1

SUPPORTING STATEMENT

NSPS FOREQUIPMENT LEAKS OF VOC IN PETROLEUM REFINERIES

(40 CFR PART 60, SUBPARTS GGG and GGGa)

Part A of the Supporting Statement

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) (Final Rule), ICR 0983.10, 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 in 

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 to subpart GGG were 

proposed on November 7, 2006 that would have added new standards and compliance 

requirements. 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. The burden estimates presented in this ICR 

reflect the reporting and recordkeeping requirements in both subparts for the 3 years after 

November 7, 2006.

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 

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. 

Owners or operators are required to periodically (time period varies depending on equipment 

type and leak history) record information identifying leaking equipment, repair methods used to 

stop the leaks, and dates of repair. 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 are 

required, in general, of all sources subject to NSPS. Any owner or operator subject to the 
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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 45

sources are currently subject to Subpart GGG. This number is not expected to change in the 3 

years after November 7, 2006. In addition, although it is expected that no new refineries will be 

built in this 3-year period, it is estimated that an additional 10 refiners per year will become 

subject to Subpart GGGa as refiners construct new process units or either reconstruct or modify

existing process units. For Subpart GGG, the labor hours are 6,495 per year and the annual cost 

of the ICR will be $508,970. For Subpart GGGa, the labor hours are 4,216 per year and the 

annual cost of the ICR will be $330,353. All reports are sent to the delegated State or local 

authority. In the event that there is no such delegated authority, the reports are sent directly to 

the EPA Regional Office.

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. 

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.
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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. Nonduplication, Consultations, and Other Collection Criteria

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

subpart GGG and subpart GGGa. 
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3(a) Nonduplication

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 

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 

A public review and comment period followed publication of the proposed amendments 

in the Federal Register. Several comments were received on the proposed standards and burden 

estimates. In consideration of these comments, several changes in the standards and compliance 

requirements were made that affected the burden estimates.

3(c) Consultations

During development of the proposed amendments, 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. 

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 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 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 (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).
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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.

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 SIC (U.S. Standard Industrial Classification) Code 2911,

which corresponds to the NAICS (North American Industry Classification System) 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)
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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)

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)
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Records are required to be retained for 2 years.

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

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 then be downloaded into a computer 

database. This database can then 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:
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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 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 EPA’s Office of Compliance. AFS is EPA’s 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, and 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 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. 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 therefore, recordkeeping) may also be reduced for sources that 

maintain low percentages of leaking components. Additionally, 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 in Table 2: Annual burden of reporting and recordkeeping requirements as a result of 
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NSPS Subpart GGG and in Table 4: Annual burden of reporting and recordkeeping 

requirements as a result of NSPS Subpart GGGa.

6. Estimating the Burden and Cost of the Collection

Tables 2 and 4 document the computation of individual burdens 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, semi-annual 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 0.3 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 0.013 hours per day was 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 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 from these recordkeeping and 

reporting requirements is estimated at 6,495 person-hours for subpart GGG and 4,216 personhours for subpart GGGa. These hours are 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 labor rates of $80.41 per hour for technical, $120.92 per hour for 

managerial and $36.67 for clerical. These rates are from the United States Department of 

Commerce Bureau of Labor Statistics, “May 2006 National Industry-specific Occupational 
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Employment and Wage Estimates; NAICS 324000 – Petroleum and Coal Products 

Manufacturing.” The wage rates have been increased by 110% 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. There are no capital/startup or operation and maintenance costs. The 

type of industry costs associated with the information collection activity in the standards are 

labor costs and maintenance costs for the VOC monitors. Monitoring equipment for leaks is 

standard in the industry for safety reasons. To the extent possible, the requirements of this 

standard are consistent with industry practice. 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 since 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. Publication and distribution of the information are part of the AFS program. 

Examination of records to be maintained by the respondents will occur as part of the periodic 

inspection of sources, which is part of EPA’s overall compliance and enforcement program. 

The average annual Agency cost during the 3 years of the ICR is estimated to be $17,138

for subpart GGG (from Table 1) and $25,975 for subpart GGGa (from Table 3). This cost is 

based on a combination of technical hours (GS 12 Step 1 multiplied by a 1.6 benefits 

multiplication factor to account for government overhead expenses, for a total of $42.45/hr), 

managerial hours (GS-13 Step 5 multiplied by 1.6 for a total of $57.20/hr), and clerical hours 

(GS-6 Step 3 multiplied by 1.6 for a total of $22.96/hr). The wage rates are from the 2006 

General Schedule from the Office of Personnel Management. Details of the analysis appear in 

Table 1: Average annual EPA resource requirements resulting from NSPS Subpart GGG and 

Table 3: Average annual EPA resource requirements resulting from NSPS Subpart GGGa.

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

Respondent Universe 1 (Subpart GGG):

Regulation Citation: 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 45 2 90
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Regulation Citation: 40 CFR Part 

60, Subpart GGG

(A)

No. of Existing 

Sources

(B)

No. of Reports 

for Existing 

Sources

(C)

Total Annual 

Responses

(AxB)

Second year 45 2 90

Third year 45 2 90

The number of total respondents in each year is 45. The number represents the number 

of existing sources averaged over the three-year period.

The number of Total Annual Responses in each year is 90. The total annual labor costs 

are $508,970. The number of burden hours on which this estimate is based is 6,495. Details 

upon which this estimate is based appear in Table 2: Annual burden of reporting and 

recordkeeping requirements as a result of NSPS Subpart GGG.

The total annual capital and O&M costs to the regulated entity are zero dollars. Capital 

and O&M costs are not applicable since this is a leak detection and repair program with no 

continuous monitoring equipment used.

Respondent Universe 2 (Subpart GGGa):

Regulation 

Citation: 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 10 4 0 2 40

Second year 10 4 10 2 60

Third year 10 4 20 2 80

Each year 10 new plants are subject to initial notification requirements. In addition, in 

any given year, all of the new facilities from preceding years are subject to semiannual reporting 

requirements. Thus, an average of 20 facilities per year are subject to subpart GGGa over the 

three-year period. 

The average number of Total Annual Responses per year is 60. The total annual labor 

costs are $330,353. The number of burden hours on which this estimate is based is 4,216. 

Details upon which this estimate is based appear in Table 4: Annual burden of reporting and 

recordkeeping requirements as a result of NSPS Subpart GGGa.

The total annual capital and O&M costs to the regulated entity are zero dollars. Capital 

and O&M costs are not applicable since this is a leak detection and repair program with no 

continuous monitoring equipment used.
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6(e) Bottom Line Burden Hours and Cost Tables

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

appear below (Tables 1, 2, 3, and 4).

6(f) Reasons for Change in Burden

The increase in burden cost from the most recently approved ICR is due to three reasons. 

First, the new standards in subpart GGGa require the same recordkeeping and reporting tasks as 

in subpart GGG as well as some additional recordkeeping requirements. Second, a higher 

number of new sources are subject to the new subpart GGGa than would have been subject to 

subpart GGG in the absence of the new standards. This is because many refineries already have 

process units that are subject to subpart GGG. Construction, reconstruction, or modification of 

another process unit at these facilities would not increase the number of new facilities subject to 

subpart GGG, but it does increase the number of new sources subject to subpart GGGa. Third, 

the revised analysis for this ICR includes time for management and clerical workers as well as 

technical staff.

6(g) Burden Statement

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

is estimated to average 72 hours per response for subpart GGG and 70 hours per response for 

subpart GGGa. 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 in 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-OAR-2006-0699, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Air and Radiation Docket and Information 

Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution 

Avenue, NW, 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 Air and Radiation 

Docket and Information Center is (202) 566-1742. An electronic version of the public docket is

available at www.regulations.gov. This site can be used to submit or view public comments, 
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access the index listing of the contents of the public 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 above. Also, you can send comments to the Office of 

Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, 

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

Number EPA-HQ-OAR-2006-0699 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
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TABLE 1: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTS RESULTING FROM NSPS SUBPART GGG.

Activity

(A) EPA 

Hours/ 

Occurrence

(B) 

Occurrences/ 

Plant/Year

(C) EPA 

Hours/

Plant/Yeara

(D) 

Plants/Year

(E) EPA 

Technical 

Hours/ Yearb

(F) EPA 

Managerial 

Hours/Year 

(E x 0.05)

(G) EPA 

Clerical 

Hours/Year

(E x 0.10)

Initial Performance 

Tests (New Plants)

24 1 24 0 0 0 0

Repeat Performance 

Testsc(New Plants)

24 0.2 4.8 0 0 0 0

Report Review 

(New Plants)

Notification of 

construction

2 1 2 0 0 0 0

Notification of 

anticipated startup

0.5 1 0.5 0 0 0 0

Notification of 

actual startup

0.5 1 0.5 0 0 0 0

Notification of 

initial test

0.5 1.2 0.6 0 0 0 0

Review test results 8 1.2 9.6 0 0 0 0

Report Review 

(Existing Plants)

Emission Reports 4 2 8 45 360 18 36

Total Annual Hours 360 18 36

Travel Expenses = (1 person x 0 plants/year x 3 days/plant x $50 per diem) + ($250 round trip/plant x 2 plants/year) = $0/year

Salaryd= (360 hours/year x $42.45/hour) + (18 hours/year x $57.20/hour) + (36 hours/year x $22.96/hour) = $17,138/year

Total Annual Cost = $0 + $17,138 = $17,138

a

 C = A x B

b

 E = C x D

c

 Assume 20% of initial performance tests must be repeated due to failure

d

 Estimate is based on a combination of technical hours (GS 12 Step 1 multiplied by a 1.6 benefits multiplication factor to account for government overhead 

expenses, for a total of $42.45), managerial hours (GS-13 Step 5 multiplied by 1.6 for a total of $57.20), and clerical hours (GS-6 Step 3 multiplied by 1.6 for a 

total of $22.96). Wages are from the 2006 General Schedule from the Office of Personnel Management
15

TABLE 2: ANNUAL BURDEN OF REPORTING AND RECORDING REQUIREMENTS AS A RESULT OF NSPS SUBPART GGGa

(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
16

(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

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 45

c

720 36 72 64,889

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

0.3 365 d109.5 45

c

4,928 246 493 444,081

F. Train Personnel

(Not Applicable)
17

(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

G. Audits (Not 

Applicable)

5. TOTAL ANNUAL 

BURDEN

5,648 282 565 $508,970

a Only existing facilities because all new sources will be subject to subpart GGGa.

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

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

d Assume that average number of affected facilities over the next three years is equal to the current number of facilities (45) because affected facilities after November 7, 2006 will 

be subject to subpart GGGa instead of subpart GGG.

e Although monitoring of the various components may be required on a weekly, monthly, quarterly, semi-annual 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 

0.3 hours and that monitoring is done 365 days per year.
18

TABLE 3: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTS RESULTING FROM NSPS SUBPART GGGa.

Activity

(A) EPA 

Hours/ 

Occurrence

(B) 

Occurrences/ 

Plant/Year

(C) EPA 

Hours/

Plant/Yeara

(D) 

Plants/Year

(E) EPA 

Technical 

Hours/ Yearb

(F) EPA 

Managerial 

Hours/Year

(G) EPA 

Clerical 

Hours/Year

Initial Performance 

Tests (New Plants)

24 1 24 10 240 12 24

Repeat Performance 

Testsc(New Plants)

24 0.2 4.8 2

c

9.6 0.48 1

Report Review 

(New Plants)

Notification of 

construction

2 1 2 10 20 1 2

Notification of 

anticipated startup

0.5 1 0.5 10 5 0.25 0.5

Notification of 

actual startup

0.5 1 0.5 10 5 0.25 0.5

Notification of 

initial test

0.5 1.2 0.6 10 6 0.3 0.6

Review test results 8 1.2 9.6 10 96 4.8 9.6

Report Review 

(Existing Plants)

Emission Reports 4 2 8 10 80 4 8

Total Annual Hours 461.6 23.1 46.2

Travel Expenses = (1 person x 10 plants/year x 3 days/plant x $50 per diem) + ($250 round trip/plant x 10 plants/year) = $4,000/year

Salaryd= (461.6 hours/year x $42.45/hour) + (23.1 hours/year x $57.20/hour) + (46.2 hours/year x $22.96/hour) = $21,975/year

Total Annual Cost = $4,000 + $21,975 = $25,975

a

 C = A x B

b

 E = C x D

c

 Assume 20% of initial performance tests must be repeated due to failure

d

 Estimate is based on a combination of technical hours (GS-12 Step 1 multiplied by a 1.6 benefits multiplication factor to account for government overhead 

expenses for a total of $42.45), managerial hours (GS-13 Step 5 multiplied by 1.6 for a total of $57.20), and clerical hours (GS-6 Step 3 multiplied by 1.6 for a 

total of $22.96). Wages are from the 2006 General Schedule from the Office of Personnel Management.
19

TABLE 4: ANNUAL BURDEN OF REPORTING AND RECORDING REQUIREMENTS AS A RESULT OF NSPS SUBPART GGGaa

(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 10 10 0.5 1 901

B. Required Activities

Initial performance 

test

24 1 24 10 240 12 24 21,630

Repeat performance 

test

24 1 24 2

b

48 2.4 4.8 4,326

C. Create Information

(Included in 3B)

D. Gather Existing

Information (Included 

in 3E)

E. Write Report

Notification of 

construction or 

reconstruction

2 1 2 10 20 1 2 1,802

Notification of 

anticipated startup

2 1 2 10 20 1 2 1,802
20

(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

Notification of actual 

startup

2 1 2 10 20 1 2 1,802

Notification of initial 

performance test 2 1 2 10 20 1 2 1,802

Report of 

performance test 

(Included in 3B)

Semiannual work 

practice reports

8 2 16 20 d320 16 32 28,839

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

0.40 365 c148 17.4 d,f2,571 129 257 231,700
21

(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

Records of operating 

parameters for small 

refiners

0.42g365 c153 2.6 d,f397 20 40 35,747

F. Train Personnel

(Not Applicable)

G. Audits (Not 

Applicable)

5. TOTAL ANNUAL 

BURDEN

3,666 183 367 $330,353

a

 Estimating that there are approximately 30 refineries (respondents) which become subject over a 3-year period. The number of new sources per year equals 30/3 = 10.

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

c

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

d

 Assume that average number of affected facilities over the next three years is estimated by the number of affected facilities in the second year (10 new and 10 existing).

e

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

monitored at any facility, monitoring overall is essentially occurring daily. An additional 0.10 hours per day are needed to complete the tasks required by the new standards.

f

 Assume 26 percent of the new process units per year are at small refineries and half of those use manual recordkeeping of instrument readings (20 x 0.26 x 0.5 = 2.6).

g

 Estimated that most facilities need an additional 0.10 hours per day to complete the tasks required by the new standards. Estimated that 0.113 hours per day are needed for small 

refineries with manual recordkeeping of instrument readings.