SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

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

60, Subpart K) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

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

Subpart K) (Renewal), EPA ICR Number 1797.05, OMB Control Number 2060-0442 

1(b) Short Characterization/Abstract

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

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

1973, and Prior to May 19, 1978, were proposed on June 11, 1973, and promulgated on March 8, 

1974. These regulations apply to facilities that store petroleum liquids in storage vessels with a 

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

capacity greater than 151,416 liters (40,000 gallons) but not exceeding 246,052 liters (65,000 

gallons), and where construction or modification commenced after March 8, 1974, and prior to 

May 19, 1978; and storage vessels that have a capacity greater than 246,052 liters (65,000 

gallons), and where construction or modification commenced after June 11, 1973, and prior to 

May 19, 1978. Facilities that are not subject to these standards are storage vessels of petroleum 

or condensate stored, processed, and/or treated at a drilling and production facility prior to 

custody transfer. This information is being collected to assure compliance with these regulations.

The number of respondents for this renewal of the ICR is assumed to be 220. It is further 

assumed that there is an average of 25 storage vessels per respondent. These assumptions are 

based on the active ICR data. This is appropriate due to the very slow growth of the petroleum 

refining and coal products manufacturing industries which are affected by the NSPS subpart K 

rule. This number was originally obtained from EPA databases, consultation with EPA regional 

staff and an EPA contractor providing support to the Office of Enforcement and Compliance 

Assurance. The overall burden imposed on the regulated industry is 769 hours, at a total 

estimated cost of $72,750.

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

collection request (ICR) without any “Terms of Clearance.”
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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 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 procedures or methods, at such locations, at 

such intervals, during such periods, and in such a manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

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

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

anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated for this 

source category at 40 CFR part 60, subpart K.

2(b) Practical Utility/Users of the Data

The control of emissions of volatile organic compounds from storage vessels for 

petroleum liquids requires not only the installation of properly designed equipment, but also the 

operation and maintenance of that equipment. Emissions of volatile organic compounds from 

these vessels for petroleum liquids are the result of operation of the affected facilities. The 

subject standards are achieved by the reduction of volatile organic compound emissions using 

vapor recovery, floating roof, or their equivalent. The notifications required in the applicable 

regulations are used to inform the Agency or delegated authority when a source became subject 
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to the requirements of the regulations. The reviewing authority may then inspect the source to 

check if the pollution control devices are properly installed and operated and the regulations are 

being met. 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 operate the control equipment in compliance with the regulation. Adequate 

monitoring, recordkeeping, and reporting are necessary to ensure compliance with the applicable 

regulations, as required by the Clean Air Act. 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 requested recordkeeping and reporting are required under 40 CFR part 60, subpart K.

3(a) Non-duplication

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

appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state 

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

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

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

exists.

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 on July 8, 2009 (74 FR32580). No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

For this information collection, the previous ICR renewal was used to obtain burden 

estimates since this ICR renewal was processed under the “Expedited Approach” option provided 

in May 1, 2008 guidance. Per this guidance, all data and assumptions from the previous ICR 

renewal were used as the basis for estimating the hourly and cost burdens associated with this 

renewal. Approximately 220 respondents will be subject to the standard over the three year 

period covered by this ICR.

Industry trade association(s) and other interested parties were provided an opportunity to 

comment on the burden associated with the standard as it was being developed and the standard 

has been previously reviewed to determine the minimum information needed for compliance 

purposes.
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It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice. In this 

case, no comments were received. 

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

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

collected less frequently, the proper operation and maintenance of control equipment and the 

possibility of detecting violations would be less likely.

3(e) General Guidelines

These reporting or recordkeeping requirements do not violate any of the regulations 

promulgated by OMB under 5 CFR part 1320, section 1320.5.

3(f) Confidentiality

Any information submitted to the Agency for which a claim of confidentiality is made 

will be safeguarded according to the Agency policies set forth in Title 40, chapter 1, part 2, 

subpart B - Confidentiality of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, 

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

The reporting or recordkeeping requirements in the standard do not include sensitive 

questions.

4. The Respondents and the Information Requested 

4(a) Respondents/NAICS Codes

The respondents to the recordkeeping and reporting requirements are facilities that have 

storage vessels of petroleum liquids meeting the rule criteria. The Standard Industrial 

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

(NAICS) for the respondents are listed below:

Category SIC Codes NAICS Codes Examples of Regulated 

Entities

Petroleum and Coal 2911 32411 Petroleum Refineries
5

Category SIC Codes NAICS Codes Examples of Regulated 

Entities

Products 

Manufacturing

2951 324121 Asphalt Paving Mixture and 

Block Manufacturing

2952 324122 Asphalt Shingle and Coating 

Materials Manufacturing

2992 324191 Petroleum Lubricating Oil and 

Grease Manufacturing

2999 324199 All Other Petroleum and Coal 

Products Manufacturing

[To compare the SIC and NAICS codes, see the website at 

http://www.census.gov/epcd/www/naics.html.]

4(b) Information Requested

(i) Data Items

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

Vessels for Petroleum Liquids for Which Construction, Reconstruction or Modification 

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

(Renewal).

A source must make the following reports:

Notifications

Construction/reconstruction. 60.7(a)(1)

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

A source must keep the following records:

Recordkeeping 

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

Owner/Operator shall maintain a record of the petroleum 

liquid stored, the period of storage and the maximum true 

vapor pressure of that liquid during the respective storage 

period.

60.113(a)

Maintain records of the occurrence and duration of any

startup, shutdown, or malfunction.

60.7(b)
6

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. However, electronic reporting systems are still 

not widely used. At this time, it is estimated that approximately 10 percent of the respondents 

use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

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

Perform an initial performance test, according to manufacturers’ instructions, and repeat 

performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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

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

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

maintaining information.

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

providing information.

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

requirements.

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

Transmit, or otherwise disclose the information.

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

Management

5(a) Agency Activities

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

storage, and distribution of the required information.
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Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

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

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the AIRS Facility Subsystem (AFS).

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 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. This information will be used to monitor vapor recovery, floating 

roof or their equivalent pollution control devices, thus ensuring continuous compliance with the 

standard. Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs.

Information contained in the reports is entered into the AFS which is operated and 

maintained by EPA’s Office of Compliance. AFS 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 AFS for tracking air pollution compliance and 

enforcement by local and state regulatory agencies, EPA regional offices and EPA headquarters. 

EPA and its delegated Authorities can edit, store, retrieve and analyze the data.

The records required by this regulation must be retained by the owner/operator for two 

years. 

5(c) Small Entity Flexibility

A majority of the affected facilities are large entities (e.g., large businesses). However,

the impact on small entities (e.g., 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 requirements the 

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

entities. 

5(d) Collection Schedule

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

shown below in Table 1: Annual Respondent Burden and Cost: NSPS for Standards of 

Performance for Storage Vessels for Petroleum Liquids for which Construction, Reconstruction 

or Modification Commenced after June 11, 1973, and prior to May 19, 1978 (40 CFR part 60, 

subpart K) (Renewal).
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6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

major assumptions have been identified. Responses to this information collection are mandatory.

The Agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB Control Number.

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 769 (Total Labor Hours from Table 1). These 

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

regulation, Agency knowledge and experience with the 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/Startup and Operation and Maintenance Costs

The only costs to the regulated industry resulting from information collection activities 

required by the subject standard are labor costs. There are no capital/startup or operation and 

maintenance costs.

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

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

regulations are labor costs. There are no capital/startup or operation and maintenance costs.
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6(c) Estimating Agency Burden and Cost

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

$228. 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.

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%)

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 Table 2: Annual Burden and Cost for the Federal Government: NSPS for 

Storage Vessels for Petroleum Liquids for which Construction, Reconstruction or Modification 

Commenced after June 11, 1973, and prior to May 19, 1978 (40 CFR part 60, subpart K)

(Renewal). 

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

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

220 existing respondents will be subject to the standard. It is also estimated that no additional 

sources will become subject.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR.

Number of Respondents

Respondents That Submit 

Reports

Respondents 

That Do Not 

Submit Any 

Reports

Year

(A)

Number of 

New 

Respondents

(B)

Number of 

Existing 

Respondents

(C)

Number of 

Existing 

Respondents 

That Keep 

Records But Do 

Not Submit 

Reports

(D)

Number of 

Existing 

Respondents 

That Are Also 

New 

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 2.2 217.8 N/A 220

2 0 2.2 217.8 N/A 220
10

Number of Respondents

Respondents That Submit 

Reports

Respondents 

That Do Not 

Submit Any 

Reports

Year

(A)

Number of 

New 

Respondents

(B)

Number of 

Existing 

Respondents

(C)

Number of 

Existing 

Respondents 

That Keep 

Records But Do 

Not Submit 

Reports

(D)

Number of 

Existing 

Respondents 

That Are Also 

New 

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

3 0 2.2 217.8 N/A 220

Average 0 2.2 217.8 N/A 220

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

Number of Respondents over the three-year period of this ICR is 220.

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

Total Annual Responses

(A)

Information Collection 

Activity

(B)

Number of 

Respondents

(C)

Number of 

Responses

(D)

Number of Existing

Respondents That 

Keep Records But 

Do Not Submit 

Reports

(E)

Total Annual 

Responses

E=(BxC)+D

Notification of 

reconstruction or 

/modification

2.2 1 217.8 220

Total 220

The number of Total Annual Responses is 220. The total annual labor costs are $72,750

(rounded). Details regarding these estimates may be found below in Table 1. Annual Respondent 

Burden and Cost: NSPS for Storage Vessels for Petroleum Liquids for which Construction, 

Reconstruction or Modification Commenced after June 11, 1973, and prior to May 19, 1978 (40 

CFR part 60, subpart K) (Renewal). 

Note that the there are no annual capital and O&M costs associated with this ICR for this

NSPS, subpart K, as indicated in Section 6(b)(iii), Capital/Startup vs. Operation and 

Maintenance (O&M) Costs, above.
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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. The annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 3.5 hours per response.

6(f) Reasons for Change in Burden

There is no change in the labor hours or cost to the respondents in this ICR compared to 

the previous ICR. This is due to two considerations: (1) the regulations have not changed over 

the past three years and are not anticipated to change over the next three years; and (2) the growth 

rate for the respondents is very low, negative, or non-existent. Therefore, the labor hours and 

cost figures in the previous ICR reflect the current burden to the respondents and are reiterated in 

this ICR.

6(g) Burden Statement

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

is estimated to average 3.5 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 currently valid OMB Control Number. The OMB 

Control Numbers for EPA’s 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-2009-0424. An electronic version of the public docket is 

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

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

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

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

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

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

Room 3334, 1301 Constitution Avenue, 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 
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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-2009-0424 and OMB Control Number 2060-0442 in any

correspondence.

Part B of the Supporting Statement

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

information.
Table 1. Annual Respondent Burden and Cost: NSPS for Standards of Performance for Storage Vessels for Petroleum 

Liquids for which Construction, Reconstruction or Modification Commenced after June 11, 1973, and prior to May 19, 1978

(40 CFR part 60, subpart K) (Renewal)

Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year 

a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

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 Included in 4E

 B. Required activities: Included in 4E

 

 iii. Monitoring of operations 

 and emissions c

Included in 4E

D. Gather Existing Information Included in 4B and 5E

E. Write report d

 i. Notification of 

 reconstruction/modification 

4 1 4 2.2 8.8 0.44 0.88 $957.24

5. Recordkeeping Requirements
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Burden item

(A)

Personhours per

occurrence

(B)

No. of

occurrences

per 

respondent

per year

(C)

Personhours per

respondent

per year

(C=AxB)

(D)

Respondents

per year 

a

(E)

Technical

personhours per

year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours 

per year

(Ex0.1)

(H)

Cost, $ b

A. Read instructions Included in 4E

B. Plan activities Included in 4E

C. Implement activities Included in 4E

D. Develop record system N/A

E. Time to enter and transmit 

information: 

 i. Records of startup, shutdown, 

 or malfunction 

1 1 1 220 220 11.0 22.0 $23,931.05

 ii. Record petroleum liquid 

 stored

0.5 1 0.5 220 110 5.5 11.0 $11,965.53

 iii. Record of storage 

 performance tests

0.5 1 0.5 220 110 5.5 11.0 $11,965.53

 iv. Record true vapor pressure of 

 liquid stored

1 1 1 220 220 11.0 22.0 $23,931.05

F. Time to train personnel N/A

G. Time for audits N/A

TOTAL LABOR BURDEN AND 

COST 668.8 33.44 66.88 $72,750.39

TOTAL LABOR HOURS 

(Rounded) 769 $72,750
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Assumptions:

a

 We have assumed that there are approximately 220 sources currently subject to the NSPS, subpart K. We have assumed that there will be no new sources subject to 

the requirements of this regulation.

b

 This ICR uses the following labor rates: $114.49 per hour for Executive, Administrative, and Managerial labor; $98.20 per hour for Technical labor, and $48.53 per 

hour for Clerical labor. 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% to account for the benefit packages 

available to those employed by private industry.

c

 The monitoring and recordkeeping of operations include maintain record of the petroleum liquid stored, the period of storage, and the maximum true vapor 

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

with the requirements in 40 CFR 60.112, or stores liquid with a Reid vapor pressure of less than 6.9 kPa (1.0 psia) provided the true vapor pressure does not exceed 

that value.

d

 We have assumed that only one percent of the respondents (0.01 of 220) or 2.2 will modify or reconstruct their tanks in such way that it triggers the reporting 

requirements under NSPS subpart K.
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Table 2: Annual Burden and Cost for The Federal Government: NSPS for Standards of Performance for Storage Vessels for 

Petroleum Liquids for which Construction, Reconstruction or Modification Commenced after June 11, 1973, and prior to 

May 19, 1978 (40 CFR part 60, subpart K) (Renewal)

Activity

(A)

EPA 

personhours per

occurrence

(B)

No. of

occurrences

per plant

per year

(C)

EPA 

personhours per

plant per

year

(C=AxB)

(D)

Plants

per

year 

a

(E)

Technical

personhours

per year

(E=CxD)

(F)

Management

person-hours

per year

(Ex0.05)

(G)

Clerical

personhours per

year

(Ex0.1)

(H)

Cost, $ b

Notification of reconstruction/

modification 

c

 

2 1 2 2.2 4.4 0.22 0.44 $228.03

Subtotal Burden and Cost 4.4 0.22 0.44 $228.03

TOTAL ANNUAL BURDEN 

AND COST (Rounded)

5 $228

Assumptions:

a

 We have assumed that there are approximately 220 sources currently subject to the NSPS, subpart K. We have assumed that there will be no new sources 

subject to the requirements of this regulation.

b

This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: 

Managerial rate of $62.27 (GS-13, Step 5, $38.92 x 1.6), Technical rate of $46.21 (GS-12, Step 1, $28.88 x 1.6), and Clerical rate of $25.01 (GS-6, Step 3, 

$15.63 x 1.6). These rates are from the Office of Personnel Management (OPM) 2010 General Schedule which excludes locality rates of pay. 

c

 We have assumed that only one percent of the respondents or 22 will modify or reconstruct their tanks in such way that it triggers the reporting requirements 

under NSPS subpart K.