SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY NSPS for VOC Emissions from Petroleum Refinery Wastewater System 1. Identification of the Information Collection 1(a) Title of the Information Collection NSPS for VOC Emissions from Petroleum Ref inery Wastewater Sy stem (40 CFR p art 60, s ubpart QQQ ) (Renewal) 1(b) Short Characterization/Abstract The New Source Performance Standards (NSPS) for v olatile o rganic c ompound (VOC ) emissions from petroleum refinery wastewater s ystems for the regulations published at 40 CFR 60.690 were proposed on May 4, 1987 and promulgated on November 23, 1988. These standards apply to the following affected facilities in petroleum refinery wastewater sy stems: individual drain sy stems, oil

- water separators, and aggregate facilities commencing construction, modification or reconstruction after the date of proposal. An individual drain sy stem consists of all process drains connected to the first downstream junction box. An oil

- water separator is the wastewater treatment equipment used to separate oil from water. An aggregate facility is an individual drain sy stem together with ancillary downstream sewer lines and oil

- water separators, down to and including the secondary oil

- water separator, as applicable. Aggregate fac ilities are intended to capture any p otential VOC emissions within the petroleum refinery w astewater sy stem during expansions of and additions to the system. There are no additional recordkeeping or reporting requirements for aggregate facilities. For th e purposes of this document, new facilities are those affected facilities that have had construction, modification or reconstruction within the last three years. T his information is being collected to determine compliance with 40 CFR part 60, subpart QQQ. In general, all NSPS standards require initial notifications, performance tests, and periodic reports. 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 s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all sources subject to NSPS. Any owner or operator subject to th e 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. 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 United States Environmental Protection Agency (EPA) regional office. Based on our consultations with industry representatives, there is an average of one affected facility

at each plant site and that each plant site has only one respondent (i.e., the owner/operator of the plant site).2

Over the next three ye ars, an average of 135 facilities per year will be subject to the standard, and it is estimated that no additi onal sources per year will becom e subject to the standard in the next three years. There are approximately 135 VOC emissions from petroleum refinery wastewater s ys tems in the United States, which are all publicly owned and operated by

the petroleum refinery wastewater s ys tem industry . None of the 135 facilities in the United States are owned by either state, local, tribal or the Federal Government. They are all owned and operated solely b y p rivatel y owned for

- profit businesses. You can find the burden t o the “Affected Public” listed below in Table 1: Annual Industry Burden and Cost

- NSPS for VOC Emissions from Petroleum Refinery Wastewater S ys tem (40 CFR p art 60, s ubpart QQQ ) . The Federal government burden does not include work performed by Federal emp loyees only

work performed by

contractors, which could be found listed below in Table 2: Average Annual EPA Burden

- NSPS for VOC Emissions from Petroleum Refinery

Wastewater S ys tem (40 CFR p art 60, s ubpart QQQ )

. The Office of Management and Budget (OMB) approved the currently active ICR without any “Terms of Clearance.” 2. Need for and Use of the Collection 2(a) Need/Authority for the Collection The EPA is charged under s ection 111 of the Clean Air Act (CAA), as amended, to establish standards of per formance for new stationary sources that reflect:

. . . application of the best technological sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or any non - air quality health and envi ronmental impact and energy requirements) the Administrator determines has been adequatel y 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 o wner or operator subject to any

requirement of this Act to: (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, an d in such manner as the Administrator shall prescribe); (E) keep records on control3 equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonabl y require. In the Administrator's judgment, VOC emissions from petroleum refinery wastewater sy stems cause or contribute to air pollution that may reasonabl y be anticipated to endanger public health or welfare. Therefore, the NSPS was promulgated for this source category at 40 CFR part 60, subpart QQQ. 2(b) Practical Utility/Users of the Data The recordkeeping and reporting requirements in the standard ensure compliance with the applicable regulations which where promulgated in accordance with the Clean Air Act. The collected information is also used for targeting inspections and as evidence in legal proceedings. Performance tests are required in order to det ermine an affected facility’s i nitial capability to comply

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

mance test may

also be observed. The required semiannual and quarterly reports are used to determine periods of excess emissions, identify

problems at the facility , verify operation/maintenance procedures, and for compliance determinations. 3. Nonduplic ation, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 60, subpart QQQ. 3(a) Nonduplication If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directl y to the delegated state or local agency
. If a state or local agency h as adopted their own similar standards to implement the Federal standards, a cop y of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required b y the Federal standards. Therefore, no duplication exists.4

3(b) Public Notice Required Prior to ICR Submission to OMB An announcement of a public comment period f or the renewal of this IC R was published in the Federal Register ( 7 2 FR 1073 5 ) on March 9, 2007. N o comments were received on the burden published in the Federal Register

. 3(c) Consultations
T he Agency ’s industry

experts have been consulted, and the Age ncy ’s internal data sources and projections of industry growth over the next three years have been considered. The primary source of information as reported b y industry , in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System (OTI S) which is operated and maintained by EPA's Office of Compliance. OTIS is EPA ’ s database for the collection, maintenance, and retrieval of all compliance data. The growth rate for the industry is based on our cons ultations with the Agency ’s internal industry experts. Approximately

135 respondents will be subject to the standard over the three ye ar period covered by this ICR. Industry trade associations and other interested parties were provided an opportunity to c omment 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. It is our polic y t o respond after a thorough review of comments received since the last ICR renewal as well as those submitted in response to the f irst Federal Register n otice. 3(d) Effects of Less Frequent Collection Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. If the information required b y these stand ards was collected less frequentl y, the proper operation and maintenance of control equipment and the possibility of detecting violations would be less likely

. 3(e) General Guidelines These reporting or recordkeeping requirements do not violate any of the regulations promulgated b y OMB under 5 CFR part 1320, section 1320.5. 3(f) Confidentiality Any i nformation submitted to the Agency for which a claim of confidentiality i s made will be safeguarded according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B

- Confidentiality

of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979).5

3(g) Sensitive Questions None of the reporting or recordkeeping requirements contain sensitive questions. 4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes The respondents to the recordkeeping and reporting requirements are source category desc ription. The United States Standard Industrial Classification (SI C) code for the respondents affected b y the standards is SI C 2911, which corresponds to the North American Industry Classification System (NAI CS) 324110 for source category description. The respondents to the recordkeeping and reporting requirements are petroleum refineries. 4(b) Information Requested None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. (i) Data Items In this ICR, all the data recorded or reported is required by the New Source Performance Standards for VOC Emissions from Petroleum Refinery Wastewater Sy stems (40 CFR p art 60, s ubpart QQQ). A source must make the following reports:
No tifications Notification of construction or reconstruction 60.7(a)(1) Notification of modification 60.7(a)(4) Notification of actual startup date 60.7(a)(3) Notification of initial performance test 60.8(a) Notification of election to construct and ope rate a completely closed drain sy stem 60.693

- 1(c) and 60.698(a) Notification of election to construct and operate a floating roof on an oil

- water separator tank or other subject auxiliary equipment 60.693

- 2(b) and 60698(a) Notification of intent to use an alternative means of emission limitation 60.694(c) Notification of intent to use a VOC control device other than a carbon absorber to meet the requirement of 60.692

- 5(a), with information describing the control device and the process parameters being mo nitored 60.695(b)

Demonstration that an alternative operational or process parameter will ensure that the control device is operated in compliance with standards 60.695(c)6 No tifications Initial certification that the requirements for equipment and inspections have been met 60.698(b)(1) Notification of delay

in compliance along with the date of the next scheduled refinery

or process unit shutdown and reasons why delay is necessary 60.698(e)

Semiannual reports of excess emissions from and performance of continuous moni toring systems, and/or summary report forms 60.7(c)and 60.7(d) Semiannual certification and required inspections have been carried out 60.698(b)(1) Initial performance test data and result for flares 60.8(a) and 60.698(b)(2) Initial and semiannual inspe ction reports detailing problems resulting in VOC emissions and the corrective actions taken 60.698(c) Semiannual reporting on control device performance 60.698(d) A source must keep the following records: Recordkeeping Maintain records of startups, shutdowns, malfunctions of affected facilities; malfunctions of control devices; and periods where the continuous monitoring sy stem is inoperative 60.7(b) Maintain records of measurements, performance evaluations, calibration checks, adjustments and maint enance related to continuous monitoring sy stems 60.7(f) Maintain records of location, date, and corrective actions for process drains not in compliance 60.697(b)(1) Maintain records of location, date, and corrective actions for junction boxes out of compliance 60.697(b)(2) Maintain records of location, date, and corrective actions for sewer lines out of compliance 60.697(b)(3) Maintain records of location, date, and corrective actions for oil

- water separators out of compliance 60.697(c) Maintain records of location, date and corrective actions for closed vent sy stems and completely

closed drain s ys tems our of compliance 60.697(d) Maintain records of expected date of repairs if emission point cannot be repaired without a process shutdown; reason for de lay ; signature of company official who authorizes the delay; and the date of actual repairs 60.697(e) Maintain records of cop y of design specifications for all equipment used to comply with the standards 60.697(f)(1) and (2)7 Recordkeeping Maintain records of informati on pertaining to the operation and maintenance of closed

- drain sy stems and closed

- vent sy stems 60.697(f)(3) Maintain records of location, plans or specifications for inactive process drains 60.697(g) Maintain records of location, plans or specifications for exempted storm water sewer s ys tems 60.697(h) Maintain records of location, plans or specification for exempted ancillary equipment 60.697(i) Maintain records of location, plans or specifications for exempted non - contact cooling water sy stems. 60.697( 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 sy stems to transmit data electronically. However, electronic reporting s ys tems are still not widely used. At this time, it is estimated that approximately 10 percent of the respondents use electronic reporting. Respondent Activities Read instructions. Install, calibrate, maintain, and operate a continuous temperature monitoring device for thermal or catal yt ic incinerators; a continuous VOC monitoring device for regenerative carbon absorbers; and/or a thermocouple or equivalent device for flares, as applicable. Perform initial performance test, Reference Method 21 test (Method 22 for flares), and repe at performance tests if necessary

. Write the notification and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and sy stems for the purpose of c ollecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining information. Develop, acquire, install and utilize technology and sy stems for the purpose of dis closing and providing information. Adjust the existing way s to comply with any previously applicable instructions and requirements. Train personnel to be able to respond to a collection of information.8 Respondent Activities Transmit, or otherwise disclose the information. Currently , sources are using monitoring equipment that provides parameter data in an automated way

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

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

. Audit facility

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

with the emission s tandard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identif ication, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into OTI S which is operated and maintained by the EPA Office of Compliance. OTI S is an EPA database for the collec tion, maintenance, and retrieval of compliance data for approximately 125,000 industrial and government

- owned facilities. E PA uses OTIS for tracking air pollution compliance and enforcement by l ocal and state regulatory

agencies, EPA regional offices and EPA headquarters. EPA and its delegated a uthorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner or operator for two ye ars.9

5(c) Small Entity Flexibility The majority

of the re spondents are large entities (i.e., large businesses). However, the impact on small entities (i.e., small businesses,) was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pes of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these to be the minimum requirements needed to ensure compliance and, therefore, cannot reduce them further for small entities. T o the ex tent that larger businesses can use economies of scale to reduce their burden, the overall burden will be reduced. 5(d) Collection Schedule The specific frequency

f or each information collection activity w ithin this request is shown in Table 1: Annual Industry Burden, NSPS for VOC Emissions from Petroleum Refinery Wastewater S ys tems ( 40 CFR p art 60, s ubpart QQQ). 6. Estimating the Burden and Cost of the Collection Table 1 documents the computation of individu al burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concept of burden under the Pa perwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required to respond to, a collecti on 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 9,237 (To tal 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 NESHAP program, the previously approved ICR, and any comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs This I CR uses the following labor rates: Managerial $105.86 ($50.41 + 110%) Technical $92.61 ($44.10 + 110%) Clerical $45.32 ($21.58 + 110%)10

These rates are from the United States Departm ent of Labor, Bureau of Labor Statistics, December 2006, Table 2. Civilian Workers, by occupational and industry group. The rates are from column 1, Total compensation. The rates have been increased by 1 10% to account for the benefit packages available t o 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 b y the subject standard are labor costs. The ty pe of industry

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

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

(iii) Capital/Startup vs. Operation and Maintenance (O&M) Costs Capital/Startup vs. Operation and Maintenance (O&M) Costs (A) Continuous Monitoring Device (B)

Capital/Startup Cost for One Respondent (C)

Number of New Respondents (D)

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

Annual O&M Costs for One Respondent (F)

Number of Respondents with O&M (G)

Total O&M, (E X F)

Portable VOC analyzer for non - regenerative carbon absorber $2,960 0 0 $130 135 $17,550

The total capital/startup costs for this I CR are zero. This is the total of column D in the above table.
T he total operation and maintenance (O&M) costs for this I CR are $17,550. This is the total of column G. The average annual cost for capital/startup and operation and maintenance costs to industry over the next three ye ars of the I CR is estimated to be $ 17,550. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with anal ys is of the reported information. 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 $104,576.11

This cost is based on the average hourl y labor rate as follows: Managerial $58.18 (GS

- 13, Step 5, $36.36 + 60%) Technical $43.17 (GS

- 12, Step 1, $26.98 + 60%) Clerical $23.36 (GS

- 6, Step 3, $14.60 + 60%) These rates are from the Office of Personnel Management (OPM) 2007 Ge neral Schedule which excludes locality

rates of pay . The rates have been increased by 60% to account for the benefit packages available to government emplo ye es. Details upon which this estimate is based appear in Table 2: Average Annual EPA Burden, NSPS for VOC Emissions from Petroleum Refinery Wastewater Sy stems ( 40 CFR p art 60, s ubpart QQQ) , below

. 6(d) Estimating the Respondent Universe and Total Burden and Costs Based on our research for this I CR, on average over the next three ye ars, approximatel y 135 existing respondents will be subject to the standard. It is estimated that no additional respondents per ye ar will become subject. The overall average number of respondents, as shown in the table below is 135 per year
. The number of respondents is calculated using the following table that addresses the three ye ars covered b y this ICR. Number of Respondents

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 0 135 0 0 135 2 0 135 0 0 135 3 0 135 0 0 135 Average 0 135 0 0 135 1 New respondent include sources with constructed, reconstructed and mo dified affected facilities . In this standard existing respondents submit initial notifications. To avoid double

- counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three

- ye ar period of this ICR is 1 35. The total number of annual responses per ye ar is calculated using the following table:12 Total Annual Responses (A) Information Collection Activity (B) Number of Respondents (C)

Number of Responses (D)

Number of Existing Respondents That Keep Reco rds But Do Not Submit Reports (E)

Total Annual Responses E=(BxC)+ D Notification of construction/reconstruction 0 1 n/a 0
Notification of modification 0 1 n/a 0 Notification of actual startup 0 1 n/a 0 Initial certification of equipment and inspections 0 1 n/a 0 Initial inspection report detailing emission problems 0 1 n/a 0
Notifications of various intent 0 1 n/a 0 Demonstration for alternative operational or process parameter 0 1 n/a 0 Notification of delay in compliance 0 1 n/a 0 Semiannual repo rt 135 2 n/a 270 Notification of initial performance test 0 1 n/a 0
Total 270 The number of total respondents is 135 The number of Total Annual Responses is 270. This is the number in column E of the Respondent Universe and Number of Responses per year in table above. The total annual labor costs are $822,810. Details regarding these estimates may be found in Table 1: Annual Industry Burden, NSPS for VOC Emissions from Petroleum Refinery Wastewater S ys tems ( 40 CFR p art 60, s ubpart QQQ) , below. 6 (e) Bottom Line Burden Hours Burden Hours and Cost Tables The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2, respectivel y, and summarized below. (i) Respondent Tally The total annual labor costs are $822,810. Details regarding these estimates may be found in Table 1. Annual Respondent Burden and Cost: NSPS VOC Emissions from Petroleum Refinery Wastewater S ys tems ( 40 CFR p art 60, s ubpart QQQ) , below. Furthermore, the annual publi c reporting and recordkeeping burden for this collection of information is estimated to average 34 hours per response.13

The total annual capital/startup and O&M cost to the regulated entity are $17,550. (ii) The Agency Tally The average annual Agency burden and cost over next three years is estimated to be 2,484 labor hours at a cost of $ 104,576 . See Table 2. Annual Agency Burden and Cost: NSPS for VOC Emissions from Petroleum Refinery Wastewater Sy stems ( 40 CFR p art 60, s ubpart QQQ) , below

. 6(f) Reaso ns for Change in Burden There is no change in the labor hours in this IC R compared to the previous ICR. This is due to two considerations. F irst, the regulations have not changed over the past three years and are not anticipated to change over the next three years. Secondly, the growth rate for the industry is very low, negative or non

- existent, so there is no significant change in the overall labor hours. There is however, a change in the cost estimate. The previous ICR used a cost figure that was ro unded

- up ($18,000). This ICR uses the exact cost figure ($17,550) resulting in a small cost de crease. Since there are no changes in the regulatory requirements and there is not significant industry growth, the labor hours in the previous ICR are used in this I CR and there is no change in the labor hours to industry. 6(g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 34 hours per response. Burden means the total time, ef fort, 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 s ys t ems for the purposes of collecting, validating, and verify ing information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; 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 requi red to respond to, a collection of information unless it displays a 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 accur acy of the provided burden estimates, and any s uggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 2007

- 0044. An electronic version of the public docket is available at http://www.regulations.gov which may be used to obtain a cop y of the draft collection of information, submit or view public comments, access the index listing of the content of the docket,14

and to access those documents in the public docket that are available electronically . When in the sy stem, select “search” than key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, N.W., Washington, 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 ho liday s. The telephone number for the Reading Room is (202) 566

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

- 1 752

. Also, yo u can send comments to the Office of Information and Regulato ry Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2007

- 0044 and OMB Control Number 2060

- 0172 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 VOC Emissions from Petroleum Ref inery Wastewater System (40 CFR p art 6 0 , s u bpart QQQ ) (A) (B) (C) (D) (E) (F) (G) (H)

Burden item Person

hours per occurrence No. of

occurrences per respondent per year Person

hours per respondent per year (C=AxB) Respondents

per year (a) Technical

person hours per year (E=CxD) Management

person - hours per year (Ex0.05) Clerical

person - hours per year (Ex0.1) Cost {$} (b)

1. Applications N/A 2. Survey and Studies N/A 3. Reporting requirements A. Read instructions 2 1 2 135 270 13.5 27 $27,6 57.45 B. Required activities 1. Inspect drain systems 2 12 24 135 3,240 162 324 $331,889.40 2. Inspect oil

- water separators 8 2 16 135 2,160 108 216 $221,259.60 3. Performance test 330 1 330 0 0 0 0 $0 C. Create information See 3B D. Gather existing information See 3E E. Write report Notification of construction/ reconstruction 2 1 2 0 0 0 0 $0 Notification of modification 2 1 2 0 0 0 0 $0 Noti fication of actual startup 2 1 2 0 0 0 0 $0 Initial certification of equipment and inspections 2 1 2 0 0 0 0 $0 Initial inspection report detailing emission problems 2 1 2 0 0 0 0 $0 Various notifications of intent 2 1 2 0 0 0 0 $0 Demonstration for alternative operational or process parameter 2 1 2 0 0 0 0 $0 Notification of delay in compliance 2 1 2 0 0 0 0 $0 Semiannual report 8 2 16 135 2,160 108 216 $221,259.60 Notification of initial performance t est 2 1 2 0 0 0 0 $016 Results of performance test See 3B 4. Recordkeeping requirements A. Read instructions See 3A B. Plan activities N/A C. Implement activities N/A D. Develop record sys tem N/A E. Enter information 1.5 1 1.5 135 202.5 10.13 20.25 $0 F. Train personnel N/A G. Audits N/A Subtotal 8,032.5 401.63 803.25 $822,809.67 TO TAL ANNUAL BURDEN AND COST (rounded) 9,237 $822,810
Assumptions:
a. We have assumed that the average number of respondents that will be subject to the rule will be 135 . There will be no additional new sources per year that will become subject to the rule over the three

- year period of this ICR. b

. This ICR uses the following labor rates: $105.86 per hour for Executive, Administrative, and Managerial labor; $92.61 per hou r for Technic al labor, and $45.32 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, Decembe r 2006, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total c om pensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.
c. We have assumed that each respondent will read instructions once per year. d. We have assumed that each respondent will take two hours to inspect drain systems twelve time per year.
e. We have assumed that it will take eight hours for each respondent to inspect oil

- water separators two time per year. f

. We have assumed that each respondent will take eight hours to w rite the semiannual report two time per year.17

Table 2 : Average Annual EPA Burden

– NSPS VOC Emissions from Petroleum Refinery Wastewater System (40 CFR p art 6 0 , s ubpart QQQ ) (A) (B) (C) (D) (E) (F) (G) (H)

Activity EP A p erson hours per occurrence No. of

occurrences per plant per year EPA

p erson hours per plant per year (C=AxB) Plants per

year (a) Technical

person hours per year (E=CxD) Management

person - hours per year (Ex0.05) Clerical

person - hours per year (Ex0. 1) Cost {$} (b)

Report Review Notification of construction/ reconstruction 2 1 2 0 0 0 0 $0 Notification of modification 2 1 2 0 0 0 0 $0 Notification of actual startup 2 1 2 0 0 0 0 $0 Initial certification for equipment and inspections 2 1 2 0 0 0 0 $0 Initial inspection detailing emission P roblems 2 1 2 0 0 0 0 $0 Notification of various intent c 2 1 2 0 0 0 0 $0 Demonstration for alternative operational or process parameter 2 1 2 0 0 0 0 $0 Notification of delay in compliance 2 1 2 0 0 0 0 $0 Notification of initial performance T est 2 1 2 0 0 0 0 $0 Initial performance test report for F lares 2 1 2 0 0 0 0 $0 Review of semiannual reports d 8 2 16 135 2,160 108 216 Subtotal 2,160 108 216 $104,576.40 TO TAL ANNUAL BURDEN AND COST (rounded) 2,484 $104,576 Assumptions:
a . We have assumed that the average number of respondents that will be subject to the rule will be 135 There will be no a dditional new sources that will become subject to the rule over the three

- year period of this ICR. b. The cost is based on the following labor rate which incorporates a 1.6 benefits multiplication factor to account for governme nt overhead expenses. Mana gerial rates of $58.18 (GS

- 13, Step 5, $36.36x1.6), Technical rate of $43.17 (GS

- 12, Step 1, $26.96 x 1.6), and Clerical rate of $23.36 (GS

- 6, Step 3, $14.60 x 1.6). T hese rates are from the Office of Personnel Management (OPM) “2007 General Schedule” whi ch excludes locality rates of pay.18

c. The following notification review is included: election to construct and operate a completely closed drain system; election to construct and operate a floating roof; intent to use an alternative means of emission limitation; and intent to use a VOC control device other than a carbon absorber to meet the requirements of 60.692

- 5(a). d

. We have assumed that it will take 8 hours two times per year to review each semiannual report.