal for Reporting Requirements 186 $18,223

4. Recordkeeping requirements

Records of operating parameters for 

control devices

1 12 12 1 12 0.6 1.2 $1,349.88

Records of operating conditions 

exceeding last performance test

1 8 8 14 112 5.6 11.2 $12,598.84
G-13

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours per 

year 

(Ex0.10)

Total cost 

per year 

($)b

Records of startup, shutdown, 

malfunction, etc.

0.25 5 1.25 14 17.5 0.88 1.75 $1,968.57

Subtotal for Recordkeeping Requirements 163 $15,917

TOTAL ANNUAL BURDEN AND COST (rounded) 349 $34,141

Assumptions:

a.

 Assume 1 new affected source per year and an average of 14 existing affected sources over the next three years. This does not include sources subject to both 

subpart III and the HON, which are assumed to be complying with the HON.

b.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c.

 Assume 20 percent of initial performance tests must be repeated due to failure.
G-14

Table G-7: Annual Respondent Burden and Cost for Subpart NNN

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions 1 1 1 177 177 8.85 17.7 $19,910.67

B. Required activities

Initial performance test report 60 1 60 177 10,620 531 1,062 $1,194,640.08

Repeat performance test report c60 1 60 35 2,100 105 210 $236,228.27

C. Write report

Notification of 

construction/modification

2 1 2 177 354 17.7 35.4 $39,821.34

Notification of actual startup 1 1 1 177 177 8.85 17.7 $19,910.67

Notification of initial/repeat 

performance test

2 1 2 177 354 17.7 35.4 $39,821.34

Semiannual report 3 2 6 1,876 11,256 562.8 1,125.6 $1,266,183.5

Subtotal for Reporting Requirements 28,794 $2,816,516

4. Recordkeeping requirements

Records of operating parameters for 

control devices

1 12 12 177 2,124 106.2 212.4 $238,928.02

Records of operating conditions 

exceeding last performance test

1 8 8 1,876 15,008 750.4 1,500.8 $1,688,244.67
G-15

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

Records of startup, shutdown, 

malfunction, etc.

0.25 5 1.25 1,876 2,345 117.25 234.5 $263,788.23

Subtotal for Recordkeeping Requirements 22,399 $2,190,961

TOTAL ANNUAL BURDEN AND COST (rounded) 51,192 $5,007,477

Assumptions:

a.

 Assume 177 new affected sources per year subject to subpart NNN and not the HON, and 1,876 existing affected sources over the next three years. These 

estimates do not include sources subject to both Subpart NNN and the HON, which are assumed to be complying with the HON.

b.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c.

 Assume 20 percent of initial performance tests must be repeated due to failure.
G-16

Table G-8: Annual Respondent Burden and Cost for Subpart RRR

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year ($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions 1 1 1 20 20 1 2 $2,249.79

B. Required activities

Initial performance test report 60 1 60 20 1,200 60 120 $134,987.58

Repeat performance test report c60 1 60 4 240 12 24 $26,997.52

C. Write report

Notification of 

construction/modification

2 1 2 20 40 2 4 $4,499.59

Notification of actual startup 1 1 1 20 20 1 2 $2,249.79

Notification of initial/repeat 

performance test

2 1 2 20 40 2 4 $4,499.59

Semiannual report 3 2 6 215 1,290 64.5 129 $145,111.65

Subtotal for Reporting Requirements 3,278 $320,596

4. Recordkeeping requirements

Records of operating parameters for 

control devices

1 12 12 20 240 12 24 $26,997.52

Records of operating conditions 

exceeding last performance test

1 8 8 215 1,720 86 172 $193,482.2
G-17

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year ($)b

Records of startup, shutdown, 

malfunction, etc.

0.25 5 1.25 215 268.75 13.44 26.88 $30,231.59

Subtotal for Recordkeeping Requirements 2,563 $250,711

TOTAL ANNUAL BURDEN AND COST (rounded) 5,841 $571,307

Assumptions:

a.

 Assume 20 new affected sources per year subject to subpart RRR and not the HON, and 215 existing affected sources over the next three years. These 

estimates do not include sources subject to both Subpart RRR and the HON, which are assumed to be complying with the HON.

b.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c.

 Assume 20 percent of initial performance tests must be repeated due to failure.
G-18

Table G-9: Annual Respondent Burden and Cost for Subpart BB

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year ($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions 1 1 1 0 0 0 0 $0

B. Required activities $0

Initial emission test 20 1 20 0 0 0 0 $0

Monitoring performance test 280 1 280 0 0 0 0 $0

Vapor-tightness test tank truck and 

railcars

11 1 11 3 33 1.65 3.3 $3,712.16

Marine vessels 80 1 80 66 5,280 264 528 $593,945.35

Closed vent leak inspection 8 1 8 54 432 21.6 43.2 $48,595.53

C. Create information See 3B

D. Gather existing information See 3E

E. Write report

Notification of construction 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 emission test 2 1 2 0 0 0 0 $0

Report of emission test 8 1 8 0 0 0 0 $0

Notification of performance test 2 1 2 0 0 0 0 $0

Report of performance test 8 1 8 0 0 0 0 $0

Report facilities below cut-off c8 1 8 0 0 0 0 $0
G-19

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year ($)b

Quarterly parameter excesses 4 4 16 54 864 43.2 86.4 $97,191.06

Subtotal for Reporting Requirements 7,600 $743,444

4. Recordkeeping requirements

A. Read instructions See 3A

B. Plan activities See 4C

C. Implement activities See 3 B

D. Develop record system N/A

E. Time to enter information

Facilities above cut-off 1.5 52 78 54 4,212 210.6 421.2 $473,806.41

Facilities below cut-off c0.5 52 26 0 0 0 0 $0

F. Train personnel N/A

Subtotal for Recordkeeping Requirements 4,844 $473,806

TOTAL ANNUAL BURDEN AND COST (rounded) 12,444 $1,217,251

Assumptions:

a.

 We estimate an average of 54 existing facilities will be subject to the standard, and that no new sources will become subject over the next three years. We 

estimate 3 tank truck/railcars and 131 marine vessels are subject to the standards. We assume 50 percent of marine vessels (66) operate at negative pressure 

and do not conduct annual vapor-tightness tests. We also assume all other transfer racks subject to subpart BB are complying with the HON.

b.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c.

 For sources below the low quantity applicability for control requirements, a report is only required the first year of operation. We assume existing sources 

previously have submitted this report.
G-20

Table G-10: Annual Respondent Burden and Cost for Subpart Y

Burden item

A B C D E F G H

Person-hours per 

occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year ($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions See 3C

B. Required activities

Initial performance test N/A

C. Create information

Annual IFR internal inspections and 

EFR seal gap measurements

8 1 8 4 32 1.6 3.2 $3,599.67

D. Gather existing information See 3C

E. Write report

Notification of construction/

reconstruction

Included in NSPS 

Kb

Notification of anticipated startup Included in NSPS 

Kb

Notification of actual startup Included in NSPS 

Kb

Notification of emission test N/A

Report of emission test N/A

Notification of control installation and 

refill at 1st IFR degassing c

2 1 2 0 0 0 0 $0

Annual inspection report 2 2 4 4 16 0.8 1.6 $1,799.83
G-21

Burden item

A B C D E F G H

Person-hours per 

occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours 

per year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year ($)b

Supplemental delay report d2 1 2 0 0 0 0 $0

Quarterly emission report e None expected

Subtotal for Reporting Requirements 55 $5,400

4. Recordkeeping requirements

A. Read instructions See 3A

B. Plan activities See 4C

C. Implement activities

Filing and maintaining records 2 1 2 4 8 0.4 0.8 $899.92

D. Develop record system See 4C

E. Time to enter information See 4C

F. Train personnel N/A

G. Audits N/A

Subtotal for Recordkeeping Requirements 9 $900

TOTAL ANNUAL BURDEN AND COST (rounded) 64 $6,299

Assumptions:

a.

 Estimate there will be 4 existing sources not covered by the HON. The burden for all new sources is included in the NSPS subpart Kb regulation for storage 

vessels at 40 CFR Part 60.

b.

 This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c.

 We believe that all vessels have been degassed and that all controls have been installed, as they were to be installed within 10 years of promulgation.

d.

 Estimate two percent of existing sources will request delay of repair in the annual report.

e.

 Assume no sources will select the option to have a fixed roof vented to a control device, and thus have no quarterly reports of excess emissions.
G-22

Table G-11: Annual Respondent Burden and Cost for Subpart V

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours per 

year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

A. Read instructions 1 1 1 2 2 0.1 0.2 $224.98

B. Required activities

Initial performance test 20 1 20 2 40 2 4 $4,499.59

Reference method 21/22 test 4 1 4 2 8 0.4 0.8 $899.92

Repeat performance test c20 0.2 4 2 8 0.4 0.8 $899.92

C. Create information See 3B

D. Gather existing information See 3B

E. Write report

Notification of construction/reconstruction 2 1 2 2 4 0.2 0.4 $449.96

Notification of anticipated startup 2 1 2 2 4 0.2 0.4 $449.96

Notification of actual startup 2 1 2 2 4 0.2 0.4 $449.96

Notification of initial performance test 2 1 2 2 4 0.2 0.4 $449.96

Report of performance test See 3B

Application for alternative 10 1 10 0.5 5 0.25 0.5 $562.45

Initial report 8 1 8 2 16 0.8 1.6 $1,799.83

Semiannual report 30 2 60 61 3,660 183 366 $411,712.12

Subtotal for Reporting Requirements 4,318 $422,399

4. Recordkeeping requirements
G-23

Burden item

A B C D E F G H

Person-hours 

per occurrence

No. 

of occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours 

per year 

(CxD)

Management 

hours per 

year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($)b

A. Read instructions See 3A

B. Plan activities See 4C

C. Implement activities See 3B

D. Develop record system N/A

E. Time to enter information

Record of startup, shutdown, malfunction, 

etc.

1.5 1 1.5 2 3 0.15 0.3 $337.47

Record of operation, parameters, and 

emissions

0.1 365 36.5 61 2,226.5 111.325 222.65 $250,458.21

Record of leaks detected 0.4 52 20.8 61 1,268.8 63.44 126.88 $142,726.87

F. Train personnel N/A

G. Audits N/A

Subtotal for Recordkeeping Requirements 4,023 $393,523

TOTAL ANNUAL BURDEN AND COST (rounded) 8,341 $815,921

Assumptions:

a.

 Assume 2 new sources per year and 61 existing sources subject to subpart V, but not the HON.

b

. This ICR uses the following labor rates: $101.22 for technical, $123.04 for managerial, and $51.18 for clerical labor. 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 by 110 percent to account for the benefit packages available to those employed by private industry.

c.

 Assume 20 percent of initial performance tests must be repeated due to failure.
G-24

Table G-12: Annual Respondent Burden and Cost for New Sources Subject to the HON

Burden item

A B C D E F G H

Average 

hours 

per activity

Number 

of activities 

per year 

per respondent

Technical 

hours 

per year 

per respondent

Estimated 

number of 

New 

Respondents

Estimated 

technical 

hours 

per year

Estimated 

managerial 

hours 

per year

Estimated 

clerical 

hours 

per year

Annual cost 

per year 

($)

1. Read rule and instructions 2.69 93 250 5 1,250 62.5 125 $140,612.06

2. Plan activities 3.82 93 355 5 1,775 88.75 177.5 $199,669.13

3. Training 3.47 38 132 5 660 33 66 $74,243.17

4. Creation, testing, research, and 

development

2.40 1,778 4,266 5 21,330 1,066.5 2,133 $2,399,404.23

5. Gather information, monitor/inspect 1.40 2,102 2,943 5 14,715 735.75 1,471.5 $1,655,285.2

6. Process/compile and review 0.80 50 40 5 200 10 20 $22,497.93

7. Complete reports 11.37 49 557 5 2,785 139.25 278.5 $313,283.68

8. Record/disclose 9.98 49 489 5 2,445 122.25 244.5 $275,037.19

9. Store/file 5.18 51 264 5 1,320 66 132 $148,486.34

TOTAL ANNUAL BURDEN AND COST (rounded) 53,452 $5,228,519

Assumptions:

(a) Average hours per activity are back-calculated by dividing (c) by (b).

(d) - From previously approved ICR. 

See Attachment I for assumptions and further description of activities.
G-25

Table G-13: Annual Respondent Burden and Cost for Existing Sources Subject to the HON

Burden item

A B C D E F G H

Average 

hours 

per activity

Number 

of activities 

per year 

per respondent

Technical hours 

per year 

per respondent a

Technical hours 

per year 

per respondent 

for wastewater a

Estimated 

technical 

hours per 

year

(Cx255) + 

(Dx80)

Estimated 

managerial 

hours 

per year

(Ex0.05)

Estimated 

clerical 

hours 

per year

(Ex0.10)

Annual cost 

per year 

($)

1. Read rule and instructions 3.61 23 69 14 18,715 935.75 1,871.5 $2,105,243.8

2. Plan activities 6.08 13 61 18 16,995 849.75 1,699.5 $1,911,761.6

3. Training 5.25 4 17 4 4,655 232.75 465.5 $523,639.32

4. Creation, testing, research,

and development

17.85 99 1,617 150 424,335 21,216.75 42,433.5 $47,733,295.63

5. Gather information, 

monitor/inspect

2.50 677 1,693 0 431,715 21,585.75 43,171.5 $48,563,469.25

6. Process/compile and review 20.00 1 20 0 5,100 255 510 $573,697.22

7. Complete reports 81.20 5 388 18 100,380 5,019 10,038 $11,291,711.07

8. Record/disclose 17.46 26 442 12 113,670 5,683.5 11,367 $12,786,698.52

9. Store/file 6.77 35 222 15 57,810 2,890.5 5,781 $6,503,026.67

TOTAL ANNUAL BURDEN AND COST (rounded) 1,349,381 $131,992,543

Assumptions:

(a) = (c + d)/(b).

(c) - there are 255 existing sources out of the 335 total that will continue to comply with the HON.

(d) - the 80 facilities complying with the CAR will still be required to comply with HON requirements for wastewater.
H-1

Attachment H

Assumptions and Item Descriptions for Attachment F: Table F-12

Assumptions:

(A) That all existing and new sources must submit an initial report within 120 days of 

promulgation and an implementation plan or permit application within 12 or 18 months of 

the compliance date. It is assumed that initial reports and implementation plans have been 

submitted for existing sources and these reports are only required for new sources. The new 

sources are most likely to be collocated within existing plants and be included in those 

existing source reports.

(B) That semiannual reports of results from equipment leak detection and repair programs 

are required by the equipment leak standard. Sources are required to comply with the 

equipment leak standard by 6 months after promulgation. It is assumed that an average of

335 facilities will submit reports semiannually (335 x 2 = 670) (even those that use the CAR 

will still have to submit reports under the HON for wastewater).

Item Descriptions:

(a) Average hours per activity are estimates of the specific activities and are the basis for 

estimating the overall burden.

(b) Number of activities per year represents the number of reports expected to be reviewed 

and other related activities during the course of the year. Under the performance test 

headings, these numbers are based upon assumptions (A) and (B), above. For one-time 

reports, the total number of reports expected over the three-year period was divided by three 

to get an annual average incorporating assumption (B), above.

(c) Estimated technical hours per year is the product of (a) and (b).

(d) Estimated managerial hours per year is 5 percent of (c).

(e) Estimated clerical hours per year is 10 percent of (c).

(f) Annual cost per year is the sum of costs for technical, managerial, and clerical hours 

based on rates from the Office of Personnel Management (OPM), 2013 General Schedule, 

which excludes locality rates of pay.

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%)

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

(Htx $46.21/hour) + (Hmx $62.27/hour) + (Hcx $25.01/hour) = (G)
H-2

Where:

H

t

is (c), or technical hours

H

m

is (d), or managerial hours, and

H

c

is (e), clerical hours

Report Review:

1) Initial represents the EPA review of all initial reports received.

2) Implementation plan or permit represents the EPA review of all implementation plans, or 

permit applications if submitted in lieu of an implementation plan.

3) Compliance status represents compliance status verification by the EPA for the portions 

of the standard which a source must comply with before the compliance date (see 

assumption (A), above).

4) Review equipment leak monitoring represents the review and screening of periodic 

reports received as a result of the equipment leaks standard.

5) Notification of construction/reconstruction represents the EPA review of this notification 

from new sources.

6) Notification of anticipated startup represents the EPA review of this notification from 

new sources.

7) Notification of actual startup represents the EPA review of this notification from new 

sources.

8) Notification of performance test represents the EPA review of this notification from new 

sources.

9) Review of test results represents the EPA review of performance test results for new 

sources.

10) Review periodic reports represents the EPA review of periodic reports.

TOTAL ANNUAL BURDEN AND COST (ROUNDED) is the sum of columns (c), (d), and (e), 

and of (f), respectively.
I-1

Attachment I

Assumptions and Item Descriptions for Attachment G: Tables G-12 and G-13

Assumptions:

(A) That there are 255 existing facilities out of 335 that will continue to comply with the 

HON, rather than the CAR. The 80 facilities complying with the CAR will still be required 

to comply with the HON wastewater provisions, as the CAR does not include wastewater 

provisions. The total number of facilities will increase by 5 new facilities per year. Since 

new facilities must be in compliance at startup, the general periodic recordkeeping and 

reporting burdens are included, which accounts for the difference in the technical hours per 

facility. No new facilities are expected to comply directly with the CAR.

(B) That the average representative source, new and existing, will consist of the following 

points of burden:

20 parameters to monitor at control devices throughout the facility

10 affected storage tanks of various capacities

3 affected major wastewater streams

4 affected transfer rack operations

3 overall leak detection and repair programs for 2,000 points

1 emissions averaging program that involves 10 emission points

1 facility wide inventory of emission points, Group 1 and Group 2

8 process vents per facility

(C) That there are 5 percent (0.05) managerial and 10 percent (0.10) clerical hours required 

for every technical hour.

(D) That some activities necessary to generate reports involve creating records in the 

process, and that these activities are assumed to be reports activities alone, to avoid double 

counting these as records activities as well. Therefore, only items 8 and 9 are considered 

records burdens directly.

Item Descriptions:

(a) Average hours per activity is back-calculated by dividing (b) into (c). Since the activities 

within each burden category can vary significantly, it is too inaccurate to assume an average 

to use to calculate (c). Estimated activity technical hours are summarized to obtain (c) first, 

then back calculate for (a) with an estimated (b).

(b) Number of activities per year per respondent represents the assumed typical number of 

separate activities a respondent may encounter during one year. This number may vary

from facility to facility, depending on consolidation of activities, collocated readings, etc. 
I-2

Since so much variability exists, it is important to note that this is an estimate. This number 

only was used to back-calculate (a).

(c) Technical hours per year per respondent is the actual best estimate of the burden for each 

burden item. The three-year separate activity burdens were divided by three, where 

appropriate, and then summarized to include in this column. The technical hours for new 

respondents are higher because some periodic compliance reports and records are required 

at startup. Existing respondents do not encounter these reporting and recordkeeping burdens 

for three years after promulgation.

(d) (Table G-12) Estimated number of new respondents reflects the number given in 

assumption (A), above. (Table G-13) Technical hours per year per respondent for 

wastewater are the annual technical hours associated with recordkeeping and reporting to 

ensure compliance with requirements for wastewater. As discussed in assumption (A), 

facilities complying with the CAR will comply with HON wastewater requirements. 

Burden hours per source, per emission type are shown in Table 5.

(e) Estimated technical hours per year is the product of (c) and (d) for new facilities (Table 

G-12). For Table G-13, estimated technical hours are the product of (c) and the number of 

existing facilities complying with all of the HON (255) added to the product of (d) and the 

number of facilities complying with only the wastewater provisions (80).

(f) Estimated managerial hours per year is 5 percent of (e).

(g) Estimated clerical hours per year is 10 percent of (e).

(h) Annual cost per year is 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 by 110 

percent to account for the benefit packages available to those employed by private industry.

Managerial $123.04 ($58.59+ 110%)

Technical $101.22 ($48.20 + 110%)

Clerical $51.18 ($24.37 + 110%)

(Htx $101.22/hour) + (Hmx $123.04/hour) + (Hcx $51.18/hour) = (G)

Where:

H

t

is (e), or technical hours

H

m

is (f), or managerial hours, and

H

c

is (g), clerical hours
I-3

Report Review:

1) Read rule and instructions are the activities, less training, which involve comprehending 

the provisions in the standard and understanding how they apply to the respective points at a 

facility.

2) Plan activities represent such burdens as design, redesign, scheduling as well as drafting 

the implementation plan, and selecting methods of compliance.

3) Training represents the portion (assumed 40 percent) of activities from 1) Read rule and 

instructions for which an average facility would elect to provide class room instruction. The 

standard does not require specific training itself.

4) Creation, testing, research, and development are the activities involving testing, retesting, 

establishing operating range for parameters and analyzing point-by-point applicability. 

Monitor related refit, calibration, and maintenance activities are also included under this 

heading.

5) Gather information, monitor/inspect are the activities involving physical inspections of 

equipment, collection of monitored data, and other related activities.

6) Process/compile and review are the activities that involve analysis of the information 

collected for accuracy, compliance, and appropriate reports and records required as a result.

7) Complete reports represents the activities normally associated with filling out forms. 

Since the standard requires no standard forms, these activities relate to the preparing of 

formal reports and cover letters as appropriate.

8) Record/disclose are activities which are solely recordkeeping which occur once the 

appropriate report information has been extracted [see assumption (D), above]. These 

activities involve software translation, duplication, or archival processes normally

associated with data management and storage common to this industry.

9) Store/file again are activities which are solely recordkeeping which occur once the 

appropriate report information has been extracted [see assumption (D), above]. These 

activities involve the management life cycle of records, from the time they are filed and 

boxed up, to the time they are disposed.

TOTAL ANNUAL BURDEN AND COST (ROUNDED) is the sum of columns (e), (f), and (g), 

and of (h), respectively.
J-1

Attachment J

Summary of Capital/Startup and Operation & Maintenance Costs for the CAR and Its 

Referencing Subparts

NSPS Subpart Ka

a. Total Capital/Startup Cost of Monitoring Equipment:

The total capital/Startup costs for this ICR are $0.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The total operating and maintenance (O&M) Costs for this ICR is $0.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $0.

NSPS Subpart Kb

a. Total Capital/Startup Cost of Monitoring Equipment:

The total capital/Startup costs for this ICR are $27,000. This is the cost for 2 new 

storage tanks to install monitoring equipment associated with the CVS routed to a 

control device. The storage tanks will use equipment similar to that used for 

subparts NNN and III; therefore, the startup costs are approximately $13,500 per 

facility for a total of $27,000. There are no capital/startup costs for the remaining 

35 new storage tanks complying by either an IFR or EFR. 

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The average annualized burden is estimated to be $1,350 per year per affected 

facility ($13,500 discounted over 10 years by straight line depreciation method) 

for both new (2) and existing affected sources (432) using CVS routed to a control 

device, for a total of $585,900.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $612,900.

NSPS Subpart VV

a. Total Capital/Startup Cost of Monitoring Equipment:

The capital/startup costs of this regulation are $0. We assume facilities that are 

already complying with subpart VV will not need to buy an additional monitor 

and that no additional facilities will become subject to subpart VV in the future.
J-2

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

Operation of monitors is included in monitoring costs. Maintenance costs for 

these units are incidental; therefore, no maintenance or operation costs will be 

incurred.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $0.

NSPS Subpart VVa

a. Total Capital/Startup Cost of Monitoring Equipment:

The capital/startup costs of this regulation total $4,200. This is based on the 

average cost of a monitor ($7,000) with a 5-year expected life. The equipment is 

not capitalized, so no discount rate applies. The average annual cost is, therefore, 

$7,000/5, or $1,400/yr. It is estimated that only area sources that construct new 

process units might purchase a monitoring instrument. All other sources should 

have monitoring equipment because they are either subject to MACT rules or 

have been subject to NSPS subpart VV for other processes. We assume 38 

process units are subject to NSPS subpart VVa each year, where 60 percent of all 

new sources are newly constructed sources and 15 percent of all new sources are 

area sources. Therefore, an estimated 3 facilities with a new process unit will buy

a monitoring instrument to comply with NSPS subpart VVa, yielding a total 

capital/startup cost of $1,400 x 3, or $4,200.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The operation of the monitors is included in the monitoring costs. Maintenance 

costs on these units is incidental; therefore, no maintenance or operation costs 

incur.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $4,200.

NSPS Subpart DDD

a. Total Capital/Startup Cost of Monitoring Equipment:

The capital/startup costs for this regulation are $300,000. This is based on 10 new 

sources per year multiplied by $30,000 per source for monitoring equipment. 

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The annual operation and maintenance costs are $910,000. This is based on 120

existing sources plus 10 new sources per year over the life of the ICR multiplied 

by $7,000 for upkeep of the monitoring devices.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $1,210,000.
J-3

NSPS Subpart III/NNN

a. Total Capital/Startup Cost of Monitoring Equipment:

The startup cost of monitoring equipment is approximately $13,500 per new 

affected facility for both subpart III, Air Oxidation Operations and subpart NNN, 

Distillation Operations, or a total of $2,403,000 (total of 178 new sources x 

$13,500/source).

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The average annualized burden is estimated to be $1,350 per year per affected 

facility ($13,500 discounted over 10 years by straight line depreciation method) 

for subpart III and for subpart NNN for a total of $2,791,800 [($1,350 x 2,068) 

total number of new and existing affected sources under NNN and III]. 

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $5,194,800.

NSPS Subpart RRR

a. Total Capital/Startup cost of Monitoring Equipment:

The capital/startup costs for this regulation are $500,000 per year. This is based 

on 20 new sources per year multiplied by $25,000 for monitoring equipment 

discounted over 10 years at 7 percent. 

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The annual operation and maintenance costs are $117,500. This is based on 215 

existing sources plus 20 new sources multiplied by $500 for upkeep of the 

monitoring device.

c. Total Capital/Startup and O&M Cost:

The total capital/startup and O&M Costs are $617,500.

NESHAP Subpart BB

a. Total Capital/Startup cost of Monitoring Equipment:

Startup costs were identified in previous ICR.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

There are no O&M cost associated because no CEMs are employed.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M costs are $0.
J-4

NESHAP Subpart Y

a. Total Capital/Startup Cost of Monitoring Equipment:

The only type of industry costs associated with the information collection activity

in the standards is labor cost. There are no capital/startup costs. 

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

There are no operation and maintenance costs. 

c. Total Capital/Startup and O&M Cost:

The total capital and O&M costs are $0.

NESHAP Subpart V

a. Total Capital/Startup Cost of Monitoring Equipment:

Startup cost were identified in previous ICR.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

There are no O&M costs associated because no CEMs are employed.

c. Total Capital and O&M Cost

The total capital and O&M costs are $0.

NESHAP HON:

Subpart G

a. Total Capital/Startup Cost of Monitoring Equipment:

Estimate the cost to purchase monitoring equipment is approximately $20-30K for 

process vents and wastewater operations, or an average of $25K with a 10-year 

life expectancy and a 7 percent depreciation rate, or $2,225 per year. There are no 

associated costs for transfer racks and storage tanks. Only new sources need to 

buy monitoring equipment; therefore, the total capital/startup cost is $25,000 x 5, 

or $125,000.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The cost to industry associated with the operation and maintenance (O&M) is 

approximately $100-500K per year (capital/startup depreciation not included) for 

reactor process vents and wastewater operations. The cost associated with the 

operation and maintenance is $50-100K per year (capital/startup depreciation not 

included) for distillation units process vents. There are no associated costs for 

transfer racks and storage tanks. The average O&M cost is assumed to be the 

average of the two ranges, or $275,000 per year. Operation and maintenance 

incur for both new and existing sources. The total O&M is, therefore, $275,000 x 

260, or $71,500,000.
J-5

c. Total Capital/Startup and O&M Cost:

The total capital and O&M costs are $71,625,000.

Subpart H

a. Total Capital/Startup Cost of Monitoring Equipment:

Only new sources will buy an organic volatile analyzer. Estimate the average cost 

of a monitor is $7,000 with a 5-year expected life. The equipment is not 

capitalized, so no discount rate applies. The average annual cost is, therefore, 

$7,000/5, or $1,400/yr. Estimate that 80 percent of facilities contract out LDAR 

services, and 20 percent perform in-house. Those facilities which contract out (4 

facilities) will purchase one unit as backup; the remaining facilities performing 

LDAR in-house (1 facility) will purchase 5 units to support the program. The 

total annual capital/startup cost is, therefore, 9 units x $1,400/unit, or $12,600/yr.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The operation of the monitors is included in the monitoring costs. Maintenance 

costs on these units is incidental; therefore, no maintenance or operation costs are 

incurred.

c. Total Capital and O&M Cost for Subparts H:

The total capital and O&M costs are $12,600.

Part 65 CAR

a. Total Capital/Startup Cost of Monitoring Equipment:

Under the CAR, it is assumed all new sources start out under the referencing 

subpart. Therefore, there is no capital/startup cost associated with this subpart.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The HON is the basis for determining O&M costs for the CAR. The average cost 

per source, based on the HON is $275,000 per year, for a total of $22,000,000.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M costs are $22,000,000.