1

MEMORANDUM

TO: Andrew Bouchard and Brenda Shine, EPA

FROM: Mae Thomas, Jason Renzaglia, and Philip Crawford, ERG

DATE: January 20, 2012

SUBJECT: Comparison of Reporting Burden between Hardcopy Reports Submitted under 

Existing Rules and Semiannual Electronic Reports Submitted for Uniform 

Standards

1.0 INTRODUCTION

All semiannual reporting elements are required to be submitted electronically by the 

proposed Uniform Standards; this is expected to result in significant cost savings and burden 

reductions for industry and regulatory agencies. In addition, some data elements previously

required to be reported semiannually are proposed to be submitted annually in the Uniform 

Standards. This memorandum describes the methods and procedures used to estimate the burden 

as a result of complying with the proposed Uniform Standards semiannual electronic reporting 

requirements and annual written reporting requirements compared to entirely written reporting 

requirements in existing rules. This analysis considered routine reporting burden and did not 

include initial reports (such as the Notification of Compliance Status reports) or reports required 

in unique situations (such as request for a performance test waiver).

Burden reductions were estimated for two model facilities: a refinery and a chemical 

plant. These models were selected to provide an estimate of the costs for facilities that are 

considered typical in size, as well as number and types of applicable rules. This memorandum 

provides a comparison of burden under existing rules and the proposed Uniform Standards for 

each model facility. This memorandum also provides a description of each model facility, 

identifies all applicable regulations and related supporting statements, and describes the specific 

methodology for estimating the burden reduction.

This memorandum is organized as follows:

1.0 Introduction

2.0 Results
2

3.0 Model Facility Descriptions

4.0 Methodology

5.0 References

Appendix A: Model Facility Descriptions: Rule Applicability

Appendix B: Burden Estimation and Supporting Statement Analysis – Model Refinery

Appendix C: Burden Estimation and Supporting Statement Analysis – Model Chemical 

Plant

Appendix D: Electronic Reporting Cost Analysis

2.0 RESULTS

For each model facility, the burden was estimated for complying with the proposed 

Uniform Standards electronic reporting requirements and compared to the burden associated 

with written reporting requirements in existing rules. It was assumed that the cost of record 

keeping would not change from existing rules to the proposed Uniform Standards for each model 

facility. Table 1 presents the total reporting costs under existing rules, the proposed Uniform 

Standards, and the potential savings for the model facilities. The model chemical plant is smaller 

than the model refinery plant which generally explains the difference in the burden estimates.

Table 1. Reporting Burden Comparison for Hardcopy and Electronic Reporting under the 

Proposed Uniform Standards for a Model Refinery and Model Chemical Plant

Reporting Scheme

Model 

Refinery 

Annual Cost

($/yr)

Model 

Chemical 

Plant Annual 

Cost ($/yr)

Existing Rules 52,847 16,014

Proposed Uniform Standards 21,4091 9,2351

Total Savings 31,438 6,779

Total Savings (%) 59% 42%

1 – An initial electronic startup cost of $5,333 was calculated for the model refinery and 

$2,685 for the model chemical plant; these costs are expected to be incurred by each model

facility for the first year of compliance with the proposed Uniform Standards. The initial 

electronic startup cost is not included in the proposed Uniform Standards annual costs shown. 

3.0 MODEL FACILITY DESCRIPTIONS

Two model facilities were developed for the burden reduction estimate: a refinery and a

chemical plant. Each model is representative of typical medium sized facilities currently 

operating in the United States. The following section briefly describes each model facility type. 
3

3.1 Refinery

The model refinery was created using issued Title V air permits for existing refineries. 

Information regarding process units, emission points, and federal rule applicability were

extracted from the technical documentation for the Title V permits. The process units associated 

with existing refineries were compared against the process units at other refineries in the United 

States using the published list of refineries and process characteristics provided in the Oil and 

Gas Journal (Oil & Gas, 2000). This comparison ensured that the model refinery was a typical 

sized facility in regards to process unit counts. For example, although one of the existing 

refineries operates more than one pipe still, only one pipe still was included in the model refinery

to reflect a capacity (i.e., 200,000 barrels per day) more typical of refineries located in the United 

States. Table 2 lists the number and type of process units included in the model refinery. 

Table 2. Number and Type of Process and Emission Points Included for Model Refinery

Process Unit Number of Units

Oil Movements 1

Pipe Stills 1

Sulfur Recovery Unit 1

Alkylation Unit 1

Isomerization Unit 1

Naptha Stream Treatment Plants 2

Ultraformers 2

Hydrogen Unit 1

Cat Feed Hydrotreating 1

Catalytic Refining 1

Fluidized Catalytic Cracking 1

Marine Dock Facility 1

Marketing Terminal 1

Emission Point

Process Vents 7

Equipment Leaks (Process Units) 16

Transfer Operations 2

External Floating Roof Storage Vessel 37

Internal Floating Roof Storage Vessel 11
4

3.2 Chemical Plant

The model chemical plant was created using issued Title V air permits for existing 

chemical plants. Information regarding process units, emission points, and federal rule 

applicability was extracted from technical documents for the Title V permits. Table 3 lists the 

number and type of process units included in the model chemical plant. 

Table 3. Number and Type of Process and Emission Points Included for Model Chemical Plant

Process Unit Number of Units

Phenol Production 1

Resin Production 1

Polymer Production 1

Emission Point

Process Vents 14

Equipment Leaks (Process Units) 3

Transfer Operations 7

Storage Vessels 20

4.0 METHODOLOGY

A similar methodology was used for both model facilities to develop the burden estimates 

for the existing regulations and reporting burden for the proposed Uniform Standards. All 

applicable federal regulations pertaining to each model facility were identified (see Section 4.1). 

Supporting statements for each applicable rule were gathered and used to estimate the annual 

record keeping and reporting burden for each model facility under existing requirements (see 

Section 4.2). The potential reporting cost savings associated with the proposed Uniform 

Standards (not considering initial electronic startup costs) were estimated by comparing 

reporting costs associated with the Uniform Standards to the reporting cost under existing 

requirements (see Section 4.3). The following sections provide specific details regarding each 

model facility and the burden reduction and cost estimation methodology. 

4.1 Applicable Rules

After developing each model facility, the first step in estimating the cost savings

consisted of identifying all applicable existing federal regulations for each model. Overlap of 

existing applicable rules was considered. For example, 40 CFR 63.640(p) indicates that if an 

owner or operator is subject to both Subpart CC and an equipment leak rule in 40 CFR 60 and/or 
5

40 CFR 61, the owner or operator need only comply with Subpart CC. The details of overlapping 

existing rules are identified in the footnotes to Table 4 and Table 5 of this section. Wastewater 

regulations were not considered because, at the time of this analysis, the Uniform Standards did 

not include wastewater requirements.

4.1.1 Refinery

Table 4 lists the federal regulations applicable to the model refinery, organized by

emission type. Appendix A provides detail of each process unit and emission point and the 

corresponding regulation. 

Table 4. Applicable Regulations by Emission Type – Model Refinery

Emission Type Applicable Regulation

Process Vents 40 CFR Part 63, Subpart CC

40 CFR Part 63, Subpart UUU

Equipment Leaks

40 CFR Part 63, Subpart CC

40 CFR Part 61, Subpart V1

40 CFR Part 60, Subpart VV2

Transfer Operations

40 CFR Part 63, Subpart CC3

40 CFR Part 60, Subpart XX

40 CFR Part 63, Subpart Y

40 CFR Part 63, Subpart R

Storage Vessels

40 CFR Part 63, Subpart CC

40 CFR Part 63, Subpart G4

40 CFR Part 60, Subpart K

40 CFR Part 60, Subpart Ka

40 CFR Part 60, Subpart Kb

1 – 40 CFR Part 61, Subpart J points to 40 CFR Part 61, Subpart V.

2 – 40 CFR Part 60, Subpart GGG points to 40 CFR Part 60, Subpart VV.

3 – 40 CFR Part 63, Subpart CC indicates that if 40 CFR Part 60, Subpart XX 

applies, the model refinery must comply with 40 CFR Part 63, Subpart CC.

4 – 40 CFR Part 63, Subpart CC requires refineries comply with 40 CFR Part 63, 

Subpart G. 

4.1.2 Chemical Plant

Table 5 lists the federal regulations applicable to the model chemical plant, organized by

emission type. Appendix A provides detail of each process unit and emission point and the 

corresponding regulation.
6

Table 5. Applicable Regulations by Emission Type – Model Chemical Plant

Emission Type Applicable Regulation

Process Vents

40 CFR Part 60, Subpart NNN1

40 CFR Part 63, Subpart SS2

40 CFR Part 63, Subpart G

40 CFR Part 63, Subpart FFFF

Equipment Leaks

40 CFR Part 63, Subpart TT3

40 CFR Part 63, Subpart H4,5

40 CFR Part 63, Subpart I5

40 CFR Part 63, Subpart FFFF

Transfer Operations

40 CFR Part 63, Subpart G

40 CFR Part 63, Subpart FFFF

Storage Vessels

40 CFR Part 63, Subpart G

40 CFR Part 63, Subpart FFFF

40 CFR Part 63, Subpart SS

40 CFR Part 60, Subpart Kb

1 – The process tank vent is subject to 40 CFR Part 60, Subpart RRR; however, 

pursuant to 40 CFR 60.700(c)(5), the vent complies with 40 CFR Part 60, Subpart 

NNN.

2 – Pursuant to 40 CFR Part 63, Subpart YY, it was assumed that the TRE is below 

4.0 for two vent gas absorbers and the model facility must comply with 40 CFR 63, 

Subpart SS.

3 – Pursuant to 40 CFR Part 63, Subpart YY, it was assumed that the model 

chemical plant has chosen to comply with the requirements of 40 CFR 63, Subpart 

TT, instead of the requirements of 40 CFR 63, Subpart UU. 

4 – It was assumed that the model chemical plant has elected to comply with 40 

CFR Part 63, subpart H for all equipment in this process unit. Compliance with the 

provisions of 40 CFR 63, Subpart H, shall be deemed to constitute compliance with 

40 CFR part 60, subpart VV.

5 – Equipment in methylene chloride service located in a process producing 

polycarbonates are regulated under 40 CFR 63, Subpart H and I instead of 40 CFR 

63, Subpart YY.

4.2 Determination of Burden Under Existing Rules

After identifying all federal regulations applicable to the model facilities, supporting 

statements were collected from the EPA "Information Collection Request, Review, and Approval 

System" (ICRAS) system and rule making dockets. Supporting statements provide a detailed 

estimation of the respondent burden and costs as a result of demonstrating compliance through 

testing, monitoring, record keeping, and reporting with a particular regulation. Supporting 

statements generally provide burden estimates for the first three years in which affected sources 

must demonstrate compliance. 

Each supporting statement generally contains standardized respondent burden and cost 

algorithms. These algorithms identify each burden item (e.g., reading instructions for reporting 
7

requirements, conducting performance tests or equipment leak monitoring, creating a periodic 

report, maintain records, etc.) and an associated estimate of the hourly requirement for each 

occurrence of the burden item. The algorithm typically contains an estimate of the number of 

occurrences, per year, for each burden item, and the number of respondents per year. The 

algorithms generally multiply the hourly requirement per burden item by the number of 

occurrences per year, and by the number of respondents per year to obtain a technical personnel 

hourly requirement for all affected sources on an annual basis. Managerial and clerical hours are 

usually obtained by multiplying the annual technical hourly requirement by standardized factors. 

Managerial and clerical hours were assumed to be five and ten percent of the annual technical 

hourly requirement, respectively. The annual hourly requirements for each labor category (i.e., 

technical, managerial, and clerical) are multiplied by standardized labor rates to obtain an annual 

cost for all sources affected by the regulation. 

Although supporting statements are relatively consistent with regards to methodology, 

the accounting for the number of occurrences per respondent and respondents per year varies 

from rule to rule. For example, for certain regulations, the supporting statement algorithm may

estimate the hourly requirement for a particular emission point as equivalent for all affected 

sources (i.e., the number of respondents per year for a performance test for one supporting 

statement might be equal to the number of affected sources) whereas another supporting 

statement may account for each individual process vent at all affected sources when estimating 

the number of respondents per year. 

To develop an annual burden estimate for each model facility, supporting statements for 

all applicable regulations were carefully reviewed to identify how the number of occurrences per 

respondent and respondents per year were determined. The same determination processes were

then applied to each model facility to estimate the annual hourly burden for record keeping and 

reporting under existing rules. Additionally, any initial or “one-time” burden items were ignored 

since the model facilities were assumed to be existing sources and already in compliance with 

any initial or “one-time” burden items.

After determining annual hourly burdens for each model facility, the hourly requirements 

were multiplied by standardized labor rates to obtain annual record keeping and reporting costs. 

Labor rates were based on U.S. Department of Labor, Bureau of Labor Statistics labor rates 

(DOL, 2009). A fringe benefit loading rate of 1.5 and an overhead and profit rate of 1.4 were 
8

multiplied by each hourly rate to obtain loaded rates. Calculated hourly labor rates are presented 

in Table 6. 

Table 6. Summary of 2009 Hourly Labor Rates

Labor Class

(A) 

Mean hourly 

labor rate1

($/hr)

(B) 

Fringe 

benefit 

loading rate

(C) 

Overhead 

and profit 

rate

(D=AxBxC) 

Loaded 

wage rate 

($/hr)

Professional Specialty and

Technical (SOC Code: 17-2081) 39.53 1.5 1.4 83.01

Executive, Administrative and 

Managerial (SOC Code: 11-9041) 57.8 1.5 1.4 121.38

Administrative Support, Including 

Clerical (SOC Code: 43-0000) 17.31 1.5 1.4 36.35

Appendices B and C contain detailed analyses of each supporting statement algorithm 

along with any assumptions associated with each model facility burden estimates.

4.3 Determination of Uniform Standards Reporting Costs

In an effort to reduce the record keeping and reporting burden for industry and regulatory

agencies, the proposed Uniform Standards require some electronic reporting in lieu of more 

traditional hardcopy methods. In particular, reports proposed to be submitted electronically in the 

Uniform Standards include all performance test reports, CEMS performance evaluation reports, 

the 40 CFR part 65, subparts I and J portions of the notification of compliance status reports 

required by 40 CFR part 65, subparts I and J, and semiannual periodic reports specified in 40 

CFR part 65, subparts H, I, J, and M. All other reports would be submitted in hardcopy or other 

method mutually agreed to between the source and the delegated authority. The potential 

reporting cost savings associated with the proposed Uniform Standards (not considering initial 

electronic startup costs) were estimated for each model facility by comparing reporting costs 

associated with the Uniform Standards to the reporting costs estimated for existing regulations.

4.3.1 Determination of Initial Electronic Reporting Costs

Initial costs of electronic reporting were estimated for each facility by first estimating the 

number of data elements included in the initial setup for electronic reporting for the model 

facility. It was assumed that sources will need to enter information about their facility that will 

include general information about their processes, emission units subject to rules, and basic 

information about the rules that apply. For example, in addition to general identification 
9

information for the facility, the following data elements were expected to be required for the 

initial transfer operations setup: control type, the control equipment identification, the type of 

material transferred, the capacity of the transfer system, and the annual average of actual material

loaded. In addition, five miscellaneous data elements were also added to the count of data 

elements due to unknown requirements of the electronic reporting program. Since sources will 

have to report similar information under multiple rules, the number of applicable regulations was 

then added to the count of data elements. The number of applicable regulations was not 

multiplied by the data element count because sources are expected to be able to simply assign the 

data elements to multiple rules instead of completely re-entering each data element.

The total count of data elements (including the number of applicable regulations) for each 

emission source type was multiplied by the number of emission sources at each model facility. In 

the case of transfer operations at the model refinery, ten data elements were added to four 

applicable rules for a total of fourteen entries. The fourteen entries were then multiplied by two 

transfer operations (e.g., two transfer operations exist at the model refinery) for a total of twentyeight data entry elements for transfer operations at the model refinery. The total number of data 

entry elements for each emission source was then divided by a factor of twenty-five data 

elements entered per hour. This hourly requirement was regarded as the initial technical hourly 

requirement for electronic reporting. 

Using this methodology, the initial hourly requirements for electronic reporting startup 

were determined for each model facility and emission source type; these are presented in 

Appendix D. The managerial and clerical hours were obtained by using the same standardized 

factors described in section 4.2. Initial costs were obtained by multiplying the hourly

requirements by the hourly labor rates presented in Table 6 in section 4.2 and are presented in 

Appendix D.

4.3.2 Determination of Annual Electronic Reporting Costs

Annual costs of electronic reporting under the Uniform Standards were estimated in a 

fashion similar to the initial costs of electronic reporting. For simplicity, annual and semiannual 

reporting costs were first estimated as if all existing written reporting were converted to 

electronic reporting. All data elements that would be required to be reported on an annual or 

semiannual basis by the proposed Uniform Standards were identified and categorized as such. 

Then, using equipment counts and other information about the model facility, the number of data 
10

elements to be entered per year into the electronic reporting program was identified. The total 

number of data entry records to be entered into the electronic reporting program was divided by a 

factor of twenty-five data elements entered per hour. This hourly requirement was regarded as 

the annual technical hourly requirement for electronic reporting. Managerial and clerical hours, 

and the costs associated with those hourly requirements, were determined in the same manner as 

the initial costs. The cost associated with the additional requirement in the Uniform Standards to 

semiannually electronically report daily and operating block averages was computed by

assuming 1 hour per process vent to upload data entered twice a year. 

In order to get a total annual cost associated with electronic semiannual and written 

annual reports, the portion of costs associated with electronic annual reporting was converted to 

costs associated with written annual reporting using a ratio. The ratio was computed by dividing 

the costs associated with written reporting under existing rules by the sum of the Uniform 

Standards costs associated with semiannual periodic electronic reports and two times the costs 

associated with annual periodic electronic reports. The annual costs were multiplied by two 

because, under most existing rules, these reporting elements are required to be submitted 

semiannually. This ratio represents a conversion factor between electronic and written reporting 

burden. Finally, the potential reporting cost savings associated with the proposed Uniform 

Standards was determined by subtracting the total costs associated with electronic semiannual 

and written annual reports, from the total annual cost associated with written reporting under 

existing rules (see Section 4.2 for determination of burden under existing rules).

The annual electronic reporting cost analysis as described here is presented in 

Appendix D to this document.

5.0 REFERENCES

U.S. Department of Labor Bureau of Labor Statistics (DOL). 2009. Occupational employment 

statistics: May 2009 Employment wage estimates. <http://stats.bls.gov/oes/current/oessrci.htm>. 

November.

Stell, J. 2000. U.S. Refineries-State Capacities as of January 1, 2001. Oil & Gas Journal. 99:52. 

Information Collection Request (ICR) Supporting Statements:
11

a. The Consolidated Air Rule (CAR) for the Synthetic Organic Chemical Manufacturing 

Industry (SOCMI) (Renewal). 2010. EPA ICR Number 1854.07, OMB Control 

Number 2060-0443. 

b. National Emission Standards for Hazardous Air Pollutants for Gasoline Distribution 

Facilities (40 CFR Part 63, Subpart R) (Renewal). 2010. EPA ICR Number 1659.07, 

OMB Control Number 2060-0325. 

c. National Emission Standards for Hazardous Air Pollutants for Marine Tank Vessel 

Loading Operations (40 CFR Part 63, Subpart Y). 2010. EPA ICR Number 1679.08. 

d. National Emission Standards for Hazardous Air Pollutants for Petroleum Refineries 

(40 CFR Part 63, Subpart CC) (Renewal). 2009. EPA ICR Number 1692.06, OMB 

Control Number 2060-0340. 

e. National Emission Standards for Hazardous Air Pollutants for Source Categories: 

Generic Maximum Achievable Control Technology Standards (40 CFR part 63, 

subpart YY) (Renewal). 2009. EPA ICR Number 1871.05, OMB Control Number 

2060-0420. 

f. National Emission Standards for Hazardous Air Pollutants for Petroleum Refineries, 

Catalytic Cracking, Reforming and Sulfur Units (40 CFR Part 63, Subpart UUU) 

(Renewal). 2009. EPA ICR Number 1844.04, OMB Control Number 2060-0554. 

g. National Emission Standards for Hazardous Air Pollutants for Miscellaneous Organic 

Chemical Manufacturing (40 CFR part 63, subpart FFFF) (Renewal). 2010. EPA ICR 

Number 1969.04. 

h. New Source Performance Standards 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). 2010. EPA 

ICR Number 1797.05, OMB Control Number 2060-0442. 

i. New Source Performance Standards for Bulk Gasoline Terminals (40 CFR Part 60, 

Subpart XX) (Renewal). 2008. EPA ICR Number 0664.09, OMB Control Number 

2060-0006. 

j. New Source Performance Standards for Equipment Leaks of VOC in Petroleum 

Refineries (40 CFR Part 60, Subpart GGG and GGGa) (Renewal). 2011. EPA ICR 

Number 0983.12, OMB Control Number 2060-0067.
Appendix A:

Model Facility Descriptions:

Rule Applicability
A-1

Table A.1 Model Refinery – Rule Applicability Table for Process Vents, Equipment Leaks, and Transfer Operations

Process Description

Process Vent Equipment Leaks Transfer Operations

40 CFR Part 

63, Subpart 

CC 

Petroleum 

Refineries 

(process 

vents)[1]

40 CFR Part 63, 

Subpart UUU 

Catalytic 

Cracking Units, 

Catalytic 

Reforming Units, 

and Sulfur 

Recovery Units 

40 CFR Part 

63, Subpart 

CC 

Petroleum 

Refineries 

(equipment 

leaks)

40 CFR Part 

61 Subpart J 

points to

40 CFR Part 

61 Subpart V

Equipment 

Leaks 

(Fugitive 

Emission 

Sources)

40 CFR Part 

60, Subpart 

GGG points 

to

40 CFR Part 

60, Subpart 

VV

Equipment 

Leaks of VOC 

in the SOCMI

40 CFR Part 63, 

Subpart CC 

Petroleum 

Refineries 

(transfer 

operations)[2]

40 CFR 

Part 60, 

Subpart XX 

Bulk

Gasoline 

Terminals

40 CFR Part 

63, Subpart Y 

Marine Tank

Vessel 

Loading 

Operations

40 CFR Part 

63, Subpart R 

Gasoline 

Distribution 

Facilities

1 and 2 Pipe Stills x x

Sulfur Recovery Unit x

Alkylation Unit x x x

Isomerization Unit x x x

No.2 Treatment Plant x x

No.4 Treatment Plant x x

Storage and Loading 

Facilities x x

No.3 Ultraformer x x x x

No.4 Ultraformer x x x

Hydrogen Unit x x

Cat Feed Hydrotreating x x

Catalytic Refining x x x

Fluidized Catalytic Cracking x x x

Oil Movements x x x

Marketing Terminal x x x

Marine Dock Facility x x x x x

Vapor Recovery 1 x x

Vapor Recovery 2 x x x

TOTAL 4 4 16 3 16 2 1 1 1

[1] Alkylation Unit: off gas knock out drum (D-3) controlled by a flare (F-27); spent acid stripper drum (D-4) controlled by a flare (F-27); and spent caustic drum (D-5) controlled by a flare (F-27). 

Isomerization Unit: flare knock out drum (D-1) controlled by a flare (F-2). No.3 Ultraformer: flare gas separator (D-1) controlled by a flare (F-2). Vapor Recovery Unit 300: off-gas knock out drum (D2) controlled by a flare (F-3).

[2] Subpart CC says that if Subparts XX and/or QQQ apply, comply with Subpart CC.
A-2

Table A.2 Model Refinery – Rule Applicability Table for Storage Vessels

Storage Vessel Description Rule

Tank ID 

#

Year Installed Size Control 

Required? Control[1] Liquid Type Vapor Pressure

40 CFR 

Part 63, 

Subpart 

CC

40 CFR 

Part 63, 

Subpart G

40 CFR 

Part 60, 

Subpart K

40 CFR 

Part 60, 

Subpart Ka

40 CFR 

Part 60, 

Subpart Kb

3486 1979 4,026,505 Y EFR petroleum hydrocarbon <15 psia x x x

3511 1973 4,066,214 Y EFR petroleum hydrocarbon <15 psia x x x

3532 1953 868,306 Y EFR petroleum hydrocarbon <15 psia x x

3533 1953 4,235,640 Y EFR petroleum hydrocarbon <15 psia x x

3601 1977 3,702,020 Y EFR petroleum hydrocarbon <15 psia x x x

3909 1956 3,388,512 Y EFR petroleum hydrocarbon <15 psia x x

3915 1980 6,353,460 Y EFR petroleum hydrocarbon <15 psia x x x

3917 1980 25,413,839 Y EFR petroleum hydrocarbon <15 psia x x x

3534 1955/1973 71,000 Y EFR petroleum hydrocarbon <15 psia x

3537 1962/1974 56,000 Y EFR petroleum hydrocarbon <15 psia x

3605 1977 3,702,000 Y EFR petroleum hydrocarbon <15 psia x

3480 1982 4,026,505 Y IFR petroleum hydrocarbon <15 psia x

3487 1980 4,026,505 Y IFR petroleum hydrocarbon <15 psia x

3525 1981 4,026,505 Y IFR petroleum hydrocarbon <15 psia x

3526 1943/1979 4,026,505 Y IFR petroleum hydrocarbon <15 psia x

3553 1981 5,070,343 Y IFR petroleum hydrocarbon <15 psia x

3554 1981 5,070,343 Y IFR petroleum hydrocarbon <15 psia x

3602 1979 3,856,271 Y IFR petroleum hydrocarbon <15 psia x

3604 1980 3,856,271 Y IFR petroleum hydrocarbon <15 psia x

3702 1943/1982/1997 3,382,264 Y IFR petroleum hydrocarbon <15 psia x

3703 1944/1982 3,382,264 Y IFR petroleum hydrocarbon <15 psia x

3704 1944/1980 3,382,264 Y IFR petroleum hydrocarbon <15 psia x

3916 1980 13,666,998 Y EFR petroleum hydrocarbon <15 psia x

3918 1980 13,666,998 Y EFR petroleum hydrocarbon <15 psia x

3919 1980 13,666,998 Y EFR petroleum hydrocarbon <15 psia x
A-3

Table A.2 Model Refinery – Rule Applicability Table for Storage Vessels (Cont.)

Storage Vessel Description Rule

Tank ID # Year Installed Size Control 

Required? Control Liquid Type Vapor Pressure

40 CFR 

Part 63, 

Subpart 

CC

40 CFR 

Part 63, 

Subpart G

40 CFR 

Part 60, 

Subpart K

40 CFR 

Part 60, 

Subpart 

Ka

40 CFR 

Part 60, 

Subpart 

Kb

3920 1980 13,666,998 Y EFR petroleum hydrocarbon <15 psia x

3474 1992 3,734,422 Y EFR petroleum hydrocarbon <15 psia x

3475 1994 3,865,445 Y EFR petroleum hydrocarbon <15 psia x

3476 1984 3,085,016 Y EFR petroleum hydrocarbon <15 psia x

3484 1996 3,865,445 Y EFR petroleum hydrocarbon <15 psia x

3488 1994 3,865,445 Y EFR petroleum hydrocarbon <15 psia x

3489 1996 3,865,445 Y EFR petroleum hydrocarbon <15 psia x

3493 1995 3,865,445 Y EFR petroleum hydrocarbon <15 psia x

3514 1984 4,066,214 Y EFR petroleum hydrocarbon <15 psia x

3527 1991 3,382,264 Y EFR petroleum hydrocarbon <15 psia x

3528 1993 3,865,445 Y EFR petroleum hydrocarbon <15 psia x

3549 1993 588,283 Y EFR petroleum hydrocarbon <15 psia x

3558 1972/1986 376,501 Y EFR petroleum hydrocarbon <15 psia x

3600 1993 847,128 Y EFR petroleum hydrocarbon <15 psia x

3622 1993 3,865,445 Y EFR petroleum hydrocarbon <15 psia x

3629 1992 3,865,445 Y EFR petroleum hydrocarbon <15 psia x

3701 1943/1993 3,382,264 Y EFR petroleum hydrocarbon <15 psia x

3715 1945/1987/1998 3,382,264 Y EFR petroleum hydrocarbon <15 psia x

3716 1996 3,865,445 Y EFR petroleum hydrocarbon <15 psia x

3860 1993 211,782 Y EFR petroleum hydrocarbon <15 psia x

3904 1956/1986 3,388,512 Y EFR petroleum hydrocarbon <15 psia x

3907 1956/1996 3,388,512 Y EFR petroleum hydrocarbon <15 psia x

3911 1956/1986 3,388,512 Y EFR petroleum hydrocarbon <15 psia x

TOTAL 8 8 5 18 22

[1] EFR - External Floating Roof; IFR - Internal Floating Roof
A-4

Table A.3 Model Chemical Plant – Rule Applicability for Process Vents, Equipment Leaks, and Transfer Operations

Process Description

Process Vent Equipment Leaks Transfer Operations

40 CFR 

Part 60, 

Subpart 

NNN 

40 CFR 

Part 63 

Subpart 

SS

40 CFR 

Part 63 

Subpart 

G

40 CFR 

Part 63 

Subpart 

FFFF

40 CFR 

Part 63 

Subpart 

TT

40 CFR 

Part 63 

Subpart 

H

40 CFR 

Part 63 

Subpart 

I

40 CFR 

Part 63 

Subpart 

FFFF

40 CFR

Part 63 

Subpart 

G

40 CFR 

Part 63 

Subpart 

FFFF

Distillation (process with scrubber) x x

1

Process Tank Vent (routed to distillation) x

2

Detoxification Knockout Drum (with thermal catalytic control) x

3

Oxidate Vent Chiller Condenser x

1

Column Vent Chiller Condenser x

1

Air Oxidation Vent to Carbon Adsorbers x

1

Resin Vent Gas Absorber #1 x

4

Resin Vent Gas Absorber #2 x

4

Process Vent Controlled by Catalytic Oxidizer x

3

Vent Tank Condenser x

1

Stripper Vent Condenser x

1

Resin Reactor x

1

Process Vent with Hydrogen Halide and Halogen HAP x

3

Condenser Vent x

1

Equipment in the Phenol plant x

5

x

Equipment in methylene chloride service located in the Resin area x

6

x

6

Equipment in HAP service in Resin area x

7

Equipment that produces polymer x

Phenol Loading Operation x

8

Phenol Rail Car Loading x

8

Truck Loading Connection #1 x

8

Truck Loading Connection #2 x

8

Truck Loading Connection #3 x

8

Truck Loading Connection #4 x

8

Railcar Loading Arms x

8
A-5

Table A.3 Model Chemical Plant – Rule Applicability for Process Vents, Equipment Leaks, and Transfer Operations (Cont.)

Process Description

Process Vent Equipment Leaks Transfer Operations

40 CFR 

Part 60, 

Subpart 

NNN 

40 CFR 

Part 63 

Subpart 

SS

40 CFR 

Part 63 

Subpart 

G

40 CFR 

Part 63 

Subpart 

FFFF

40 CFR 

Part 63 

Subpart 

TT

40 CFR 

Part 63 

Subpart 

H

40 CFR 

Part 63 

Subpart I

40 CFR 

Part 63 

Subpart 

FFFF

40 CFR 

Part 63 

Subpart 

G

40 CFR 

Part 63 

Subpart 

FFFF

TOTAL 2 2 5 6 1 2 1 2 1 5

[1] - Group 2 process vent with recovery device.

[2] Process vent is subject to 40 CFR Part 60, Subpart RRR; however, pursuant to 40 CFR 60.700(c)(5), VOC emissions from the process tank vent, shall be considered in compliance with the 

provisions of Subpart RRR because the vent stream is routed to a distillation unit (C-1) subject to 40 CFR 60, Subpart NNN and has no other releases to the air except for a pressure relief valve.

[3] Group 1 process vent with control equipment.

[4] Process vent is subject to 40 CFR Part 63, Subpart YY; however, there are no applicable requirements (or standards) for process vents with TRE index values greater than 4.0. 

[5] Pursuant to 40 CFR 63.160(c), the chemical plant has elected to comply with 40 CFR Part 63, subpart H for all equipment in this process unit. All VOC’s in the phenol operations shall be considered, 

for purposes of applicability and compliance with 40 CFR Part 63, subpart H, as if it were organic hazardous air pollutant. Compliance with the provisions of 40 CFR 63, Subpart H, shall be deemed to 

constitute compliance with 40 CFR part 60, subpart VV.

[6] Pursuant to 40 CFR 63.190(b)(4), Subpart I, these components are regulated under 40 CFR 63, Subpart H and I instead of 40 CFR 63, Subpart YY.

[7] 40 CFR Part 63 Subpart YY points to 40 CFR Part 63 Subparts TT and UU. Pursuant to Table 5 of 40 CFR 63.1103(d), Subpart YY, the chemical plant has chosen to comply with the requirements 

of 40 CFR 63, Subpart TT, instead of the requirements of 40 CFR 63, Subpart UU. 

[8] Group 2 loading operation.
A-6

Table A.4 Model Chemical Plant – Rule Applicability for Storage Vessels

Storage Vessel Description Rule

Tank ID # Year Installed Size Control 40 CFR Part 63, 

Subpart G

40 CFR Part 63 

Subpart FFFF

40 CRF Part 63 

Subpart SS

40 CFR Part 60, 

Subpart Kb

Phenol Tank #1 after 1984 >=75m^3 IFR x

[1]

Phenol Tank #2 after 1984 >=75m^3 EFR x

[1]

Phenol Tank #3

x

[2]

Phenol Tank #4 x

[2]

Phenol Tank #5 x

[2]

Phenol Tank #6

x

[2]

Phenol Tank #7 x

[2]

Phenol Tank #8 x

[2]

Phenol Tank #9 IFR x

[1]

Phenol Tank #10 EFR x

[1]

Resin Tank #1 75<x<151m^3 x

[3]

Resin Tank #2 75<x<151m^3

x

[3]

Resin Tank #3 75<x<151m^3 x

[3]

Resin Tank #4 75<x<151m^3 x

[3]

Resin Tank #5 75<x<151m^3

x

[3]

Resin Tank #6 75<x<151m^3 x

[3]

Resin Tank #7 x

[2]

Resin Tank #8

x

[2]

Resin Tank #9 x

[2]

Resin Tank #10

x

[2]

TOTAL 8 4 6 2

[1] Group 1 Process Tank (control required)

[2] Group 2 Process Tank (control required)

[3] In order to comply with 40 CFR 63, Subpart YY, pursuant to the control requirements of 40 CFR 63, Subpart SS, this chemical plant reduces HAP emissions by 95 weight percent by routing 

emissions from these tanks to the polycarbonate production process where methylene chloride is recovered and recycled. No record keeping and reporting estimated for these tanks, since only initial 

records and reports are required.
Appendix B:

Burden Estimation and Supporting Statement Analysis – Model Refinery
B-1

Table B.1 Model Refinery - Summary of Potential Cost Savings Associated with 

Uniform Standard Electronic Semiannual Reporting

RULE (A) Recordkeeping (B) Reporting Under Existing 

Rules Via Paper Methods

(C) Reporting Under 

Proposed Uniform Standards 

with Electronic Elements 

Removed[1]

Part 63, Subpart CC $10,848 $18,357 $4,265

Part 60, Subpart K $834 $0 $0

Part 60, Subpart Ka $2,058 $742 $93

Part 60, Subpart Kb $12,331 $22,029 $0

Part 63, Subpart G $4,543 $8,010 $0

Part 60, Subpart VV $0 $0 $0

Part 61, Subpart V $0 $0 $0

Part 60, Subpart GGG $0 $0 $0

Part 63, Subpart R $17,152 $1,854 $0

Part 60, Subpart XX $0 $0 $0

Part 63, Subpart Y $116 $0 $0

Part 63, Subpart UUU $4,844 $1,854 $0

Total $52,726 $52,847 $4,358

(D) Initial Electronic Start-up Cost for Proposed Uniform Standards $5,333

(E) Cost of Semiannual Electronic Reporting for proposed Uniform Standards $4,992

(F) Cost of Annual Electronic Reporting for proposed Uniform Standards $1,502

(G) Written to Electronic Reporting Burden Ratio (G=B/(E+2F)) [2] 6.61

(H) Administrative Preparation for Electronic Data Entry – management of log in information, etc. $834

(I) Additional Reporting Requirement in Uniform Standards - Cost to semiannually report daily and operating block averages, required in §65.882(e).

[3] $1,298

(J) Proposed Uniform Standards Reporting Costs for Electronic Semiannual and Written Annual Reports (J=C+E+(F*G)+H+I) [4] $21,409

(K) Potential Reporting Cost Savings Not Considering Initial Electronic Startup Costs for Proposed Uniform Standards (K=B-J) $31,438

(L) Savings Percentage - Reporting Cost Basis (L=K/B*100) 59%

(M) Savings Percentage - Record Keeping and Reporting Cost Basis (M=K/(A+B)*100) 30%

[1] Certain reporting elements are not able to be transferred to the electronic cost such as reading and understanding the reporting requirements; therefore, costs for such items are retained.

[2] Burden for annual reports multiplied by two because these are required semiannually under most existing rules. This ratio provides a general conversion between burden for electronic and written 

reports.

[3] Assumes 1 hour per process vent to upload data (7 process vents) entered twice a year for semiannual reporting for a total of 14 technical hours. Managerial and clerical hours were assumed to be five 

and ten percent of the annual technical hourly requirement, respectively. Rates used are in Table 6 of memo.

[4] Annual reports are required in written format, therefore the burden associated with electronic annual reports was converted to burden for written reports (E*F).
B-2

Table B.2 Model Refinery – 40 CFR Part 63, Subpart CC Supporting Statement Analysis[1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the Model 

Refinery per 

year

Personhours for 

the Model 

Refinery 

per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

1. Applications N/A 0 0 0 0 0 0 0.0 

2. Survey and Studies N/A 0 0 0 0 0 0 0.0 

3. Acquisition, Installation, 

and Utilization of 

Technology and Systems

4. Reporting Requirements

A. Read instructions and 

planning

 Initial:

 i. General/applicability 20 1 20 0 0 0 0 0 0 0.0 

 ii. Storage vessels 20 1 20 0 0 0 0 0 0 0.0 

 iii. Process units –LDAR 20 1 20 0 0 0 0 0 0 0.0 

 iv. Process vents 20 1 20 0 0 0 0 0 0 0.0 

 Periodic:

 i. General/applicability 4 2 8 4 2 8 8 0.4 0.8 741.7 

 ii. Storage vessels 1 2 2 1 2 2 2 0.1 0.2 185.4 

 iii. Process units –LDAR 2 2 4 2 1 4 4 0.2 0.4 370.9 

 iv. Process vents 2 2 4 2 2 4 4 0.2 0.4 370.9 

B. Required activities

 Initial:

 i. General: applicability 10 1 10 0

[2] 0 0 0 0 0 0.0 

 ii. Storage vessels 88 0.9 79.2 0

[2] 0 0 0 0 0 0.0 

 iii. Process units –LDAR 8 1.1 88 0

[2] 0 0 0 0 0 0.0 

 iv. Process vents - initial 

performance test 11 0.2 22 0

[2] 0 0 0 0 0 0.0 
B-3

Table B.2 Model Refinery – 40 CFR Part 63, Subpart CC Supporting Statement Analysis(Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the Model 

Refinery per 

year

Personhours for 

the Model 

Refinery 

per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

 v. Process vents -repeat 

performance test 11 0.1 11 0

[3] 0 0 0 0 0 0.0 

Periodic

 i. General/applicability 3 2 6 3 2 6 6 0.3 0.6 556.3 

 ii. Storage vessels 4 9 36 0

[4] 0 0 0 0 0 0.0 

 iii. Process units –LDAR 1

[5] 16 16 16 0.8 1.6 1,483.4 

 iv. Process vents 2 24 48 2 3

[6] 6 6 0.3 0.6 556.3 

C. Create information See 4B

D. Gather existing information See 4B

E. Write report 

Startup, shutdown and 

malfunction plan 40 1 40 0 0 0 0 0 0 0.0 

Notification of compliance 

status 

 i. Storage vessels 1 0.9 0.9 0

[2]

0 0 0 0 0 0.0 

 ii. Process units –LDAR 4 1.1 4.4 0

[2]

0 0 0 0 0 0.0 

 iii. Process vents 1 0.9 0.9 0

[2]

0 0 0 0 0 0.0 

Notification of storage 

vessel inspection 1 0.9 0.9 0

[2]

0 0 0 0 0 0.0 

Notification of 

reconstruction-process vent 

control device 

4 0.4 1.6 0

[2]

0 0 0 0 0 0.0 

Notification of performance 

test See 4B

Startup, shutdown and 

malfunction reports NA

Semiannual compliance reports: 

reports:
B-4

Table B.2 Model Refinery – 40 CFR Part 63, Subpart CC Supporting Statement Analysis (Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the Model 

Refinery per 

year

Personhours for 

the Model 

Refinery 

per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

 i. General 18 2 36 18 2 36 36 1.8 3.6 3,337.7 

 ii. Storage vessels 1 18 18 1

[7]

8

[8]

8 8 0.4 0.8 741.7 

 iii. Storage vessels seal gap 

failure 3 2 6 3

[7]

0.9[8,9]3 3 0.15 0.3 278.1 

 iv. Process units –LDAR 3 22 66 3 32 96 96 4.8 9.6 8,900.5 

 v. Process vents 1.5 4 6 1.5 6

[10]

9 9 0.45 0.9 834.4 

5. Recordkeeping Requirements

A. Read instructions See 4A

B. Plan activities See 4A

C. Implement activities See 4B

D. Develop record system N A

 Initial:

 i. Storage vessels 2 0.9 1.8 0

[2] 0 0 0 0 0 0

 ii. Process units –LDAR 75 1.1 82.5 0

[2] 0 0 0 0 0 0

 iii. Process vents 2 0.9 1.8 0

[2] 0 0 0 0 0 0

 Periodic

 i. Storage vessels 2 18 36 0

[2] 0 0 0 0 0 0.0 

 ii. Process units –LDAR 0

[2] 0 0 0 0 0 0.0 

 iii. Process vents 2 9 18 0

[2] 0 0 0 0 0 0.0 

E. Time to enter information 

and transmit it

 Initial:

 i. Storage vessels 6 0.9 3.6 0

[2] 0 0 0 0 0 0

 ii. Process units –LDAR 99 1.1 108 0

[2] 0 0 0 0 0 0
B-5

Table B.2 Model Refinery – 40 CFR Part 63, Subpart CC Supporting Statement Analysis (Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the Model 

Refinery per 

year

Personhours for 

the Model 

Refinery 

per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

 iii. Process vents 12 0.2 24 0

[2] 0 0 0 0 0 0

 Periodic

 i. Storage vessels 3.5 18 63 0

[4] 16 0 0 0 0 0.0 

 ii. Process units –LDAR 99 11 1,089 1

[5,11]

16 16 16 0.8 1.6 1,483.4 

 iii. Process vents 15 4 60 15 6

[10]

90 90 4.5 9 8,344.3 

F. Time to train personnel

 Initial: 

 i. Storage vessels 1 0.9 0.9 0

[2] 0 0 0 0 0 0

 ii. Process units –LDAR 0

[2] 0 0 0 0 0 0

 iii. Process vents 1 0.4 0.4 0

[2] 0 0 0 0 0 0

 Periodic

 i. Storage vessels NA

 ii. Process units –LDAR 0.5[5] 16 8 8 0.4 0.8 741.7 

 iii. Process vents 1 4 4 1 3 3 3 0.15 0.3 278.1 

TOTAL with Paper Reporting Paper (Sum of Items 1 through 4) 18,357

TOTAL with Electronic Reporting (Sum of Periodic Items under 4.A and 4.B) 4,265

TOTAL Record Keeping (Sum of Periodic Items under 5.D, 5.E, and 5.F) 10,848

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] For the purposes of the Model Plant burden estimate, we are excluding the cost of reporting associated with construction and reconstruction of existing plants. The SFI estimated that 10% of existing facilities would be 

affected by this reporting burden.

[3] For the purposes of the Model Plant burden estimate, we are excluding the cost of repeating performance tests. 

[4] Required activities reporting burden is accounted for in the HON - Subpart G and has been set equal to zero in the Subpart CC analysis. 

[5] The LDAR burden is reflected here, in the Subpart CC burden. The Subpart VV burden estimate has been set equal to zero for LDAR to avoid double counting. 

[6] Assumed three process vents - the number of Subpart CC applicable miscellaneous process vents - note that the isomerization unit and the No. 3 Ultraformer share a common process vent control device. 
B-6

Table B.2 Model Refinery – 40 CFR Part 63, Subpart CC Supporting Statement Analysis (Cont.) [1]

[7] The HON storage burden estimate for the model refinery was done using a table modeled from the subpart Kb Burden table (B-6). Because Subpart Kb does not require semiannual reporting, the semiannual reporting 

requirements have been maintained in the Subpart CC analysis.

[8] Number of occurrences have been reduced by half since the HON accounts for half of the burden through annual reporting. The HON ICR analysis used annual reporting instead of semiannual because it directly copied the 

methodology in the 40 CFR Part 60, Subpart Kb ICR, which only requires reports of the gap measurement results once per year.

[9] Assumed the same non-compliance rate (1/9) as the original Subpart CC SFI. 

[10] Semiannual reports for three control devices. 

[11] Typo in the Subpart CC ICR Table. Footnote in original table clarifies the correct number is 77; changed to 1 hour because Method 21 testing is counted in cost impacts and 1 hour per process unit should be adequate time 

to transmit the data from the analyzer to a computer.
B-7

Table B.3 Model Refinery – 40 CFR Part 60, Subpart K Supporting Statement Analysis[1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Personhours per 

occurrence 

for SFI 

(from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

occurrence 

applicable 

to Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Personhours for 

the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

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

D. Gather Existing Information Included in 4E

E. Write report

 i. Notification of 

reconstruction/modification 4 1 4 0 0 0 0 0 0 0

5. Recordkeeping Requirements

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 1 3 3 3 0.15 0.3 278.14
B-8

Table B.3 Model Refinery – 40 CFR Part 60, Subpart K Supporting Statement Analysis (Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Personhours per 

occurrence 

for SFI 

(from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

occurrence 

applicable 

to Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Personhours for 

the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

 ii. Record petroleum liquid 

stored 0.5 1 0.5 0.5 3 1.5 1.5 0.075 0.15 139.07

 iii. Record of storage 

performance tests 0.5 1 0.5 0.5 3 1.5 1.5 0.075 0.15 139.07

 iv. Record true vapor pressure 

of liquid stored 1 1 1 1 3 3 3 0.15 0.3 278.14

F. Time to train personnel N/A

G. Time for audits N/A

TOTAL with Paper Reporting Paper 0

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of Items under 5.E) 834

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 
B-9

Table B.4 Model Refinery – 40 CFR Part 60, Subpart Ka Supporting Statement Analysis[1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences per 

respondent per 

year (from 

supporting 

statement)

Person-hours 

per occurrence 

applicable to 

Model Refinery

No. of 

occurrences for 

the Model 

Refinery per 

year

Person-hours 

for the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read Instruction Included in 3B.

B. Required Activities

Vapor recovery information 20 1 20 0

[2] 0 0 0 0 0

Measure seal gap Included in 4E.

C. Create Information Included in 3B.

D. Gather Existing Information 1 1 1 1 1 1 0.05 0.1 92.71

E. Write Report

Notification of construction 2 1 0 0 0 0 0 0 0

Notification of actual startup 2 1 0 0 0 0 0 0 0

Notification of gap 

measurement 1.5 1 1.5 4

[3] 6 6 0.3 0.6 556.28

Report of seal gap excess 2.5 0.03 2.5 0.4[4] 1 1 0.05 0.1 92.71

Information on vapor recovery Included in 3B.

4. Recordkeeping Requirements

A. Read Instructions Included in 3B.

B. Plan Activities Included in 3B

C. Implement Activities Included in 3B

D. Develop Record N/A

E. Time to Enter

New tank seal gap measurements 250 1 0 0 0 0 0 0 0

Secondary seal gap 250[5] 1 5 4 20 20 1 2 1,854.28
B-10

Table B.4 Model Refinery – 40 CFR Part 60, Subpart Ka Supporting Statement Analysis (Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences per 

respondent per 

year (from 

supporting 

statement)

Person-hours 

per occurrence 

applicable to 

Model Refinery

No. of 

occurrences for 

the Model 

Refinery per 

year

Person-hours 

for the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

Primary seal gap measurements 20[5] 0.2 2 0.8[3] 1.6 1.6 0.08 0.16 148.34

Fill/refill record 2

[6]

1 0.2 3 0.6 0.6 0.03 0.06 55.63

TOTAL with Paper Reporting Paper (Sum 3.B, 3.C, 3.D, 3.E) 742

TOTAL with Electronic Reporting (Item 3.D) 93

TOTAL Record Keeping (Sum of Items under 4.E) 2,058

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Vapor recovery is not used on any storage tanks in the model refinery.

[3] The seal gap measurements apply only to the 4 external floating roofs (EFRs); therefore, 4 occurrences per year for the annual requirement and 0.8 for the 5 year requirement. 

[4] Assumed the same non-compliance rate (1/9) as in the Subpart CC supporting statement.

[5] The 250 hours in the SFI is 5 hours per tank and 50 tanks per facility. The 20 hours in the SFT represents 2 hours per tank for 20% of the tanks at the facility (50 tanks) for a total of 20 hours. The 5 and 2 hour/tank burden 

estimates were used for the model refinery estimate.

[6] The SFI used an estimate of 0.2 hours per tank for the fill or refill record, or a total of 2 hours for 20% of the tanks. The model refinery has a total of 15 tanks subject to subpart Ka or 3 tanks requiring fill/refill records.
B-11

Table B.5 Model Refinery – 40 CFR Part 60, Subpart Kb Supporting Statement Analysis[1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Person-hours 

for the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Manageria

l Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read Instruction 1 1 0 0 0 0 0 0 0

B. Required Activities 

One-Time Only Requirements 2 1 0 0 0 0 0 0 0

Notification of Start of Construction

Notification of Actual Startup 2 1 0 0 0 0 0 0 0

Notification of Physical or Operational 

Changes N/A

Notification of Malfunction N/A

Notification of Initial 

Inspection

IFR Internal Inspection 2 1 0 0 0 0 0 0 0

EFR Gap Measurement 2 1 0 0 0 0 0 0 0

 Initial Inspection Report

IFR Internal Inspection Report 12 1 0 0 0 0 0 0 0

EFR 2nd Seal Gap Measurement 8 1 0 0 0 0 0 0 0

EFR 1st Seal Gap Measurement 12 1 0 0 0 0 0 0 0

CVS Operating Plan Report 8 1 0 0 0 0 0 0 0
B-12

Table B.5 Model Refinery – 40 CFR Part 60, Subpart Kb Supporting Statement Analysis (Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Person-hours 

for the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

Repeat Requirements

Internal IFR Inspection 12 1 12 0 0 0 0 0 0

Visual IFR Inspection 8 1 8 0 0 0 0 0 0

Report of IFR Failure 2 1 2 0

[2] 0 0 0 0 0

Notification of Delay of Repair or 

Emptying for IFR 4 1 4 0

[2]

0 0 0 0 0

EFR 2nd Seal Gap Measure Report 8 1 8 22[3]176 176 8.8 17.6 16,317.66

EFR 1st Seal Gap Measure Report 12 1 12 4.4[4]52.8 52.8 2.64 5.28 4,895.30

Notification of Refill 2 1 2 4.4[4]8.8 8.8 0.44 0.88 815.88

 Number of Responses 

4.RECORDKEEPING REQUIREMENTS

A.. Read Instructions 1 1 1 1 1 1 0.05 0.1 92.71

B. Gather and Record Information 

i. Vessel Volumes, Liquid Vapor Pressure, 

flares 8 1 8 0 0 0 0 0 0

ii. 113b(a) inspection 12 1 12 0 0 0 0 0 0

iii. 113b(b) gap measurement for Secondary 

Seal 12 1 5 22[2]

110 110 5.5 11 10,198.54

iii. 113b(b) gap measurement for Primary 

Seal 5 4.4[4]

22 22 1.1 2.2 2,039.71

C. Develop Record System 10 1 0 0 0

D. Time to Enter Information - CVS Parameter 

Records 2 52 2 0

[5]

0 0 0 0 0
B-13

Table B.5 Model Refinery – 40 CFR Part 60, Subpart Kb Supporting Statement Analysis (Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Person-hours 

for the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

F. Train Personnel N/A

G. Audits N/A

TOTAL with Paper Reporting Paper (Sum of Items 1 through 3) 22,029

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of Items under 4.A and 4.B) 12,331

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] The model refinery does not have any IFR tanks subject to subpart Kb.

[3] 22 external floating roof (EFR) tanks subject to Part 60, Subpart Kb. The SFI assumed 12 hours for an average of 2.5 EFR tanks, or about 5 hours per EFR.

[4] This measurement occurs only once every 5 years, so the number should be 1/5 of the number of occurrences for the secondary seal measurements. 

[5] Requirement is for closed vent system and control device. Model refinery does not use closed vent system and control to comply with subpart Kb.
B-14

Table B.6 Model Refinery – 40 CFR Part 60, Subpart G Supporting Statement Analysis [1,2]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

occurrence 

applicable 

to Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Personhours for the 

Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read Instruction 1 1 0 0 0 0 0 0 0

B. Required Activities 

One-Time Only Requirements 2 1 0 0 0 0 0 0 0

Notification of Start of Construction

Notification of Actual Startup 2 1 0 0 0 0 0 0 0

Notification of Physical or Operational Changes N/A

Notification of Malfunction N/A

Notification of Initial Inspection

IFR Internal Inspection 2 1 0 0 0 0 0 0 0

EFR Gap Measurement 2 1 0 0 0 0 0 0 0

 Initial Inspection Report

IFR Internal Inspection Report 12 1 0 0 0 0 0 0 0

EFR 2nd Seal Gap Measurement 8 1 0 0 0 0 0 0 0

EFR 1st Seal Gap Measurement 12 1 0 0 0 0 0 0 0

CVS Operating Plan Report 8 1 0 0 0 0 0 0 0

Repeat Requirements

Internal IFR Inspection 12 1 12 0 0 0 0 0 0

Visual IFR Inspection 8 1 8 0 0 0 0 0 0

Report of IFR Failure 2 1 2 0

[3] 0 0 0 0 0
B-15

Table B.6 Model Refinery – 40 CFR Part 60, Subpart G Supporting Statement Analysis (Cont.) [1,2]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

occurrence 

applicable 

to Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Personhours for the 

Model

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

Notification of Delay of Repair or Emptying for 

IFR 4 1 4 0

[3]

0 0 0 0 0

EFR 2nd Seal Gap Measure Report 8 1 8 8

[4]

64 64 3.2 6.4 5,933.70

EFR 1st Seal Gap Measure Report 12 1 12 1.6[4]19.2 19.2 0.96 1.92 1,780.11

Notification of Refill 2 1 2 1.6[4]3.2 3.2 0.16 0.32 296.68

 Number of Responses 

4.RECORDKEEPING REQUIREMENTS

A.. Read Instructions 1 1 1 1 1 1 0.05 0.1 92.71

B. Gather and Record Information 

i. Vessel Volumes, Liquid Vapor Pressure, flares 8 1 8 0 0 0 0 0 0

ii. 113b(a) inspection 12 1 12 0 0 0 0 0 0

iii. 113b(b) gap measurement for Secondary Seal 12 1 5 8

[4]

40 40 2 4 3,708.56

iii. 113b(b) gap measurement for Primary Seal 5 1.6[4]8 8 0.4 0.8 741.71

C. Develop Record System 10 1 0 0 0 0 0 0 0

D. Time to Enter Information - CVS Parameter Records 2 52 2 0 0 0 0 0 0

F. Train Personnel N/A

G. Audits N/A

TOTAL with Paper Reporting Paper (Sum of Items 1 through 3) 8,010

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of Items under 4.A and 4.B) 4,543

[1] Original Subpart G supporting statement was unavailable for the analysis; therefore, Subpart Kb was used to estimate the burden under Subpart G.

[2] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[3] The model refinery has no IFR tanks subject to subpart G or CC.

[4] 8 EFR's are subject to Subpart CC/Subpart G - one gap measurement per year equates to 8 occurrences; one measurement every 5 years equates to 1.6 occurrences.
B-16

Table B.7 Model Refinery – 40 CFR Part 60, Subpart VV Supporting Statement Analysis [1,2]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery 

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Personhours for 

the Model 

Refinery 

per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

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

B. Required Activities 48 1 0 0 0 0 0 0 0 

Initial Performance Test Report

Repeat Performance Test Report 48 1 0 0 0 0 0 0 0 

C. Create Information Included in 3B

D. Gather Existing Information Included in 3E

E. Write Report 2 1 0 0 0 0 0 0 0 

New Sources

Notification of Construction 

Notification of Reconstruction/ 

Modification 2 1 0 0 0 0 0 0 0 

Notification of Actual Startup 2 1 0 0 0 0 0 0 0 

Notification of Initial/Repeat 

Performance Test 2 1 0 0 0 0 0 0 0 

Existing Sources Semiannual 

Report 4 2 0 0 0 0 0 0 0 

4. Recordkeeping Requirements

A. Read Instructions Included in 3A

B. Plan Activities Included in 4C

C. Implement Activities Included in 3B

D. Develop Record System N/A

E. Time to Enter Information

Records of Operating Parameters 80 1 0 0 0 0 0 0 0 
B-17

Table B.7 Model Refinery – 40 CFR Part 60, Subpart VV Supporting Statement Analysis (Cont.) [1,2]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery 

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Personhours for 

the Model 

Refinery 

per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

F. Train personnel N/A

G. Audits N/A

TOTAL with Paper Reporting Paper 0 

TOTAL with Electronic Reporting 0 

TOTAL Record Keeping 0 

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] All record keeping and reporting burden for Subpart VV is accounted for under Subpart CC.
B-18

Table B.8 Model Refinery – 40 CFR Part 61, Subpart V Supporting Statement Analysis [1,2]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours per 

occurrence for SFI (from 

supporting statement)

No. of occurrences per 

respondent per year 

(from supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery 

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Personhours for the 

Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

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

B. Required Activities 20 1 0 0 0 0 0 0 0

Initial Performance Test

Reference Method 21/22 Tests 4 1 0 0 0 0 0 0 0

Repeat Performance Test 20 0.2 0 0 0 0 0 0 0

C. Create Information See 3B

D. Gather Existing 

Information See 3B

E. Write Report 2 1 0 0 0 0 0 0 0

Notification of Construction/

Reconstruction

Notification of Anticipated 

Startup 2 1 0 0 0 0 0 0 0

Notification of Actual Startup 2 1 0 0 0 0 0 0 0

Notification of Initial 

Performance Test 2 1 0 0 0 0 0 0 0

Report of Performance Test See 3B

Application for Alternative 10 1

Initial Report 8 1 0 0 0 0 0 0 0

 Semiannual Report 30 2 0 0 0 0 0 0 0

4. Recordkeeping 

Requirements

A. Read Instructions See 3A

B. Plan Activities See 4C

C. Implement Activities See 3B
B-19

Table B.8 Model Refinery – 40 CFR Part 61, Subpart V Supporting Statement Analysis (Cont.) [1,2]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours per 

occurrence for SFI (from 

supporting statement)

No. of occurrences per 

respondent per year 

(from supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery 

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Personhours for the 

Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

D. Develop Record System N/A

E. Time to Enter Information 1.5 1 0 0 0 0 0 0 0

Records of startups, shutdown, 

malfunction, etc.

Records of operating, 

parameters and emissions 0.1 365 0 0 0 0 0 0 0

Records of leak detected 0.4 52 0 0 0 0 0 0 0

F. Train personnel N/A

G. Audits N/A

TOTAL with Paper Reporting Paper 0

TOTAL with Electronic Reporting 0

TOTAL Record Keeping 0

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Pursuant to Subpart CC, since the model refinery is subject to CC and an Equipment Leak rule in Part 60 or Part 61, the facility only complies with Subpart CC. All model process units subject to Subpart V are also subject to 

Subpart CC; therefore, the values for the Subpart V analysis are zero.
B-20

Table B.9 Model Refinery – 40 CFR Part 61, Subpart GGG Supporting Statement Analysis [1,2]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences per 

respondent per 

year (from 

supporting 

statement)

Person-hours per 

respondent per 

year (from 

supporting 

statement)

Personhours per 

occurrence 

applicable to 

Model 

Refinery 

No. of 

occurrences 

for the Model 

Refinery per 

year

Personhours for 

the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

1. APPLICATIONS (Not 

Applicable)

2. SURVEY AND STUDIES 

(Not Applicable)

3. REPORT 

REQUIREMENTS

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

B. Required Activities

Initial performance test 24 1 24 0 0 0 0 0 0 0

Repeat performance test 24 1 24 0 0 0 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 0 0

Notification of anticipated 

startup 2 1 2 0 0 0 0 0 0 0

Notification of actual startup 2 1 2 0 0 0 0 0 0 0

Notification of initial 

performance test 2 1 2 0 0 0 0 0 0 0

Report of performance test 

(Included in 3B)

Semiannual work practice 

reports 8 2 16 0 0 0 0 0 0 0

Subtotal for Reports

4. RECORDKEEPING 

REQUIREMENTS
B-21

Table B.9 Model Refinery – 40 CFR Part 61, Subpart GGG Supporting Statement Analysis (Cont.) [1,2]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences per 

respondent per 

year (from 

supporting 

statement)

Person-hours per 

respondent per 

year (from 

supporting 

statement)

Personhours per 

occurrence 

applicable to 

Model 

Refinery 

No. of 

occurrences 

for the Model 

Refinery per 

year

Personhours for 

the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

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 0.3 365 109.5 0 0 0 0 0 0 0

F. Train Personnel (Not 

Applicable)

G. Audits (Not Applicable)

Subtotal for Recordkeeping

5. Total Annual Labor Hours 

and Cost (rounded)

TOTAL with Paper Reporting Paper 0

TOTAL with Electronic Reporting 0

TOTAL Record Keeping 0

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Burden analysis for Subpart GGG is zero since units at the model refinery are also subject to Subpart VV and are complying with Subpart GGG by complying with Subpart VV. Burden is 

accounted for in Subpart VV. 
B-22

Table B.10 Model Refinery – 40 CFR Part 61, Subpart GGGa Supporting Statement Analysis [1,2]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

respondent 

per year (from 

supporting 

statement)

Personhours per 

occurrence 

applicable 

to Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Person-hours 

for the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

1. APPLICATIONS (Not 

Applicable)

2. SURVEY AND STUDIES 

(Not Applicable)

3. REPORT 

REQUIREMENTS

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

B. Required Activities 0 0 0 0

Initial performance test 24 1 24 0 0 0 0 0 0 0

Repeat performance test 24 1 24 0 0 0 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 0 0

Notification of anticipated 

startup 2 1 2 0 0 0 0 0 0 0

Notification of actual startup 2 1 2 0 0 0 0 0 0 0

Notification of initial 

performance test 2 1 2 0 0 0 0 0 0 0

Report of performance test 

(Included in 3B)

Semiannual work practice 

reports 8 2 16 0 0 0 0 0 0 0

Subtotal for Reports

4. RECORDKEEPING 

REQUIREMENTS
B-23

Table B.10 Model Refinery – 40 CFR Part 61, Subpart GGGa Supporting Statement Analysis (Cont.) [1,2]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

respondent 

per year (from 

supporting 

statement)

Personhours per 

occurrence 

applicable 

to Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Person-hours 

for the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

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 refineries 0.4 365 148 0 0 0 0 0 0 0

Records of operating 

parameters for small refineries 0.42 365 153 0 0 0 0 0 0 0

F. Train Personnel (Not 

Applicable)

G. Audits (Not Applicable)

Subtotal for Recordkeeping

5. Total Annual Labor Hours 

and Cost (rounded)

TOTAL with Paper Reporting Paper 0

TOTAL with Electronic Reporting 0

TOTAL Record Keeping 0

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Burden analysis for Subpart GGG is zero since units at the model refinery are also subject to Subpart VV and are complying with Subpart GGG by complying with Subpart VV. Burden is 

accounted for in Subpart VV. 
B-24

Table B.11 Model Refinery – 40 CFR Part 63, Subpart R Supporting Statement Analysis [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences per 

respondent per 

year (from 

supporting 

statement)

Person-hours per 

respondent per 

year (from 

supporting 

statement)

Personhours per 

occurrence 

applicable 

to Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery 

per year

Personhours 

for the 

Model 

Refinery 

per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

1. APPLICATIONS N/A N/A N/A

2. SURVEY AND STUDIES N/A N/A N/A

3. ACQUISITION, INSTALLATION, AND 

UTILIZATION OF TECHNOLOGY AND 

SYSTEMS

4. REPORTING REQUIREMENTS

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

B. Required Activities

Initial performance test 175 1 175 0 0 0 0 0 0 0

Repeat of performance test 175 1 175 0 0 0 0 0 0 0

Storage tank seal/seal gap inspections tanks 

certification 16 1 16 0 0 0 0 0 0 0

Annual testing certification of area source 

compliance status 1 1 1 0 0 0 0 0 0 0

C. Create Information ------------------------Included in 4B----------------------------

D. Gather Existing Information ------------------------Included in 4B----------------------------

E. Write Report

Notification of applicability 3 1 3 0 0 0 0 0 0 0

Notification of 

construction/reconstruction/modification 2 1 2 0 0 0 0 0 0 0

Notification of actual startup 2 1 2 0 0 0 0 0 0 0

Notification of performance test 2 1 2 0 0 0 0 0 0 0

Notification of CEMS performance 

evaluation 2 1 2 0 0 0 0 0 0 0

Notification of area source compliance status 1 1 1 0 0 0 0 0 0 0

Report of performance test ------------------------Included in 4B----------------------------
B-25

Table B.11 Model Refinery – 40 CFR Part 63, Subpart R Supporting Statement Analysis (Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences per 

respondent per 

year (from 

supporting 

statement)

Person-hours 

per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrence

s for the 

Model 

Refinery 

per year

Personhours for 

the Model 

Refinery 

per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

Semiannual compliance reports bulk terminals 

major sources 10 2 20 10 2 20 20 1 2 1,854.28

Semiannual compliance reports pipeline 

breakout major sources 8 2 16 0

[2] 0 0 0 0 0 0

5. RECORDKEEPING REQUIREMENTS

A. Read Instructions ------------------------Included in 4A------------------------

B. Plan Activities ------------------------Included in 4B and 5C---------------

C. Implement Activities

Gasoline terminals:

File cargo tank inspection records 0.5 26 13 0.50 26 13 13 0.65 1.3 1,205.28

Update cargo tank inspection records 6 1 6 6 1 6 6 0.3 0.6 556.28

Cross-check cargo tank inspection file 6 26 156 6 26 156 156 7.8 15.6 14,463.38

Pipeline breakout stations ------------------------Included in 4B------------------------

D. Develop Record System 8 1 8 0 0 0 0 0 0 0

E. Time to Enter Information 

Record equipment subject to visual inspection 

requirements at pipeline breakout stations 1 1 1 0

[2] 0 0 0 0 0 0

Record equipment leaks data at bulk terminals 0.1 4 0.4 0

[3] 0 0 0 0 0 0

Record equipment leaks data at pipeline 

breakout stations 0.1 12 1.2 0

[2] 0 0 0 0 0 0

Record storage tank seal inspection results 1 1 1 0

[4] 0 0 0 0 0 0

Records of startups, shutdowns, malfunctions, 

etc. 1 4 4 1 4 4 4 0.2 0.4 370.86

Area source recordkeeping: 0.25 1.0 0.25 0 0 0 0 0 0 0

F. Time to train personnel 1 1 1 0 0 0 0 0 0 0
B-26

Table B.11 Model Refinery – 40 CFR Part 63, Subpart R Supporting Statement Analysis (Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence for 

SFI (from 

supporting 

statement)

No. of 

occurrences per 

respondent per 

year (from 

supporting 

statement)

Person-hours 

per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrence

s for the 

Model 

Refinery 

per year

Personhours for 

the Model 

Refinery 

per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

G. Time to adjust existing ways to comply 

with previously applicable requirements N/A N/A N/A

H. Time to transmit information ------------------------Included in 5E-------------------------

I. Time for audits: N/A N/A N/A

Bulk gasoline terminals 6 1 6 6 1 6 6 0.3 0.6 556.28

Pipeline breakout stations 4 1 4 0

[2] 0 0 0 0 0 0

TOTAL with Paper Reporting Paper (Semiannual Compliance Reports) 1,854

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of All Items under 5) 17,152

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Model refinery does not include a pipeline breakout station. 

[3] Model refinery is not required to comply with equipment leak requirements under Subpart R. 

[4] Model refinery is not required to comply with storage vessel requirements under Subpart R. 
B-27

Table B.12 Model Refinery – 40 CFR Part 60, Subpart XX Supporting Statement Analysis [1,2]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours per 

occurrence for SFI 

(from supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Person-hours 

for the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting requirements

 A. Read instructions 1 1 1 0 0 0 0 0 0 0

 B. Required activities

 Initial performance tests 60 1 60 0 0 0 0 0 0 0

 Repeat performance tests 60 0.2 12 0 0 0 0 0 0 0

 Monitoring of operations 

and equipment e See 4E

 C. Gather existing 

information See 3B and 4E

 D. Write Report

 Notification of 

compliance status 2 1 2 0 0 0 0 0 0 0

 Notification of actual 

startup 2 1 2 0 0 0 0 0 0 0

 Notification of 

construction/modification 2 1 2 0 0 0 0 0 0 0

 Notification of 

performance test 2 1 2 0 0 0 0 0 0 0

 Reports of performance 

test results See 3B

 Operation and 

maintenance reports N/A

 Semiannual reports N/A

Subtotal for Reporting 

Requirements

4. Recordkeeping 

requirements

 A. Read instructions See 3A

 B. Plan activities See 3B

 C. Implement Activities See 3B
B-28

Table B.12 Model Refinery – 40 CFR Part 60, Subpart XX Supporting Statement Analysis (Cont.) [1,2]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours per 

occurrence for SFI 

(from supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Person-hours 

for the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

 D. Develop record system N/A

E. Time to enter and 

transmit information

Records of startup, 

shutdown, malfunction 1.5 50 75 1.5 0 0 0 0 0 0

Record of tank 

identification numbers 0.1 2,100 210 0.1 0 0 0 0 0 0

Leak detection records of 

monthly control 

equipment inspections

0.1 12 1.2 0.1 0 0 0 0 0 0

 F. Time to train personnel N/A

 G. Time for audits N/A

Subtotal for 

Recordkeeping 

Requirements 

TOTAL with Paper Reporting Paper 0

TOTAL with Electronic Reporting 0

TOTAL Record Keeping 0

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Burden analysis for Subpart XX is zero since units are complying with Subpart XX by complying with Subpart CC and burden is accounted for in Subpart CC analysis. 
B-29

Table B.13 Model Refinery – 40 CFR Part 63, Subpart Y Supporting Statement Analysis [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Personhours for 

the Model 

Refinery 

per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

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 8 1 8 0 0 0 0 0 0 0

B. Required activities

Performance test (Method 25A) 100 1 100 0 0 0 0 0 0 0

Repeat of performance test 100 1 100 0 0 0 0 0 0 0

Leak check 16 1 16 16 0

[2] 0 0 0 0 0

Vapor tightness test 8 1 8 8 0

[2] 0 0 0 0 0

C. Create information Included in 3B 

and 4E

D. Gather existing information Included in 3B 

and 4E

E. Write report

Initial notification of applicability 4 1 4 0 0 0 0 0 0 0

Notification of compliance status Included in 3B

Site-specific test plan Included in 3B

Notification of performance test 2 1 2 0

[3] 0 0 0 0 0 0

Report of HAP control Efficiency 8 1 8 0

[2] 0 0 0 0 0 0

5. Recordkeeping Requirements

A. Read instructions 1 1 1 0 0 0 0 0 0 0

B. Plan activities N/A

C. Implement activities 16 1 16 16 0 0 0 0 0 0
B-30

Table B.13 Model Refinery – 40 CFR Part 63, Subpart Y Supporting Statement Analysis (Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year

(from 

supporting 

statement)

Person-hours 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrences 

for the 

Model 

Refinery per 

year

Personhours for 

the Model 

Refinery 

per year

Technical

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

D. Develop record system 16 1 16 0 0 0 0 0 0 0

E. Time to enter information 1 1 1 1 1 1 1 0.05 0.1 92.71

F. Time to transmit or disclose 

information 0.25 1 0.25 0.25 1 0.25 0.25 0.0125 0.025 23.18

G. Time for audits N/A

TOTAL with Paper Reporting Paper 0

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of 5.E and 5.F) 116

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Marine terminal at model refinery not subject to requirement. 

[3] One time performance test requirement. 
B-31

Table B.14 Model Refinery – 40 CFR Part 63, Subpart UU Supporting Statement Analysis [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrence

s for the 

Model 

Refinery 

per year

Personhours for 

the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, Installation, and 

Utilization of Technology and 

Systems 

40 1 40 0 0 0 0 0 0 0

4. Reporting Requirements

A. Read instructions 2 1 2 0 0 0 0 0 0 0

B. Required activities

 Initial Performance test 40 1 40 0 0 0 0 0 0 0

 Performance test 40 1 40 0

[2] 0 0 0 0 0 0

 Startup, shutdown, malfunction 

Plan 40 1 40 0 0 0 0 0 0 0

 Operating, maintenance, and 

monitoring plan 40 1 40 0 0 0 0 0 0 0

C. Create information See 4B

D. Gather existing information See 4B

E. Write report

 Notification of construction/ 

reconstruction 2 1 2 0 0 0 0 0 0 0

 Notification of actual startup 2 1 2 0 0 0 0 0 0 0

 Notification of special 

compliance requirements N/A

 Notification of performance 

test 2 1 2 0 0 0 0 0 0 0

 Notification of compliance 

Status 4 1 4 0 0 0 0 0 0 0

 Extended compliance request N/A

 Report of performance test See 4B

 Semiannual compliance reports 10 2 20 10 2 20 20 1 2 1,854.28
B-32

Table B.14 Model Refinery – 40 CFR Part 63, Subpart UU Supporting Statement Analysis (Cont.) [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Refinery

No. of 

occurrence

s for the 

Model 

Refinery 

per year

Personhours for 

the Model 

Refinery per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(C=AxB) (G=F) (H=G*0.05) (I=G*0.10)

5. Recordkeeping Requirements

A. Read instructions See 4A

B. Plan activities See 4B

C. Implement activities See 4B

D. Develop record system N/A

E. Time to enter information

 Records of operations 1 52 52 1 52 52 52 2.6 5.2 4,821.13

F. Time to train personnel 4 1 4 0 0 0 0 0 0 0

G. Time to adjust existing ways 

to comply with previously 

applicable requirements 

N/A

H. Time to transmit or disclose 

Information 0.25 1 0.25 0.25 1 0.25 0.25 0.0125 0.025 23.18

I. Time for audits N/A

TOTAL with Paper Reporting Paper (Semiannual Compliance Reports) 1,854

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of 5.E, 5.F, and 5.H) 4,844

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Performance test required for a significant process change - assumed requirement was not applicable.
Appendix C:

Burden Estimation and Supporting Statement Analysis – Model Chemical Plant
C-1

Table C.1 Model Chemical Plant – Summary of Potential Cost Savings Associated with 

Uniform Standard Electronic Semiannual Reporting

RULE (A) Recordkeeping (B) Reporting Under Existing Rules Via 

Paper Methods

40 CFR Part 60, Subpart NNN $858 $556

40 CFR Part 60, Subpart Kb $528 $590

40 CFR Part 63 Subpart YY, SS, and TT $11,682 $1,669

40 CFR Part 63 Subpart G, H, and I (PV, EL, TR Only) $18,543 $6,305

40 CFR Part 63 Subpart G (SV Only) $501 $590

40 CFR Part 63 Subpart FFFF $18,728 $6,305

Total $50,840 $16,014

(C) Initial Electronic Start-up Cost for Proposed Uniform Standards $2,685

(D) Cost of Semiannual Electronic Reporting for proposed Uniform Standards $4,740

(E) Cost of Annual Electronic Reporting for proposed Uniform Standards $363

(F) Written to Electronic Reporting Burden Ratio (F=B/(D+2E))[1] 2.93

(G) Administrative Preparation for Electronic Data Entry – management of log in information, etc. $834

(H) Additional Reporting Requirement in Uniform Standards - Cost to semiannually report daily and operating block averages, required in §65.882(e).[2]$2,596

(I) Proposed Uniform Standards Reporting Costs for Electronic Semiannual and Written Annual Reports (I=D+(E*F)+G+H)

[3] $9,235

(J) Potential Reporting Cost Savings Not Considering Initial Electronic Startup Costs for Proposed Uniform Standards (J=B-I) $6,779

(K) Savings Percentage - Reporting Cost Basis (K=J/B*100) 42%

(L) Savings Percentage - Record Keeping and Reporting Cost Basis (L=J/(A+B)*100) 10%

[1] Burden for annual reports multiplied by two because these are required semiannually under most existing rules. This ratio provides a general conversion between burden for electronic and written 

reports.

[2] Assumes 1 hour per process vent to upload data (14 process vents) entered twice a year for semiannual reporting for a total of 28 technical hours. Managerial and clerical hours were assumed to be 

five and ten percent of the annual technical hourly requirement, respectively. Rates used are in Table 6 of memo.

[3] Annual reports are required in written format, therefore the burden associated with electronic annual reports was converted to burden for written reports (E*F).
C-2

Table C.2 Model Chemical Plant – 40 CFR Part 63, Subpart NNN Supporting Statement Analysis [1]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per occurrence 

applicable to 

Model 

Chemical Plant

No. of 

occurrences for 

the Model 

Chemical Plant 

per year

Personhours for 

the Model 

Chemical 

Plant per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

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

B. Required Activities

Initial Performance Test Report 60 1 0 0 0 0 0 0 0

Repeat Performance Test Report 60 1 0 0 0 0 0 0 0

C. Write Report

Notification of Construction/Modification 2 1 0 0 0 0 0 0 0

 Notification of Actual Startup 1 1 0 0 0 0 0 0 0

 Notification of Initial Performance Test 2 1 0 0 0 0 0 0 0

 Semiannual Report 3 2 3 2 6 6 0.3 0.6 556.28

Total Annual Responses ()

4. Recordkeeping Requirements

Record of Operating Parameters for Control Devices 1 12 0

[2] 0 0 0 0 0 0

Records of Operating Conditions Exceeding Last 

Performance Test 1 8 1 8 8 8 0.4 0.8 741.71

Records of Startup, Shutdown, Malfunction, etc. 0.25 5 0.25 5 1.25 1.25 0.0625 0.125 115.89

TOTAL with Paper Reporting Paper (Sum of Item 3.C) 556

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of Item 4) 858

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, 

included in the rulemaking docket. 

[2] Assumed the model chemical plant currently complies with 40 CFR 60 Subpart NNN by maintaining a TRE greater than 8.0 through the use of two condensers and a scrubber. By 40 CFR 60.662(c)(4) each affected facility 

that has a total resource effectiveness index value greater than 8.0 is exempt from all provisions of this subpart except for 60.662 (standards), 60.664(d),(e),and(f) (Test Methods and Procedures), and 60.665(h) and (l) (Record 

keeping and reporting). Records of operating parameters are not included in (h) or (l).
C-3

Table C.3 Model Chemical Plant – 40 CFR Part 63, Subpart RRR Supporting Statement Analysis [1,2]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant

No. of 

occurrences 

for the Model 

Chemical

Plant per year

Person-hours 

for the Model 

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

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

B. Required Activities 60 1 0 0 0 0 0 0 0

Initial Performance Test Report

Repeat Performance Test Report 60 1 0 0 0 0 0 0 0

C. Write Report 2 1 0 0 0 0 0 0 0

Notification of Construction/

 Modification

 Notification of Actual Startup 1 1 0 0 0 0 0 0 0

 Notification of Initial Performance Test 2 1 0 0 0 0 0 0 0

 Semiannual Report 3 2 0 0 0 0 0 0 0

Total Annual Responses ()

4. Recordkeeping Requirements

Record of Operating Parameters for Control Devices 1 12 0 0 0 0 0 0 0

Records of Operating Conditions Exceeding Last 

Performance Test 1 8 0 0 0 0 0 0 0

Records of Startup, Shutdown, Malfunction, etc. 0.25 5 0 0 0 0 0 0 0
C-4

Table C.3 Model Chemical Plant – 40 CFR Part 63, Subpart RRR Supporting Statement Analysis (Cont.) [1,2]

Burden item

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant

No. of 

occurrences 

for the Model 

Chemical 

Plant per year

Person-hours 

for the Model 

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

TOTAL with Paper Reporting Paper 0

TOTAL with Electronic Reporting 0

TOTAL Record Keeping 0

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking 

docket. 

[2] Process vent is subject to 40 CFR Part 60, Subpart RRR; however, pursuant to 40 CFR 60.700(c)(5), VOC emissions from the process tank vent D285, shall be considered in compliance with the provisions of Subpart RRR 

because the vent stream is routed to a distillation unit (C-650) subject to 40 CFR 60, Subpart NNN and has no other releases to the air except for a pressure relief valve. Therefore, all burden is accounted for under Subpart NNN. 
C-5

Table C.4 Model Chemical Plant – 40 CFR Part 63, Subpart Kb Supporting Statement Analysis [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model 

Chemical 

Plant per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read Instruction 1 1 0 0 0 0 0 0 0

B. Required Activities 

One-Time Only Requirements 2 1 0 0 0 0 0 0 0

Notification of Start of 

Construction

Notification of Actual Startup 2 1 0 0 0 0 0 0 0

Notification of Physical or 

Operational Changes N/A

Notification of Malfunction N/A

Notification of Initial Inspection

IFR Internal Inspection 2 1 0 0 0 0 0 0 0

EFR Gap Measurement 2 1 0 0 0 0 0 0 0

 Initial Inspection Report

IFR Internal Inspection Report 12 1 0 0 0 0 0 0 0

EFR 2nd Seal Gap Measurement 8 1 0 0 0 0 0 0 0

EFR 1st Seal Gap Measurement 12 1 0 0 0 0 0 0 0

CVS Operating Plan Report 8 1 0 0 0 0 0 0 0

Repeat Requirements

Internal IFR Inspection 12 1 12 0.2[2] 2.4 2.4 0.12 0.24 66.75
C-6

Table C.4 Model Chemical Plant – 40 CFR Part 63, Subpart Kb Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model 

Chemical 

Plant per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

Visual IFR Inspection 8 1 8 1 8 8 0.4 0.8 222.51

Report of IFR Failure 2 1 2 0

[3] 0 0 0 0 0.00

Notification of Delay of Repair 

or Emptying for IFR 4 1 4 0

[3] 0 0 0 0 0.00

EFR 2nd Seal Gap Measure 

Report 8 1 8 1

[4] 8 8 0.4 0.8 222.51

EFR 1st Seal Gap Measure 

Report 12 1 12 0.2[5] 2.4 2.4 0.12 0.24 66.75

Notification of Refill 2 1 2 0.2[6] 0.4 0.4 0.02 0.04 11.13

 Number of Responses 

4.RECORDKEEPING 

REQUIREMENTS

A.. Read Instructions 1 1 1 1 1 1 0.05 0.1 27.81

B. Gather and Record 

Information 

i. Vessel Volumes, Liquid Vapor 

Pressure, flares 8 1 8 0

[7] 0 0 0 0 0

ii. 113b(a) inspection 12 1 12 1

[8] 12 12 0.6 1.2 333.77

iii. 113b(b) gap measurement for 

Secondary Seal 12 1 5 1

[9] 5 5 0.25 0.5 139.07

iii. 113b(b) gap measurement for 

Primary Seal 12 1 5 0.2[5] 1 1 0.05 0.1 27.81

C. Develop Record System 10 1 0

D. Time to Enter Information -

CVS Parameter Records 2 52 2 0 0 0 0 0 0

F. Train Personnel N/A N/A .

G. Audits N/A N/A
C-7

Table C.4 Model Chemical Plant – 40 CFR Part 63, Subpart Kb Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model 

Chemical 

Plant per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

TOTAL with Paper Reporting Paper (Sum of Repeat Requirements Under 3.B) 590

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of Items 4.A and 4.B) 528

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Original supporting statement indicate 20% of IFRs will be inspected, because inspections are conducted every 5 years. To account for the inspections for the one IFR tank we have included 20% 

of total hours for an annual average.

[3] Assumed no IFR failures at model facility. 

[4] One external floating roof (EFR) tank subject to Part 60, Subpart Kb. 

[5] This measurement occurs only once every 5 years, therefore, the occurrence rate is 1/5 the number of occurrences for the secondary seal measurement. 

[6] Assumed 20% per year will do refill notification.

[7] This burden estimate from the original supporting statement includes requirement in Kb provision in 60.115(b)(2) to keep a record of all periods of operation during which the flare pilot flame is 

absent. As none of the model chemical plant storage tanks are controlled with a closed vent system and flare to comply with §60.112b, the burden associated with complying with this provision does 

not apply.

[8] This requirement is for IFR tanks. The original supporting statement indicated that the average facility has 12.5 tanks with 75% IFR or 12 hours for 9.4 tanks (1.3 hours per tank). The model 

chemical facility has 1 IFR subject to Kb. 

[9] Original supporting statement indicated average facility has 12.5 tanks of which 20% (2.5 tanks) are EFR, therefore, 3.2 hours per tank - the model chemical plant has 1 Kb EFR, therefore, assumed 

3.2 hours. Also assumed that 70% of the cost attributable to performing the gap measurements (so only 30% is associated with the record burden for this line item.)
C-8

Table C.5 Model Chemical Plant – 40 CFR Part 63, Subpart G Supporting Statement Analysis [1,2]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per year

Person-hours 

for the Model 

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read Instruction 1 1 0 0 0 0 0 0 0

B. Required Activities 

One-Time Only Requirements 2 1 0 0 0 0 0 0 0

Notification of Start of 

Construction

Notification of Actual Startup 2 1 0 0 0 0 0 0 0

Notification of Physical or 

Operational Changes N/A

Notification of Malfunction N/A

Notification of Initial 

Inspection

IFR Internal Inspection 2 1 0 0 0 0 0 0 0

EFR Gap Measurement 2 1 0 0 0 0 0 0 0

 Initial Inspection Report

IFR Internal Inspection Report 12 1 0 0 0 0 0 0 0

EFR 2nd Seal Gap 

Measurement 8 1 0 0 0 0 0 0 0

EFR 1st Seal Gap 

Measurement 12 1 0 0 0 0 0 0 0

CVS Operating Plan Report 8 1 0 0 0 0 0 0 0

Repeat Requirements

Internal IFR Inspection 12 1 12 0.2[3] 2.4 2.4 0.12 0.24 66.75
C-9

Table C.5 Model Chemical Plant – 40 CFR Part 63, Subpart G Supporting Statement Analysis (Cont.) [1,2]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per year

Person-hours 

for the Model 

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

Visual IFR Inspection 8 1 8 1 8 8 0.4 0.8 222.51

Report of IFR Failure 2 1 2 0

[4] 0 0 0 0 0.00

Notification of Delay of Repair 

or Emptying for IFR 4 1 0 0

[4] 0 0 0 0 0.00

EFR 2nd Seal Gap Measure 

Report 8 1 8 1

[5] 8 8 0.4 0.8 222.51

EFR 1st Seal Gap Measure 

Report 12 1 12 0.2[6] 2.4 2.4 0.12 0.24 66.75

Notification of Refill 2 1 2 0.2[7] 0.4 0.4 0.02 0.04 11.13

 Number of Responses 

4.RECORDKEEPING 

REQUIREMENTS

A.. Read Instructions 1 1 0 0 0 0 0 0 0.00

B. Gather and Record 

Information 

i. Vessel Volumes, Liquid 

Vapor Pressure, flares 8 1 8 0

[8] 0 0 0 0 0.00

ii. 113b(a) inspection 12 1 12 1

[9] 12 12 0.6 1.2 333.77

iii. 113b(b) gap measurement 

for Secondary Seal 12 1 5 1

[10] 5 5 0.25 0.5 139.07

iii. 113b(b) gap measurement 

for Primary Seal 12 1 5 0.2[6] 1 1 0.05 0.1 27.81

C. Develop Record System 10 1 0

D. Time to Enter Information -

CVS Parameter Records 2 52 2 0 0 0 0 0 0.00

F. Train Personnel N/A N/A .

G. Audits N/A N/A
C-10

Table C.5 Model Chemical Plant – 40 CFR Part 63, Subpart G Supporting Statement Analysis (Cont.) [1,2]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per year

Person-hours 

for the Model 

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

TOTAL with Paper Reporting Paper (Sum of Repeat Requirements Under 3.B) 590

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of Items 4.A and 4.B) 501

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Original Subpart G supporting statement was unavailable for the analysis; therefore, Subpart Kb was used to estimate the burden under Subpart G.

[3] Original supporting statement indicate 20% of IFRs will be inspected, because inspections are conducted every 5 years. To account for the inspections for the one IFR tank we have included 20% 

of total hours for an annual average.

[4] Assumed no IFR failures at model facility. 

[5] One external floating roof (EFR) tank subject to Part 60, Subpart G. 

[6] This measurement occurs only once every 5 years, therefore, the occurrence rate is 1/5 the number of occurrences for the secondary seal measurement. 

[7] Assumed 20% per year will do refill notification.

[8] This burden estimate from the original supporting statement includes requirement in Kb provision in 60.115(b)(2) to keep a record of all periods of operation during which the flare pilot flame is 

absent. As none of the model chemical plant storage tanks are controlled with a closed vent system and flare to comply with §60.112b, the burden associated with complying with this provision does 

not apply.

[9] This requirement is for IFR tanks. The original supporting statement indicated that the average facility has 12.5 tanks with 75% IFR or 12 hours for 9.4 tanks (1.3 hours per tank). The model 

chemical facility has 1 IFR subject to Kb. 

[10] Original supporting statement indicated average facility has 12.5 tanks of which 20% (2.5 tanks) are EFR, therefore, 3.2 hours per tank - the model chemical plant has 1 Kb EFR, therefore, 

assumed 3.2 hours. Also assumed that 70% of the cost attributable to performing the gap measurements (so only 30% is associated with the record burden for this line item.)
C-11

Table C.6 Model Chemical Plant – 40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per year

Person-hours 

for the Model

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements 

 A. Read Instructions

 Polycarbonated (PC) 

Production 4 1 0 0 0 0 0 0 0

 Acrylic and Modacrylic 

Fibers (AMF) Production 4 1 0 0 0 0 0 0 0

 Acetal Resins (AR) 

Production 4 1 0 0 0 0 0 0 0

 Hydrogen Fluoride (HF) 

Production 4 1 0 0 0 0 0 0 0

 B. Required Activities for 

PC, AMF, AR, & HF Included in 4C

 C. Create Information for PC, 

AMF, AR, & HF Included in 4C

 D. Gather existing 

information for PC, AMF, AR 

& HF

Included in 4C

 E. Write report

 i Initial requirements: 

notifications, initial 

compliance determination, 

performance tests 

 PC Production 52 1 0 0 0 0 0 0 0

 AMF Production 52 1 0 0 0 0 0 0 0

 AR Production 52 1 0 0 0 0 0 0 0

 HF Production 52 1 0 0 0 0 0 0 0
C-12

Table C.6 Model Chemical Plant – 40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

 ii Startup, Shutdown 

malfunction reports

 PC Production 2 1 2 1 2 2 0.1 0.2 185.43

 AMF Production 2 1 0 0

[2] 0 0 0 0 0

 AR Production 2 1 0 0

[2] 0 0 0 0 0

 HF Production 2 1 0 0

[2] 0 0 0 0 0

 iii Periodic reports

 PC Production 8 2 8 2 16 16 0.8 1.6 1,483.42

 AMF Production 8 2 0 0

[2] 0 0 0 0 0

 AR Production 8 2 0 0

[2] 0 0 0 0 0

 HF Production 8 2 0 0

[2] 0 0 0 0 0

 iv Leak detection and repair 

(LDAR) reports

 PC Production 8 2 8 2 16 16 0.8 1.6 1,483.42

 AMF Production 8 2 0 0

[2] 0 0 0 0 0

 AR Production 8 2 0 0

[2] 0 0 0 0 0

 HF Production 8 2 0 0

[2] 0 0 0 0 0

4. Recordkeeping 

Requirements

 A. Read Instructions for

 PC Production 4 1 0 0

[3] 0 0 0 0 0

 AMF Production 4 1 0 0

[2,3] 0 0 0 0 0

 AR Production 4 1 0 0

[2,3] 0 0 0 0 0
C-13

Table C.6 Model Chemical Plant – 40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

 HF Production 4 1 0 0

[2,3] 0 0 0 0 0

 B. Plan Activities for

 PC Production 40 1 0 0

[3] 0 0 0 0 0

 AMF Production 40 1 0 0

[2,3] 0 0 0 0 0

 AR Production 40 1 0 0

[2,3] 0 0 0 0 0

 HF Production 40 1 0 0

[2,3] 0 0 0 0 0

 C. Implement Activities

 i Material determinations

 PC Production N/A N/A

 AMF Production N/A N/A

 AR Production N/A N/A

 HF Production N/A N/A

 ii Control equipment 

inspection

 a. Tanks

 PC Production N/A N/A

 AMF Production 2 12 0 0

[2] 0 0 0 0 0

 AR Production 2 12 0 0

[2] 0 0 0 0 0

 HF Production N/A N/A

 b. Closed-vent system

 PC Production 2 2 2 2 4 4 0.2 0.4 370.86

 AMF Production 2 2 0 0

[2] 0 0 0 0 0
C-14

Table C.6 Model Chemical Plant – 40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

 AR Production 2 2 0 0

[2] 0 0 0 0 0

 HF Production 2 2 0 0

[2] 0 0 0 0 0

 iii Control equipment leak 

monitoring

 a. Cover vented to control 

device

 PC Production 1 2 0 0

[4] 0 0 0 0 0

 AMF Production 1 2 0 0

[2,4] 0 0 0 0 0

 AR Production 1 2 0 0

[2,4] 0 0 0 0 0

 HF Production 1 2 0 0

[2,4] 0 0 0 0 0

 b. Closed-vent system

 PC Production 1 2 1 0 0 0 0 0 0.00

 AMF Production 1 2 0

[2] 0[2] 0 0 0 0 0

 AR Production 1 2 0

[2] 0[2] 0 0 0 0 0

 HF Production 1 2 0

[2] 0[2] 0 0 0 0 0

 iv. Control devices

 a. Initial requirements 

design analysis, performance

 Test

 PC Production 80 1 0 0

[3] 0 0 0 0 0

 AMF Production 80 1 0 0

[2,3] 0 0 0 0 0

 AR Production 80 1 0 0

[2,3] 0 0 0 0 0

 HF Production 80 1 0 0

[2,3] 0 0 0 0 0
C-15

Table C.6 Model Chemical Plant – 40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

 b. Operate and maintain 

CMS

 PC Production 8 12 8 12 96 96 4.8 9.6 8,900.54

 AMF Production 8 12 0 0

[2] 0 0 0 0 0

 AR Production 8 12 0 0

[2] 0 0 0 0 0

 HF Production 8 12 0 0

[2] 0 0 0 0 0

 v. LDAR Program

 a. Initial requirement: 

Identify all effected streams

 PC Production 20 1 0 0

[3] 0 0 0 0 0

 AMF Production 20 1 0 0

[2,3] 0 0 0 0 0

 AR Production 20 1 0 0

[2,3] 0 0 0 0 0

 HF Production 20 1 0 0

[2,3] 0 0 0 0 0

 b. Perform 

monitoring/repairs

 PC Production 

 1) In-house 0.1 1,092 0 0 0 0 0 0 0.00

 2) Use of 

contractor support

 AMF Production 16 12 0 0

[2] 0 0 0 0 0

 AR Production 16 12 0 0

[2] 0 0 0 0 0

 HF Production 0.1 1,092 0 0

[2] 0 0 0 0 0

 vi. Container vapor 

tightness certification

 PC Production N/A N/A
C-16

Table C.6 Model Chemical Plant – 40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

 AMF Production N/A N/A

 AR Production N/A N/A

 HF Production N/A N/A

 D. Develop Record System

 i. Develop startup, 

shutdown, malfunction plan

 PC Production 20 1 0 0

[3] 0 0 0 0 0

 AMF Production 20 1 0 0

[2,3] 0 0 0 0 0

 AR Production 20 1 0 0

[2,3] 0 0 0 0 0

 HF Production 20 1 0 0

[2,3] 0 0 0 0 0

 ii. Control equipment

 PC Production 16 1 0 0

[3] 0 0 0 0 0

 AMF Production 16 1 0 0

[2,3] 0 0 0 0 0

 AR Production 16 1 0 0

[2,3] 0 0 0 0 0

 HF Production 16 1 0 0

[2,3] 0 0 0 0 0

 iii. LDAR Program

 PC Production 40 1 0 0

[3] 0 0 0 0 0

 AMF Production 40 1 0 0

[2,3] 0 0 0 0 0

 AR Production 40 1 0 0

[2,3] 0 0 0 0 0

 HF Production 40 1 0 0

[2,3] 0 0 0 0 0

E. Record Information (all 

information required by 

standard)
C-17

Table C.6 Model Chemical Plant – 40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

 i. Initial requirements: cover 

design, control device  

design, and control equipment 

testing

 PC Production 17 1 0 0

[3] 0 0 0 0 0

 AMF Production 17 1 0 0

[2,3] 0 0 0 0 0

 AR Production 17 1 0 0

[2,3] 0 0 0 0 0

 HF Production 17 1 0 0

[2,3] 0 0 0 0 0

 ii. Control equipment 

inspection

 PC Production 1 2 1 2 2 2 0.1 0.2 185.43

 AMF Production 1 2 0 0

[2] 0 0 0 0 0

 AR Production 1 2 0 0

[2] 0 0 0 0 0

 HF Production 1 2 0 0

[2] 0 0 0 0 0

 iii. Control equipment 

monitoring

 PC Production 1 52 0 0

[5] 0 0 0 0 0.00

 AMF Production 1 52 0 0

[2] 0 0 0 0 0

 AR Production 1 52 0 0

[2] 0 0 0 0 0

 HF Production 1 52 0 0

[2] 0 0 0 0 0

 iv. Control device CMS 

 PC Production 1 12 1 12 12 12 0.6 1.2 1,112.57

 AMF Production 1 12 0 0

[2] 0 0 0 0 0

 AR Production 1 12 0 0

[2] 0 0 0 0 0
C-18

Table C.6 Model Chemical Plant – 40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

 HF Production 1 12 0 0

[2] 0 0 0 0 0

 v. LDAR program

 PC Production 0.02 1,092 1 2 2 2 0.1 0.2 185.43

 AMF Production 2 12 0 0

[2] 0 0 0 0 0

 AR Production 2 12 0 0

[2] 0 0 0 0 0

 HF Production 0.02 1,092 0 0

[2] 0 0 0 0 0

 F. Time to Train Personnel

 i. Material determination 

methods

 PC Production N/A N/A

 AMF Production N/A N/A

 AR Production N/A N/A

 HF Production N/A N/A

 ii. Control equipment 

inspection and monitoring

 PC Production 8 1 1 8 8 8 0.4 0.8 741.71

 AMF Production 8 1 0 0

[2] 0 0 0 0 0

 AR Production 8 1 0 0

[2] 0 0 0 0 0

 HF Production 8 1 0 0

[2] 0 0 0 0 0

 iii. LDAR program

 PC Production 2 1 2 1 2 2 0.1 0.2 185.43

 AMF Production 2 1 0 0

[2] 0 0 0 0 0

 AR Production 2 1 0 0

[2] 0 0 0 0 0
C-19

Table C.6 Model Chemical Plant – 40 CFR Part 63, Subpart YY, SS, and TT Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (C) (D) (E) (F) (G) (H) (I)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per respondent 

per year (from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Person-hours 

for the Model

Chemical 

Plant per year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(F=E) (G=F*0.05) (H=F*0.10)

 HF Production 2 1 0 0

[2] 0 0 0 0 0

 iv. Container leak tight 

method

 PC Production N/A N/A

 AMF Production N/A N/A

 AR Production N/A N/A

 HF Production N/A N/A

Subtotal Labor Burden

TOTAL with Paper Reporting Paper (Sum of Items Under 3.E) 1,669

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of Items From 4.C.ii.b to 4.F.iii) 11,682

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Process unit not applicable to model chemical plant. 

[3] One time requirement.

[4] Cover not applicable to model chemical plant. 

[5] There are no weekly control equipment monitoring for model chemical plant.
C-20

Table C.7 Model Chemical Plant – 40 CFR Part 63, Subpart FFFF Supporting Statement Analysis [1]

Burden item 

(A) (B) (D) (E) (F) (G) (H) (I) (J)

Personhours per 

occurrence 

for SFI 

(from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the 

Model 

Chemical 

Plant per 

year

Personhours for the 

Model 

Chemical 

Plant per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost 

($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(G=F) (H=G*0.05) (I=G*0.10)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

a. Read rule and instructions 1 1 0 0 0 0 0 0 0

b. Required Activities

i. Initial Performance Test - process vents 480 1 0 0 0 0 0 0 0

ii. Initial Performance Test - wastewater 160 1 0 0 0 0 0 0 0

iii. Initial CMS performance evaluation 10 1 0 0 0 0 0 0 0

iv. Repeat Performance Test 20 1 0 0 0 0 0 0 0

c. Create Information Included in 

3e

d. Gather existing Information Included in 

3e

e. Write Reports

i. Notification of 

Construction/Reconstruction 2 1 0 0 0 0 0 0 0

ii. Notification of Actual Startup 2 1 0 0 0 0 0 0 0

iii. Initial Notification 2 1 0 0 0 0 0 0 0

iv. Emissions Averaging Plan 40 1 0 0 0 0 0 0 0

v. Precompliance Report 40 1 0 0 0 0 0 0 0

vii. Performance Test Notification 2 1 0 0 0 0 0 0 0

viii. Notification of Initial CMS 

performance evaluation 2 1 0 0 0 0 0 0 0

ix. Notification of Compliance Status 0 0 0 0
C-21

Table C.7 Model Chemical Plant – 40 CFR Part 63, Subpart FFFF Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

occurrence 

applicable 

to Model 

Chemical 

Plant 

No. of 

occurrences 

for the 

Model 

Chemical 

Plant per 

year

Person-hours 

for the Model 

Chemical 

Plant per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost 

($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(G=F) (H=G*0.05) (I=G*0.10)

a. With performance test 80 1 0 0 0 0 0 0 0

b. W/O performance test 120 1 0 0 0 0 0 0 0

x. Notification of Physical/ Operational 

Change 8 1 0 0 0 0 0 0 0

xi. Semiannual Summary Report

a. No Deviations 8 2 8 0 0 0 0 0 0.00

b. Deviations 24 2 24 2

[2] 48 48 2.4 4.8 4,450.27

c. SS&M Report 8 2 8 2 16 16 0.8 1.6 1,483.42

d. LDAR Report 404 2 1

[3] 4 4 4 0.2 0.4 370.86

e. Emission Averaging report 20 2 20 0 0 0 0 0 0.00

4. Recordkeeping Requirements

a. Read rule and instructions Included in 

3e

b. Plan Activities N/A

c. Implement Activities N/A

d. Develop Record System 40 1 0 0 0 0 0 0 0

e. Develop SS&M Plan 100 1 0 0 0 0 0 0 0

f. Develop QA/QC Plan for CMS 40 1 0 0 0 0 0 0 0

g. Time to train personnel 40 1 0 0 0 0 0 0 0

h. Time to retrain/refresh personnel 16 1 16 1 16 16 0.8 1.6 1,483.42

i. Time to enter information

i. Records of SS&M 1.5 52 1.5 52 78 78 3.9 7.8 7,231.69
C-22

Table C.7 Model Chemical Plant – 40 CFR Part 63, Subpart FFFF Supporting Statement Analysis (Cont.) [1]

Burden item 

(A) (B) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

occurrence 

applicable 

to Model 

Chemical 

Plant 

No. of 

occurrences 

for the 

Model 

Chemical 

Plant per 

year

Person-hours 

for the Model 

Chemical 

Plant per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost ($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(G=F) (H=G*0.05) (I=G*0.10)

ii. Records of CMS data

a. Record of Continuously Monitored 

Parameters 1 365 1 12 12 12 0.6 1.2 1,112.57

b. Compile Data 24 2 24 2 48 48 2.4 4.8 4,450.27

c. Enter/verify Information for 

Semiannual report 16 2 16 2 32 32 1.6 3.2 2,966.85

d. LDAR Included in 

3e

j. Calibration of CMS 16 1 16 1 16 16 0.8 1.6 1,483.42

TOTAL with Paper Reporting Paper (Sum of Items Under 3.e.xi) 6,305

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of Items 4.h through 4.j) 18,728

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Assumed one deviation per semiannual report at model chemical plant. 

[3] Changed to 1 hour because Method 21 testing is counted in cost impacts and 1 hour per process unit should be adequate time to transmit the data from the analyzer to a computer.
C-23

Table C.8 Model Chemical Plant – 40 CFR Part 63, Subpart G, H, and I Supporting Statement Analysis [1,2]

Burden item 

(A) (B) (D) (E) (F) (G) (H) (I) (J)

Personhours per 

occurrence 

for SFI 

(from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Personhours per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the 

Model 

Chemical 

Plant per 

year

Personhours for the 

Model 

Chemical 

Plant per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost 

($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(G=F) (H=G*0.05) (I=G*0.10)

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

a. Read rule and instructions 1 1 0 0 0 0 0 0 0

b. Required Activities

i. Initial Performance Test - process vents 480 1 0 0 0 0 0 0 0

ii. Initial Performance Test - wastewater 160 1 0 0 0 0 0 0 0

iii. Initial CMS performance evaluation 10 1 0 0 0 0 0 0 0

iv. Repeat Performance Test 20 1 0 0 0 0 0 0 0

c. Create Information Included in 

3e

d. Gather existing Information Included in 

3e

e. Write Reports

i. Notification of 

Construction/Reconstruction 2 1 0 0 0 0 0 0 0

ii. Notification of Actual Startup 2 1 0 0 0 0 0 0 0

iii. Initial Notification 2 1 0 0 0 0 0 0 0

iv. Emissions Averaging Plan 40 1 0 0 0 0 0 0 0

v. Precompliance Report 40 1 0 0 0 0 0 0 0

vii. Performance Test Notification 2 1 0 0 0 0 0 0 0

viii. Notification of Initial CMS 

performance evaluation 2 1 0 0 0 0 0 0 0

ix. Notification of Compliance Status 0 0 0 0
C-24

Table C.8 Model Chemical Plant – 40 CFR Part 63, Subpart G, H, and I Supporting Statement Analysis (Cont.) [1,2]

Burden item 

(A) (B) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Personhours for 

the Model 

Chemical 

Plant per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost 

($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(G=F) (H=G*0.05) (I=G*0.10)

a. With performance test 80 1 0 0 0 0 0 0 0

b. W/O performance test 120 1 0 0 0 0 0 0 0

x. Notification of Physical/ Operational 

Change 8 1 0 0 0 0 0 0 0

xi. Semiannual Summary Report

a. No Deviations 8 2 8 0 0 0 0 0 0.00

b. Deviations 24 2 24 2

[3] 48 48 2.4 4.8 4,450.27

c. SS&M Report 8 2 8 2 16 16 0.8 1.6 1,483.42

d. LDAR Report 404 2 1

[4] 4 4 4 0.2 0.4 370.86

e. Emission Averaging report 20 2 20 0 0 0 0 0 0.00

4. Recordkeeping Requirements

a. Read rule and instructions Included in 

3e

b. Plan Activities N/A

c. Implement Activities N/A

d. Develop Record System 40 1 0 0 0 0 0 0 0

e. Develop SS&M Plan 100 1 0 0 0 0 0 0 0

f. Develop QA/QC Plan for CMS 40 1 0 0 0 0 0 0 0

g. Time to train personnel 40 1 0 0 0 0 0 0 0

h. Time to retrain/refresh personnel 16 1 16 1 16 16 0.8 1.6 1,483.42

i. Time to enter information

i. Records of SS&M 1.5 52 1.5 52 78 78 3.9 7.8 7,231.69
C-25

Table C.8 Model Chemical Plant – 40 CFR Part 63, Subpart G, H, and I Supporting Statement Analysis (Cont.) [1,2]

Burden item 

(A) (B) (D) (E) (F) (G) (H) (I) (J)

Person-hours 

per 

occurrence 

for SFI (from 

supporting 

statement)

No. of 

occurrences 

per 

respondent 

per year 

(from 

supporting 

statement)

Person-hours 

per 

occurrence 

applicable to 

Model 

Chemical 

Plant 

No. of 

occurrences 

for the Model 

Chemical 

Plant per 

year

Personhours for 

the Model 

Chemical 

Plant per 

year

Technical 

Hours

(hr/yr)

Managerial 

Hours

(hr/yr)

Clerical 

Hours

(hr/yr)

Total Cost 

($)

Technical 

$83.01/hr

Managerial 

$121.38/hr

Clerical 

$36.35/hr

(G=F) (H=G*0.05) (I=G*0.10)

ii. Records of CMS data

a. Record of Continuously Monitored 

Parameters 1 365 1 10 10 10 0.5 1 927.14

b. Compile Data 24 2 24 2 48 48 2.4 4.8 4,450.27

c. Enter/verify Information for 

Semiannual report 16 2 16 2 32 32 1.6 3.2 2,966.85

d. LDAR Included in 3e

j. Calibration of CMS 16 1 16 1 16 16 0.8 1.6 1,483.42

TOTAL with Paper Reporting Paper (Sum of Items Under 3.e.xi) 6,305

TOTAL with Electronic Reporting 0

TOTAL Record Keeping (Sum of Items 4.h through 4.j) 18,543

[1] The referenced supporting statement contains several footnotes associated with the original burden estimate. Please refer to the original supporting statement, included in the rulemaking docket. 

[2] Original Subpart G/H/I (HON) supporting statement was unavailable for the analysis; therefore, Subpart FFFF was used to estimate the burden under Subpart G/H/I (HON). 

[3] Assumed one deviation per semiannual report at model chemical plant. 

[4] Changed to 1 hour because Method 21 testing is counted in cost impacts and 1 hour per process unit should be adequate time to transmit the data from the analyzer to a computer.
Appendix D:

Electronic Reporting Cost Analysis
D-1

Table D.1 Initial Start Up Cost for Electronic Reporting for the Model Refinery

Emission Source

(A) (B) (C) (D) (E) (F) (G) (H)

TOTAL COST ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

Count of 

Occurrences 

Per Facility

Count of 

Applicable 

Data Elements

Count of Rules 

Applicable to 

Emission 

Source

Count of Data 

Entry Records

Hours Required 

to Enter Data 

Elements[1]

Technical 

Hours

Managerial 

Hours

Clerical 

Hours

D=Ax(B+C) E=D/25 (G=F*0.05) (H=F*0.10)

Transfer Operations[2] 2 10 4 28 1.12 1.12 0.06 0.11 104

Equipment Leaks[3] 16 19 3 352 14.1 14.1 0.70 1.41 1,305

Process Vents[4] 7 12 2 98 3.92 3.92 0.20 0.39 363

Storage Vessels[5] 48 12 5 816 32.6 32.6 1.63 3.26 3,026

Generic Data Elements[6] 16 9 0 144 5.76 5.76 0.29 0.58 534

Total 5,333

[1] Assumed 25 data element entries per hour.

[2] 2 transfer operations at model refinery (marine dock and loading terminal). Assumed 10 data elements - control type, identification number, material loaded, capacity, annual 

amount of material loaded, and 5 other miscellaneous data elements. Assumed 4 applicable rules listed in Table [Insert Name of Rule Applicability Table 1]. 

[3] 16 process vents are subject to equipment leak standards at the model refinery. Assumed 19 data elements - Count of pumps, compressors, agitators, pressure relief devices, 

sampling connection systems, open-ended valves or lines, valves, connectors, instrumentation systems, and control devices; classification of equipment; location of equipment; 

control type for equipment; regulated material status; HAP/VOC; and 5 other miscellaneous data elements. Assumed 3 applicable rules listed in Table [insert name of Rule 

Applicability Table 1]. 

[4] 7 process vents are subject to process vent standards at the model refinery. Assumed 12 data elements - control type, identification number, flow, concentration, TRE, description, 

regulated material status, and 5 other miscellaneous data elements. Assumed 2 applicable rules listed in Table [insert name of Rule Applicability Table 1]. 

[5] 48 tanks are subject to storage vessel requirements at the model refinery. Assumed 12 data elements - size, orientation, materials being stored, installation date, control type, 

capacity, vapor pressure, and 5 other miscellaneous elements. Assumed 5 applicable rules listed in Table [insert name of Rule Applicability Table 1].

[6] 16 process units require generic data elements at the model refinery. Assumed 9 data elements - facility contact name, address, phone number, facility type (process), and 5 other 

miscellaneous data elements. 
D-2

Table D.2 Initial Start Up Cost for Electronic Reporting for the Model Chemical Plant

Emission Source

(A) (B) (C) (D) (E) (F) (G) (H)

TOTAL COST ($)

Technical $83.01/hr

Managerial 

$121.38/hr

Clerical $36.35/hr

Count of 

Occurrences 

Per Facility

Count of 

Applicable 

Data 

Elements

Count of 

Rules 

Applicable to 

Emission 

Source

Count of Data 

Entry Records

Hours Required to 

Enter Data 

Elements[1]

Technical 

Hours

Managerial 

Hours

Clerical 

Hours

D=Ax(B+C) E=D/25 (G=F*0.05) (H=F*0.10)

Transfer Operations[2] 7 10 2 84 3.36 3.36 0.17 0.34 312

Equipment Leaks[3] 3 19 4 69 2.8 2.8 0.14 0.28 256

Process Vents[4] 14 12 4 224 8.96 8.96 0.45 0.90 831

Storage Vessels[5] 20 12 4 320 12.8 12.8 0.64 1.28 1,187

Generic Data Elements[6] 3 9 0 27 1.08 1.08 0.05 0.11 100

Total 2,685

[1] Assumed 25 data element entries per hour.

[2] 7 transfer operations at model chemical plant. Assumed 10 data elements - control type, identification number, material loaded, capacity, annual amount of material loaded, and 5 other 

miscellaneous data elements. Assumed 4 applicable rules listed in Table [Insert Name of Rule Applicability Table 1]. 

[3] 3 process vents are subject to equipment leak standards at model chemical plant. Assumed 19 data elements - Count of pumps, compressors, agitators, pressure relief devices, sampling connection 

systems, open-ended valves or lines, valves, connectors, instrumentation systems, and control devices; classification of equipment; location of equipment; control type for equipment; regulated 

material status; HAP/VOC; and 5 other miscellaneous data elements. Assumed 3 applicable rules listed in Table [insert name of Rule Applicability Table 1]. 

[4] 14 process vents are subject to process vent standards at model chemical plant. Assumed 12 data elements - control type, identification number, flow, concentration, TRE, description, regulated 

material status, and 5 other miscellaneous data elements. Assumed 2 applicable rules listed in Table [insert name of Rule Applicability Table 1]. 

[5] 20 tanks are subject to storage vessel requirements at model chemical plant. Assumed 12 data elements - size, orientation, materials being stored, installation date, control type, capacity, vapor 

pressure, and 5 other miscellaneous elements. Assumed 5 applicable rules listed in Table [insert name of Rule Applicability Table 1].

[6] 3 process units require generic data elements at model chemical plant. Assumed 9 data elements - facility contact name, address, phone number, facility type (process), and 5 other miscellaneous 

data elements. 
D-3

Table D.3 Annual Cost for Electronic Reporting for the Model Refinery

Data Element

(A) (B) (F) (G) (H)

TOTAL COST ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr 

Data 

Elements to 

be Entered 

Per Year

Total Hours 

per Year[1] Technical

Hours

Managerial

Hours

Clerical

Hours

B=A/25 (G=F*0.05) (H=F*0.10)

Information Required in the Annual Report

Subpart I[2]

Inspection records

Defect 5 0.2 0.2 0.01 0.02 18.54

Leak 5 0.2 0.2 0.01 0.02 18.54

Failure 5 0.2 0.2 0.01 0.02 18.54

Documentation of Emptying for:

Defect 5 0.2 0.2 0.01 0.02 18.54

Leak 5 0.2 0.2 0.01 0.02 18.54

Failure 5 0.2 0.2 0.01 0.02 18.54

Documentation of Repair for:

Defect 5 0.2 0.2 0.01 0.02 18.54

Leak 5 0.2 0.2 0.01 0.02 18.54

Failure 5 0.2 0.2 0.01 0.02 18.54

Estimate of Emissions from Floating Roof Landings 5 0.2 0.2 0.01 0.02 18.54

Estimate of Emission from Overfilling 5 0.2 0.2 0.01 0.02 18.54

Estimate of Emissions from Pressure Vessel Defects 5 0.2 0.2 0.01 0.02 18.54

Subpart I, Annual Subtotal 60 2.4 2.4 0.12 0.24 222.51

Subpart J[3]

Process Unit Identification 16 0.64 0.64 0.032 0.064 59.34

Count of Leaking Equipment

Valves 16 0.64 0.64 0.032 0.064 59.34
D-4

Table D.3 Annual Cost for Electronic Reporting for the Model Refinery (Cont.)

Data Element

(A) (B) (F) (G) (H)

TOTAL COST ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr 

Data 

Elements to 

be Entered 

Per Year

Total Hours 

per Year[1] Technical

Hours

Managerial

Hours

Clerical

Hours

B=A/25 (G=F*0.05) (H=F*0.10)

Pumps 16 0.64 0.64 0.032 0.064 59.34

Connectors 16 0.64 0.64 0.032 0.064 59.34

Agitators 16 0.64 0.64 0.032 0.064 59.34

Compressors 16 0.64 0.64 0.032 0.064 59.34

Total Count of Valves Monitored 16 0.64 0.64 0.032 0.064 59.34

Percent Leaking 16 0.64 0.64 0.032 0.064 59.34

Total Count of Connectors Monitored 16 0.64 0.64 0.032 0.064 59.34

Percent Leaking 16 0.64 0.64 0.032 0.064 59.34

Count of Equipment not Repaired

Valves 16 0.64 0.64 0.032 0.064 59.34

Pumps 16 0.64 0.64 0.032 0.064 59.34

Connectors 16 0.64 0.64 0.032 0.064 59.34

Agitators 16 0.64 0.64 0.032 0.064 59.34

Compressors 16 0.64 0.64 0.032 0.064 59.34

Non-repairable/Inaccessible 16 0.64 0.64 0.032 0.064 59.34

Delay of Repair Report 16 0.64 0.64 0.032 0.064 59.34

Results of M21 Test Post Release Test for G/V PRD 16 0.64 0.64 0.032 0.064 59.34

Results of M21 Test for Compressors 16 0.64 0.64 0.032 0.064 59.34

Results of M21 Test for OEL 16 0.64 0.64 0.032 0.064 59.34

Process vent Requirements 25 1 1 0.05 0.1 92.71

Subpart J, Annual Subtotal 345 13.8 13.8 0.69 1.38 1,279.45

Subpart M (Annual) There are no annual Subpart M reports.

Information Required in the Semiannual Report
D-5

Table D.3 Annual Cost for Electronic Reporting for the Model Refinery (Cont.)

Data Element

(A) (B) (F) (G) (H)

TOTAL COST ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr 

Data 

Elements to 

be Entered 

Per Year

Total Hours 

per Year[1] Technical

Hours

Managerial

Hours

Clerical

Hours

B=A/25 (G=F*0.05) (H=F*0.10)

Subpart I[4]

Storage Vessel ID 10 0.4 0.4 0.02 0.04 37.09

Date of Empty/Repair 10 0.4 0.4 0.02 0.04 37.09

Start Date Floating Roof Landing Does Not Meet 

65.315(b)(1) 10 0.4 0.4 0.02 0.04 37.09

End Date Floating Roof Landing Does Not Meet 

65.315(b)(1) 10 0.4 0.4 0.02 0.04 37.09

Inspection record for pressure vessels 10 0.4 0.4 0.02 0.04 37.09

Subpart I, Semiannual Subtotal 50 2 2 0.1 0.2 185.43

Subpart J

PRD Release[5]

PRD ID 160 6.4 6.4 0.32 0.64 593.37

Duration of PRD Release 160 6.4 6.4 0.32 0.64 593.37

Emissions from PRD Release 160 6.4 6.4 0.32 0.64 593.37

Compressor Leak[6]

Compressor ID 32 1.28 1.28 0.064 0.128 118.67

Number of days between Instrument Reading 32 1.28 1.28 0.064 0.128 118.67

OEL Leak (Cap and Plug)[6]

OEL ID 32 1.28 1.28 0.064 0.128 118.67

Number of days between Instrument Reading 32 1.28 1.28 0.064 0.128 118.67

OEL Release from Emergency Shutdown[6]

OEL ID 32 1.28 1.28 0.064 0.128 118.67

Number of Releases 32 1.28 1.28 0.064 0.128 118.67
D-6

Table D.3 Annual Cost for Electronic Reporting for the Model Refinery (Cont.)

Data Element

(A) (B) (F) (G) (H)

TOTAL COST ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr 

Data 

Elements to 

be Entered 

Per Year

Total Hours 

per Year[1] Technical

Hours

Managerial

Hours

Clerical

Hours

B=A/25 (G=F*0.05) (H=F*0.10)

Low Barrier Pressure Fluid[6]

Equipment ID 32 1.28 1.28 0.064 0.128 118.67

Number of Occurrences 32 1.28 1.28 0.064 0.128 118.67

Subpart J, Semiannual Subtotal 736 29.4 29.44 1.472 2.944 2,729.50

Subpart M

Process Vents[7]

Process Unit ID 140 5.6 5.6 0.28 0.56 519.20

Start/End Date of Reporting Period 140 5.6 5.6 0.28 0.56 519.20

Start/End Date of Exceedence (Above Emission 

Limit/Parameter) 140 5.6 5.6 0.28 0.56 519.20

Average Parameter or Emission During Exceedence 140 5.6 5.6 0.28 0.56 519.20

Subpart M, Semiannual Subtotal 560 22.4 22.4 1.12 2.24 2,076.79

Log In/Out Time[8]

Annual Report

Storage Vessels 1.5 1.5 0.075 0.15 139.07

Equipment Leaks 1.5 1.5 0.075 0.15 139.07

Process Vents 1.5 1.5 0.075 0.15 139.07

Login/Out Subtotal (due to annual report) 4.5 4.5 0.225 0.45 417.21

Semi Annual Report

Storage Vessels 3 3 0.15 0.3 278.14

Equipment Leaks 3 3 0.15 0.3 278.14

Process Vents 3 3 0.15 0.3 278.14
D-7

Table D.3 Annual Cost for Electronic Reporting for the Model Refinery (Cont.)

Data Element

(A) (B) (F) (G) (H)

TOTAL COST ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr 

Data 

Elements to 

be Entered 

Per Year

Total Hours 

per Year[1] Technical

Hours

Managerial

Hours

Clerical

Hours

B=A/25 (G=F*0.05) (H=F*0.10)

Login/Out Subtotal (due to semiannual report) 9 9 0.45 0.9 834.43

Total Annual Hourly Reporting Requirement 83.5 83.5 4.2 8.4 

7,745.33 

[1] Assumed 25 data elements entered per hour.

[2] Assumed 10% of 48 Tanks (approximately 5).

[3] Assumed 1 instance for every process unit (16 process units).

[4] Assumed 10% of 48 Tanks (approximately 5) with data elements entered twice a year for semiannual reporting. 

[5] Assumed 5 releases per process units (16 process units) with data elements entered twice a year for semiannual reporting.

[6] Assumed 1 occurrence per process unit (16 process units) with data elements entered twice a year for semiannual reporting.

[7] Assumed 10 instances for every process vent (7 process vents) with data elements entered twice a year for semiannual reporting.

[8] Assumed a general 1.5 hour period to log in and out of system for each report to account for administrative issues such as account and password.
D-8

Table D.4 Annual Cost for Electronic Reporting for the Model Chemical Plant

Data Element

(A) Data 

Elements to be 

Entered Per 

Year

(B) Total Hours 

per Year[1]

B=A/25

(F) Technical 

Hours

(G) 

Managerial 

Hours

(G=F*0.05)

(H) 

Clerical 

Hours

(H=F*0.10)

TOTAL COST ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr 

Information Required in the Annual Report

Subpart I[2]

Inspection records

Defect 2 0.08 0.08 0.004 0.008 7.42

Leak 2 0.08 0.08 0.004 0.008 7.42

Failure 2 0.08 0.08 0.004 0.008 7.42

Documentation of Emptying for:

Defect 2 0.08 0.08 0.004 0.008 7.42

Leak 2 0.08 0.08 0.004 0.008 7.42

Failure 2 0.08 0.08 0.004 0.008 7.42

Documentation of Repair for:

Defect 2 0.08 0.08 0.004 0.008 7.42

Leak 2 0.08 0.08 0.004 0.008 7.42

Failure 2 0.08 0.08 0.004 0.008 7.42

Estimate of Emissions from Floating Roof Landings 2 0.08 0.08 0.004 0.008 7.42

Estimate of Emission from Overfilling 2 0.08 0.08 0.004 0.008 7.42

Estimate of Emissions from Pressure Vessel Defects 2 0.08 0.08 0.004 0.008 7.42

Total 24 0.96 0.96 0.048 0.096 89.01 

Subpart J[3]

Process Unit Identification 3 0.12 0.12 0.006 0.012 11.13

Count of Leaking Equipment 3
D-9

Table D.4 Annual Cost for Electronic Reporting for the Model Chemical Plant (Cont.)

Data Element

(A) Data 

Elements to be 

Entered Per Year

(B) Total Hours 

per Year[1]

B=A/25

(F) Technical 

Hours

(G) 

Managerial 

Hours

(G=F*0.05)

(H) 

Clerical 

Hours

(H=F*0.10)

TOTAL COST ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr 

Valves 3 0.12 0.12 0.006 0.012 11.13

Pumps 3 0.12 0.12 0.006 0.012 11.13

Connectors 3 0.12 0.12 0.006 0.012 11.13

Agitators 3 0.12 0.12 0.006 0.012 11.13

Compressors 3 0.12 0.12 0.006 0.012 11.13

Total Count of Valves Monitored 3 0.12 0.12 0.006 0.012 11.13

Percent Leaking 3 0.12 0.12 0.006 0.012 11.13

Total Count of Connectors Monitored 3 0.12 0.12 0.006 0.012 11.13

Percent Leaking 3 0.12 0.12 0.006 0.012 11.13

Count of Equipment not Repaired

Valves 3 0.12 0.12 0.006 0.012 11.13

Pumps 3 0.12 0.12 0.006 0.012 11.13

Connectors 3 0.12 0.12 0.006 0.012 11.13

Agitators 3 0.12 0.12 0.006 0.012 11.13

Compressors 3 0.12 0.12 0.006 0.012 11.13

Non-repairable/Inaccessible 3 0.12 0.12 0.006 0.012 11.13

Delay of Repair Report 3 0.12 0.12 0.006 0.012 11.13

Results of M21 Test Post Release Test for G/V PRD 3 0.12 0.12 0.006 0.012 11.13

Results of M21 Test for Compressors 3 0.12 0.12 0.006 0.012 11.13

Results of M21 Test for OEL 3 0.12 0.12 0.006 0.012 11.13
D-10

Table D.4 Annual Cost for Electronic Reporting for the Model Chemical Plant (Cont.)

Data Element

(A) Data 

Elements to be 

Entered Per 

Year

(B) Total Hours 

per Year[1]

B=A/25

(F) Technical 

Hours

(G) 

Managerial 

Hours

(G=F*0.05)

(H) 

Clerical 

Hours

(H=F*0.10)

TOTAL COST ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr 

Process vent Requirements 14 0.56 0.56 0.028 0.056 51.92 

Total 77 2.96 2.96 0.148 0.296 274.43 

Subpart M There are no annual Subpart M reports.

Information Required in the Semiannual Report

Subpart I[4]

Storage Vessel ID 4 0.16 0.16 0.008 0.016 14.83 

Date of Empty/Repair 4 0.16 0.16 0.008 0.016 14.83 

Start Date Floating Roof Landing Does Not Meet 

65.315(b)(1) 4 0.16 0.16 0.008 0.016 14.83 

End Date Floating Roof Landing Does Not Meet 

65.315(b)(1) 4 0.16 0.16 0.008 0.016 14.83 

Inspection record for pressure vessels 4 0.16 0.16 0.008 0.016 14.83 

Total 20 0.8 0.8 0.04 0.08 74.17 

Subpart J

PRD Release[5]

PRD ID

30 1.2 1.2 0.06 0.12 111.26

Duration of PRD Release 30 1.2 1.2 0.06 0.12 111.26

Emissions from PRD Release 30 1.2 1.2 0.06 0.12 111.26

Compressor Leak[6]

Compressor ID 6 0.24 0.24 0.012 0.024 22.25 

Number of days between Instrument Reading 6 0.24 0.24 0.012 0.024 22.25 

OEL Leak (Cap and Plug)[6]

OEL ID 6 0.24 0.24 0.012 0.024 22.25 
D-11

Table D.4 Annual Cost for Electronic Reporting for the Model Chemical Plant (Cont.)

Data Element

(A) Data 

Elements to be 

Entered Per 

Year

(B) Total Hours 

per Year[1]

B=A/25

(F)

Technical 

Hours

(G) 

Managerial 

Hours

(G=F*0.05)

(H) 

Clerical 

Hours

(H=F*0.10)

TOTAL COST ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr 

Number of days between Instrument Reading 6 0.24 0.24 0.012 0.024 22.25 

OEL Release from Emergency Shutdown[6]

OEL ID 6 0.24 0.24 0.012 0.024 22.25 

Number of Releases 6 0.24 0.24 0.012 0.024 22.25 

Low Barrier Pressure Fluid[6]

Equipment ID 6 0.24 0.24 0.012 0.024 22.25 

Number of Occurrences 6 0.24 0.24 0.012 0.024 22.25 

Total 138 5.5 5.52 0.276 0.552 511.78 

Subpart M

Process Vents[7]

Process Unit ID

280 11.2 11.2 0.56 1.12 1,038.40

Start/End Date of Reporting Period 280 11.2 11.2 0.56 1.12 1,038.40

Start/End Date of Exceedence (Above Emission 

Limit/Parameter) 280 11.2 11.2 0.56 1.12 1,038.40

Average Parameter or Emission During Exceedence 280 11.2 11.2 0.56 1.12 1,038.40

Total 1120 44.8 44.8 2.24 4.48 4153.59

Log In/Out Time[8]

Annual Report

Storage Vessels 1.5 1.5 0.075 0.15 139.07

Equipment Leaks 1.5 1.5 0.075 0.15 139.07

Process Vents 1.5 1.5 0.075 0.15 139.07
D-12

Table D.4 Annual Cost for Electronic Reporting for the Model Chemical Plant (Cont.)

Data Element

(A) Data Elements 

to be Entered Per 

Year

(B) Total Hours per 

Year[1]

B=A/25

(F) Technical 

Hours

(G) 

Managerial 

Hours

(G=F*0.05)

(H) 

Clerical 

Hours

(H=F*0.10)

TOTAL COST ($)

Technical $83.01/hr

Managerial $121.38/hr

Clerical $36.35/hr 

Login/Out Subtotal (due to annual report) 4.5 4.5 0.225 0.45 417.21

Semi Annual Report

Storage Vessels 3 3 0.15 0.3 278.14

Equipment Leaks 3 3 0.15 0.3 278.14

Process Vents 3 3 0.15 0.3 278.14

Login/Out Subtotal (due to semiannual report) 9 9 0.45 0.9 834.43 

Total Annual Hourly Reporting Requirement 68.5 68.5 3.4 6.9 6,354.62 

[1] Assumed 25 data elements entered per hour.

[2] Assumed 10% of 20 Tanks.

[3] Assumed 1 instance for every process unit (3 process units).

[4] Assumed 10% of 20 Tanks with data elements entered twice a year for semiannual reporting. 

[5] Assumed 5 releases per process unit (3 process units) with data elements entered twice a year for semiannual reporting

[6] Assumed 1 occurrence per process unit (3 process units) with data elements entered twice a year for semiannual reporting

[7] Assumed 10 instances for every process vent (14 process vents) with data elements entered twice a year for semiannual reporting

[8] Assumed a general 1.5 hour period to log in and out of system for each report to account for administrative issues such as account and password.