SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts 

GGG and GGGa) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGG 

and GGGa) (Renewal), EPA ICR Number 0983.12, OMB Control Number 2060-0067

1(b) Short Characterization/Abstract

This information collection request (ICR) is for the New Source Performance Standards 

(NSPS) for Equipment Leaks of VOC (Volatile Organic Compounds) in Petroleum Refineries 

(40 CFR part 60, subparts GGG and GGGa). The NSPS in subpart GGG were proposed on 

January 4, 1983, and promulgated on May 30, 1984. These standards apply to the following 

facilities in petroleum refineries: compressors and the group of all equipment (e.g., valves, 

pumps, flanges, etc.) within a process unit in VOC service, commencing construction, 

modification or reconstruction after the date of proposal. Amendments that would have added 

new standards and compliance requirements to subpart GGG were proposed on November 7, 

2006. In response to public comments, all new requirements are being incorporated in a new 

subpart GGGa that applies to sources that commence construction, reconstruction, or 

modification after November 7, 2006. The final amendments to subpart GGG involve only

clarifications and additional compliance options.

Owners or operators of the affected facilities described must make one-time-only

notifications. Owners or operators 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. Monitoring requirements specific to 

the NSPS for equipment leaks of VOC in petroleum refineries provide information on which 

components are leaking VOCs. NSPS Subpart GGG references the compliance requirements of

NSPS subpart VV, and NSPS subpart GGGa references the compliance requirements of NSPS 

subpart VVa. Periodically, owners or operators are required to record information identifying 

leaking equipment, repair methods used to stop the leaks, and the dates of repair. The time 

period varies depending on equipment type and leak history. Semiannual reports are required to 

measure compliance with the standards of NSPS Subparts VV and VVa, as referenced by NSPS 

subparts GGG and GGGa. These notifications, reports, and records are essential in determining 

compliance and in general, are required, of all sources subject to NSPS. Any owner or operator 

subject to the provisions of this part shall maintain a file of these measurements, and retain the 

file for at least two years following the date of such measurements, maintenance reports, and 

records.

The Environmental Protection Agency’s (EPA’s) databases show that approximately 130 

refineries are currently subject to subpart GGG. This number is not expected to change over the 

next three years. In addition, it is assumed that 30 of the 135 refineries are also subject to NSPS 

subpart GGGa. For analysis purposes, the burden is calculated for each subpart separately and 

then combined. The combined total number of burden hours is 24,525. The combined total 

annual labor cost is $2,319,816. There are no capital/startup or Operation and Maintenance 

(O&M) costs associated with this ICR.
2

The burden to the “Affected Public” (i.e., major source petroleum refineries) can be 

found in both Table 1a: Annual Respondent Burden and Cost - NSPS for Equipment Leaks of 

VOC in Petroleum Refineries (40 CFR Part 60, Subparts GGG) (Renewal), and Table 1b:

Annual Respondent Burden and Cost- NSPS for Equipment Leaks of VOC in Petroleum 

Refineries (40 CFR Part 60, Subparts GGGa) (Renewal). The burden to the “Federal 

government” is attributed entirely to work performed by Federal employees or government 

contractors. The burden to the Federal government can be found below in Table 2a: Annual 

Burden and Cost to the Federal/State Government - NSPS for Equipment Leaks of VOC in 

Petroleum Refineries (40 CFR Part 60, Subparts GGG) (Renewal), and Table 2b: Annual Burden 

and Cost to the Federal/State Government - NSPS for Equipment Leaks of VOC in Petroleum 

Refineries (40 CFR Part 60, Subparts GGGa) (Renewal).

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

without any “Terms of Clearance.”

The number of information collections has been reduced from two to one as shown in 

ICRAS (Information Collection Request, Review and Submission) under ICR Number 0983.12, 

Paperwork Reduction Act Submission Worksheet(s), Part 2: IC Details. The previous ICR used 

an individual worksheet for each subpart (GGG and GGGa). However, the “Affected Public” is 

the same for both subparts and only one worksheet is indicated. Therefore, the two worksheets 

have been combined. 

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, 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 nonair quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated 

[Section 111(a)(l)]. 

The Agency refers to this charge as selecting the best demonstrated technology (BDT). 

Section 111 also requires that the Administrator review and, if appropriate, revise such standards 

every four years. 

In addition, section 114(a) states that the Administrator may require any owner 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 methods at such locations, at such intervals, 

during such periods, and in such manner as the Administrator shall 

prescribe); (E) keep records on control equipment parameters, 

production variables, or other indirect data when direct monitoring 

of emissions is impractical; (F) submit compliance certifications in 

accordance with Section 114(a)(3); and (G) provide such other 

information as the Administrator may reasonably require. 
3

In the Administrator’s judgment, VOC emissions from Equipment Leaks of VOC in 

Petroleum Refineries cause or contribute to air pollution that may reasonably be anticipated to 

endanger public health or welfare. Therefore, NSPS were promulgated for this source category

at 40 CFR part 60, subparts GGG and GGGa.

2(b) Practical Utility/Users of the Data

The control of emissions of VOC from equipment leaks in petroleum refineries requires 

not only the installation of properly designed equipment, but also the operation and maintenance 

of that equipment. Emissions of VOC from equipment leaks in petroleum refineries are the 

result of operation of the compressors and the group of all equipment (e.g., valves, pumps, 

flanges, etc.) within a process unit in VOC service. These standards rely on the prevention of 

VOC emissions through work practices, such as proper leak detection and timely repair. The 

notifications required in these standards are used to inform the Agency or delegated authority

when a source becomes subject to these standards. The reviewing authority may then inspect the 

source to check if the leaks are being detected and repaired and the standard is being met.

Performance test reports are needed, as these are the Agency’s record of a source’s initial 

capability to comply with the emission standard and serve as a record of the operating conditions 

under which compliance was achieved. NSPS Subpart GGG references NSPS Subpart VV for 

compliance, and NSPS Subpart GGGa references NSPS Subpart VVa for compliance. Monthly

monitoring of compressors and equipment in VOC service under NSPS Subpart GGG shall take 

place as specified in NSPS Subpart VV §60.485(b). For valves, if no leaks are detected for two 

successive months, monitoring may be performed once per quarter (see §60.482-7(c)). If a leak 

is detected, the equipment shall be monitored monthly until a leak is not detected for two 

successive months. Also, leak location shall be recorded in a log, and this information shall be 

kept available for two years. Leaks shall be repaired within 15 days and the date of successful 

repair shall be recorded in the log. Additionally, an owner or operator may use specified 

equipment eliminating the need for monitoring, or seek approval of alternative emission 

limitations under other various sections of 40 CFR part 60, subpart VV or VVa.

Semiannual reports shall be submitted itemizing the information for each month. 

Notifications are used to inform the Agency or delegated authority when a source becomes 

subject to a standard. The reviewing authority may then inspect the source to check if the 

standard is being met. The semiannual reports are used for problem identification, as a check on 

source operations and maintenance, and for compliance determinations. The information 

generated by the monitoring, recordkeeping and reporting requirements described in this ICR is 

used by the Agency to ensure that facilities affected by the NSPS continue to identify and repair 

leaking equipment and achieve compliance with the regulation. Adequate monitoring, 

recordkeeping, and reporting are necessary to ensure compliance with these standards, as 

required by the Clean Air Act. The additional records required by subpart GGGa have been 

identified as additional information needed by Agency inspectors to ensure compliance. The 

information collected from recordkeeping and reporting requirements is also used for targeting 

inspections, and is of sufficient quality to be used as evidence in court.

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

The recordkeeping and reporting requested is required under 40 CFR part 60, 

subpart GGG and subpart GGGa. 

3(a) Non-duplication

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

EPA regional office. Otherwise, the information is sent directly to the delegated state or local 
4

agency. If a state or local agency has adopted their own similar standards to implement the 

Federal standards, a copy of the report submitted to the state or local agency can be sent to the 

Administrator in lieu of the report required by the Federal standards. Therefore, no duplication 

exists.

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 (75 FR 30812) on June 2, 2010. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

During development of the standard and the amendments in 2006, EPA held meetings 

and conference calls in which representatives of petroleum refining companies and their trade 

associations (National Petroleum Refiners Association and American Petroleum Institute) were 

provided an opportunity to comment on the burden associated with the proposed amendments.

We also reviewed our internal data sources such as the Air Facility System (AFS). In the 

past, we have discussed the industry growth rate with the EPA Office of Air Quality Planning 

and Standards (OAQPS) and Norbert Dee of the National Petrochemical and Refiners 

Association in Washington, D.C., (202) 457-0480.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

facilities are continuing to meet the required standards. Requirements for information gathering 

and recordkeeping are useful techniques to ensure that good operation and maintenance practices 

are applied and that emission limitations are met. If the information required by these standards 

was collected less frequently, the likelihood of detecting poor operation and maintenance of 

control equipment and noncompliance would decrease.

3(e) General Guidelines

None of the reporting or recordkeeping requirements contained in 40 CFR part 60, 

subpart GGG or GGGa, or otherwise pertinent to this request, violate any of the regulations 

established by OMB in 5 CFR 1320.6.

3(f) Confidentiality

The required information consists of emissions data and other information that have been 

determined not to be private. However, 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

None of the reporting or recordkeeping requirements contained in 40 CFR part 60, 

subpart GGG or GGGa, or otherwise pertinent to this request, contain sensitive questions.
5

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents of the recordkeeping and reporting requirements are petroleum refineries 

where the affected compressors or group of equipment within a process unit commenced 

construction, modification, or reconstruction after January 4, 1983. The SIC code for the 

respondents affected by the standards is the United States Standard Industrial Classification 

(SIC) Code 2911, which corresponds to the North American Industry Classification System 

(NAICS) Code 324110 for petroleum refineries where the affected compressors or group of 

equipment within a process unit commenced construction, modification, or reconstruction after 

January 4, 1983.

4(b) Information Requested

(i) Data Items

All data in this ICR that is recorded and/or reported is required by 40 CFR part 60, 

subpart GGG or subpart GGGa. These requirements are summarized in the following tables.

A source must make the following notifications and reports:

Notifications for 40 CFR Part 60, Subparts GGG 

and GGGa

Citation for 

subpart GGG

Citation for 

subpart GGGa

Construction/reconstruction 60.7(a)(1) 60.7(a)(1)

Anticipated startup 60.7(a)(2) 60.7(a)(2)

Actual startup 60.7(a)(3) 60.7(a)(3)

Physical or operational change 60.7(a)(4) 60.7(a)(4)

Initial performance test 60.8(d) 60.8(d)

Alternative standard selected 60.487(d) 60.487a(d)

Reports for 40 CFR Part 60, Subparts 

GGG and GGGa

Citation for 

subpart GGG

Citation for subpart 

GGGa

Initial performance test results 60.8(a) 60.8(a)

Comply with the provisions of 60.487 60.592(e) 60.592a(e)

Semiannual reports 60.486, 60.487(a) 

through (c)

60.486a, 60.487a(a) 

through (c)

Performance test 60.8, 60.487(e) 60.8, 60.487a(e)

A source must keep the following records:

Recordkeeping for 40 CFR Part 60, Subparts GGG 

and GGGa

Citation for 

subpart GGG

Citation for 

subpart GGGa

All measurements, monitoring device, and performance 

testing measurements

60.7(e) 60.7(e)

Comply with the provisions of 60.486 or 60.486a 60.592(e) 60.592a(e)
6

Recordkeeping for 40 CFR Part 60, Subparts GGG 

and GGGa

Citation for 

subpart GGG

Citation for 

subpart GGGa

The date and instrument reading of each monitored 

component must be recorded 

N/A 60.486a(a)

Each detected leak shall be recorded in a log and kept 

for 2 years 

60.486(c) 60.486a(c)

Information pertaining to design requirements or closed 

vent systems and control devices 

60.486(d) 60.486a(d)

Equipment identification numbers and designations, 

and dates of performance tests 

60.486(e) 60.486(e)(1) 

through (5)

Dates and results of weekly visual inspections N/A 60.486a(e)(6)

Information related to instrument calibrations and drift 

checks

N/A 60.486a(e)(7)

Information pertaining to valves and pumps that are 

designated as unsafe to monitor or difficult to monitor

60.486(f) 60.486a(f)

Information pertaining to valves complying with 

alternative compliance requirements

60.486(g) 60.486a(g)

Design criteria and any changes 60.486(h) 60.486a(h)

Records for use in determining exemptions 60.486(i) 60.486a(i)

Information and data to demonstrate that a piece of 

equipment is not in VOC service

60.486(j) 60.486a(j)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

Also, regulatory agencies, in cooperation with the respondents, continue to create 

reporting systems to transmit data electronically. At this time, it is estimated that approximately 

30 percent of the respondents use electronic reporting.

ii. Respondent Activities

The respondent activities required by 40 CFR part 60, subparts GGG and GGGa are 

identified in the following table:

Respondent Activities

Read instructions

Perform initial performance test as per 40 CFR 60.485, Reference Method 21 and 22 tests, and 

repeat performance tests

Write the notifications and reports listed above

Enter information required to be recorded above
7

Respondent Activities

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

As refiners replace/upgrade their monitoring equipment, they may choose to use systems 

that automatically log the results of monitoring which can be downloaded into a computer 

database. This database can be used to develop the required reports.

5. The Information Collected -- Agency Activities, 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 information required under 40 CFR part 60, subparts GGG and 

GGGa:

Agency Activities

Observe initial performance tests and repeat performance tests if necessary

Review notifications and reports, including performance test reports, and other reports, 

required to be submitted by industry

Audit facility records

Input, analyze, and maintain data in the Air Facility System

5(b) Collection Methodology and Management

The required data and reports can be evaluated onsite by conducting a partial compliance 

evaluation, full compliance evaluation or inspection, or through offsite review of compliance 

monitoring records and reports. 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 the Air Facility System (AFS), which 

is operated and maintained by the EPA Office of Compliance. AFS is the EPA database for the 

collection, maintenance, and retrieval of compliance data for over 125,000 industrial and 

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

enforcement by local and state regulatory agencies, the EPA regional offices, and EPA 
8

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 or operator for two years.

5(c) Small Entity Flexibility

A majority of the affected facilities are large businesses. However, the impact on small 

businesses was taken into consideration during development of the regulation. The number of 

small entities is estimated to be five. Due to technical considerations involving the process 

operations and leak detection and repair programs, the recordkeeping and reporting requirements 

are the same for both small and large businesses. The Agency considers these requirements to be 

the minimum needed to ensure compliance and, therefore, cannot reduce them further for small 

businesses. To the extent that larger businesses can use economies of scale to reduce their 

burden, the overall burden will be reduced.

For sources that install “leakless” components, monitoring may not be required for those 

components. Monitoring and recordkeeping may be reduced for sources that maintain low 

percentages of leaking components. In addition, alternative means of emission limitation are 

allowed after proper demonstration of their effectiveness to the Administrator.

5(d) Collection Schedule

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

shown below in both Table 1a: Annual Respondent Burden and Cost - NSPS for Equipment 

Leaks of VOC in Petroleum Refineries (40 CFR Part 60, Subpart GGG) (Renewal), and Table 

1b: Annual Respondent Burden and Cost - NSPS for Equipment Leaks of VOC in Petroleum 

Refineries (40 CFR Part 60, Subpart GGGa) (Renewal).

6. Estimating the Burden and Cost of the Collection

Tables 1a and 1b show the burden for the recordkeeping and reporting requirements 

applicable to the industry for the subparts included in this ICR. The individual burdens are 

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

under the Paperwork Reduction Act. Where appropriate, specific tasks and major assumptions 

have been identified. Responses to this information collection are mandatory. The Agency may

not conduct or sponsor, and a person is not required to respond to, a collection of information 

unless it displays a currently valid OMB control number. 

6(a) Estimating Respondent Burden

Although monitoring of the various components may be required on a weekly, monthly, 

quarterly, semiannual or annual basis, given the number of components that must be monitored 

at any facility, monitoring overall is essentially occurring daily. Therefore, it is assumed that the 

average recordkeeping time for each day’s worth of monitoring for both subpart GGG and 

subpart GGGa is 0.30 hours and that monitoring is done 365 days a year. An additional 0.10 

hours per day are estimated for a typical refinery to complete the new recordkeeping tasks 

required by subpart GGGa. These tasks include: collecting and maintaining records of all 

instrument readings (3 minutes per day); daily instrument calibrations and drift checks (3 

minutes per day); and weekly pump inspections (15 minutes per week). Instrument readings are 

assumed to be collected electronically; thus, the additional time is for downloading additional 

data and organizing it for storage. Smaller facilities may record instrument readings manually. 

For a facility with a typical process, an average of 0.02 hours per day is estimated to prepare and 

print recordkeeping forms and to manually record the instrument readings on the forms. This 

includes 2 hr/yr to prepare and print recordkeeping forms and 10 seconds to record each reading 

for 9 pumps monitored monthly and 452 valves monitored semiannually. The time to prepare 
9

reports is estimated to be the same under both subparts because the information in the new 

records must be maintained on-site, but it does not have to be reported.

The average annual burden to industry over the three years for these recordkeeping and 

reporting requirements is estimated at 24,525 hours per year. There are neither capital/startup 

nor O&M costs. This estimate is based on Agency studies and background documents from the 

development of the standards or test methods, Agency knowledge and experience with the NSPS 

program, the previously approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $114.49 ($54.52 + 110%) 

Technical $98.20 ($46.76 + 110%)

Clerical $48.53 ($23.11 + 110%)

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

September 2009, ”Table 2. Civilian Workers, by Occupational and Industry group.” The rates 

are from column 1, ”Total Compensation.” The rates have been increased by 110 percent to 

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

(ii) Estimating Capital and Operations and Maintenance Costs

The only industry costs associated with the information collection activity in the 

standards are labor costs. To the extent possible, the requirements of this standard are consistent 

with industry practices. VOC monitors used for leak detection are typically used in the industry 

for safety reasons and do not impose an additional cost to the respondents. Consequently, there 

are no capital or O&M costs associated with this standard.

(iii) Capital/Start-up vs. Operation and Maintenance (O&M) Costs

This is not applicable because this is a leak detection and repair program with no 

continuous monitoring equipment, as stated in the previous section.

6(c) Estimating Agency Burden and Cost

The only costs to the Agency are those costs associated with analysis of the reported 

information. EPA's overall compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

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

$55,970.46 for subpart GGG, and $11,837.64 for subpart GGGa. The combined total cost is 

$67,808 (rounded).

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%)
10

These rates are from the Office of Personnel Management (OPM), 2010 General Schedule, 

which excludes locality rates of pay. The rates have been increased by 60 percent to account for 

the benefit packages available to government employees. Details upon which this estimate is 

based appear below in both Tables 2a and 2b.

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

The respondent universe is shown in two parts, subpart GGG and subpart GGGa.

Respondent Universe - Subpart GGG

40 CFR Part 60, Subpart GGG

(A)

No. of Existing 

Sources

(B)

No. of Reports for 

Existing Sources

(C)

Total Annual 

Responses (AxB)

First Year 130 2 260

Second year 130 2 260

Third year 130 2 260

The average number of respondents each year is 130. All subject facilities are subject to 

semiannual reporting requirements. The number of annual responses for subpart GGG is 260. 

Respondent Universe - Subpart GGGa

40 CFR Part 60, 

Subpart GGGa

(A)

No. of New 

Sources/Year

(B)

No. of Initial 

Reports for 

New Sources

(C)

No. of 

Existing 

Sources

(D)

No. of 

Reports for 

Existing 

Sources

(E)

Total Annual 

Responses

(AxB+CxD)

First year 0 0 30 2 60

Second year 0 0 30 2 60

Third year 0 0 30 2 60

It is assumed that no facilities will be subject to initial notification requirements over the 

three-year period of this ICR. An average of 30 facilities per year will be subject to subpart 

GGGa over the three-year period of this ICR. All facilities are subject to semiannual reporting 

requirements. The number of annual responses for subpart GGGa is 60. 

The total number of responses for subparts GGG and GGGa combined is 320 (260 + 60 = 

320).

The table below shows the combined total labor burden and cost for subparts GGG and 

GGGa as computed in Tables 1a and 1b. 

Respondent – Combined Labor Hours and Burden

Citation Subpart Reporting (hours). Recordkeeping (hours) Cost (dollars)

GGG (Table 1a) 2484.00 16,999.88 1,842,962.79

GGGa (Table 1b) 552.00 4,489.31 476,853.37

Subtotals (rounded) 3,036 21,489

Totals (rounded) 24,525 $2,319,816
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The total number of burden hours is 24,525. The total annual labor cost is $2,319,816.

There are no annual capital and O&M costs to the regulated entities. Capital and O&M 

costs are not applicable because this is a leak detection and repair program with no continuous 

monitoring equipment.

6(e) Bottom Line Burden Hours and Cost Tables

The bottom line burden hours and cost tables for both the Agency and the respondents 

appear below (Tables 1a, 1b, 2a, and 2b) and are summarized above in sections 6(c) and 6(d), 

respectively. The total number of burden hours for the respondents is 24,525. The total annual 

labor cost for the respondents is $2,319,816. There are no annual capital and O&M costs to the 

regulated entities.

6(f) Reasons for Change in Burden

There is an overall decrease in the number of burden labor hours and an increase in the 

labor hour cost. The burden hours have decreased because we anticipate that no new refineries 

will be built in the United States over the next three years. This results in a decrease in the 

number of labor burden hours. We also refined our estimate of the number of major refineries. 

This calculation reduced the number of affected facilities.

The increase in labor hour cost is due to a recalculation of burden using current labor 

rates and the correction of a mathematical error.

There are no annual capital and O&M costs to the regulated entities. Capital and O&M 

costs are not applicable because this is a leak detection and repair program with no continuous 

monitoring equipment.

6(g) Burden Statement

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

is estimated to average 77 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-2010-0357. An electronic version of the public docket is 

available at http://www.regulations.gov/ which may be used to obtain a copy of the draft 

collection of information, submit or view public comments, access the index listing of the 

contents of the docket, and to access those documents in the public docket that are available 

electronically. When in the system, select “search,” then key in the docket ID number identified 
12

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

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

Room 3334, 1301 Constitution 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 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 N.W., 

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

Number EPA-HQ-OECA-2010-0357 and OMB Control Number 2060-0067 in any

correspondence. 

Part B of the Supporting Statement

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

information
13

Table 1a: Annual Respondent Burden and Cost - NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 

60, Subparts GGG) (Renewal) a

Activity

(A)

Hours per 

Occurrence

(B)

Occurrences/ 

Respondent/

Year

(C)

Hours/ 

Respondent

/Year

(A x B)

(D)

Respondents/ 

Year

(E)

Technical 

Hours/ 

Year

(C x D)

(F)

Managerial 

Hours/Year 

(E x 0.05)

(G)

Clerical 

Hours/

Year

(E x 0.10)

(H)

Cost/ Year, $$

1. APPLICATIONS 

(Not Applicable)

2. SURVEY AND 

STUDIES (Not 

Applicable)

3. REPORT 

REQUIREMENTS

A. Read Instructions 1 1 1 0 0 0 0 0

B. Required Activities

Initial performance 

test 24 1 24 0 0 0 0 0

Repeat performance 

test 24 1 24 0 b

0 0 0 0

C. Create Information

(Included in 3B)

D. Gather Existing 

Information (Included 

in 3E)

E. Write Report

Notification of 

construction or 

reconstruction

2 1 2 0 0 0 0 0

Notification of 

anticipated startup 2 1 2 0 0 0 0 0 

Notification of actual 

startup

2 1 2 0 0 0 0 0 

Notification of initial 

performance test 2 1 2 0 0 0 0 0 

Report of performance 

test (Included in 3B)

Semiannual work 

practice reports 8 2 16 135 c

2,160 108 216 234,959.40

Subtotal for Reports 2,484 $234,959.40
14

Activity

(A)

Hours per 

Occurrence

(B)

Occurrences/ 

Respondent/

Year

(C)

Hours/ 

Respondent

/Year

(A x B)

(D)

Respondents/ 

Year

(E)

Technical 

Hours/ 

Year

(C x D)

(F)

Managerial 

Hours/Year 

(E x 0.05)

(G)

Clerical 

Hours/

Year

(E x 0.10)

(H)

Cost/ Year, $$

4. 

RECORDKEEPING 

REQUIREMENTS

A. Read Instructions 

(Included in 3A)

B. Plan Activities 

(Included in 3B)

C. Implement 

Activities (Included in 

3B)

D. Develop Record 

System (Not 

Applicable)

E. Time to Enter 

Information

Records of operating 

parameters e 0.30 365 d

109.5 135 c14,782.50 739.13 1,478.25 1,608,003.39

F. Train Personnel 

(Not Applicable)

G. Audits (Not 

Applicable)

Subtotal for 

Recordkeeping 16,999.88 $1,608,003.39

5. Total Annual Labor 

Burden and Cost 

(rounded)

19,484 $1,842,963

Assumptions:

a Only existing facilities. All new facilities subject to subpart GGGa.

b

 Assume 20 percent of initial performance tests must repeat due to failure.

c

 Assume that average number of affected facilities over the next three years is equal to the current number of facilities (135) because affected facilities after November 7, 2006 

will be subject to subpart GGGa instead of subpart GGG.

d Assume operation is 365 days per year as specified in the NSPS review document.

e Although monitoring of the various components may be required on a weekly, monthly, quarterly, semiannual, or annual basis, given the number of components that must be 

monitored at any facility, monitoring overall is essentially occurring daily. Therefore, it is assumed that the average recordkeeping time for each day’s worth of monitoring is 0.30 

hours and that monitoring is done 365 days per year.
15

Table 1b: Annual Respondent Burden and Cost - NSPS for Equipment Leaks of VOC in Petroleum Refineries (40 CFR Part 

60, Subparts GGGa) (Renewal) a

Activity

(A)

Hours per 

Occurrence

(B)

Occurrences/ 

Respondent/

Year

(C)

Hours/ 

Respondent

/ Year

(A x B)

(D)

Respondents/ 

Year

(E)

Technical 

Hours/Year

(C x D)

(F)

Managerial 

Hours/Year

(E x 0.05)

(G)

Clerical 

Hours/

Year

(E x 0.10)

(F)

Cost/ Year, 

$$

1. APPLICATIONS 

(Not Applicable)

2. SURVEY AND 

STUDIES (Not 

Applicable)

3. REPORT 

REQUIREMENTS

A. Read Instructions 1 1 1 0 0 0 0 0

B. Required Activities

Initial performance test 24 1 24 0 0 0 0 0

Repeat performance test 24 1 24 0 b0 0 0 0

C. Create Information

(Included in 3B)

D. Gather Existing 

Information (Included in 

3E)

E. Write Report

Notification of 

construction or 

reconstruction

2 1 2 0 0 0 0 0

Notification of 

anticipated startup 2 1 2 0 0 0 0 0

Notification of actual 

startup 2 1 2 0 0 0 0 0

Notification of initial 

performance test 2 1 2 0 0 0 0 0

Report of performance 

test (Included in 3B)

Semiannual work 

practice reports 8 2 16 30 480 24 48 52,213.20

Subtotal for Reports 552 $52,213.20
16

Activity

(A)

Hours per 

Occurrence

(B)

Occurrences/ 

Respondent/

Year

(C)

Hours/ 

Respondent

/ Year

(A x B)

(D)

Respondents/ 

Year

(E)

Technical 

Hours/Year

(C x D)

(F)

Managerial 

Hours/Year

(E x 0.05)

(G)

Clerical 

Hours/

Year

(E x 0.10)

(F)

Cost/ Year, 

$$

4. RECORDKEEPING 

REQUIREMENTS

A. Read Instructions 

(Included in 3A)

B. Plan Activities

(Included in 3B)

C. Implement Activities

(Included in 3B)

D. Develop Record 

System (Not 

Applicable)

E. Time to Enter 

Information

Records of operating 

parameters at large 

refiners e

0.40 c365 d148 22.5 e3,333.00 166.50 333.00 362,229.08

Records of operating 

parameters for small 

refiners

0.42 c365 d153 3.75 e573.75 28.69 57.38 62,411.09

F. Train Personnel (Not 

Applicable)

G. Audits (Not 

Applicable)

Subtotal for 

Recordkeeping 4,489.31 $424,640.17

5. Total Annual Labor 

Hours and Cost 

(rounded)

5,041 $476,853

Assumptions:

a

 There are approximately 30 refineries (respondents) subject to the standard.

b

 Assume 20% of initial performance tests must repeat due to failure.

c

 Assume that most facilities need an additional 0.10 hours per day to complete the tasks required by the new standards (0.30 + 0.10 = 0.40); and, an additional 

0.02 hours per day are needed for small refineries with manual recordkeeping of instrument readings (0.40 + 0.02 = 0.42).

d

 Assume operation for 365 days per year as specified in the NSPS review document.

e

 Assume that 75 percent of the process units are located at large refineries (30 x 75% = 22.5), and that 25 percent of the new process units are located at small 

refineries and half of those use manual recordkeeping of instrument readings (20 x 25% x 0.5 = 3.75).
17

Table 2a: Annual Burden and Cost to the Federal Government - NSPS for Equipment Leaks of VOC in Petroleum Refineries 

(40 CFR Part 60, Subparts GGG) (Renewal)

Activity

(A)

EPA Hours/ 

Occurrence

(B)

Occurrences/ 

Plant/Year

(C)

EPA Hours/ 

Plant/Year

(D)

Respondents/Y

ear

(E)

EPA 

Technical 

Hours/Year b

(F)

EPA 

Managerial 

Hours/Year

(E x 0.05)

(G)

EPA Clerical 

Hours/Year

(E x 0.10)

(I)

Cost per 

Year, $$

Performance Test 

Report Review (New 

Plants)

4 1.2 a4.80 0 0 0 0 0

Notification of 

construction 2 1 2 0 0 0 0 0

Notification of 

anticipated startup 0.5 1 0.5 0 0 0 0 0

Notification of actual 

startup 0.5 1 0.5 0 0 0 0 0

Notification of initial 

test 0.5 1.2 0.6 0 0 0 0 0

Review test results 8 1.2 9.6 0 0 0 0 0

Report Review 

(Existing Plants) 4 2 8 135 1,080 54 108 55,970.46

Total Annual Labor 

Burden and Cost 

(rounded)

1,242 $55,970.46

Assumptions:

a Assume that 20 percent of the respondents will retest.
18

Table 2b: Annual Burden and Cost to the Federal Government - NSPS for Equipment Leaks of VOC in Petroleum Refineries 

(40 CFR Part 60, Subparts GGGa) (Renewal)

Activity

(A)

EPA Hours/ 

Occurrence

(B)

Occurrences/ 

Plant/Year

(C)

EPA Hours/ 

Plant/Year

(D)

Plants/

Year

(E)

EPA 

Technical 

Hours/ 

Year b

(F)

EPA 

Managerial 

Hours/Year

(G)

EPA Clerical 

Hours/Year

(H)

Cost Per 

Year, $$

Performance Test 

Report Review (New 

Plants)

4 1.2 a4.8 0 0 0 0 0

Notification of 

construction 2 1 2 0 0 0 0 0

Notification of 

anticipated startup 0.5 1 0.5 0 0 0 0 0

Notification of actual

startup 0.5 1 0.5 0 0 0 0 0

Notification of initial 

test 0.5 1.2 0.6 0 0 0 0 0

Review test results 8 1.2 9.6 0 0 0 0 0

Report Review 

(Existing Plants) 4 2 8 30 240 12 24 11,837.84

Total Annual Labor 

Hours and Cost 

(rounded)

276 $11,838

Assumptions:

a Assume that 20 percent of the respondents will retest.