**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY** 
**NESHAP for NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline**  **Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC**  **(Renewal)**
**1. Identification of the Information Collection**  **1(a) Title of the Information Collection** NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC ( Renewal) , EPA IC R number 2237.03, OMB Control Number 2060

- 0620

. **1(b) Short Characterization/Abstract** The National Emission Standards for Hazardous Air Pollutants (NESHAP), for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC ) were proposed on January 10 , 20 08 (73FR1916) , and amended on January 2 4, 2011 ( 76 FR 4156 ). These regulations apply to existing and new gasoline distribution facilities that are area sources of hazardous air pollutants (HAP). New facilities include those that commenced construction or reconstruction after the date of the proposal. This information is being collected to ensure compliance with 40 CFR part 63 subparts BBBBBB and CCCCCC

. In general, all NESHAP standards require initial notifications, performance tests, and periodic reports. In addition to the initial notification and notification of compliance status required b y the General Provisions to 40 CFR part 63, subpart A, respondents are required to submit one

- time reports of start of construction, anticipated and actual startup dates, and phys ical or operational changes to existing facilities. Reports of initial performance tests on control devices at gasoline distribution storage tanks, loading racks, and vapor balance s ys tems are also required and are necessary

to show that the installed control devices are meeting the emission limitations required b y the NESHAP. Annual reports of storage tank inspections at all affe cted facilities are required. In addition, respondents must submit semiannual compliance and continuous monitoring system performance reports, and semiannual reports of equipment leaks not repaired within 15 days or loadings of cargo tanks for which vapor tightness documentation is not available. These notifications, reports, and records of such measurements are essential in determining compliance and are required of all sources subject to NESHAP standards. Any owner or operator subject to the provisions of this part will maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are sent to the del egated state or local authority . In the event that there is no such delegated authority, the reports are sent directly to the United States Environmental Protection Agency regional office.2

Approximately 350,000 sources are currentl y subject to the se stan dard s, with the gasoline dispensing facility

segment alone accounting for about 340,000 of these facilities. However, a large percentage of these facilities are already complying with this rule as a result of their compliance with applicable State and loc al rules. We have minimized or eliminated the reporting and recordkeeping requirements under this rule for most of those sources. Therefore, the total estimated number of affected sources expected to incur reporting and recordkeeping costs under this rul e is about 19,120. Also, there are no new or reconstructed facilities expected within the larger, bulk segment of the industry and new gasoline dispensing facilities are expected to be subject to State and local rules. Thus, we have estimated that no additional sources will become subject to the regulation and therefore, we expect th at only existing sources will be subject to the reporting and recordkeeping requirements of the rule. We have, however, included a description of the notifications that would be required if new affected sources are constructed.

None of the 350,000 facilities in the United States are owned by state, local, tribal or the Federal government. They are owned and operated by p rivately o wned for

-profit businesses. Y ou can find the different burden s to the “Affected Public” listed below , respectively , in Table 1 a : One

- Time Annual Respondent Burden and Cost

- NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC ) (Renewal) and Table 1b: Recurrent Annual Respondent Burden and Cost

- NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC ) (Renewal) The Federal government burden does not in clude work performed by Federal employees. This particular burden refers onl y to work performed for the Federal government by contractors, which c an be found listed below in Table 2: Average Annual EPA Burden

- NESHAP for Gasoline Distribution Bulk Termin als, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC ) (Renewal)

. In the development of the IC R, we addressed the Office of Management and Budget (OMB) “Terms of Clearance (TOC)” on the active ICR. The TOC are as follows:

When this I CR is renewed, EPA should review the respondent burden, universe, labor rates, and capital costs , and ensure these estimates have been updated. EPA has addressed each item of concern in the TOC. The respondent burden, universe, labor rates, and capital cost, have been thoroughly checked and all estimates updated.
**2. Need for and Use of the Collection 2(a) Need/Authority for the Collection**  The EPA is charged under section 112 of the Clean Air Act, as am ended, to establish standards of performance for each category or subcategory

of major sources and area sources of hazardous air pollutants (HAP). These standards are applicable to new or existing sources of HAP and shall require the maximum degree of emi ssion reduction. In addition, section 114(a) states3

that the Administrator may require any o wner or 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 presc ribe); (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 reasonabl y require.
Inthe Administrator's judgment, HAP compounds found in the gasoline stored, transferred, and distributed at these facilities cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for this area source category

at 40 CFR part 63, subpart s BBBBBB and CCCCCC

. In total, this NESHAP will regulate 9 HAP compounds normally found in gasoline , including : b enzene , ethylbenzene , h exane , toluene , x yl enes , i sooctane , n aphthalene , cumene , and m ethyl tert

- butyl ether

. **2(b) Practical Utility/Users of the Data** The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where 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 i nitial capab ility to comply

with the emission standard. Continuous emission monitors are used to ensure compliance with the standard at all times. During the performance tests, a record of the operating parameters under which compliance was achieved may be recorded and used to determine compliance in place of a continuous emission monitor. The notifications required in the standard are used to inform the Agency or delegated authority when a source becomes subject to the requirements of the regulations. The reviewin g authority may then inspect the source to ensure that the pollution control devices are properl y installed and operated, that leaks are being detected and repaired, and that the standards are being met. The performance test may also be observed.
The inf ormation generated by

the monitoring, recordkeeping, and reporting requirements described in this I CR is used by the agency

to ensure that facilities affected by the NESHAP continue to operate the control equipment in compliance with the regulation.
**3. N on**  **- duplication, Consultations, and Other Collection Criteria** 4

The requested recordkeeping and reporting are required under 40 CFR part 63, subpart s BBBBBB and CCCCCC

. **3(a) Non**
**- duplication** 
Some of the facilities subject to this NESHAP will also be subje ct to requirements under 40 CFR part 60 new source performance standards (NSPS), subparts K, Ka, Kb, and XX. Some operations also occup y the same plant site as facilities complying with other NESHAP such as 40 CFR part 63, subpart CC (the Refinery NESHAP ). The burden requested for this NESHAP does not duplicate any of the burden accounted for under the mentioned NSPS or NESHAP subparts. If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional off ice. Otherwise, the information is sent directl y to the delegated state or local agency
. If a state or local agency h as adopted their own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency ca n be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, no duplication exists. **3(b) Public Notice Required Prior to ICR Submission to OMB** An announcement of a public comment period for the renewal of this IC R w as published in the Federal Register ( 7 6 FR 2 6 900 ) on May 9, 20 11 . 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 b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information Sy stem (OTI S) 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. The growth rate for the industry is based on our consultations with the Agenc y’s internal industry experts.
The Gasoline Distribution

- Area Sources NESHAP was developed with the help of industry stakeholders. Industry

stakeholders were informed of the project’s progress in two stakeholder meetings conducted in Research Triangl e Park, North Carolina. Table 1 contains the names, affiliations, and phone numbers of stakeholders involved in the rulemaking effort. These stakeholders were consulted during all phases of this NESHAP development.5

**Table 1. List of People Consulted in Gasoline Distribution NESHAP Development** 

It is our polic y to respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the f irst Federal Register n otice. **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 b y these standards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely

. **3(e) Gen eral Guidelines**  None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. Name Organization Position Telephone Charles Bennett Marathon Petroleum Co. Corporate Environment, Safety & Security 606

- 921

- 3636
Judy Bigon ExxonMobil 281

- 848

- 3506 Rob Ferry TGB Partnership Consultant 919

- 644

- 8250 Clay R. Freeberg Chevron Policy, Government & Public Affairs 925

- 842

- 3451 Joseph Green SIGMA and NACS 202

- 342

- 8451 Moraima Grinnell ExxonMobil Kim ber Hamilton Marathon Petroleum Co. Corporate Environment, Safety & Security 419

- 421

- 2891

Terri Holloman Magellan Pipeline Tom Kelly Colonial Pipeline Jan L. Laughlin ConocoPhillips Regulatory Issues Coordinator 281

- 293

- 1142 Tim L. Laughlin North Carolina Petroleum

Marketers Association Technical Director 919

- 782

- 4411

Usha Mehra ILTA/GATX Terminals Corporation Environmental, Health and Safety

Manager

- Gulf Region 713

- 450

- 0400

Jack McClure Shell Matthew A. Todd API Regulatory Analysis and Scientific Affairs 202

- 682

- 8319
Doug Vopat BP 216

- 271

- 8189 Peter Weaver ILTA6

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. E PA believes that the five

- ye ar records retention re quirement is consistent with the Part 70 permit program and the five

- ye ar 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

- c ompliance and to determine the appropriate level of enforcement action. EPA has found that the most flagrant violators have violations extending beyond the 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 i s 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 b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions** None of the reporting or recordkeeping requirements contain sensitive questions. **4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes**  The respondents are owners or operators of gasoline distribution facilities subject to the recordkeep ing and reporting requirements of the NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities . The United States Standard Industrial Classification (SI C) codes for the respondents affected by the standards, which corresponds to The North American Industry Classification System (NAICS) codes, are listed below for source category description.

**Standard s**  **(40 CFR subparts**  **BBBBBB and CCCCCC) NAICS Codes**  **SIC Codes**
Pipeline transportation of refined petroleum products 486910 4613

Bulk gasoline terminals and bulk plants 424710 5171

Gasoline stations with convenience stores 447110 54117

Gasoline stations without convenience stores 447190 5541
Hazardous materials trucking

- local 48422 0 4214 Hazardous materials trucking

– long distance 48423 0 4213

**4(b) Information Requested** None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. **(i) Data Items** In this ICR, all the data recorded or reported is required by NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC

. A source must make the fol lowing reports: **Notification Reports** Initial n otification s, reports of startups, shutdowns, malfunctions, anticipated construction/reconstruction , and modification 63.5, 63.9(b) (2

- 5) , 63.10(d)(5), 63.8 67(a) N otification and report of performance test and results 63.7( a - b), 63.9 (e) , 63.10(d)(2) Notification of initial continuous monitoring system (CMS)/ continuous opacity

monitoring s ys tem (COMS) demonstration 63. 9 ( g ), 63. 867 ( a)
Notification and report o f compliance status 63. 9 (h), 63.9(b)(2) , 63.11095(b). Notification of installation of a new control device or reconstruction of an existing one 63.5(b)(6) and §63.5(d)(1) Reporting results of CMS/COMS demonstration 63.1 0 ( e )(2), 63.8 67 ( a) Semiannual compliance reports 63.10(e)(3), 63.8 67 ( c ) , 63.11095(b) A source must keep the following records: **Recordkeeping** Five ye ars retention of records 63 .1 0 (b)(1) , 63.11094(a Startup, shutdown, and malfunction plan 63.6(e)(3), 63.866(a) Records of startup, shutdown, and malfunction 63.6(e)(3)(iii)

- (iv), 63.10(b)(2)(i)

- (v)8 **Recordkeeping** Records of performance tests 63.10(b)(2)(viii) Documentation supporting initial notifications and notification of compliance status 63.1 0 (b ) (2)(xiv) , 63.11094(b) Records of annual inspections 63.11094(a) and (e) Record of operating parameter monitoring data, as well as specific records to ensure that the monitoring activities will provide an indication of the facility ’s compliance, are to be kept pursuant to 63.11094(b) and (f).

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

agencies in cooperation with the respondents continue to create reporting systems to transmit data electronically. However, electronic reporting s ys tems are still not widely used. At this time, it is estimate d that approximately 1 0 percent of the respondents use electronic reporting. **(ii) Respondent Activities Respondent Activities**  Read instructions. Install, calibrate, maintain, and operate CMS for opacity , or for pressure drop and liquid supply pressure for wet scrubber. Perform initial performance test, Reference Method 18, Method 25A, and Method 27 1, 1A , as applicable, and repeat performance tests if necessary

. Write the notification and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install , and utilize technology and sy stems for the purpose of disclosing and providing information. Adjust the existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information. Transmit, or otherwise disclose the information.9

Currently , sources are using monitoring equipment that provid es parameter data in an automated way

e.g., continuous parameter monitoring s ys tem. Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantly reduced the burden associated with monitoring and rec ordkeeping. **5. The Information Collected: Agency Activities, Collection Methodology, and Information Management**  **5(a) Agency Activities**
EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the required information. **Agency Activities** Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, excess emissions reports, required to be submitted by industry

. Audit facility

records. Input, anal yz e, and maintain data in the Online Tracking Information System (OTI S). **5(b) Collection Methodology and Management** Following notification of startup, the reviewing authority might inspect the source to determine whether the pollution control devices are properl y installed and operational. P erformance test reports are used b y the Agency to discern a source’s initial capability to comply

with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs.
In formation contained in the reports is entered into OTI S which is operated and maintained by the EPA Office of C ompliance. OT IS i s the EPA database for the collection, maintenance, and retrieval of compliance data for approximately 8,000 industrial and government

- owned facilities. EPA uses OTI S for tracking air pollution compliance and enforcement by local and state regulatory

a gencies, EPA regional offices, and EPA headquarters. EPA delegated Authorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner or operator for five ye ars. **5(c) Small Entity Flexibility** 
Since these regulations address area sources of HAP emissions (i.e., a source that emits less than 10 tons per year of any individual hazardous air pollutant (HAP) or less than 25 tons per year of any combination of HAP ) , the a majori ty of the respondents (i.e., owner s or operators of10

gasoline dispensing facilities , bulk plants , bulk terminals, pipeline breakout stations, and pipeline pumping stations ) are typ ically small facilities and many of them meet the definition of a small business entity (i.e., small business) Therefore , the impact on small entities was taken into consideration during the development of the se regulation s . 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. Con struction, modification, and reconstruction reports take very little time to complete and are filed onl y once. Equipment leak monitoring and storage tank inspection records are brief, and cargo tank vapor tightness documentation will be supplied primarily by

independent cargo tank operators and kept at the gasoline distribution facility f or each cargo tank and railcar that is to be loaded at the facility

. To the extent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. **5(d) Collection Schedule** The specific frequency for each information collection activity within this request is shown below in both Table 1: Annual Respondent Burden and Cost

- NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC (Renewal

. **6. Estimating the Burden and Cost of the Collection** Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. 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 60,517 person - hours (Total Labor Hours summ arized from Table s 1 (1.1 through 1.5 ). These hours are based on Agency studies and background documents from the development of the regulation, Agency knowledge and experience with the NESHAP program, the previously a pproved IC R, and any

c omments receive d. **6(b) Estimating Respondent Costs** This I CR uses the following labor rates: Managerial $118.92 ($56.63 + 110%) Technical $97.78 ($46.56 + 110%) Clerical $48.76 ($23.22 + 110%)11

These rates are from the United States Department of Labor, Bureau of Labor Statistics, December 2010, "Table 2. Civilian Workers, by Occupational and Industry group." The rates are from column 1, "Total Compensation." The rates have been increased by 11 0 percent to account for the benefit packages available to those employed by private industry

. **(ii) Estimating Capital/Startup and Operation and Maintenance Costs** The ty pe of industry

costs associated with the information collection activities in the subject standard are both labor costs which are addressed elsewhere in this ICR and the costs associated with continuous monitoring. The capital/startup costs are one

- time costs when a facility becomes subject to the regulation. The annual operation and maintenance costs are the ongoing costs to maintain the monitor and other costs such as photocopying and postage.

**(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs.**  **Operation and Maintenance (O&M) Costs** (A) Activity (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

Total Capital/Startup Cost, (B X C) (E)

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)
C P MS for vapor processors * $ 0 0 $ 0 $ 1 ,000 110 $ 110,000
TO TAL $0 $ 1,000 $ 110,00 0
* Assumed that there are no new respondents that would be required to install operating parameter monitoring systems for vapor processors as a result of these regulations and would have associated O&M costs. The O&M costs for initial compliance have already occurred in order to comply with the existing rule. The total capital/startup costs for this I CR is $0. This is the total of column D in the table a bove. There were n o capital costs included in the estimated monitoring, reporting, and recordkeeping costs because the ty pes of monitors that are required b y the rule (operating parameter monitors or CPMS for vapor processors) are ty pically included as a standard component of the control device itself

. The total operation and maintenance (O&M) cost is $ 110,000 for CPMS, photocopying, and postage

. This is the total of column G.
The average annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the IC R is estimated to be $ 110,000

. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported information. The EPA compliance and enforcement program includes activities such as: the examination of record s maintained by the respondents; periodic inspection of sources of12

emissions; and the publication and distribution of collected information. The average annual Agency cost during the three years of the ICR is estimated to be $ 1,652,63 4

. This cost is based on the average hourl y 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%)
These rates are from the Office of Pers onnel Management (OPM) “2011 General Schedule” which excludes locality

rates of pay . The rates have been increased by 60 percent to account for the benefit packages available to government employees . Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC (Renewal)

. **6(d) Estimating the Respondent Universe and Total Burden and Costs**  We estimate that the number of potentially affected sources under this rule may be as high as 350,000. However, the gasoline dispensing facility segment alone accounts for about 340,000 of these facil ities. In addition, a large percentage of the total facilities in the gasoline distribution industry are already regulated by State and local rules that are as at least as stringent as this NESHAP. As a result of these facts, we have included provisions in the rule to allow those facilities that are compl yi ng with the requirements of State and local rules to minimize the burden of this NESHAP. For example, gasoline dispensing facilities that are located in States with submerged fill requirements will hav e no reporting or recordkeeping requirements under the NESHAP. Also, other types of facilities that are complying with the NESHAP by virtue of their compliance with State or local rules will be allowed to utilize performance tests and monitoring results p erformed as a condition of their State or local permit to satisfy the requirements of the NESHAP. Within the primary industry segments in the source category , it is estimated that the following numbers of affected area source facilities will incur a reporting or recordkeeping burden as a result of the NESHAP: 1,100 b ulk terminals , 460 p ipeline breakout stations, 1,800 p ipeline pumping stations , 5,900 b ulk p lants , 9,860 gasoline dispensing facilities for a total of 19,120 facilities , as described in the table below

. Therefore, we estimate that on average over the next three ye ars, approximately 19,120 existing respondents will be subject to the standard. It is estimated that no additional new sources will become subject to the rule . The overall average number of respondents, as shown in the table below is 19,120 per year. **6(e) Bottom Line Burden Hours Burden Hours and Cost Tables** On an individual basis, the detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 a, 1b, and 2, respectively , and summarized below.13 **(i) Respondent Tally**  The total annual labor costs are $ 6,068,409 . Details regarding these estimates may be found below in both Table 1 : Annual Respondent Burden and Cost: NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC (Renewal)

.

The total annual capital/startup and operation and m aintenance ( O&M ) costs to the regulated entity are $ 110,000

.

**(ii) The Agency Tally**  The average annual Agency b urden and cost over next three ye ars is estimated to be 20,870 labor hours at a cost of $ 1,652,634

. See below Table 2 : Average Annual EPA Burden and Cost

- NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC (Renewal)

. **6(f) Reasons for Change in Burden** The adjusted decrease in burden from the m ost recently approved ICR is due to the assumption that existing sources would have already complied with the initial requirements of the rules, including testing and initial notifications

. In addition, we expect that there would be n o new facilities cons tructed or reconstructed over the next three years of this I CR that would need to conduct this initial testing

. The total cost per year for labor decreased as a result of the revised changes even when we updated labor rates.
Because there are no new sources with reporting requirements, no capital/startup costs are incurred. The only

cost that is incurred is for the operation and maintenance (O&M) of the parameter monitoring equipment for vapor processors **6(g) Burden Statement** The annual public reporting and recordkeeping burden for this collection of information is estimated to average 8 hours per response. Burden means the total time, effort, or financial resources expended by

persons to generate, maintain, retain, or disclos e or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; c omplete 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 Numb er. The OMB Control Numbers for EPA ’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.14

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OAR

- 2011

- 0230 . 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 content of the docket, and to access those documents in the public docket that are avai lable electronically . When in the system, select “search” than 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 In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W., Washington, D

. C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday , excluding legal holidays. The telephone number for the Reading Ro om is (202) 566

- 1744, and the telephone number for the Enforcement and Compliance Docket and Information Center Docket is (202) 566

- 17 52

. Also, yo u can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, D

. C

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

- HQ

- OAR

- 2011

- 0230 and OMB Control Number 2060

- 0620 in any correspondence. **Part B of the Supporting Statement** This part is not applica

ble because no statistical methods were used in collecting this information.15

**Table 1(1.1 through 1.5): Annual Respondent Burden and Cost: NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC**  **(Renewal)**

**Assu mptions**  **for Table 1.1:**  a) We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 1,100 existing bulk terminals. b) Assumed that all bulk terminal loading racks with >250,000 gallons per day throughput (threshold for vapor processor control requirement) already have vapor processors and that all have been tested. c) Assumed that 10 % of bulk terminals (110) must install operating parameter monitoring systems. d) Assumed that 50 % of bulk terminals (550) m ust begin performing annual storage tank inspections and that all are currently performing equipment leak inspections at least once per month. **Burden Item (A)** 

**Technical Hrs per**  **Occurrence (B)** 

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

**Technical Hours per**  **Respondent (C=AxB)**  **(D)**

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

**Persons**
**- Hours**  **per year** **(C*D)** **Technical**

**Persons**
**- Hours**  **per year** **(E*$97.78)** **Management**

**Hours per Year**  **(E*0** **.0 5**  ***** **$118.9 2/hr** **) Clerical hours** 

**per Year** **(E*0.1** ***** **$48.76/ h**  **) Labor Cost per** 

**Year ($)**

1.1 Bulk Terminals (a) Read and understand rule requirements 6 1 6 0 0 0 0 0 0 (b) Prepare I

nitial Notification 4 0 4 0 0 0 0 0 0 (c) Perform I

nitial Performance Test 175 0 175 0 0 0 0 0 0 (d) Prepare Notification of Compliance Status 4 0 4 0 0 0 0 0 0 (e ) Perform annual storage tank inspection 12 1 12 550 6600 645,348 .00 39,243.60 32,181.6 716,773.20 ( f ) Perform equipment leak inspections 2 12 24 0 0 0 0 0 0 ( g) Keep records of performance tests, storage tank and equipment leak inspections, and cargo tank vapor tightness documentation 0.75 12 9 733 6597 1,290,402 .66 39,225,76 32,166.97 1,361,795.39 (h ) Submit semiannual compliance report 4 2 8 733 5864 1,863,784.58 34,867.34 28,592.86 1,927,244.78 Subtotal 19,061 2,437,166.50 113,336.70 92,941.434 2,643,444.6316

**Table 1.2**

**Burden Item (A)** 

**Technical Hrs per Occurrence**  **(B)**

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

**Technical Hours per**  **Respondent (C=AxB)**  **(D)**

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

**Persons**
**- Hours**  **per year** **(C*D)** **Technical**

**Persons**
**- Hours**  **per year** **(E*$97.78)** **Management**

**Hours per Year**  **@ (E** * **0. 05** * **$118.9 2/hr** **) Clerical** 

**hours per Year**  **(E*0**
**. 1**  ***** **$48.7 6/h**  **) )**  **Labor Cost per**

**Year ($)**

1 .2 Pipeline Breakout Stations (a) Read and understand rule requirements 6 1 6 0 0 0 0 0 0 (b) Prepare I

nitial Notification 8 1 8 0 0 0 0 0 0 (c) Prepare Notification of Compliance Status 8 1 8 0 0 0 0 0 0 (d) Perform annual storage tank inspection 12 1 12 230 2,760 269,872.8 16,410.96 13,457.76 299,741.52 ( e ) Perform equipment leak inspections 2 4 8 0 0 0 0 0 0 (f) Keep records of storage tank and equipment leak inspections 16 1 16 306 1,836 179,524.08 10,916.86 8,952.34 199,3993.28 (g) Submit semiannual compliance report 4 2 8 306 2,448 239,365.44 14,555.81 11,936.45 265,857.70 Subtotal 7,044 688,762.32 41,883.62 34,346.55 764,992.5 **Assu mptions**  **for Table 1**  **.2:** a) We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 460 pipeline breakout stations

. b) Assumed that 50 % of pipeline breakout stations (230) must begin performing annual storage tank inspections and that all are currently performing equipment leak inspections at least once per month.17

**Table 1.3 Burden Item**  **(A)**

**Technical Hrs per**  **Occurrence (B)** 

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

**Technical Hours per**  **Respondent (C=** **AxB) (D)** 

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

**Persons**
**- Hours**  **per year** **(C*D)** **Technical**

**Persons**
**- Hours**  **per year** **(E*$97.78)** **Management**

**Hours per Year**  **(E*** **0. 05** * **$118.9 2/hr** **) Clerical** 

**hours per Year**  **(E*0.1*** **$48.7 6/h**  **) Labor Cost per** 

**Year ($)**

1 .3 Pipeline Pumping Stations (a) Read and understand rule requirements 4 1 4 0 0 0 0 0 0 (b) Prepare I

nitial Notification 1 1 4 0 0 0 0 0 0 (c) Prepare Notification of Compliance Status 1 1 4 0 0 0 0 0 0 (d) Perform equipment leak inspections 1 12 12 0 0 0 0 0 0 (e) Keep records of equipment leak inspections 0. 1 1 2 1

. 2 1, 2 00 1,440 140,803.20 190.90 7,021.44 148,015.54 (f) Submit semiannual compliance report 0.25 2 1 1, 2 00 600 58,668.00 148.90 2,925.6 61,742.5 Subtotal 2,040 199,471.20 339.8 9,947.04 209,758.04 **Assu mptions**  **for Table 1.3:** a) We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged as 1,800 pipeline pumping stations

. b) Assumed that all facilities currently inspect for leaks at least once per month. c) Assumed that, on an annual average basis, 2 percent of facilities (36) will be required to submit a semiannual compliance rep ort because of delays in repairing equipment leaks.18

**Table 1.4 Burden Item**  **(A)**

**Technical Hrs per Occurrence**  **(B)**

**Number of Occurrences**  **per Respondent**  **per Year (C) Technical** 

**Hours per Respondent**  **(C=AxB) (D)** 

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

**Persons**
**- Hours**  **per year** **(C*D)** **Technical**

**Persons**
**- Hours**  **per year** **(E*$97.78)** **Management**

**Hours per Year**  **(E*05*** **$118.92 /hr** **) Clerical** 

**hours per Year**  **(E*0.1*** **$48.7 6/h**  **) Labor Cost per** 

**Year ($)**

1 .4 Bulk Plants (a) Read and understand rule requirements 4 1 4 0 0 0 0 0 0 (b ) Read and understand rule requirements 2 1 2 0 0 0 0 0 0 ( c ) Prepare I

nitial Notification 2 1 2 0 0 0 0 0 0 (d) Prepare Notification of Compliance Status 1 1 1 0 0 0 0 0 0 (e ) Perform equipment leak inspections 0.25 12 3 0 0 0 0 0 0 (f ) Keep records of equipment leak inspections 0.10 12 1.2 3,933 4,719.60 461,482.49 28,062.74 22,984.45 512,529.68 (g) Submit semiannual compliance report 1 2 2 118 236 23,076 1,403,26 1,149.32 25,628.58 Subtotal 4,955.6 538,158.26 **Assu mptions**  **for Table 1.4:** a) We expect no new affected sources the next 3 years of this ICR. Therefore, the estimated number of respondents remains unchanged from previous ICR at 5,900 bulk plants

. b) Assumed that all facilities currently inspect for equipment leaks at least once per month. c) Assumed that, on an annual average basis, 2 percent of facilities (118) will be required to submit a semiannual compliance report because of delays in repairing equipment leaks.19

**Table 1.5 Burden Item**  **(A)**

**Technical Hrs per Occurrence**  **(B)**

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

**Technical Hours per**  **Respondent (C=AxB)**  **(D)**

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

**Persons**
**- Hours**  **per year** **(C*D)** **Technical**

**Persons**
**- Hours**  **per year** **(E*$97.78)** **Management**

**Hours per Year**  **(E*05*** **$118.92 /hr** **) Clerical** 

**hours per Year**  **(E*0.1*** **$48.7 6/h**  **) Labor Cost per** 

**Year ($)**

1 .5 Gasoline Dispensing Facilities (a) Read and understand rule requirements ( (facilities >100k already in compliance) 0.5 1 0.5 0 0 0 0 0 0 (b) Read and understand rule requirements (facilities <100k already in compliance) 0.25 0.33 0.25 0 0 0 0 0 0 (c) initial vapor balance system testing 6 1 6 0 0 0 0 0 0 ( d) Prepare In itial Notification 1 1 1 0 0 0 0 0 0 (d) Prepare Notification of Compliance Status 1 1 1 0 0 0 0 0 0 (e) vapor balance system testing 6 0.3 1.98 9,860 19,523 1,908,958.94 1,095.07 2,001.06 1,912,055.07 Subtotal 19,523 1,912,055.07 **Assu mptions**  **for Table 1.5:** a) We expect no new affected sources the next 3 years of this ICR. Of the total 340,000 facilities, 243,587 facilities with throughputs of <100,000 gpm that are complying with a SLT submerged fill requirement, and for the 85,340 facilities with throughputs of >100,000 gpm that are comp lying with a state (SLT) vapor balancing requirement, there are no other reporting or recordkeeping requirements associat ed with this rule for this ICR. Therefore, the estimated number of respondents with recordkeeping and reporting requirements remains unchanged from the previous ICR as 11,073 gasoline dispensing facilities , of which 9,860 install vapor balance system and 1,213 must add submerged filled s a result of this rulemaking. b) Assume that all existing sources are in compliance with initial requirements. c) Assume vapor balance pressure retesting require every three years . There are 9,860 gasoline dispensing facilities would have to retest.20

**Summary (Tables 1.1 through 1.5): Total Annual Respondent Burden and**  **Cost**

**– NESHAP for Gasoline Distribution**  **Bulk Terminals,**  **Bulk Plants, and Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC (Renewal)** 

**Average Number of**  **Respondents per year**  **Average Num ber** 

**of Activities per Respondent**  **Total Annual**

**Hours Average Hours** 

**per Facility per Year**  **b Total Labor** 

**Cost per Year c** 

19,120 5 60,517.14 3.1 $ 6,068,409

**Assu mptions**  **for Table 1**  **:** a) Estimated by summing the annual technical (52,623.6) , managerial (2,631.1) , and clerical (5,262.36 ) hours for all facility types and activities. b) Obtained by dividing total annual hours by the number of respondents. c) Includes te chnical, managerial, and clerical labor costs for affected sources as calculated in the tables for bulk terminals, pipelines breakout stations, pipeline pum ping stations, bulk plants and gasoline dispensing facilities

.

.

.21

**Table 2: Average Annual EPA Burden and Cost** 
**- NESHAP for Gasoline Distribution Bulk Terminals, Bulk Plants, and**  **Pipeline Facilities; and Gasoline Dispensing Facilities (40 CFR part 63, subparts BBBBBB and CCCCCC (Renewal** 

**Burden Item (A)** 

**Number of Activities**  **per Year (B)** 

**EPA Hours per**  **Activity (C)** 

**Total EPA**  **Technical Hours for**  **Item Technical** 

**Hours per Year**  **(C*** **$ 46.21**  **) Managem**  **ent**

**Hours per Year** **(C*0.05*** **$ 6**  **2. 27** **/hr )**  **Clerical Hours per Year**  **(C*0.1*** **$ 25.01**  **/hr )**  **EPA Cost**

**per Year ($/yr)**  Revie w of storage tank inspection reports 780 4 3,120 144 , 175.2 194282.4 78031.2 416488.8 Revie w semiannual compliance reports 4714 2 9,428 435,667.88 29,354.08 23,579.43 488,601.39 Revie w of other, non - routine reports 1400 4 5600 258776 348712 140056 747544

TO TAL 6,894 **18 ,**  **148 1,652,634.19** 
**Assu mptions**  **for Table 2**  **:** a) This cost is based on the average hourly labor rate from the Office of Personnel Management (OPM) “2011 General Schedule” whi ch excludes locality rates of pay. b) Number of activities per year is the sum of the number of applicable respondents from Tables 1 .1 through 1.5. c) Assumed that 10 percent of affected facilities industry

- wide will submit non

- routine reports each year.22

**Table 2b**  **:**

**Assu mptions**  **for Table 2b**  **:** a) The average annual hours is the total hours for technical, managerial and clerical

.

a) Number of Industry Respondents Number of

Agency Activities Average

Annual Hours a Average Hours

per Industry Respondent Total

Annual Labor Costb 19,120 6,894 20,870 1.09 $ 1,652,634