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SUPPORTING STATEMENT 

ENVIRONMENTAL PROTECTION AGENCY

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

Industry (SOCMI) (Renewal)

Part A of the Supporting Statement

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

(SOCMI) (Renewal), EPA ICR Number 1854.07, OMB Control Number 2060-0443

1(b) Short Characterization/Abstract

This information collection request (ICR) is for the Consolidated Federal Air Rule (CAR) 

for the Synthetic Organic Chemical Industry (SOCMI) and its referencing subparts. The burden 

estimates in this ICR reflect the addition of the Direct Final Rule for Revisions to the CAR (72 

FR 48938; August 27, 2007); other burden estimates are consistent with the most recently 

approved ICR for the CAR. The U.S. Environmental Protection Agency (EPA) will use this 

information to ensure compliance with the provisions in the CAR and its referencing subparts.

All existing sources must be in compliance with the requirements of the CAR and/or its 

referencing subparts within three years of the effective date (i.e., promulgation date) of the 

appropriate standard for the affected source. All new sources must be in compliance with the 

requirements of the CAR and/or its referencing subparts upon startup or the promulgation date of 

standards for an affected source, whichever is later. Compliance is assumed through initial 

performance testing or design analysis, as appropriate; and ongoing compliance is demonstrated 

through parametric monitoring. Types of parameters monitored are incinerator temperature, 

scrubber flow rate, carbon adsorber regeneration frequency, as well as others. The appropriate 

parameter to monitor depends on the type of control device with the owner or operator chooses 

to comply.

On December 14, 2000, the CAR was promulgated under 40 CFR part 65. The CAR is 

an optional alternative compliance approach for plant sites that must comply with existing 

subparts in the Code of Federal Regulations (CFR). The CAR is a consolidation of major 

portions of 14 different New Source Performance Standards (NSPS) and National Emission 

Standards for Hazardous Air Pollutants (NESHAP) pertaining to storage vessels, process vents, 

transfer racks, equipment leaks, and the general provisions for the three applicable parts 

(40 CFR parts 60, 61, and 63). These subparts from 40 CFR parts 60, 61, and 63 are referred to 

as “referencing subparts” because they have been amended to refer to the CAR as a compliance 

alternative. The referencing subparts include 40 CFR part 60, subparts Ka, Kb, VV, VVa, DDD, 
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III, NNN, and RRR; 40 CFR part 61, subparts BB, Y, and V; 40 CFR part 63, subparts F, G, H, 

and I.

Compliance with the CAR is a voluntary alternative. Sources may continue to comply

with existing applicable rules or may choose to comply with the consolidated rule. When 

preparing renewals for the CAR, or the referencing subparts, estimates are made of the 

percentage of existing sources that will opt to comply with the CAR in lieu of the referencing 

subparts. Because the CAR is designed for, although not limited to, SOCMI facilities, the 

number of facilities opting to comply with the CAR is based on the estimated number of SOCMI 

facilities. It is estimated that 25 percent of non-Hazardous Organic NESHAP (HON) sources 

will opt to comply with the CAR if the per-source burden of complying with the CAR is less 

than the per-source burden of complying with the referencing subpart. For those referencing 

subparts for which the per-source burden of complying with the CAR is higher than the persource burden of complying with the referencing subpart (subparts Ka, Kb, Y, VV, VVa, III, 

NNN, RRR, and DDD), it is estimated that 5 percent of sources will opt to comply with the 

CAR. It is also estimated that 25 percent of HON sources will opt to comply with the CAR. 

It is assumed that all new sources will initially comply with the appropriate referencing subpart. 

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

Collection Request (ICR) with the following “Terms of Clearance” (TOC): 

Before this ICR is renewed, the burden hours should be adjusted to 

include those of ICR 2060-0599, and a nonsubstantive change filed 

to indicate that the two ICRs (2060-0599 and 2060-0443) are being 

consolidated into one ICR.

EPA has addressed each item of concern in the TOC by updating the burden estimates to 

include the burden hours and costs from ICR 2060-0599 which references the Direct Final Rule 

for Revisions to the CAR. It is estimated that the information collection for the Direct Final Rule 

for Revisions to the CAR will involve 6 respondents with 6 annual responses and respondent 

labor costs of $653. The total Agency burden for the revisions is estimated to be 6 hours per 

year at a cost of $311. There are no capital or operation and maintenance (O&M) costs 

associated with the Direct Final Rule for Revisions to the CAR. Additionally, information from 

ICR 2060-0599 was consolidated within the text of this ICR.

It is estimated that the consolidated collection will involve 3,311 respondents with 9,959 

annual responses and respondent labor costs of $188,133,406. The total Agency burden is 

estimated to be 24,543 hours per year at a cost of $1,290,254. Other costs will be $95,329,000

per year 1) total capital/setup costs will be $3,373,000 per year; and 2) O&M costs will be 

$91,956,000 per year.

The burden to the “Affected Public” may be found below in Table 8: Summary of 

Respondent and Agency Burden and Cost for Referencing Subparts and the CAR. The burden to 

the “Federal government” burden is attributed entirely to work performed by Federal employees 
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or government contractors and may also be found below in Table 8: Summary of Respondent 

and Agency Burden and Cost for Referencing Subparts and the CAR.

The CAR (Consolidated Air Rule)

In general, the NSPS, NESHAP, CAR, and maximum achievable control technology

(MACT) regulations require initial notifications including one-time notifications of initial 

startup, applicability, and initial compliance status; performance tests, periodic monitoring, 

recordkeeping, and reporting. Periodic reports are required semiannually, and a startup, 

shutdown, and malfunction (SSM) plan must be submitted and updated as needed. In addition, 

respondents taking advantage of various provisions for waivers, approval of alternative methods, 

and changes in submittal schedules would be required to submit requests or applications. This 

information is being collected to assure compliance with 40 CFR part 65.

The Direct Final Rule for Revisions to the CAR includes direct final amendments to the 

General Provisions of the CAR which allow source owners and operators to petition the 

Administrator for an extension of the regulatory deadline to conduct performance tests during 

force majeure events. A force majeure event is an event caused by circumstances beyond the 

control of the affected facility, its contractors, or any entity controlled by the affected facility that 

results in not meeting the regulatory requirement to conduct performance tests within the 

specified timeframe despite the affected facility’s best efforts to fulfill the obligation. Examples 

of such events are acts of nature, acts of war, terrorism, equipment failure, or safety hazard 

beyond the control of the affected facility. The source owner or operator must provide to the 

Administrator a written description of the event and a rationale for attributing the delay in testing 

beyond the regulatory deadline to the force majeure; describe the measures taken or to be taken 

to minimize the delay; and identify a date by which the performance test would be conducted.

NSPS subpart Ka: Storage Vessels for Petroleum Liquids

The NSPS for subpart Ka were proposed on May 18, 1978, and promulgated on April 4, 

1980. These standards apply to storage vessels of petroleum liquids that have a storage capacity 

greater than 151,416 (40,000 gallons), and for which construction, reconstruction, or 

modification commenced after May 18, 1978 and prior to July 23, 1984. There is a de minimis 

exemption located at §60.110a(b). The regulated pollutants are volatile organic compounds 

(VOC). The universe of sources subject to NSPS subpart Ka is closed. Any new sources will be 

subject to NSPS subpart Kb, the most recent VOC standard applicable to storage vessels. This 

information is being collected to assure compliance with 40 CFR part 60, subpart Ka.

NSPS subpart Kb: Volatile Organic Liquid (VOL) Storage Vessels

The NSPS for subpart Kb were proposed on July 23, 1984, and promulgated on April 8, 

1987. These standards apply to each storage vessel with a capacity greater than or equal to 40 

cubic meters that is used to store volatile organic liquids, for which construction, reconstruction, 

or modification commenced after July 23, 1984. There are exemptions for specific storage 

vessels listed in §§60.110b(b), 60.110b(c), and 60.110b(d). The standards include visual 
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inspection, leak detection, and repair for equipment configurations including fixed and floating 

roofs. The regulated pollutants are VOC. This information is being collected to assure 

compliance with 40 CFR part 60, subpart Kb.

NSPS subpart VV: Equipment Leaks of VOC in the SOCMI Industry

The NSPS for Emissions of VOC from Equipment Leaks in the SOCMI Industry were 

proposed on January 5, 1981, and promulgated on October 18, 1983. They apply to specific 

pieces of equipment contained within a process unit in the synthetic organic chemicals 

manufacturing industry which was constructed, modified, or reconstructed after the date of 

proposal and on or before November 7, 2006, and which produce as an intermediate or final 

product, one or more of the chemicals listed in §60.489. These include pumps in light liquid 

service, compressors, pressure relief devices in gas/vapor service, sampling connection systems, 

open-ended valves or lines, valves in gas/vapor service and light liquid service, pumps and 

valves in heavy liquid service, pressure relief devices in light liquid or heavy liquid service, 

flanges, and other connectors. The regulated pollutants are VOC. The universe of sources 

subject to NSPS subpart VV is closed. Any new sources will be subject to NSPS subpart VVa, 

the most recent VOC standard applicable to equipment leaks. This information is being 

collected to assure compliance with 40 CFR part 60, subpart VV.

NSPS subpart VVa: Equipment Leaks of VOC in the SOCMI Industry

NSPS subpart VVa is a standard that applies to equipment contained within a SOCMI

process unit that is constructed, modified, or reconstructed after November 7, 2006. The 

regulated pollutants are VOC. This information is being collected to assure compliance with 

40 CFR part 60, subpart VVa.

NSPS subpart DDD: VOC Emissions from the Polymer Manufacturing Industry

The NSPS for the polymer manufacturing industry were proposed on both September 30, 

1987 and January 10, 1989, and promulgated on December 11, 1990. These standards apply to 

facilities involved in the manufacture of polypropylene, polystyrene, or poly(ethylene 

terephthalate) commencing construction, modification, or reconstruction after the date of 

proposal or after January 10, 1989, depending on the process section. The affected facilities 

include: 1) For polypropylene and polyethylene manufacturing: each raw material preparation 

section, each polymerization reaction section, each material recovery section, each product 

finishing section, and each product storage; 2) For polystyrene manufacturing processes: each 

material recovery section; and 3) For polyethylene (terephthalate) manufacturing: each 

polymerization reaction section. For equipment leaks, the affected facilities are each group 

of fugitive emissions equipment within any process unit. The regulated pollutants are VOC. 

This information is being collected to assure compliance with 40 CFR part 60, subpart DDD.

NSPS subpart III: VOC Emissions from SOCMI Air Oxidation Unit Processes

The NSPS for the SOCMI Air Oxidation Unit Processes were proposed on October 21, 
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1983, and promulgated on June 29, 1990. These standards apply to the following facilities for 

which construction, modification or reconstruction is commenced after the date of proposal: 1) 

Each air oxidation reactor not discharging its vent stream into a recovery device; 2) Each 

combination of an air oxidation reactor and the recovery system into which its vent stream is 

discharged; and 3) Each combination of two or more air oxidation reactors and the common 

recovery system into which their vent streams are discharged. The standard applies to the 

affected facility which produces one or more of the chemicals listed in §60.617 as a product, coproduct, byproduct, or intermediate. The regulated pollutants are VOC. This information is 

being collected to assure compliance with 40 CFR part 60, subpart III.

NSPS subpart NNN: VOC Emissions from SOCMI Distillation Operations

The NSPS for the SOCMI Distillation Operations were proposed on December 30, 1983, 

and promulgated on June 29, 1990. These standards apply to the following facilities for which 

construction, modification or reconstruction is commenced after the date of proposal: 1) Each 

distillation unit not discharging its vent stream into a recovery device; 2) Each combination of a 

distillation unit and the recovery system into which its vent stream is discharged; and 3) Each 

combination of two or more distillation units and the common recovery system into which their 

vent streams are discharged. The standard applies to affected facilities producing one or more of 

the chemicals listed in §60.667 as a product, co-product, by-product, or intermediate. The 

regulated pollutants are VOC. This information is being collected to assure compliance with 40 

CFR part 60, subpart NNN.

NSPS subpart RRR: VOC Emissions from SOCMI Reactor Processes

The NSPS for the synthetic organic chemical manufacturing industry (SOCMI) Reactor 

Processes were proposed on June 29, 1990, and promulgated on August 31, 1993. These 

standards apply to affected facilities commencing construction, modification or reconstruction 

after the date of proposal: (1) Each reactor process not discharging its vent stream into a recovery

system; (2) Each combination of a reactor processes and the recovery system into which its vent 

stream is discharged; (3) Each combination of two or more reactor processes and the common 

recovery system into which their vent streams are discharged. The standard applies to affected 

facilities producing one or more of the chemicals listed in §60.707 as a product, co-product, byproduct, or intermediate. The regulated pollutants are VOC. This information is being collected 

to assure compliance with 40 CFR part 60, subpart RRR.

NESHAP subpart BB: Benzene Emissions from Benzene Transfer Operations

The National Emission Standards for Benzene Emissions from Benzene Transfer Operations 

were proposed on September 14, 1989, and promulgated on March 7, 1990. The affected facility

to which this subpart applies is the total of all loading racks handling a liquid containing 70 

weight-percent or more benzene, at which benzene is loaded into tank trucks, railcars, or marine 

vessels at each benzene production facility and each bulk terminal. However, specifically 

exempted from this regulation are loading racks at which only the following are loaded: benzeneladen waste (covered under subpart FF of part 61), gasoline, crude oil, natural gas liquids, 
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petroleum distillates (i.e., fuel oil, diesel, or kerosene), or benzene-laden liquid from coke byproduct recovery plants. In addition, any affected facility which loads only liquid containing less 

than 70 weight-percent benzene or whose annual benzene loading is less than 1.3 million liters of 

70 weight-percent or more benzene is exempt from the control requirements except for the 

recordkeeping and reporting requirements in §61.305(i). Marine vessels were given a one-year 

industry wide waiver of compliance, which was later extended to July 23, 1991, in order to allow 

for concurrent compliance with United States Coast Guard regulations. The regulated pollutant 

is benzene. This information is being collected to assure compliance with 40 CFR part 61, 

subpart BB.

NESHAP subpart Y: Benzene Emissions from Benzene Storage Vessels

The NESHAP for Benzene Emissions from Storage Vessels were proposed in 1980, and 

re-promulgated in 1989 (54 FR 38077) as 40 CFR part 61, subpart Y. Entities affected by this 

action are those owners and operators of benzene storage vessels that store benzene having a 

specific gravity within the range of specific gravities as specified in ASTM D 4734-98 for 

Refined Benzene-545. Storage vessels with a design storage capacity less than 38 cubic meters 

(10,000 gallons) are exempt from the provisions of the subpart. Similarly, storage vessels used 

for storing benzene at coke by-product facilities or vessels permanently attached to motor 

vehicles, such as trucks, rail cars, barges, ships, or pressure vessels designed to operate in excess 

of 204.9 kPa and without emissions to the atmosphere, are also exempt from this subpart. The 

regulated pollutant is benzene. This information is being collected to assure compliance with 40 

CFR part 61, subpart Y.

NESHAP subpart V: National Emission Standard for Equipment Leaks (Fugitive Emission 

Sources)

Affected facilities include the following sources that are intended to operate in volatile 

hazardous air pollutant (HAP) service: pumps, compressors, pressure relief devices, sampling 

connection systems, open-ended valves or lines, valves, flanges and other connectors, product 

accumulator vessels, and control devices or systems. The standards for this subpart are leak 

detection and repair (LDAR). The regulated pollutants are volatile HAPs. This information is 

being collected to assure compliance with 40 CFR part 61, subpart V.

NESHAP subparts F, G, H, and I: The HON

The MACT standards for the HON were proposed on December 31, 1992, and 

promulgated on April 22, 1994. These standards apply to chemical manufacturing process units 

(CMPU’s) in the SOCMI industries, which manufacture as a primary product one or more of the 

chemicals listed in Table 1 of 40 CFR part 63, subpart F; use as a reactant or manufacture as a 

product, by-product, or co-product, one or more of the organic HAPs listed in Table 2 of subpart 

F; and are located at a plant site that is a major source as defined in section 112(a) of the Act. 

Additionally, styrene-butadiene rubber production, pesticide production, polybutadiene 

production, chlorinated hydrocarbon use in the production of chemicals, pharmaceutical 

production, and miscellaneous butadiene use are subject to the negotiated regulations affecting 
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equipment leaks promulgated under subpart I. The emission points include transfer racks, 

storage tanks, wastewater systems, process vents and equipment leaks. The regulations apply to 

existing sources as well as new sources commencing construction or reconstruction after the date 

of proposal. Hazardous air pollutants are the pollutants regulated under these subparts. This 

information is being collected to assure compliance with 40 CFR part 63, subparts F, G, H, and I.

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

The EPA is charged under section 111 of the Clean Air Act (CAA), as amended, to 

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

achieving such emissions reduction, or any non-air quality health 

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

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

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

every four years.

The EPA is also charged under section 112 of the Clean Air Act, as amended, to establish 

standards of performance for each category or subcategory of major sources and area sources of 

hazardous air pollutants. These standards are applicable to new or existing sources of hazardous 

air pollutants and shall require the maximum degree of emission reduction.

In addition, section 114(a) states that the Administrator may require any owner/operator 

subject to any requirement of this Act to: 

(A) (A)Establish and maintain such records; (B) make such 

reports; (C) install, use, and maintain such monitoring 

equipment, and use such audit procedures, or methods; (D) 

sample such emissions (in accordance with such procedures or 

methods, at such locations, at such intervals, during such 

periods, and in such manner as the Administrator shall 

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

production variables or other indirect data when direct 

monitoring of emissions is impractical; (F) submit compliance 

certifications in accordance with Section 114(a)(3); and (G) 

provide such other information as the Administrator may

reasonably require.
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In the Administrator's judgment, pollutant emissions from storage vessels, process vents, 

transfer racks, and equipment leaks associated with the SOCMI cause or contribute to air 

pollution that may reasonably be anticipated to endanger public health or welfare. Therefore, the 

NSPS and NESHAP were promulgated for this source category at 40 CFR parts 60, 61, and 63 

referencing subparts.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure compliance with 

the applicable regulations which where promulgated in accordance with the Clean Air Act. The 

collected information is also used for targeting inspections and as evidence in legal proceedings.

The required recordkeeping and reporting are also used to: 1) certify compliance with the 

regulations; 2) determine the respondent’s compliance with the designated emission 

limitation(s); 3) notify regulatory agencies when a standard is violated; 4) evaluate continuous 

compliance through the use of emission or operational parameter monitors; and 5) ensure that 

plant personnel are following the required procedures and are periodically trained, as indicated.

3. Nonduplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under 40 CFR parts 60, 61, and 

63 referencing subparts. 

3(a) Nonduplication

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

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

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

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

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no 

duplication exists.

3(b) Public Notice Required Prior to ICR Submission to OMB

An announcement of a public comment period for the renewal of this ICR was published 

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

burden published in the Federal Register.

3(c) Consultations

Interested parties were provided an opportunity to comment on the burden associated 

with the CAR and other referencing subparts when the CAR was being developed. The first 

Federal Register Notice announcing renewal of this ICR also provided an opportunity to provide 

comments. In addition, the EPA provided a 90-day public comment period after proposal of the 

amendments to the standards of performance for equipment leaks of VOC in the SOCMI. All 
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affected parties were given the opportunity to comment on the proposed amendments during this 

period. During development of the amendments, EPA held meetings and conference calls with 

representatives of petroleum refining companies and their trade associations (the National 

Petroleum Refiners Association and the American Petroleum Institute); however, the 

recordkeeping and reporting requirements for the standards were not the specific items being 

discussed. Representatives of the American Chemistry Council declined invitations to 

participate in development of the proposed amendments.

For this renewal, representatives of the American Chemistry Council [Jim Griffin, 

Director, Regulatory and Technical Affairs, (703) 741-5242] and the Society of Chemical 

Manufacturers and Affiliates [Dan Moss, Manager, Environmental Policy and Advocacy, (202) 

721-4143] were contacted for consultation regarding EPA’s burden estimates. No comments 

were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

promulgated by OMB under 5 CFR part 1320, section 1320.5. However, most NESHAP and a 

few NSPS require records to be kept more than three years. This is consistent with the General 

Provisions as applied to the standards. EPA believes that the five-year records retention 

requirement is consistent the Part 70 permit program and the five-year statute of limitations on 

which the permit program is based.

The retention of records for five years allows EPA to establish the compliance history of 

a source, any pattern of non-compliance, and to determine the appropriate level of enforcement 

action. EPA has found that the most flagrant violators have violations extending beyond five 

years. In addition, EPA would be prevented from pursuing the violators due to the destruction or 

nonexistence of essential records.

3(f) Confidentiality

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

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

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

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

1978; 44 FR 17674, March 23, 1979).
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3(g) Sensitive Questions

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

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are source category

description. The United States Standard Industrial Classification (SIC) codes and the 

corresponding North American Industry Classification System (NAICS) codes for the 

respondents are listed below.

Standard SIC Code NAICS Code

All referenced subparts 

2821 325211

2824 325222

2851 32551

2865 325111, 325132, 325192

2869 32511, 325193, 325199

2899 32511, 325199

2911 32411

2951 324121

2952 324122

2992 324191

2999 324199

4212 562111, 562112, 562119, 48411, 

48421, 48422

4213 484121, 484122, 48421, 48423

4214 48411, 48421, 48422

4215 49211, 49221

4221 49313

4222 49312

4225 49311, 53113

4226 49312, 49311, 49319

4231 48849

4412 483111

4424 483113

4432 483113

4449 483211

4481 483112, 483114

4482 483114, 483212

4489 483212, 48721

4491 48831, 48832

4492 48833
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Standard SIC Code NAICS Code

4493 71393

4499 532411, 48831, 48833, 48839

4724 56151

4725 56152

4729 488999, 561599

4731 541614, 48851

4741 532411, 48821

4783 488991

4785 48839, 48849

4789 488999, 48711, 72231, 48821

This table is not meant to be exhaustive, but rather provides a guide for readers regarding 

the entities likely to be regulated by this standard. To determine whether the standard applies to 

a particular entity, please see the applicability provisions in the standard.

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the CAR and its 

referencing subparts.

Attachment A lists the recordkeeping and reporting requirements for the CAR and its 

referencing subparts.

Electronic Reporting

At present, many respondents to CAA standards use monitoring equipment that 

automatically records parameter data. Although personnel at the affected facility must evaluate 

the data, this internal automation has significantly reduced the burden associated with monitoring 

and recordkeeping at the plant site.

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

reporting systems to transmit data electronically. However, electronic reporting systems are still 

not widely used. At this time, it is estimated that approximately 20 percent of the respondents 

use electronic reporting.

(ii) Respondent Activities

The respondent activities required by the CAR and its referencing subparts are identified 

in the following table.

Respondent Activities

Read instructions.
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Respondent Activities

Install, calibrate, maintain, and operate CPMS for the appropriate control device

Perform initial performance test and repeat performance tests if necessary.

Write the notifications and reports listed in Attachment A

Enter information required to be recorded in Attachment A.

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

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

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

maintaining information.

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

providing information.

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

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

Transmit, or otherwise disclose the information.

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

Management

5(a) Agency Activities 

The Agency activities associated with the CAR are presented in Table 1; the Agency

activities associated with the Direct Final Rule for Revisions to the CAR are shown below in 

Table 3; and the Agency activities associated with the referencing subparts are shown in Tables 

F-1 through F-12. EPA conducts one or more of these activities in connection with the 

acquisition, analysis, storage, and distribution of the required information.

5(b) Collection Methodology and Management

Following notification of startup, the reviewing authority could inspect the source to 

determine whether the pollution control devices are properly installed and operated. 

Performance test reports are used by the Agency to discern a sources initial capability to comply

with the emission standard. Data and records maintained by the respondents are tabulated and 

published for use in compliance and enforcement programs. The semiannual reports are used for 

problem identification, as a check on source operation and maintenance, and for compliance 

determinations.

The results of these evaluations are entered into the Air Facility System (AFS), which is 

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

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

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

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

EPA and its delegated Authorities can edit, store, retrieve, and analyze the data.
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The records required by this regulation must be retained by the owner/operator for five

years.

5(c) Small Entity Flexibility

A majority of the respondents are large entities (i.e., large businesses). The number of 

small businesses affected by this rule is not known. However, the impact on small entities (i.e., 

small businesses) was taken into consideration during the development of the regulation. Due to 

technical considerations involving the process operations and the types of control equipment 

employed, the recordkeeping and reporting requirements are the same for both small and large 

entities. The Agency considers these to be the minimum requirements needed to ensure 

compliance and, therefore, cannot reduce them further for small entities. To the extent that 

larger businesses can use economies of scale to reduce their burden, the overall burden will be 

reduced.

5(d) Collection Schedule

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

shown below in Table 6: Basis for Annual Respondent Burden of Reporting and Recordkeeping 

for the CAR, and Tables G-1 through G-13: Annual Burden of Reporting and Recordkeeping 

Requirements for the referencing subparts, respectively.

6. Estimating the Burden and Cost of the Collection

Table 6 for the CAR, Table 7 for the Direct Final Standards, and Tables G-1 through G13 for the referencing subparts document the computation of individual burdens for the 

recordkeeping and reporting requirements applicable to the industry. The individual burdens are 

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

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

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

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

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

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 1,988,952 hours. The recordkeeping hours shown 

in Table 8 are 410,576. The reporting requirement hours shown in Table 8 are 1,578,376. These 

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

regulation, Agency knowledge and experience with the NSPS and NESHAP programs, the 

previously approved ICR, and any comments received.
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6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $114.49 ($54.52 + 110%) 

Technical $98.20 ($46.76 + 110%)

Clerical $48.53 ($23.11 + 110%)

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

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

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

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

(ii) Estimating Capital/Startup and Operation and Maintenance Costs

Because we assume that no new sources will opt to comply with the CAR at startup over 

the next 3 years, there are no capital costs associated with the CAR. Facilities that comply with 

the CAR are assumed to have already purchased any equipment needed to comply with the 

referencing subpart. There are no capital costs associated with the Direct Final Rule for 

Revisions to the CAR. Capital/startup and O&M costs for the referencing subparts are 

summarized in Table 8. 

Details of the capital/startup and O&M costs, as taken from the most recently approved 

ICR for the CAR and referencing subparts, are detailed in Appendix J. 

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

The total capital/startup costs for this ICR are $3,373,000. This is the total of column J in 

Table 8. The total operation and maintenance (O&M) costs for this ICR are $91,956,000. This 

is the total of column I. in Table 8 The average annual cost for capital/startup and operation and 

maintenance costs to industry over the next three years of the ICR is estimated to be 

$95,329,000. These are recordkeeping costs.

6(c) Estimating Agency Burden and Costs

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

information. The EPA compliance and enforcement program includes activities such as the 

examination of records maintained by the respondents and the publication and distribution of 

collected information.

The average annual Agency burden and cost during the three years of the ICR is 24,543 

hours and $1,290,254. This is calculated below in Table 2 for the CAR, Table 3 for the Direct 
15

Final Rule for Revisions to the CAR, and Attachments F-1 through F-12 for the referencing 

subparts, and is summarized in Table 8.

This cost is based on the average hourly labor rate as follows:

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

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

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

the benefit packages available to government employees.

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

The total number of respondents is 3,311. The calculation of respondents is summarized 

below in Column (A) of Table 8 for the CAR the Direct Final Rule for Revisions to the CAR, 

and the referencing subparts.

The total number of responses is 9,959. The calculation of responses is summarized 

below in Column (B) of Table 8 for the CAR the Direct Final Rule for Revisions to the CAR, 

and the referencing subparts.

The total annual labor costs are $188,133,406. A summary of the annual labor costs may

be found below in Table 8. A detailed description of the annual labor costs may be found in 

Table 6 for the CAR, Table 7 for the Direct Final Rule for Revisions to the CAR , and 

Attachments G-1 through G-13 for the referencing subparts. 

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculations for the respondents and the 

Agency are summarized below in Table 8 and detailed in Tables 2 and 6 for the CAR, Tables 3 

and 7 for the Direct Final Rule for Revisions to the CAR, and Tables F-1 through F-12, and G-1 

through G-13 for the referencing subparts, respectively.

(i) Respondent Tally

The total annual labor hours are 1,988,952. Details regarding these estimates may be 

found below in Table 6 for the CAR, Table 7 for the Direct Final Rule for Revisions to the CAR,

and Tables F-1 through F-12, and G-1 through G-13 for the referencing subparts, respectively. 

Furthermore, the overall annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 200 hours per response.

 
16

The total annual capital/startup and O&M costs to the regulated entity are $95,329,000. 

The cost calculations are detailed in Section 6(b)(iii), Capital/Startup vs. Operation and 

Maintenance (O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 

24,543 labor hours at a cost of $1,290,254. This is summarized below in Table 8 and detailed in 

Table 2 for the CAR, Table 3 for the Direct Final Rule for Revisions to the CAR, and Tables F-1 

through F-12 for the referencing subparts. 

6(f) Reasons for Change in Burden

There is an increase of 43 burden hours from the most recently approved ICR due to 

adjustments. These adjustments include revisions to the CAR in the Direct Final Rule, the 

retention of decimal places during intermediate calculations, and correction of a calculation error 

in the burden estimates for subpart VVa in the most recent approved ICR. Additionally, there is 

an increase in both respondent and Agency costs resulting from labor rate adjustments from the 

year 2006 to the most recently available rates. The increases in respondent and Agency labor 

costs are the result of labor rate increases in the managerial, technical, and clerical labor 

categories. Specific changes to tables are described below:

Tables 2 and 6 - The tables were updated to calculate Agency and respondent costs 

based on updated labor rates which increased the overall cost for the CAR.

Table 3 – The table was added to include the Agency cost and hourly burden associated 

with the Direct Final Rule for Revisions to the CAR. The estimates are based on the 

estimates made in the previous ICR renewal for the revisions.

Table 7 – The table was added to include the respondent cost and hourly burden 

associated with the Direct Final Rule for Revisions to the CAR. The estimates are based 

on the estimates made in the previous ICR renewal for the revisions.

Table 8 - Since this is a summary table, the appropriate entries were changed according 

to the changes made to Tables F-1 to F-12, and G-1 to G-13. Summary information was 

also added for the Direct Final Rule for Revisions to the CAR.

Tables F-1 to F-12 - The tables were updated to calculate Agency costs based on 

updated labor rates which increased the overall cost for each subpart.

Tables G-1 to G-13 - The tables were updated to calculate Respondent costs based on 

updated labor rates which increased the overall cost for each subpart.
17

6(g) Burden Statement

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

is estimated to average 200 hours per response. Burden means the total time, effort, or financial 

resources expended by persons to generate, maintain, retain, disclose, or provide information to 

or for a Federal agency. This includes the time needed to review instructions; to develop, 

acquire, install, and utilize technology and systems for the purposes of collecting, validating and 

verifying information, processing and maintaining information, and disclosing and providing 

information; to adjust the existing ways to comply with any previously applicable instructions 

and requirements; to train personnel to be able to respond to a collection of information; to 

search data sources; to complete and review the collection of information; and to transmit or 

otherwise disclose the information.

An agency may not conduct or sponsor, and a person is not required to respond to, a 

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

Numbers for EPA’s regulations are listed at 40 CFR part 9 and 48 CFR chapter 15.

To comment on the Agency’s need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID Number EPA–HQ–OECA–2010–0376. An electronic version of the public docket is 

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

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

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

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

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

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

Room 3334, 1301 Constitution Avenue NW, Washington, DC. The EPA Docket Center Public 

Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal 

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the docket center is (202) 566-1752. Also, you can send comments to the Office of 

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

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

Number EPA–HQ–OECA–2010–0376 and OMB Control Number 2060-0443 in any

correspondence.

Part B of the Supporting Statement

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

information.
18

TABLE 1: AGENCY ACTIVITIES

Performance Tests

 - Initial

 - Repeat

Review Reports

 - Notification of Initial Startup

 - Notification of Performance Test

 - Initial Compliance Status

 - Startup, Shutdown, Malfunction Plans

 - Periodic Reports

TABLE 2: ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT FOR 

THE CAR PROVISIONS

Burden Item

(Reports to Review)

Average 

Hours per 

Activity

(a)

Number of 

Activities per 

Year

(b)

Estimated 

Technical 

Hours per 

Yeara

(c) 

Estimated 

Managerial 

Hours per 

Yearb

(d)

Estimated 

Clerical 

Hours per 

Yearc

(e)

Annual 

Costd

(f)

1. Initial Notification of Part 

65 Applicability 2 27 e

54 3 5 $2,799 

2. Review Equipment Leak 

Monitoring 5 636 f

3,180 159 318 $164,802 

3. Review Periodic Reports 4 80 g320 16 32 $16,584 

TOTAL ANNUAL COST 3,554 178 355 $184,185

TOTAL ANNUAL BURDEN 4,087 $368,369

Assumptions:

a

c = a x b

b Estimate managerial hours are 5 percent of technical hours.

c Estimate clerical hours are 10 percent of technical hours.

d Annual cost is the sum of costs for technical, managerial, and clerical hours based on the Office of Personnel 

Management (OPM),

2010 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to 

account for the benefit packages available to government employees.

Managerial - $62.27 (GS-13, Step 5, $38.92 + 60%)

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)

e Estimate that all CAR sources must submit an Initial Notification of Part 65 Applicability. It is estimated that 1/3 

of the sources will submit an initial notification in each of the three years covered by this ICR. This equates to 27 

per year (80/3) during each of the three years following promulgation.

f Estimate that 318 equipment leak sources will comply with the CAR (240 from the HON, 59 from subpart VV and 

19 from subpart V - see Table 4). Reports for equipment leaks will be submitted semiannually (318 x 2 = 636 per 

year). See Attachment C for assumptions and further description of activities.

g Estimate that 25 percent of the 320 SOCMI facilities which equals 80 facilities will opt to comply with the CAR 

and must submit periodic reports each year. 
19

TABLE 3: ANNUAL BURDEN AND COST TO THE FEDERAL GOVERNMENT 

OF THE DIRECT FINAL STANDARDS

Activity

(A)

Hours per 

occurrence

(B)

Hours per plant 

per year

(C) 

Plants per 

year

(D)

Technical personhours per year 

(D=BxC)

(E)

Management 

person-hours 

per year 

(Dx0.05)

(F)

Clerical 

person-hours 

per year 

(Dx0.1)

(G)

Cost, $a

Report Review/Filing 1 1 6 6 0.3 0.6 $310.95 

TOTAL BURDEN AND 

COST (SALARY)

6 0.3 0.6 $310.95

TOTAL ANNUAL COST

Assumptions:

a Costs are based on the following hourly rates: technical at $46.21, management at $62.27, and clerical at $25.01
20

TABLE 4: ESTIMATED NUMBER OF SOURCES SUBJECT TO REFERENCING 

SUBPARTS THAT WILL OPT TO COMPLY WITH THE CAR

Referencing Subpart Estimated Number of Sources 

Complying with CAR a,b

Storage Vessels

Ka 458

Kb 382

Y 0

Transfer Racks

BB 0

Equipment Leaks

V 19

VV 59

VVa 0

Process Vents

III 1

NNN 71

RRR 8

DDD 5

HON F & G - Storage Vessels 800

HON F & G - Transfer Racks 320

HON H &I -- Equipment Leaks 240

HON F & G - Process Vents 640

Assumptions:

a Note that the estimate is on a per-source basis, rather than on a facility basis and 

therefore correlates to (as described in the footnote to the appropriate Table), but 

does not match the facility entries in the referencing subpart burden tables in Tables 

F1-F12, and G1-G13. For the purpose of this information collection request, a source 

is defined as:

- one storage vessel (subparts Ka, Kb, Y, and G);

- one process vent (subparts DDD, III, NNN, RRR, and G);

- the collection of subject equipment for one process unit (subparts VV, VVa, V, 

and H & I); or

- one transfer rack (subparts BB and G).

b

From the most recently approved ICR. 
21

TABLE 5: BASIS FOR ANNUAL RESPONDENT BURDEN OF REPORTING AND RECORDKEEPING FOR THE CAR

Burden Item

Annual Burden in Technical Hours

Process Vents Storage Vessels Transfer Racks

Equipment Leaks

Inventory

Totald

With Connectors Without 

Connectorsa

per 

sourceb totalc per sourceb totalc per sourceb totalc per sourceb totalc per sourceb totalc per sourceb totalc

Read Rule and 

Instructions 2.9 2,103 1.1 1,804 1.1 352 2.5 600 1 78 1.8 144 5,081

Plan Activities 2.1 1,523 1.7 2,788 0.85 272 0.57 137 0.23 18 4.5 360 5,097

Training 1.3 943 0.5 820 0.5 160 0 0 0 0 0 0 1,923

Create, Test, Research 

and Development 28

20,30

0 16 26,240 16 5,120 380 91,200 155

12,09

0 0 0 154,950

Gather Information, 

Monitor and Inspect 14

10,15

0 17 27,880 17 5,440 263 63,120 108 8,424 54 4,320 119,334

Compile, Process and 

Review Data 0 0 0 0 0 0 0 0 0 0 18 1,440 1,440

Complete Forms 9 6,525 5.4 8,856 5.4 1,728 57 13,680 23 1,794 5.4 432 33,015

Record/ Disclose 28

20,30

0 2.8 4,592 2.8 896 4.7 1,128 1.9 148 9 720 27,784

File/Store 3 2,175 1.25 2,050 1.25 400 2.75 660 0.9 70 1.58 126 5,482

TOTAL 88.3

64,01

8 46 75,030 45 14,368 711 170,525 290

22,62

2 94 7,542 354,106

Assumptions:

a The HON, the basis for the CAR burden estimate, requires connector monitoring. Sources originally complying with subpart V or VV will not be required to perform 

connector monitoring if these facilities is the average of the per source burden for subparts V and VV. The average for subparts V and VV is 294 hours, 40.9 percent less 

than the HON-based estimate. Per-source estimates for each burden item were estimated by multiplying the HON-based estimate by 40.9 percent.

b

From most recently approved CAR ICR.
22

c Total burden for each source type is the product of the per-source burden and the total number of sources estimated to opt to comply with the CAR. The number of 

sources estimated to comply with the CAR are from the most recently approved ICR and are detailed in Table 4:

process vents - 725

 storage vessels - 1,640

transfer racks - 320

equipment leaks with connector monitoring - 240

equipment leaks without connector monitoring - 78 

facilities (used for inventory estimate) - 80

d Total burden for each burden item is the sum of totals for each source type. This burden represents technical hours only and is the basis for determining total burden in 

Table 6. 
23

TABLE 6: ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTS 

FOR THE CAR

Burden Item

Average 

Hours per 

Activity

(a)

Number of 

Activities per 

year per 

source (b)

Technical 

Hours per year 

per source

(c)

Estimated 

Technical Hours 

per year

(d)

Estimated 

Managerial Hours 

per year

(e)

Estimated 

Clerical Hours 

per year

(f)

Annual Cost

(g)

Read Rule and Instructions 2.76 23 63.51 5,081 254 508 $552,698 

Plan Activities 4.90 13 63.71 5,097 255 510 $554,439 

Training 6.01 4 24.04 1,923 96 192 $209,179 

Create, Test, Research and 

Development 19.56 99 1936.88 154,950 7,748 15,495 $16,855,074 

Gather Information, Monitor and 

Inspect 2.20 677 1491.68 119,334 5,967 11,933 $12,980,854 

Compile, Process and Review Data 18.00 1 18.00 1,440 72 144 $156,640 

Complete Forms 82.54 5 412.69 33,015 1,651 3,302 $3,591,289 

Record/ Disclose 13.36 26 347.30 27,784 1,389 2,778 $3,022,274 

File/Store 1.96 35 68.53 5,482 274 548 $596,318 

TOTAL COST 354,106 17,705 35,411 $38,518,765 

TOTAL BURDEN HOURS 407,222

Assumptions:

Following is a brief explanation of each column. A more detailed description is provided in Attachment E.

(a) Average hours per activity are back-calculated by dividing (c) by (b)

(b) Number of activities per year is based on the estimate of number of activities per year for the HON, with a reduction to reflect the consolidation of activities achieved 

through the CAR.

(c) Technical hours per year per source are the total technical hours for a burden item as estimated in Table 5, divided by 80 facilities.

(d) Estimated technical hours per year are the total technical hours for all facilities for each burden item, as estimated in Table 4.

(e) Estimated managerial hours per year are assumed to be 5 percent of technical hours. (e) = (d) x 0.05.

(f) Estimated clerical hours per year are assumed to be 10 percent of technical hours. (f) = (d) x 0.10.

(g) Annual Cost is the sum of costs for technical, managerial, and clerical hours based on the following rates from the United States Department of Labor, Bureau of 

Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates 

have been increased by 110 percent to account for the benefit packages available to those employed by private industry: Managerial -$114.49 ($54.52 + 110%), 

Technical - $98.20 ($46.76 + 110%), Clerical - $48.53 ($23.11 + 110%).
24

TABLE 7: ANNUAL RESPONDENT BURDEN AND COST OF REPORTING REQUIREMENTS OF THE DIRECT FINAL 

STANDARDS

Burden item

(A)

Personhours per 

occurrence

(B)

No. of 

occurrences 

per 

respondent 

per year

(C) 

Personhours per 

respondent 

per year 

(C=AxB)

(D)

Number of 

respondents 

per year

(E)

Technical 

personhours per 

year 

(E=CxD)

(F)

Management 

person-hours 

per year 

(Ex0.05)

(G)

Clerical 

personhours per 

year 

(Ex0.1)

(H)

Cost,$a

1. Applications N/A

2. Survey and Studies N/A

3. Acquisition, Installation, and

 Utilization of Technology and N/A

 Systems

4. Reporting Requirements

A. Read instructions 0.5 1 0.5 6

b

3 0.15 0.3 $326.33

B. Required activities N/A

C. Create information N/A

D. Gather existing information N/A

E. Write report 0.5 1 0.5 6

b

3 0.15 0.3 $326.33

5. Recordkeeping Requirements N/A

A. Read instructions N/A

TOTAL LABOR BURDEN AND COST 6 0.3 0.6 $652.67

Annualized cost of capital 0

Operation and maintenance (O&M) 0

Total (capital recovery plus O&M) 0

Assumptions:

a Costs are based on the following hourly rates: technical at $98.20, management at $114.49, and clerical at $48.53.

b One-time event for 6 respondents per year.
25

TABLE 8: SUMMARY OF RESPONDENT AND AGENCY BURDEN AND COST FOR REFERENCING SUBPARTS AND 

THE CAR

Subpart

(A)

Number of 

Respondents

(B)

Total 

Annual 

Responsesa

(C) 

Respondent 

Reporting 

Burden 

Hours

(D) 

Respondent 

Recordkeeping 

Burden Hours

(E) 

Respondent 

Burden 

Hoursa

(F)

Respondent 

Burden 

Costsa

(G)

Agency 

Burden 

Hoursb

(H)

Agency 

Burden 

Costsb

(I)

O&M 

Costs in 

000’sc

(J)

Capital/

Startup 

Costs in 

000’sc

NSPS Ka 174 194 522 45,931 46,453 $4,393,958 115 $5,182 0 0

NSPS Kb 580 1,976 21,607 63,879 85,486 $8,086,084 976 $43,999 42 27

NSPS VV 436 872 4,011 40,112 44,123 $4,173,575 2,006 $90,382 0 0

NSPS VVa 76 244 3,257 3,938 7,194 $680,512 614 $27,674 0 4.2

NSPS DDD 90 222 5,658 1,096 6,754 $638,850 570 $25,705 630 300

NSPS III 11 26 166 131 297 $28,065 69 $3,089 15 14

NSPS NNN 1,345 3,433 25,130 16,750 41,880 $3,961,350 8,955 $403,557 1,816 2,390

NSPS RRR 155 394 2,864 1,925 4,789 $452,950 1,026 $46,227 78 500

NESHAP BB 54 216 7,600 4,844 12,444 $1,177,081 497 $22,388 0 0

NESHAP Y 4 8 55 9 64 $6,092 9 $415 0 0

NESHAP V 55 123 3,904 3,628 7,533 $712,493 289 $13,008 0 0

NESHAP F, G, H, and I 245 1,845 1,134,630 190,078 1,324,708 $125,302,978 5,325 $239,947 67,375 138

CAR 80 400 368,966 38,256 407,222 $38,518,765 4,087 $368,369 22,000 0

CAR Revisionsd6 6 6 0 6 $653 6 $311 0 0

Totals 3,311 9,959 1,578,376 410,576 1,988,952 $188,133,406 24,543 $1,290,254 91,956 3,373

Assumptions:

a

From Tables G1- G13

b

From Tables F-1 through F-12

c

From Appendix J

d From Tables 3 and 7
1

Attachment A

Part 1: Recordkeeping and Reporting under the Consolidated Air Rule

1. General Records

2. Storage Vessel Records

• Storage vessel records where emissions are controlled by a fixed roof and internal 

floating roof (IFR), external floating roof (EFR), or EFR converted into an IFR as 

specified in §65.47.

• Storage vessel records where emissions are controlled by a control device as specified 

in §65.159 for flare compliance determination and §65.163 for closed vent systems.

• Storage vessel records where emissions are routed to a fuel gas system or process as 

specified in §65.163.

3. Process Vent Records

• General process vent records as specified in §§65.66, 65.63, and 65.160.

• Process vent records where emissions are controlled by a control device as specified 

in §65.159 for flare compliance determination records and §§65.162 and 65.163.

• Process vent records where recovery devices are used to maintain the total resource 

effectiveness (TRE) index value above 1.0 as specified in §65.160.

4. Transfer Rack Records

• General Transfer Rack Records as specified in §§65.83, 65.87, and 65.160.

• Transfer Rack Records where emissions are controlled by a control device (except for 

low-throughput transfer operations) as specified in §§65.159, 65.162, and 65.163.

• Low-throughput transfer operation records where emissions are controlled by a 

control device as specified in §§65.159 and 65.163.

5. Equipment Leak Records

• General equipment leak records as specified in §§65.103, 65.104, and 65.105. 

Specific equipment leak records where equipment leak emissions are not controlled 

by a control device or routed to a process or fuel gas system as specified in §§65.106, 

65.109, 65.111, and 65.120.

• Equipment leak records where emissions are controlled by a control device as 

specified in §§65.159 and 65.163.

6. Notification of Initial Startup

• General contents as specified in §§65.5 and 65.48.
2

• Initial Notification of Part 65 Applicability as specified in §65.5.

7. Initial Compliance Status Report

• General contents as specified in §65.5.

• Storage vessels as specified in §§65.163 and 65.164.

• Process vents as specified in §§65.63, 65.67, 65.160, 65.164, and 65.165.

• Low-volume transfer racks as specified in §§65.164 and 65.165.

• High-volume transfer racks as specified in §§65.83, 65.164, and 65.165.

• Equipment leaks as specified in §§65.117, 65.118, 65.119, and 65.120.

8. Periodic Reports

• General contents as specified in §65.6.

• Storage vessel records where emissions are controlled by an IFR, EFR, or EFR 

converted into an IFR as specified in §65.48.

• Storage vessels where emissions are controlled by a control device as specified in 

§65.166.

• Process vents as specified in §§65.67 and 65.166.

• Low-volume transfer racks as specified in §65.166.

• High-volume transfer racks as specified in §65.166.

• Equipment leaks as specified in §65.120.

• Closed vent systems as specified in §§65.143 and 65.166.

• Flares as specified in §65.166.

9. Other Notification and Reports

• Request for alteration of time periods or postmark as specified in §65.5.

• Startup, shutdown, and malfunction periodic report as specified in §65.6 (can be 

included with a periodic report).

• Written application for waiver of recordkeeping and reporting requirements as 

specified in §65.7.

• Written request for approval to use alternatives to the monitoring or recordkeeping 

provisions as specified in §65.7.

• Storage vessel refilling notification as specified in §65.48.

• Storage vessel seal gap measurement notification as specified in §65.48.

• Process vent Group 2A without a recovery device monitoring and recordkeeping and 

reporting plan as specified in §65.63.

• Process vent report of a process change if not included with the periodic report as 

specified in §65.67.

• Intent to conduct a performance test as specified in §65.67.

• Process vent report according to the plan for Group 2A process vents without a 

recovery device as specified in §65.67.

• Equipment leaks written request for alternative means of emission limitation as 
3

specified in §65.102.

Part 2: Burden for NSPS Sources Not Electing to Comply with the CAR

• Initial notifications as specified in §60.7.

• Provide notification of construction or reconstruction as specified in §60.7(a)(1).

• Provide notification of anticipated startup as specified in §60.7(a)(2).

• Provide notification of actual startup as specified in §60.7(a)(3).

• Provide notification of physical or operational change as specified in §60.7(a)(4).

• Demonstration of continuous monitoring system as specified in §60.7(a)(5).

• Performance test as specified in §60.8.

• Report on initial performance test results as specified in §60.8(a).

• Provide notification of initial performance test as specified in §60.8(d).

Requirements Specific to NSPS Subpart Ka

• Information prior to construction on vapor recovery and return or disposal system 

including emissions data, operations design specifications, and maintenance plan as 

specified in §60.113a(a)(2)(i-iv).

• Submit notification 30 days prior to seal gap measurement as specified in 

§60.113a(a)(1)(iv).

• Report within 60 days when a seal gap measurement exceeds the limits of §60.112a 

as specified in §60.113a(a)(1)(i)(E).

• Record gap measurements: Secondary seals every year and Primary seals every five 

years as specified in §60.113a (a)(1)(i)(D).

• Record whenever the liquid is changed, stored, period of storage and maximum true 

vapor pressure as specified in §60.115a(a).

Requirements Specific to NSPS Subpart Kb

• Notification 30 days prior to re/filling vessel for (a)(1) and (a)(4) IFR inspections as 

specified in §60.113b(a)(5).

• Notice 30 days prior to seal gap measurements as specified in §60.113b(b)(5).

• Notification 30 days prior to re/filling vessel for (b)(6) EFR inspections as specified 

in §60.113b(b)(6).

• Submit operating plan for closed vent or exempt control device as specified in 

§60.113b(c).

• Report describing equipment and certifying control for IFR as specified in 

§60.115b(a)(1).

• Record of each inspection required at §§60.113b(a) and 60.115b(a)(2).

• Report of visual defects as specified in §60.115b(a)(3).

• Report of seal holes/tears as specified in §60.115b(a)(4).

• Report describing equipment and certifying control for EFR as specified in 

§60.115b(b)(1).
4

• Report results of seal gap measurement required at §60.113b(b)(1) within 60 days as 

specified in §60.115b(b)(2).

• Record of each gap measurement required at §§60.113b(b) and 60.115b(b)(3).

• Report gaps exceeding limits within 30 days of inspection required by 

§§60.113b(b)(4) - 60.115b(b)(4).

• Records kept on closed-vent system as specified in §60.115b(c).

• Report of flare measurements as specified in §60.115b(d)(1).

• Records kept on flare as specified in §60.115b(d)(2).

• Report semiannually periods of pilot flame absent from flare as specified in 

§60.115b(d)(3).

• Records of dimensions and capacity of vessel as specified in §60.116b(b).

• Record of VOL stored, period of storage, and maximum true vapor pressure of lower 

kPa vessels as specified in §60.116b(c).

• Record of VOL stored, period of storage, and maximum true vapor pressure of higher 

kPa vessels as specified in §60.116b(d).

Requirements Specific to NSPS Subpart VV and VVa

• Recordkeeping as specified in §§60.486 and 60.486a.

• Semiannual reporting requirements as specified in §§60.487(a) through (c) and 

60.487a(a) through (c).

• Notification of alternative standard selected as specified in §§60.487(d) and 

60.487a(d).

• Report Performance tests as specified in §§60.487(e) and 60.487a(e).

Requirements Specific to NSPS Subpart DDD

• Initial performance test results or specified alternative reports as specified in §60.565.

• Semiannual reports of deviations from monitoring parameters, monitoring 

exceedances, changes in process operations, and periods during which control device 

is inoperative as specified in §60.565(k).

• Records of periods when flow monitor indicates emission stream is being diverted 

away from the control device as specified in §60.565(b).

• Records of monitoring parameters as specified in §60.565(c), (d), (e), (f), (g), (h).

• Results of monitoring during performance tests, including the vent system used to 

vent each affected stream to the control device; evidence of compliance with 

incineration requirements; evidence of compliance with boiler or process heater 

operation, and records from flare or pilot light flame heat sensing monitoring and 

periods of operation when the flare or pilot flame is absent as specified in §60.565(a), 

(b), (c), (d), (e), (f).

• Changes in production capacity, feedstock type, or catalyst type or replacement, 

removal or addition of product recovery equipment or an air oxidation reactor as 

specified in §60.565(g).

• Evidence of compliance with elected alternative provisions, and all periods of 
5

operation during which the performance boundaries are exceeded as specified in 

§60.565(h).

Requirements Specific to NSPS Subpart III

• Notification of the specific provisions of the standards which the owner has elected to 

comply as specified in §60.615(a).

• Record data measured during each performance test as specified in §§60.615(b) and 

60.615(h)(3).

• Continuously record equipment operating parameters as specified in §§60.615(c) and 

60.615(g).

• Record periods of operation during which the performance boundaries established 

during the most recent performance test are exceeded as specified in §§60.615(c) and 

60.615(g).

• Continuously record the indication of vent stream flow to the control device as 

specified in §60.615(d).

• Record all periods of operation of a boiler or process heater as specified in 

§60.615(e).

• Record results of flare pilot flame monitoring and all periods of operations in which 

the pilot flame is absent as specified in §60.615(f).

• Record changes in production capacity, feedstock type, catalyst type, or replacement, 

removal or addition of recovery equipment or an air oxidation reactor as specified in 

§60.615(h)(1).

• Record any recalculation of the TRE index value as specified in §60.615(h)(2).

• Written report of initial performance test results as specified in §§60.8 and 60.615(b).

• For the semiannual report exceedances of parameter boundaries established during 

the most recent performance test as specified in §60.615(j)(1).

• For the semiannual report all periods when the vent stream is diverted from the 

control device or has no flowrate as specified in §60.615(j)(2).

• For the semiannual report all periods when the boiler or process heater was not 

operated as specified in §60.615(j)(3).

• For the semiannual report all periods in which the flare pilot flame was absent as 

specified in §60.615(j)(4).

• For the semiannual report any recalculation of the TRE index value as specified in 

§60.615(j)(5).

Requirements Specific to NSPS Subpart NNN

• Notification of the specific provisions of the standards which the owner has elected to 

comply as specified in §60.665(a).

• Record data measured during each performance test as specified in §§60.665(b) and 

60.665(h)(3).

• Continuously record equipment operating parameters as specified in §§60.665 and 

60.665(g).
6

• Record periods of operation during which the performance boundaries established 

during the most recent performance test are exceeded as specified in §§60.665 and 

60.665(g).

• Continuously record the indication of vent stream flow to the control device as 

specified in §60.665(d).

• Record all periods of operation of a boiler or process heater as specified in 

§60.665(e).

• Record results of flare pilot flame monitoring and all periods of operations in which 

the pilot flame is absent as specified in §60.665(f).

• Record changes in production capacity, feedstock type, catalyst type, or replacement, 

removal or addition of recovery equipment or an air oxidation reactor as specified in 

§60.665(h)(1).

• Record any recalculation of the TRE index value as specified in §60.665(h)(2).

• Record data showing that the vent stream flowrate is less than 0.008 m3/min and any 

change in equipment or process operation that increases the operating vent stream 

flowrate including a measurement of the new flowrate as specified in §60.665(i).

• Record any change in equipment or process operation that increases the design 

production capacity of the process unit as specified in §60.665(j).

• Written report of performance test results as specified in §§60.8 and 60.665(b).

• For demonstrating compliance with the low capacity exemption levels, a report 

detailing the design production capacity of the process unit as specified in §60.665(n).

• For demonstrating compliance with the low flow exemption level, a report of the 

flowrate measurement as specified in §60.665(o).

• For the semiannual report, exceedances of parameter boundaries established during 

the most recent performance test as specified in §60.665(l)(1).

• For the semiannual report, all periods when the vent stream is diverted from the 

control device or has no flowrate as specified in §60.665(l)(2).

• For the semiannual report, all periods when the boiler or process heater was not 

operated as specified in §60.665(l)(3).

• For the semiannual report, all periods in which the flare pilot flame was absent as 

specified in §60.615(j)(4).

• For the semiannual report, any change in equipment or process operation that 

increases the operating vent stream flowrate above the low flow exemption level as 

specified in §60.665(l)(5).

• For the semiannual report, any change in equipment or process operation that 

increases the design production capacity above the low capacity exemption level as 

specified in §60.665(l)(6).

• For the semiannual report, any recalculation of the TRE index value as specified in 

§60.665(l)(7).

Requirements Specific to NSPS Subpart RRR

• Notification of the specific provisions of the standards which the owner has elected to 

comply as specified in §60.705(a).
7

• Exceedances of parameter boundaries established during the most recent performance 

test as specified in §60.705(l)(1).

• All periods when the vent stream is diverted from the control device or has no 

flowrate as specified in §60.705(l)(2).

• All periods in which the flare pilot flame was absent as specified in §60.705(l)(3).

• For the semiannual report, any changes in equipment or process operation that 

increases the operating vent stream flowrate above the low flow exemption level as 

specified in §60.705(l)(4).

• For the semiannual report, any change in equipment or process operation, that 

increases the design production capacity above the low capacity exemption level as 

specified in §60.705(l)(5).

• For the semiannual report, any recalculation of the TRE index value as specified in 

§60.705(l)(6).

• For the semiannual report, all periods recorded in which the seal mechanism is broken 

or the bypass line valve position has changed. A record of the serial number of the 

car-seal or a record to show that the key to unlock the bypass line valve was checked 

out must be maintained to demonstrate the period, the duration, and frequency in 

which the bypass line was operated as specified in §60.705(l)(7).

• For the semiannual report, any change in equipment or process operation that 

increases the vent stream concentration above the low concentration exemption level, 

including a measurement of the new vent stream concentration as specified in 

§60.705(l)(8).

• For the initial report, written report of performance test results as specified in §§60.8 

and 60.705(b).

• Record data measured during each performance test as specified in §§60.705(b) and 

60.705(g)(3).

• Continuously record equipment operating parameters as specified in §60.705(c).

• Records of diversion of vent stream from the control device as specified in 

§60.705(d)(1).

• Record results of flare pilot flame monitoring and all periods of operations in which 

the pilot flame is absent as specified in §60.705(e).

• Record periods of operation during which the performance boundaries established 

during the most recent performance test are exceeded as specified in §60.705(f).

• Record changes in production capacity, feedstock type, catalyst type, or replacement, 

removal or addition of recovery equipment as specified in §60.705(g)(1).

• Record any recalculation of the TRE index value as specified in §60.705(g)(2).

• Records to indicate that the vent stream flowrate is less than 0.011 scm/min and of 

any change in equipment or process operation that increases the operating vent stream 

flowrate, including measurement of the new vent stream flowrate as specified in 

§60.705(h).

• Each owner or operator of an affected facility that seeks to comply with the 

requirements of this subpart by complying with the design production capacity

provision, shall keep up-to-date, readily accessible records of any change in 

equipment or process operation that in creases the design production capacity of the 
8

process unit in which the affected facility is located as specified in §60.705(i).

• Each owner or operator of an affected facility that seeks to complying with the low 

concentration exemption, shall keep up-to-date, readily accessible records of any

change in equipment or process operation that increases the concentration of the vent 

stream of the affected facility as specified in §60.705(j).

Part 3: Burden for 40 CFR Part 61 NESHAP Sources Not Electing to Comply with the 

CAR

• Construction or modification application as specified in §61.07.

• Provide notification of anticipated startup as specified in §61.09(a)(1). 

• Provide notification of actual startup as specified in §61.09(a)(2).

• Source status report as specified in §61.10(a).

• Initial performance test as specified in §61.13.

• Provide notification of initial performance test as specified in §61.13.

• Report on initial performance test results as specified in §61.13(f).

• Provide notification of physical or operational change as specified in §61.15 .

Requirements Specific to NESHAP Subpart V

• Application for alternative means of emissions limitation as specified in §61.244.

• Recordkeeping as specified in §61.246.

• Reporting as specified in §61.247.

Requirements Specific to NESHAP Subpart Y

• Initial source report as specified in §61.274.

• Report of annual and periodic inspections for IFR as specified in §61.275(a).

• Supplemental annual periodic report for IFR as specified in §61.275(a).

• Report of 5 or 10 year internal inspections for IFR as specified in §61.275(b).

• Report of annual seal gap measurements for EFR as specified in §61.275(d).

• Report of 5 year seal gap measurements for EFR as specified in §61.275(d).

• Report of excess emissions for closed vent systems with control devices as specified 

in §61.275(e).

• Record of storage vessel design capacity as specified in §61.276(b).

• Record of information on closed vent systems with control devices as specified in 

§61.276(c).

Requirements Specific to NESHAP Subpart BB

• Obtain vapor tightness documentation at §61.305(h) every 12 months as specified in 

§61.302(d).

• Maintain vapor-tightness file on each affected facility as specified in §61.302(d) and 

(e).
9

• Record of measurements during each performance test as specified in §61.305(a).

• Engineering report as specified in §61.305(a)(5).

• Record of monitoring equipment parameters and excess emissions as specified in 

§61.305(b).

• Record vent valves status and maintain for at least two years as specified in 

§61.305(c).

• Records of periods of operation of steam generator or process heater kept up-to-date 

as specified in §61.305(d).

• Records of flare operation and monitoring kept up-to-date as specified in §61.305(e).

• Quarterly report by sources subject to as specified in §61.302, and controls as 

specified in §61.305(f).

• Documentation of vapor-tightness required under §61.302(d) and (e) on permanent 

file as specified in §61.305 (g).

• Documentation of vapor-tightness renewed at least once per year as specified in 

§61.305(h).

• Record and report information when exempt under §§61.300(b) and 61.305(i).

• Record of closed-vent system annual leak inspection required at §§61.242-ll(f)(2) 

through 61.302(k), and 61.246(d).

Part 4: Burden for 40 CFR Part 63 NESHAP Sources Not Electing to Comply with the 

CAR (MACT Subparts F, G, H and I: The HON)

1. Notifications

• Notification of construction or reconstruction as specified in §§63.5, 63.9, 63.100, 

63.151, 63.182, and 63.192.

• Notification of anticipated date of initial startup as specified in §§63.5, 63.9, 63.151, 

63.182, and 63.192.

• Notification of actual date of initial startup as specified in §§63.9, 63.151, 63.182, 

and 63.192.

• Notification of process changes as specified in §§63.100, 63.118, 63.146, 63.151, 

63.152, 63.182, and 63.192.

• Notification of performance test as specified in §63.103.

• Notification for storage tanks as specified in §63.192.

2. Reporting - Initial and Notification of Compliance Status

• Initial report requirements as specified in §§63.117, 63.122, 63.129, 63.146, 63.151, 

63.182, and 63.192.

• Reporting of operating parameter levels as specified in §§63.117, 63.120, 63.122, 

63.129, 63.130, 63.146, 63.151, 63.182, and 63.192.

• Statement of compliance/noncompliance as specified in §§63.117, 63.120, 63.122, 

63.127, 63.128, 63.129, 63.151, 63.152, 63.182, and 63.192.
10

3. Reporting - Periodic and Event Triggered

• Startup, shutdown and malfunction as specified in §§63.6, 63.10, 63.103, and 63.105.

• Exceedance of parameter boundaries established during the most recent performance 

test as specified in §§63.118, 63.122, 63.130, 63.146, 63.148, 63.151, 63.152, 63.182, 

and 63.192.

• Any change in equipment or process operation that increases emission levels above 

requirements in the standard as specified in §§63.103, 63.104, 63.122, 63.130, 

63.146, 63.148, 63.151, 63.152, 63.182, and 63.192.

• Written report of performance tests as specified in §§63.117, 63.120, 63.122, 63.129, 

63.146, 63.151, 63.152, 63.182, and 63.192.

• Delay of repair as specified in §§63.104, 63.122, 63.182, and 63.192.

4. Recordkeeping

• General Recordkeeping as specified in §63.103.

• Record of data measured during each performance test as specified in §§63.117, 

63.118, 63.123, 63.129, 63.130, 63.147, 63.148, 63.151, 63.152, 63.181, and 63.192.

• Record of periods of operation during which the performance boundaries established 

in the Notification of Compliance Status are exceeded as specified in §§63.118, 

63.120, 63.123, 63.130, 63.147, 63.148, 63.151, and 63.152.

• Records of Monthly visual inspections as specified in §§63.118, 63.130, 63.147, 

63.148, 63.181, and 63.192.

• Records of Annual visual inspections as specified in §§63.123, 63.147, 63.148, 

63.181 and 63.192.

• TRE records for process vents as specified in §63.117.

• Monitoring records as specified in §§63.118 and §63.123.

• Records of process changes for process vents as specified in §63.118.

• Records of delay of repair as specified in §§63.120 and §63.123.

• Record of storage vessel size as specified in §63.123.

• Record of vent system configuration for transfer racks as specified in §63.129.

• Record of design criteria for equipment leaks as specified in §63.118.

• Record of startup, shutdown and malfunction as specified in §§63.6, 63.103, 63.105, 

and 63.152.

• Records of continuous monitoring systems as specified in §63.103.
1

Attachment B

Purposely left blank.
1

Attachment C

Assumptions and Item Descriptions for Table 4

Assumptions are the same as Attachment E, and:

(A) That there are 318 total sources (240 from the HON, 59 from Subpart VV, 0 from 

Subpart VVa, and 19 from Subpart V) that must submit semiannual reports from equipment leak 

detection and repair programs as well as semiannual periodic reports. This equates to 636 EPA 

activities (318 * 2) during each of the three years following promulgation.

(B) That all sources must submit an Initial Notification of Part 65 Applicability or submit the 

corresponding information in a modification to their Title V permits. This equates to 80 EPA 

activities, or 27 per year (80/3) during each of the three years following promulgation.

Item descriptions:

(a) Average Hours per Activity are estimates of the specific activities and are the basis for 

estimating the overall burden.

(b) Number of Activities per Year represents the number of reports expected to be reviewed 

and other related activities during the course of the year, based upon assumptions (A) and (B).

(c) Estimated Technical Hours per Year is the product of (a) and (b).

(d) Estimated Managerial Hours per Year is 5 percent of (c).

(e) Estimated Clerical Hours per Year is 10 percent of (c).

(f) Estimated Annual Cost in $ Thousands per Year is the total cost of technical, managerial, 

and clerical hours and overhead using this formula:

(Ht * $46.21/hour) + (Hm * $62.27.20/hour) + (Hc * $25.01/hour) = (h)

1,000

Where:

Ht is (c), or technical hours,

Hm is (d), or managerial hours, and

Hc is (e), or clerical hours.

Source:

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

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

for the benefit packages available to government employees.
2

1) Initial Notification of Part 65 Applicability/Title V Modification represents the EPA 

review of either the Initial Notification of Part 65 Applicability report or the source’s Title V 

modification through which the source notifies EPA that it intends to comply with the CAR. As 

noted in the supporting statement text, the EPA does not expect any new sources to elect to 

comply with the CAR during the 3-year period following promulgation.

2) Review Equipment Leak Monitoring represents the review and screening of periodic

reports received as a result of the equipment leaks standard.

3) Review Periodic Reports represents the EPA review of periodic reports from new and 

existing sources.

TOTAL BURDEN AND COST is the total for each of the columns (c), (d), (e), and (f).
D1

Attachment D

Purposely left blank.
1

Attachment E

Assumptions and Item Descriptions for Table 6 

Assumptions are:

(A) That there are 320 existing facilities, of which 25 percent (80) chose to comply with the 

CAR.

(B) That the average representative source will consist of a variety of sources. The total 

number of sources expected to comply with the CAR includes (from Table 4):

• 1,640 storage vessels;

• 320 transfer racks;

• 240 collections of subject equipment, including connectors;

• 78 collections of subject equipment, not including connectors; 

• 80 facility wide inventories of emission points; and

• 725 process vents.

(C) That there are 5 percent (0.05) managerial and 10 percent (0.10) clerical hours required 

for every technical hour.

(D) That some activities necessary to generate reports involve creating records in the 

process, and that these activities are assumed to be reports activities alone, to avoid double 

counting these as records activities as well. Therefore, only items 8 and 9 are considered 

records burdens directly.

Item descriptions:

(a) Average Hours per Activity is back-calculated by dividing (b) into (c). Since the 

activities within each burden category can vary significantly, it is too inaccurate to assume 

an average to use to calculate (c). Estimated activity technical hours are calculated in Table 

5 and entered into column (d); (a) is then back-calculated with an estimated (b).

(b) Estimated Number of Activities per Year per Source represents the assumed typical 

number of separate activities a source may encounter during one year. This number may

vary from facility to facility depending on consolidation of activities, co-located readings, 

etc. Since so much variability exists, it is important to note that this an estimate. This 

number was only used to back-calculate (a). The numbers are based on the number of 

activities per year estimated for complying with the HON. The numbers have been reduced 

to reflect the consolidation of activities achieved through the CAR.

(c) Technical Hours per Year per Source is the total technical hours for a burden item, as 

estimated in Table 7 divided by 80 facilities. Because of the variability in the number and 
2

combination of sources at a facility, this value could vary widely.

(d) Estimated Technical Hours per Year is the sum of total technical hours for all sources for 

each burden item, as estimated in Table 7.

(e) Estimated Managerial Hours per Year is 5 percent of (d).

(f) Estimated Clerical Hours per Year is 10 percent of (d).

(g) Estimated Annual Cost in Thousands of Dollars per Year is the total cost of technical, 

managerial, and clerical hours and overhead using this formula:

(Ht * $98.20/hour) + (Hm * $114.49/hour) + (Hc * $48.53/hour)=(g)

Where:

Ht is (d), or technical hours,

Hm is (e), or managerial hours, and

Hc is (f), or clerical hours.

Source:

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

September 2009, Table 2. Civilian Workers, by occupational and industry group. The 

rates are from column 1, Total compensation. The rates have been increased by 110 

percent to account for the benefit packages available to those employed by private 

industry.

1) Read Rule and Instructions consists of the activities, less training, which involve 

comprehending the provisions in the standard and understanding how they apply to the 

respective points at a facility.

2) Plan Activities represents such burdens as design, redesign, and scheduling, as well as 

selecting methods of compliance.

3) Training represents the portion of activities from 1) Read Rule and Instructions for 

which an average facility would elect to provide class room instruction. The standard 

does not require specific training itself.

4) Create, Test, Research and Development are the activities involving testing, retesting, 

establishing operating ranges for parameters, and analyzing point by point applicability. 

Monitor-related refit, calibration, and maintenance activities are also included under this 

heading.
3

5) Gather Information, Monitor, and Inspect are the activities involving physical 

inspections of equipment, collection of monitored data, and other related activities.

6) Process/Compile and Review are the activities that involve analysis of the information 

collected for accuracy and compliance as well as appropriate records and reports required 

as a result.

7) Complete Reports represents the activities normally associated with filling out forms. 

Since the standard requires no standard forms, these activities relate to the preparing of 

formal reports and cover letters.

8) Record/Disclose are solely recordkeeping activities which occur once the appropriate 

report information has been extracted; see assumption (D). These activities involve 

software translation, duplication, or archival processes normally associated with data 

management and storage common to this industry.

9) Store/File are activities which are solely recordkeeping which occur once the 

appropriate report information has been extracted; see assumption (D). These activities 

involve the management life cycle of records, from the time they are filed and boxed up 

to the time they are disposed.

TOTAL BURDEN AND COST is the total for each of the columns (d), (e), (f), and (g)
4

ATTACHMENT F: EPA BURDEN AND COST FOR REFERENCING SUBPARTS

TABLE F-1: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART Kaa

Activity

(A)

EPA/hr 

Occurrence

(B)

Occurrences/

plant/yr

(C =AxB)

EPA 

hr/plant/yr

(D)

Plants/year

(E=CxD)

Technical 

hr/yr

(F=Ex0.05)

Managerial 

Hr/yr

(G=Ex0.10)

Clerical 

Hr/Yr

(H)

Total 

Cost per 

yeare

Report Review: New Plant

Vapor recoveryb

N/A

Report Review: Existing Plant

Notification of Reconstruction 2 1 2 0 0 0 0 $0

Notification of Modification 2 1 2 0 0 0 0 $0

Notification of seal gap measurement c

0.5 1 0.5 188 94 5 9 $4,872

Report of gap excessesc,d

1 1 1 6 6 0 1 $311

TOTAL ANNUAL HOURS 100 5 10

TOTAL ANNUAL BURDEN 115 $5,182

Assumptions”

a Assume no new sources subject to this regulation. All similar new sources will be subject to subpart Kb.

b Required only at start of construction. Any new storage vessel being constructed would be subject to the NSPS subpart Kb.

c Assume that 90 percent of the storage vessels will use a floating roof and be subject to seal gap measurement. The remaining 10 percent will use a closed vent 

system.

d Assume 25 percent of respondents using a floating roof will have excessive seal gaps requiring that a single report be filed once per year.

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%) 

 Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)
5

TABLE F-2: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART Kb

Reporting and Recordkeeping Requirements Assumptionsa

(A) 

Technical 

Hours

(B=A*.05)

Managerial Hours

(C=A*.10)

Clerical Hours

Cost/year

$

a

1) Review notification of construction. 37bnew 

notifications at 2 hours each 74 4 7 $3,835

2) Review notice of anticipated startup. 37 new

notifications at 1 hour each 37 2 4 $1,918

3) Review notice of actual startup. 37 new notifications at 

1 hour each 37 2 4 $1,918

4) Review notification of initial inspection @1 hr. each 37 2 4 $1,918

5) Review of IFR Failure Reportc; 55 sources @ 1 hr/ea 55 3 6 $2,850

6) Review Notification of Delay for Repair/Emptying IFRd; 

6 sources@ 1.2 hr/ea 7 0 1 $363

7) Review Notification to Re-Filld; 602 sources@ 1 hr/ea 602 30 60 $31,198

TOTAL ANNUAL HOURS 849 42 85

TOTAL ANNUAL BURDEN 976 $43,999

Assumptions:

a Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management 

(OPM) “2010 General Schedule” which excludes locality rates of pay.

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%) 

Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)

b Assume 111 new storage tanks will be constructed during each of the next three years, or 37 tanks per year (28 IFR’s, 7 EFR’s, 2 CVS).

c One percent failure rate for the 5468 IFRs choosing annual visual inspections equals approximately 55.

d

From Table G.2
6

TABLE F-3: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART VV

Activity

(A)

EPA 

hr/Occurrence

(B)

Occurrences 

plant/yr

(C)

plants/yr

(D)a

Technical 

hrs/yr

(E=D*.05)

Managerial 

hrs/hr

(F=E*.10)

Clerical 

hrs/yr

Cost/yrd

Report Review: New Plant

Notification of Construction 8 1 0

b

0 0 0 $0

Notification of Reconstruction/ 

Modification 2 1 0 0 0 0 $0

Notification of Actual Startup 0.5 1 0 0 0 0 $0

Notification of Initial/Repeat Test 0.5 1 0

c

0 0 0 $0

Review Test Results 2 1 0

c

0 0 0 $0

Report Review: Existing Plant

Semiannual Emission Reports 2 2 436c1,744 87 174 $90,382

TOTAL ANNUAL HOURS 1,744 87 174

TOTAL ANNUAL BURDEN 2,006 $90,382

Assumptions:

a D=AxBxC

b All new sources will be subject to subpart VVa.

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%) 

Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)
7

TABLE F-4: ANNUAL AVERAGE EPA RESOURCE REQUIREMENT FOR SUBPART DDD

Activity

(A)

EPA 

hr/Occurrence

(B)

Occurrences 

plant/yr

(C)

plants/yr

(D)a

Technical 

hrs/yr

(E=D*.05)

Managerial 

hrs/hr

(F=E*.10)

Clerical 

hrs/yr

(G)b

Cost/yr 

($)

Report Review

 Notification of Construction/ Reconstruction/ 

Modification

2 1 10 20 1 2 $1,036 

Notification of Actual Startup 2 1 10 20 1 2 $1,036 

Initial Performance Test 8 1 10 80 4 8 $4,146 

Repeat Performance Testd8 0.2 10 16 1 2 $829 

Semiannual Reports 2 2 90c360 18 36 $18,657 

TOTAL ANNUAL HOURS 496 25 50

TOTAL ANNUAL BURDEN 570 $25,705 

Assumptions:

a D=AxBxC

b Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2010 

General Schedule” which excludes locality rates of pay.

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%) 

Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)

c Average number of affected sources over next three years.

d Assume 20 percent of performance tests repeated due to failure
8

TABLE F-5: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART III

Activity

(A)

EPA 

hr/Occurrence

(B)

Occurrences 

plant/yr

(C)

plants/yr

(D)a

Technical 

hrs/yr

(E=D*.05)

Managerial 

hrs/hr

(F=E*.10)

Clerical 

hrs/yr

(G)b

Cost/yr 

($)

Report Review

New Plant - Notification of 

Construction/Reconstruction/Modification

2 1 1 2 0.1 0.2 $104

Notification of Anticipated Startup 2 1 1 2 0.1 0.2 $104

Notification of Actual Startup 2 1 1 2 0.1 0.2 $104

Initial Test 8 1 1 8 0.4 0.8 $415

Repeat Performance Testc

8 0.2 1 1.6 0.08 0.16 $83

Semiannual Reports 2 2 11d

44 2.2 4.4 $2,280

TOTAL ANNUAL HOURS 59.6 2.98 5.96

TOTAL ANNUAL BURDEN 69 $3,089

Assumptions:

a D=AxBxC

b Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2010 General 

Schedule” which excludes locality rates of pay.

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%) 

Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)

c Assume 20 percent of performance tests are repeated due to failure

d Average number of affected sources over next three years. Does not include sources subject to both Subpart III and the HON, which are assumed to be 

complying with the HON.
9

TABLE F-6: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART NNN

Activity

(A)

EPA 

hr/Occurrence

(B)

Occurrences 

plant/yr

(C)

plants/yr

(D)a

Technical 

hrs/yr

(E=D*.05)

Managerial 

hrs/hr

(F=E*.10)

Clerical 

hrs/yr

(G)b

Cost/yr ($)

Report Review

New Plant - Notification of 

Construction/Reconstruction/

Modification

2 1 177 354 18 35 $18,346 

Notification of Actual Startup 2 1 177 354 18 35 $18,346 

Initial Test 8 1 177 1,416 71 142 $73,383 

Repeat Performance Testc8 0 177 283 14 28 $14,666 

Semiannual Reports 2 2 1,345d5,380 269 538 $278,816 

TOTAL ANNUAL HOURS 7,787 389 779

TOTAL ANNUAL BURDEN 8,955 $403,557 

Assumptions:

a D=AxBxC

b Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2010 General 

Schedule” which excludes locality rates of pay.

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%) 

Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)

c Assume 20 percent of performance tests are repeated due to failure.

d Average number of affected sources over next three years. Does not include sources subject to both Subpart NNN and the HON, which are assumed to be 

complying with the HON.
10

TABLE F-7: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART RRR

Activity

(A)

EPA 

hr/Occurrence

(B)

Occurrences 

plant/yr

(C)

plants/yr

(D)a

Technical 

hrs/yr

(E=D*.05)

Managerial 

hrs/hr

(F=E*.10)

Clerical 

hrs/yr

(G)b

Cost/yr ($)

Report Review

New Plant - Notification of 

Construction/Reconstruction/Modification

2 1 20 40 2 4 $2,073

Notification of Actual Startup 2 1 20 40 2 4 $2,073

Initial Test 8 1 20 160 8 16 $8,292

Repeat Performance Testc

8 0.2 20 32 2 3 $1,658

Semiannual Reports 2 2 155d

620 31 62 $32,131

TOTAL ANNUAL HOURS 892 45 89

TOTAL ANNUAL BURDEN 1,026 $46,227

Assumptions:

a D=AxBXC

b Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2010 General 

Schedule” which excludes locality rates of pay.

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%) 

Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)

c Assume 20 percent of performance tests are repeated due to failure.

d Average number of affected sources over next three years. Does not include sources subject to both Subpart NNN and the HON, which are assumed to be complying 

with the HON.
11

TABLE F-8: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART BB

Activity

(A)

EPA/hr 

Occurrence

(B)

Occurrences/plant/yr

(C)b

Plants/year

(D)

Technical 

hrs/yra

(E=D*.05)c

Managerial 

hr/yr

(F=D*.1)

Clerical 

hr/yr

(G)

Cost/yr $d

Report Review

New Plantc

Notification of construction 0.5 0 0 0 0 0 $0

Notification of anticipated startup 0.5 0 0 0 0 0 $0

Notification of actual startup 0.5 0 0 0 0 $0

Initial report 8 0 0 0 0 0 $0

Notification of emission test 0.5 0 0 0 0 0 $0

Result of emission test 4 0 0 0 0 0 $0

Notification of performance test 0.5 0 0 0 0 0 $0

Result of performance test 8 0 0 0 0 0 $0

Review test results 8 0 0 0 0 0 $0

Report Review

Existing Plant

Quarterly reports 2 4 54 432 22 43 $22,388

TOTAL ANNUAL HOURS 432 22 43

TOTAL ANNUAL BURDEN 497 $22,388

Assumptions:

a AxBxC=D

b Assume an estimated total of 81 facilities. Assume 2/3 (54) facilities are marine vessel loading facilities and must continue to comply with this subpart; 

assume 2 of these 54 marine vessel loading facilities also load tank trucks and railcars that are not subject to the HON.

c Assume no new sources.

d Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2010 

General Schedule” which excludes locality rates of pay.

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%) 

Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)
12

TABLE F-9: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART Y

Activity

(A)

EPA/hr 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/year

(D)

Technical 

hrs/yrb

(E=D*.05)c

Managerial 

hr/yr

(F=D*.1)

Clerical 

hr/yr

(G)

Cost/yr 

$

c

Report Review

New Sources Included in 

Notification of construction NSPS Kb

Notification of anticipated startup Included in 

NSPS Kb

Notification of actual startup Included in 

NSPS Kb

Notification of performance test N/A N/A N/A N/A N/A N/A

Report of performance test N/A N/A N/A N/A N/A N/A

Notification of control installation and refill at 1st 

degassingd 1 1 0 0 0 0 $0

Existing Plant 2 1 4 8 0 1 $415

Annual IFR internal inspections and EFR seal gap 

measurements

Supplemental delay reporte1 1 0 0 0 0 $0

Quarterly emission reportsf N/A N/A N/A N/A N/A N/A N/A

TOTAL ANNUAL HOURS 8 0.4 0.8

TOTAL ANNUAL BURDEN 9 $415

Assumptions:

a Estimate that there are 4 existing sources not covered by the HON. All new source burden is included in the NSPS subpart Kb regulation for storage vessels 

at 40 CFR Part 60.

b D=AxBxC

c Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2010 General 

Schedule” which excludes locality rates of pay: Technical - $46.21 (GS-12, Step 1, $28.88 + 60%); Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%);

Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%).

d

It is believed that all vessels have been degassed and all controls have been installed as they were to have been installed within 10 years of promulgation.. 

e Estimate that two percent of existing sources will request delay of repair in the annual report.

f Assume that no source will select the fixed roof vented to a control device option and thus have no quarterly report of excess emissions.
13

TABLE F-10: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART V

Activity

(A)

EPA/hr 

Occurrence

(B)

Occurrences/

plant/yr

(C)

Plants/yearb

(D)a

Technical 

hrs/yr

(E=D*.05)c

Managerial 

hr/yr

(F=D*.1)

Clerical 

hr/yr

(G)

Cost/yr $d

Report Review

New Plant - Notification of 

Construction/Reconstruction/Modification 2 1 2 4 0.2 0.4 $207

Notification of Anticipated Startup 2 1 2 4 0.2 0.4 $207

Notification of Actual Startup 2 1 2 4 0.2 0.4 $207

Initial Test 8 1 2 16 0.8 1.6 $829

Repeat Performance Testc8 0.2 2 3 0.15 0.3 $155

Semiannual Reports 2 2 55 220 11 22 $11,401

TOTAL ANNUAL HOURS 251 13 25

TOTAL ANNUAL BURDEN 289 $13,008

Assumptions:

a AxBxC=D

b Assume 2 new sources per year at one new facility and 55 existing process units subject to NESHAP subpart V, but not the HON.

c Assume 20 percent of initial performance test must be repeated due to failure.

d Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2010 

General Schedule” which excludes locality rates of pay.

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%) 

 Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)
14

TABLE F-11: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPARTS F, G, H, and I

Burden Item

Average 

Hours

per Activity

(a)

Number of

Activities per 

Year

(b)

Estimated 

Technical 

Hours per year

(c)

Estimated 

Managerial 

Hours per year 

(d)

Estimated Clerical 

Hours per year 

(e)

Annual Cost $

(f)

REPORTS REVIEW:

1) Initial 2 5 10 1 1 $518

2) Implementation Plan or Permit 20 5 100 5 10 $5,182

3) Compliance status 40 5 200 10 20 $10,365

4) Review equipment leak monitoring 7 240 1,680 84 168 $87,065

5) Notification of 

Construction/Reconstruction. 2 5 10 1 1 $518

6) Notification of anticipated startup 2 5 10 1 1 $518

7) Notification of actual startup 2 5 10 1 1 $518

8) Notification of Performance Test 2 5 10 1 1 $518

9) Review of test results 8 5 40 2 4 $2,073

10) Review periodic reports 4 640 2,560 128 256 $132,671

TOTAL ANNUAL HOURS 4,630 232 463

TOTAL ANNUAL BURDEN 5,325 $239,947

See Attachment H for assumptions and further description of activities.
15

TABLE F-12: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART VVa

Activity

(A)

EPA hr/Occurrence

(B)

Occurrences 

plant/yr

(C)

plants/yr

(D)a

Technical 

hrs/yr

(E=D*.05)

Managerial 

hrs/hr

(F=E*.10)

Clerical 

hrs/yr

Cost/yre

Report Review: New Plant

Notification of Construction 8 1 23b184 9 18 $9,536 

Notification of Reconstruction/Modification 2 1 15 30 2 3 $1,555 

Notification of Actual Startup 0.5 1 38 19 1 2 $985 

Notification of Initial/Repeat Test 0.5 1 46c23 1 2 $1,192 

Review Test Results 2 1 46c92 5 9 $4,768 

Report Review: Existing Plant

Semiannual Emission Reportse2.45 2 38d186 9 19 $9,639 

TOTAL ANNUAL HOURS 534 27 53

TOTAL ANNUAL BURDEN 614 $27,674

Assumptions:

a D=AxBxC

b Estimate that there are 38 new affected sources each year over the next three years (23 will be due to construction, and 15 will be reconstructed or modified). 

The estimate of 38 sources is based on annual growth and reconstruction/modification being equal to 3% of the estimated 1,272 existing sources.

c Assume 20 percent of performance tests are repeated due to failure (7.6)

d There are an average of 38 new affected sources each year after promulgation of VVa. Assume that costs are being calculated for the 2nd year in the three years 

after promulgation of VVa so that the 38 new sources in the first year are existing sources in the second year.

e Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2010 General 

Schedule” which excludes locality rates of pay.

Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)

Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%) 

Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)
1

ATTACHMENT G: RESPONDENT BURDEN AND COST FOR REFERENCING SUBPARTS

TABLE G-1: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART Ka

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/year

(D)

Technical hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yrb

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 0 0 0 0 $0

Measure seal gap Included in 4E

C. Create Information Included in 3B

D. Gather Existing Information 1 1 157c157 8 16 $17,078

E. Write Report

Notification of construction 2 1 0 0 0 0 $0

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

Notification of gap measurement 1.5 1 188c282 14 28 $30,675

Report of seal gap excess 2.5 1 6

d

15 1 2 $1,632

Information on vapor recovery Included in 3B.

Total Annual Responses 194

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

Secondary seal gap 250d,e 1 157c39,250 1,963 3,925 $4,269,517

Primary seal gap measurements 100d0.2f31c620 31 62 $67,442

Fill/refill record 2

h

1 35g70 4 7 $7,614

TOTAL ANNUAL HOURS 40,394 2,020 4,039

TOTAL ANNUAL BURDEN 46,453 $4,393,958
2

Assumptions:

a Assume that there will be no new source subject to the requirements of this regulation. Similar new sources will be subject to NSPS subpart Kb. There are 

174 existing sources with an average of 50 tanks per facility. 

b United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The 

rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed 

by private industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr

c Estimate that 10 percent of respondents (17) will use a vapor recovery control system and 90 percent (157) will use a floating roof system. Respondents 

using vapor recovery control are not required to do seal gap measurements. All of the tanks using floating roof (157) will perform a secondary seal gap 

measurement. 20 percent (31) will conduct a primary seal gap measurement. 157 + 31 = 188 respondents submitting a notification of either primary or 

secondary gap measurement. 

d Assume that 3 percent of respondents using a floating roof will have excessive seal gaps (primary or secondary) requiring that a 

single report be filed once a year.

e Estimate five hours to conduct secondary seal measurements annually for the average 50 tanks per respondent.

f Estimate two hours to conduct primary seal measurements every five years for the average 50 tanks per respondent.

g During any one year, a respondent would change liquid in approximately 20 percent of the facilities (35).

h Estimate 0.2 hours to record a liquid change per tank in 20 percent (10) of the average of 50 tanks per facility.
3

TABLE G-2: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART Kb

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/plant/yr

(C)a

Plants/year

(D)

Technical 

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical hr/yr

(G)

Cost/yrb

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read Instruction 1 1 37d 37 2 4 $4,025

B. Required Activities 

One-Time Only Requirements 2 1 37 74 4 7 $8,050

Notification of Start of 

Construction

Notification of Actual Startup 2 1 37 74 4 7 $8,050

Notification of Physical or 

Operational Changesc N/A

Notification of Malfunctionc N/A

Notification of Initial 

Inspection

IFR Internal Inspection 2 1 28d56 3 6 $6,092

EFR Gap Measurement 2 1 7

d

14 1 1 $1,523

 Initial Inspection Report

IFR Internal Inspection Report 12 1 28d336 17 34 $36,549

EFR 2nd Seal Gap Measurement 8 1 7 56 3 6 $6,092

EFR 1st Seal Gap Measurement 12 1 7 84 4 8 $9,137

CVS Operating Plan Report 8 1 2 16 1 2 $1,740

Repeat Requirements

Internal IFR Inspectione12 1 116 1,392 70 139 $151,418

Visual IFR Inspectione8 1 464 3,712 186 371 $403,782

Report of IFR Failuref2 1 55 110 6 11 $11,966

Notification of Delay of Repair or 

Emptying for IFRg 4 1 6 24 1 2$2,611

EFR 2nd Seal Gap Measure Report 8 1 580 4,640 232 464 $504,728

EFR 1st Seal Gap Measure Report 12 1 580 6,960 348 696 $757,091

Notification of Refillh2 1 602 1,204 60 120 $130,968

 Number of Responses 1976
4

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/plant/yr

(C)a

Plants/year

(D)

Technical 

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical hr/yr

(G)

Cost/yrb

4.RECORDKEEPING 

REQUIREMENTS 1 1 37 37 2 4 $4,025

A.. Read Instructions

B. Gather and Record Information 8 1 580 4,640 232 464 $504,728

i. Vessel Volumes, Liquid Vapor 

Pressure, flares

ii. 113b(a) inspection 12 1 580 6,960 348 696 $757,091

iii. 113b(b) gap measurement 12 1 580 6,960 348 696 $757,091

C. Develop Record System 10 1 3 30 2 3 $3,263

D. Time to Enter Information - CVS 

Parameter Records 2 52 355 36,920 1,846 3,692 $4,016,065

F. Train Personnel N/A

G. Audits N/A

TOTAL ANNUAL HOURS 74,336 3,717 7,434

TOTAL ANNUAL BURDEN 85,486 $8,086,084

Assumptions:

a Estimate that there are 580 existing respondents with an average of 7,254 regulated vessels in service over the next three years. Estimate that 75 percent (5468) 

of vessels have IFR and 20 percent (1458) have EFR and 5 percent (355) have closed-vent control systems. This does not include sources subject to both subpart 

Kb and the HON, which are assumed to be complying with the HON.

b United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates 

are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by 

private industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr

c The General Provision notifications of modification or malfunction will be covered by notification within the subpart.

d Assume that there will be 37 new respondents each of the next three years, which includes 28 IFR and 7 EFR and 2 CVS.

e

For each of the 5,468 IFRs at 580 respondents, eighty (80) percent (464) will conduct an annual visual inspection, and 20 percent (116) will conduct an internal 

inspection. These activities are required to generate the information for the IFR failure report and the EFR primary and secondary seal gap reports, but do not 

generate a response.

f One percent failure rate for the 5468 IFRs choosing annual visual inspections equals approximately 55.

g Ten percent of 55 failed IFRs are delayed in repair or emptying equals approximately 6.

h Assume that all 5,468 IFR tanks will be routinely serviced through a shutdown and degassed once every ten years. One tenth the 5468 IFR will be degassed 

each year for an annual average of 547 per year. This number was added to the estimated 55 visual inspection failures that would lead to internal inspections for a 

total estimate of 602 notices of refill.
5

TABLE G-3: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART VV

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/

year

(D)

Technical 

hr/yr

(E=D*.05)

Manageria

l hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yrb

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

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

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

Initial Performance Test Report

Repeat Performance Test Report 48 1 0

c

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

New Sources

Notification of Construction 

Notification of Reconstruction/ Modification 2 1 0 0 0 0 $0

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

Notification of Initial/Repeat Performance Test 2 1 0 0 0 0 $0

Existing Sources Semiannual Report 4 2 436 3,488 174 349 $379,416

Total Annual Responses 872

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 1 436 34,880 1,744 3,488 $3,794,159

F. Train personnel N/A

G. Audits N/A
6

TOTAL ANNUAL HOURS 38,368 1,918 3,837

TOTAL ANNUAL BURDEN 44,123 $4,173,575

Assumptions:

a All new sources will be subject to subpart VVa. There are an average of 436 existing sources per year for the next three years, based on the assumption of 

525 sources in the first and second year, and 258 in the third year (when sources will become subject to the MON). These sources do not include those 

subject to both Subpart VV and the HON, which are assumed to be complying with the HON. See the footnote in Table F-3 for the derivation of the 

estimated number of sources.

b United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The 

rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those 

employed by private industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr

c Assume that 20 percent of the performance tests must be repeated.
7

TABLE G-4: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART DDD

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/plant

/yr

(C)

Plants/year

(D)

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yrb

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read Instructions 1 1 10c 10 1 1 $1,088

B. Required Activities 360 1 10 3600 180 360 $391,599

Initial Performance Test Report

Repeat Performance Test Report 360 1 2d 720 36 72 $78,320

C. Write Report 2 1 10 20 1 2 $2,176

Notification of Construction/Modification

 Notification of Actual Startup 1 1 10 10 1 1 $1,088

 Notification of Initial Performance Test 2 1 10 20 1 2 $2,176

 Semiannual Report 3 2 90e 540 27 54 $58,740

Total Annual Responses 222

4. Recordkeeping Requirements

Record of Operating Parameters for Control 

Devices 1 12 10 120 6 12 $13,053

Records of Operating Conditions Exceeding 

Last Performance Test 1 8 90 720 36 72 $78,320

Records of Startup, Shutdown, Malfunction, etc. 0.25 5 90 113 6 11 $12,292

TOTAL ANNUAL HOURS 5873 294 587

TOTAL ANNUAL BURDEN 6754 $638,850

Assumptions:

a AxBxC=D

b United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are 

from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private 

industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr

c Assume 10 new affected sources per year.

d Assume 20 percent of performance tests are repeated due to failure. 

e Average number of affected sources over next three years.
8

TABLE G-5: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART III

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/ 

plant/yr

(C)

Plants/year

(D)

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yrb

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements 0

A. Read Instructions 1 1 1

c

1 0 0 $109

B. Required Activities 60 1 1 60 3 6 $6,527

Initial Performance Test Report 0

Repeat Performance Test Report 60 1 0.2d12 1 1 $1,305

C. Write Report 2 1 1 2 0 0 $218

Notification of Construction/Modification 0

 Notification of Actual Startup 1 1 1 1 0 0 $109

 Notification of Initial Performance Test 2 1 1 2 0 0 $218

 Semiannual Report 3 2 11e66 3 7 $7,179

Total Annual Responses () 26

4. Recordkeeping Requirements

Record of Operating Parameters for Control 

Devices 1 12 1 12 1 1 $1,305

Records of Operating Conditions Exceeding Last 

Performance Test 1 8 11 88 4 9 $9,572

Records of Startup, Shutdown, Malfunction, etc. 0.25 5 11 14 1 1 $1,523

TOTAL ANNUAL HOURS 258 13 26

TOTAL ANNUAL BURDEN 297 $28,065

Assumptions:

a AxBxC=D

b United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are 

from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private 

industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr

c Assume 1 new affected source per year subject to subpart III and not the HON.

d Assume 20 percent of performance tests are repeated due to failure.

e Average number of affected sources over next three years. This does not include sources subject to both subpart III and the HON, which are assumed to be complying 

with the HON.
9

TABLE G-6: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART NNN

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/plant/yr

(C)

Plants/year

(D)

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yrb

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read Instructions 1 1 177c177 9 18 $19,254

B. Required Activities 60 1 177 10,620 531 1,062 $1,155,217

Initial Performance Test Report

Repeat Performance Test Report 60 1 35d2,100 105 210 $228,433

C. Write Report 2 1 177 354 18 35 $38,507

Notification of Construction/Modification

 Notification of Actual Startup 1 1 177 177 9 18 $19,254

 Notification of Initial Performance Test 2 1 177 354 18 35 $38,507

 Semiannual Report 3 2 1345e8,070 404 807 $877,834

Total Annual Responses () 3,433

4. Recordkeeping Requirements

Record of Operating Parameters for Control 

Devices 1 12 177 2,124 106 212 $231,043

Records of Operating Conditions Exceeding Last 

Performance Test 1 8 1345 10,760 538 1,076 $1,170,446

Records of Startup, Shutdown, Malfunction, etc. 0.25 5 1345 1,681 84 168 $182,855

TOTAL ANNUAL HOURS 36,417 1,821 3,642

TOTAL ANNUAL BURDEN 41,880 $3,961,350

Assumptions:

a AxBxC=D

b United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, 

“Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. Technical - $98.20/hr; 

Managerial - $114.49/hr; Clerical - $48.53/hr

c Assume 177 new affected sources per year subject to subpart NNN and not the HON.

d Assume 20 percent of performance tests are repeated due to failure. 

e Average number of affected sources over next three years. This does not include sources subject to both Subpart NNN and the HON, which are assumed to be complying with 

the HON.
10

TABLE G-7: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART RRR

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/plant/yr

(C)

Plants/year

(D)

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yrb

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read Instructions 1 1 20c

20 1 2 $2,176

B. Required Activities 60 1 20 1,200 60 120 $130,533

Initial Performance Test Report

Repeat Performance Test Report 60 1 4

d

240 12 24 $26,107

C. Write Report 2 1 20 40 2 4 $4,351

Notification of Construction/

 Modification

 Notification of Actual Startup 1 1 20 20 1 2 $2,176

 Notification of Initial Performance Test 2 1 20 40 2 4 $4,351

 Semiannual Report 3 2 155e930 47 93 $101,163

Total Annual Responses () 394

4. Recordkeeping Requirements

Record of Operating Parameters for Control 

Devices 1 12 20 240 12 24 $26,107

Records of Operating Conditions Exceeding Last 

Performance Test 1 8 155 1,240 62 124 $134,884

Records of Startup, Shutdown, Malfunction, etc. 0.25 5 155 194 10 19 $21,103

TOTAL ANNUAL HOURS 4,164 208 416

TOTAL ANNUAL BURDEN 4,789 $452,950

Assumptions:

a AxBxC=D

b United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates 

are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by 

private industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr.

c Assume 20 new affected sources per year subject to subpart RRR and not the HON.

d Assume 20 percent of performance tests are repeated due to failure. (.2 x 20 = 4).

e Average number of affected sources over next three years. This does not include sources subject to both subpart RRR and the HON which are assumed 

to be complying with the HON.
11

TABLE G-8: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART BB

Activity

(A)

hr/ Occurrence

(B)

Occurrences/plant/yr

(C)a

Plants/year

(D)

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical hr/yr

(G)

Cost/yrb

1. Applications

Application for approval of 

Construction/Modification

N/A

2. Surveys and Studies N/A

3. Reporting Requirements

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

B. Required Activities

Initial emission test 20 0 0 0 0 0 $0 

Monitoring performance test 280 1 0 0 0 0 $0 

Vapor-tightness test tank truck and railcars 11 1 3

c

33 2 3 $3,590 

Marine vessels 80 1 66c

5,280 264 528 $574,345 

Closed vent leak inspection 8 1 54c

432 22 43 $46,992 

C. Create Information Included in 3B

D. Gather Existing Information Included in 3E

E. Write Report

Notification of anticipated startup 2 0 0 0 0 0 $0 

Notification of actual startup 2 0 0 0 0 0 $0 

Notification of emission test 2 0 0 0 0 0 $0 

Report of emission test 8 0 0 0 0 0 $0 

Notification of performance test 2 0 0 0 0 0 $0 

Report of performance test 8 0 0 0 0 0 $0 

Report facilities below cut-offd

8 0 0 0 0 0 $0 

Quarterly parameter excesses 4 4 54 864 43 86 $93,984 

Total Annual Responses () 216

SUBTOTAL

4. Recordkeeping Requirements

A. Read Instructions Included in 3A

B. Plan Activities Included in 4C

C. Implement Activities Included in 3B
12

Activity

(A)

hr/ Occurrence

(B)

Occurrences/plant/yr

(C)a

Plants/year

(D)

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical hr/yr

(G)

Cost/yrb

D. Develop Record System N/A

E. Time to Enter Information

 i. Facilities above cut-off 1.5 52 54 4,212 211 421 $458,171 

 ii. Facilities below cut-off

d

0.5 52 0 0 0 0 $0 

F. Train Personnel N/A

G. Audits N/A

TOTAL ANNUAL HOURS 10,821 541 1,082

TOTAL ANNUAL BURDEN 12,444 $1,177,081 

Assumptions:

a Expect that there will be no new sources covered by these standards over the next three years.

b United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from 

column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry. 

Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr

c Estimate that there are 54 facilities subject to this standard. Estimate there are 3 tank truck and railcars and 131 marine vessels subject to the standards. All other transfer 

racks subject to subpart BB are assumed to be complying with the HON. Assume 50 percent of the marine vessels (66) operate at negative pressure and do not conduct 

annual vapor-tightness tests.

d

For sources below the low quantity applicability for control requirements, a report is only required the first year of operation. It is assumed that this report has been 

submitted.
13

TABLE G-9: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART Y

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/year

(D)

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yrb

1. Applications

Application for approval of Construction/Modification N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read Instructions Included in 3C

B. Required Activities

Initial performance test N/A

C. Create Information

Annual IFR Internal Inspections and EFR Seal Gap 

measurements (existing sources) 8 1 4 32 2 3 $3,481 

D. Gather Existing Information Included in 3C

E. Write Report

New Sources

Notification of Construction/ Reconstruction Included in NSPS Kb

Notification of anticipated startup Included in NSPS Kb

Notification of actual startup Included in NSPS Kb

Notification of emission test N/A

Report of emission test N/A

Notification of Control installation and refill at 1st IFR 

Degassingc 2 1 0 0 0 0 $0 

Existing Sources

Annual Inspection Reports 2 2 4 16 1 2 $1,740 

Supplemental Delay Reportd

2 1 0 0 0 0 $0 

Quarterly Emission Report None Expectede

Total Annual Responses () 8

4. Recordkeeping Requirements

A. Read Instructions Included in 3A

B. Plan Activities Included in 4C

C. Implement Activities - Filing and Maintaining 

Records 2 1 4 8 0 1 $870 

D. Develop Record System Included in 4C
14

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/year

(D)

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yrb

E. Time to Enter Information Included in 4C

F. Train Personnel N/A

G. Audits N/A

TOTAL ANNUAL HOURS 56 3 6

TOTAL ANNUAL BURDEN 64 $6,092 

Assumptions:

a Estimate that there will be 4 existing sources not covered by the HON. All new source burden is included in the NSPS subpart Kb regulation for storage vessels at 

40 CFR Part 60

b United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are 

from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private 

industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr

c

It is believed that all vessels have been degassed and all controls have been installed as they were to be installed within 10 years of promulgation.

d Estimate that two percent of existing sources will request delay of repair in the annual report.

e Assume that no sources will select the fixed roof vented to a control device option and thus have no quarterly reports of excess emissions.
15

TABLE G-10: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART V

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)

Plants/year

(D)

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yra

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read Instructions 1 1 2

b

2 0 0 $218 

B. Required Activities 20 1 2 40 2 4 $4,351 

Initial Performance Test

Reference Method 21/22 Tests 4 1 2 8 0 1 $870 

Repeat Performance Test 20 0.2 2 8 0 1 $870 

C. Create Information See 3B

D. Gather Existing Information See 3B

E. Write Report 2 1 2 4 0 0 $435 

Notification of Construction/

Reconstruction

Notification of Anticipated Startup 2 1 2 4 0 0 $435 

Notification of Actual Startup 2 1 2 4 0 0 $435 

Notification of Initial Performance Test 2 1 2 4 0 0 $435 

Report of Performance Test See 3B

Application for Alternative 10 1 0.5 5 0 1 $544 

Initial Report 8 1 2 16 1 2 $1,740 

 Semiannual Report 30 2 55c3,300 165 330 $358,966 

 Total Annual Responses 123

4. Recordkeeping Requirements

A. Read Instructions See 3A

B. Plan Activities See 4C

C. Implement Activities See 3B

D. Develop Record System N/A

E. Time to Enter Information 1.5 1 2 3 0 0 $326 

Records of startups, shutdown, 

malfunction, etc.
16

Activity

(A)

hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)

Plants/year

(D)

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yra

Records of operating, parameters and 

emissions 0.1 365d

55c2,008 100 201 $218,425 

Records of leak detected 0.4 52 55 1,144 57 114 $124,441 

F. Train personnel N/A

G. Audits N/A

TOTAL ANNUAL HOURS 6,550 328 655

TOTAL ANNUAL BURDEN 7,533 $712,493 

Assumptions:

a United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” 

The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to 

those employed by private industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr.

b Assume one new facility per year comprising two new sources.

c Estimate 21 existing facilities comprising 55 sources.
17

TABLE G-11: NEW SOURCE ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND 

RECORDKEEPING REQUIREMENTS OF THE HON

Activity

Average 

Hours per 

Activity

(a)

Number of 

Activities 

per year per 

respondent

(b)

Technical 

Hours per 

year per 

respondent

(c)

Estimated. 

Number New 

respondents

(d)

Estimated 

Technical 

Hours per 

year

(e)

Estimated 

Managerial 

Hours per 

year

(f)

Estimated 

Clerical 

Hours per 

year

(g)

Annual Cost 

per year

(h)

1) Read Rule and Instructions 2.7 93 250 5 1,250 63 125 $135,972 

2) Plan Activities 3.8 93 355 5 1,775 89 178 $193,080 

3) Training 3.5 38 132 5 660 33 66 $71,793 

4) Create, Test, Research and 

Development 2.4 1,778 4,266 5 21,330 1,067 2,133

$2,320,224 

5) Gather Information, 

Monitor/Inspect 1.4 2,102 2,943 5 14,715 736 1,472

$1,600,661 

6) Process/ 0.8 50 40 5 200 10 20 $21,756 

Compile and Review

7) Complete Reports 11.4 49 557 5 2,785 139 279 $302,945 

Total Annual Responses 245

8) Record/Disclose 10.0 49 489 5 2,445 122 245 $265,961 

9) Store/File 5.2 51 264 5 1,320 66 132 $143,586 

TOTAL ANNUAL HOURS 46,480 2,324 4,648

TOTAL ANNUAL BURDEN 53,452 $5,055,978 

Assumptions:

(a) = (c)/(b)

(d) - From previously approved ICR. 

See Attachment I for assumptions and further description of activities.
18

TABLE G-12: EXISTING SOURCE ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND 

RECORDKEEPING REQUIREMENTS OF THE HON PROVISIONS

Activity

Average 

Hours per 

Activity

(a)

Number of 

Activities 

per year per 

respondent

(b)

Total 

Technical 

Hours per 

year per 

respondent

(c)

Technical 

Hours per 

year per 

respondent 

for 

wastewater

(d)

Estimated 

Technical 

Hours per 

year

(e)

Estimated 

Managerial 

Hours per 

year

(f)

Estimated 

Clerical 

Hours per 

year

(g)

Annual Cost

per year

1) Read Rule and Instructions 3.6 23 69 14 17,680 884 1,768 $1,923,186 

2) Plan Activities 6.1 13 61 18 16,080 804 1,608 $1,749,142 

3) Training 5.3 4 17 4 4,400 220 440 $478,621 

4) Create, Test, Research and 

Development

17.8 99 1617 150 400,080 20,004 40,008 $43,519,702 

5) Gather Information, 

Monitor/Inspect

2.5 677 1693 0 406,320 20,316 40,632 $44,198,474 

6) Process/Compile and Review 20.0 1 20 0 4,800 240 480 $522,132 

7) Complete Reports 81.2 5 388 18 94,560 4,728 9,456 $10,286,000 

Total Annual Responses a1,600

8) Record/Disclose 17.5 26 442 12 107,040 5,352 10,704 $11,643,544 

9) Store/File 6.8 35 222 15 54,480 2,724 5,448 $5,926,198 

TOTAL ANNUAL HOURS 1,105,440 55,272 110,544

TOTAL ANNUAL BURDEN 1,271,256 $120,247,000 

Assumptions:

(a) = (c + d)/(b)

(c) - there are 240 existing sources out of the 320 total that will continue to comply with the HON. 

(d) - the 80 facilities complying with the CAR will still be required to comply with the HON for wastewater. 

a Total number of respondents is 320 ( 240 for HON + 80 CAR still complying with HON Wastewater). See Attachment I for assumptions and further 

description of activities.
19

TABLE G-13: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART VVa

Activity

(A)

hr/Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/yea

r

(D)

Technical 

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical 

hr/yr

(G)

Cost/yrb

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read Instructions 1 1 38 38 2 4 $4,134 

B. Required Activities 48 1 38 1,824 91 182 $198,410 

Initial Performance Test Report

Repeat Performance Test Report 48 1 8c 384 19 38 $41,771 

C. Create Information Included in 3B

D. Gather Existing Information Included in 3E

E. Write Report 2 1 23 46 2 5 $5,004 

New Sources

Notification of Construction 

Notification of Reconstruction/ Modification 2 1 15 30 2 3 $3,263 

 Notification of Actual Startup 2 1 38 76 4 8 $8,267 

Notification of Initial/Repeat Performance Test 2 1 46 92 5 9 $10,008 

 Existing Sources Semiannual Report 4.5 2 38 342 17 34 $37,202 

Total Annual Responses 244

4. Recordkeeping Requirements Included in 3A

A. Read Instructions

B. Plan Activities Included in 4C

C. Implement Activities Included in 3B

D. Develop Record System N/A

E. Time to Enter Informationd

Average Facilities - Records of Operating Parameters 89.5 1 34 3,043 152 304 $331,010 

Small Facilities - Records of Operating Parameters 95.2 1 4 381 19 38 $41,444 

F. Train personnel N/A

G. Audits N/A

TOTAL ANNUAL HOURS 6,256 313 626

TOTAL ANNUAL BURDEN 7,194 $680,512 
20

Assumptions:

a Assume that there will be an average 38 new, modified, or reconstructed facilities each year over the next 3 years. Estimate that 23 of new affected sources 

will be due to construction, and 15 will be reconstructed or modified. There are an average of 38 new affected sources each year after promulgation of VVa. 

Assume 10 percent are small facilities that will record instrument readings manually, and 90 percent of facilities use automated equipment to capture instrument 

readings electronically. Assume that costs are being calculated for the second of the three years after promulgation of VVa, so that the 38 new sources in 

the first year are existing sources in the second year. Since subpart VVa is more stringent than the HON and MON, no sources are assumed to be complying 

with the HON or MON instead of subpart VVa.

b United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” 

The rates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by 

private industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr

c Assume 20 percent of initial performance tests must be repeated due to failure.

d Details of the additional hours relative to the hours for a source subject to subpart VV are provided in section 6(f) of Part A of the Supporting Statement.
1

Attachment H

Assumptions and Item Descriptions for Attachment F: Table F-11

(A) That all existing and new sources must submit an initial report within 120 days of 

promulgation and an implementation plan or permit application within 12 or 18 months of the 

compliance date. It is assumed that initial reports and implementation plans have been submitted 

for existing sources and these reports are only required for new sources. The new sources are 

most likely to be collocated within existing plants and be included in those existing source 

reports.

(B) That semiannual reports of results from equipment leak detection and repair programs 

are required by the equipment leak standard. Sources are required to comply with the equipment 

leak standard by 6 months after promulgation. It is assumed that an average of 320 facilities will 

submit reports semiannually (320 x 2 = 640) (even those that use the CAR will still have to 

submit reports under the HON for wastewater).

Item Descriptions:

(a) Average Hours per Activity are estimates of the specific activities and are the basis 

for estimating the overall burden.

(b) Number of Activities per year represents the number of reports expected to be 

reviewed and other related activities during the course of the year. Under the performance test 

headings, these numbers are based upon assumptions (A) and (B), above. For one-time reports, 

the total number of reports expected over the three-year period was divided by three to get an 

annual average incorporating assumption (C), above.

(c) Estimated Technical Hours per year is the product of (a) and (b).

(d) Estimated Managerial Hours per year is 5 percent of (c).

(e) Estimated Clerical Hours per year is 10 percent of (c).

(f) Estimated Annual Cost per year is the sum of costs for technical, managerial, and 

clerical hours based on rates from the Office of Personnel Management (OPM), 2010 

General Schedule which excludes locality rates of pay.

Managerial $62.27 (GS-13, Step 5, $38.92 + 60%) 

Technical $46.21 (GS-12, Step 1, $28.88 + 60%)

Clerical $25.01 (GS-6, Step 3, $15.63 + 60%)

(Htx $46.21/hour)+(Hmx $62.27/hour)+(Hcx $25.01/hour) = (G)

Where:

H

t

is (c), or technical hours

H

m

is (d), or managerial hours, and

H

c

is (e), clerical hours

Report Review:

1) Initial represents the EPA review of all initial reports received.
2

2) Implementation Plan or Permit Applications represents the EPA review of all 

implementation plans, or permit applications if submitted in lieu of an implementation plan.

3) Compliance Status represents compliance status verification by the EPA for the 

portions of the standard which a source must comply with before the compliance date (see 

assumption (D) above).

4) Review equipment leak monitoring represents the review and screening of periodic 

reports received as a result of the equipment leaks standard.

5) Notification of construction/reconstruction represents the EPA review of this 

notification from new sources.

6) Notification of anticipated startup represents the EPA review of this notification from 

new sources.

7) Notification of actual startup represents the EPA review of this notification from new 

sources.

8) Notification of performance test represents the EPA review of this notification from 

new sources.

9) Review of test results represents the EPA review of performance test results for new 

sources.

10) Review periodic reports represents the EPA review of periodic reports.

TOTAL BURDEN AND COST is the sum of each of the columns (d), (e), (f), and (g).
1

Attachment I

Assumptions and Item Descriptions for Attachment G: Tables G-11 and G-12

Assumptions are:

(A) That there are 240 existing facilities out of 320 that will continue to comply with the 

HON, rather than the CAR. The 80 facilities complying with the CAR will still be required to 

comply with the HON wastewater provisions, as the CAR does not include wastewater 

provisions. The total number of facilities will increase by 5 new facilities per year. Since new 

facilities must be in compliance at startup, the general periodic recordkeeping and reporting 

burdens are included, which accounts for the difference in the technical hours per facility. No 

new facilities are expected to comply directly with the CAR.

(B) That the average representative source, new and existing, will consist of the 

following points of burden:

20 parameters to monitor at control devices throughout the facility

10 affected storage tanks of various capacities

3 affected major wastewater streams

4 affected transfer rack operations

3 overall leak detection and repair programs for 2,000 points

1 emissions averaging program that involves 10 emission points

1 facility wide inventory of emission points, Group 1 and Group 2

8 process vents per facility

(C) That there are 5 percent (0.05) managerial and 10 percent (0.10) clerical hours 

required for every technical hour.

(D) That some activities necessary to generate reports involve creating records in the 

process, and that these activities are assumed to be reports activities alone, to avoid double 

counting these as records activities as well. Therefore, only items 8 and 9 are considered records 

burdens directly.

Item Descriptions:

(a) Average Hours per Activity is back-calculated by dividing (b) into (c). Since the

activities within each burden category can vary significantly, it is too inaccurate to assume an 

average to use to calculate (c). Estimated activity technical hours are summarized to obtain (c) 

first, then back calculate for (a) with an estimated (b).

(b) Estimated Number of Activities per year per source represents the assumed typical 

number of separate activities a source may encounter during one year. This number may vary

from facility to facility, depending on consolidation of activities, collocated readings, etc. Since 

so much variability exists, it is important to note that this is an estimate. This number was only 

used to back-calculate (a).

(c) Technical Hours per year per source is the actual best estimate of the burden for each 

burden item. The three-year separate activity burdens were divided by three, where appropriate, 

and then summarized to include in this column. The technical hours for new sources is higher 

because some periodic compliance reports and records are required at startup. Existing sources 

do not encounter these reports and record burdens for three years after promulgation.
2

(d) (Table G-11) Estimated Number of New Sources reflect the number given in 

assumption (A), above. (Table G-12) Technical Hours Per Year Per Source for Wastewater are 

the annual technical hours associated with recordkeeping and reporting to ensure compliance 

with requirements for wastewater. As discussed in assumption (A), facilities complying with the 

CAR will comply with the HON wastewater requirements. Burden hours per source, per 

emission type are shown in Table B-1.

(e) Estimated Technical Hours per year is the product of (c) and (d) for new facilities 

(Table G-11). For Table G-12, estimated technical hours are the product of (c) and the number 

of existing facilities complying with all of the HON (240) added to the product of (d) and the 

number of facilities complying with only the wastewater provisions (80).

(f) Estimated Managerial Hours per year is 5 percent of (e).

(g) Estimated Clerical Hours per year is 10 percent of (e).

(h) Estimated Annual Cost per year is from the United States Department of Labor, 

Bureau of Labor Statistics, September 2009, Table 2. Civilian Workers, by Occupational and 

Industry group. The rates are from column 1, Total Compensation. The rates have been 

increased by 110 percent to account for the benefit packages available to those employed by 

private industry.

(Htx $98.20/hour)+(Hmx $114.49/hour)+(Hcx $48.53/hour) = (G)

Where:

H

t

is (e), or technical hours

H

m

is (f), or managerial hours, and

H

c

is (g), clerical hours

1) Read Rule and Instructions are the activities, less training, which involve 

comprehending the provisions in the standard and understanding how they apply to the 

respective points at a facility.

 2) Plan Activities represents such burdens as design, redesign, scheduling as well as 

drafting the implementation plan, and selecting methods of compliance.

3) Training represents the portion (assumed 40 percent) of activities from 1) Read Rule 

and Instruction for which an average facility would elect to provide class room instruction. The

standard does not require specific training itself.

4) Create, Test, Research and Development are the activities involving testing, retesting, 

establishing operating range for parameters and analyzing point by point applicability. Monitor 

related refit, calibration and maintenance activities are also included under this heading.

5) Gather Information, Monitor and Inspect are the activities involving physical 

inspections of equipment, collection of monitored data and other related activities.

6) Process/Compile and Review are the activities that involve analysis of the information 

collected for accuracy, compliance, and appropriate reports and records required as a result.

7) Complete Reports represents the activities normally associated with filling out forms. 

Since the standard requires no standard forms, these activities relate to the preparing of formal 

reports and cover letters as appropriate.
3

8) Record/Disclose are activities which are solely recordkeeping which occur once the 

appropriate report information has been extracted [see assumption (D)] above. These activities 

involve software translation, duplication, or archival processes normally associated with data 

management and storage common to this industry.

9) Store/File are again activities which are solely recordkeeping which occur once the 

appropriate report information has been extracted (see assumption (D) above). These activities 

involve the management life cycle of records, from the time they are filed and boxed up, to the 

time they are disposed.

TOTAL BURDEN AND COST is the sum of each of the columns (e), (f), (g), and (h).
1

Attachment J

Summary of Capital/Startup and Operation and Maintenance Costs for the CAR and Its 

Referencing Subparts

NSPS Subpart Ka

a. Total Capital/Startup Cost of Monitoring Equipment:

The total capital/Startup costs for this ICR are $0.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The total operating and maintenance (O&M) Costs for this ICR is $0.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $0.

NSPS Subpart Kb

a. Total Capital/Startup Cost of Monitoring Equipment:

The total capital/Startup costs for this ICR are $27,000. This is the cost for 2 new 

storage tanks to install monitoring equipment associated with the CVS routed to a 

control device. The storage tanks will use equipment similar to that used for 

subparts NNN and III; therefore, the startup costs are approximately $13,500 per 

facility for a total of $27,000. There are no capital/startup costs for the remaining 

35 new storage tanks complying by either an IFR or EFR. 

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The average annualized burden is estimated to be $1,350 per year per affected 

facility ($13,500 discounted over 10 years by straight line depreciation method) 

for both new and existing affected sources using CVS to a control device (31), for 

a total of $41,850.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $68,850.

NSPS Subpart VV

a. Total Capital/Startup Cost of Monitoring Equipment:

The capital/startup costs of this regulation are $0. It is assumed that facilities that 

are already complying with subpart VV will not need to buy an additional monitor 

and no additional facilities will become subject to subpart VV in the future.
2

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The operation of the monitors is included in the monitoring costs. Maintenance 

costs on these units is incidental, therefore no maintenance or operation costs 

incur.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $0.

NSPS Subpart VVa

a. Total Capital/Startup Cost of Monitoring Equipment:

The capital/startup costs of this regulation are $4,200. This is based on the 

average cost of a monitor ($7,000) with a 5-year expected life. The equipment is 

not capitalized, so no discount rate applies. The average annual cost is, therefore, 

$7,000/5, or $1,400/yr. It is estimated that only area sources that construct new 

process units might purchase a monitoring instrument. All other sources should 

have monitoring equipment because they are either subject to MACT rules or 

have been subject to NSPS subpart VV for other processes. Assuming that 38 

process units are subject to NSPS subpart VVa each year, 60 percent of new 

sources are newly constructed sources, and that 15 percent of all new sources are 

area sources, an estimated 3 facilities with a new process unit will buy a 

monitoring instrument to comply with NSPS subpart VVa.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The operation of the monitors is included in the monitoring costs. Maintenance 

costs on these units is incidental; therefore, no maintenance or operation costs 

incur.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $4,200.

NSPS Subpart DDD

a. Total Capital/Startup Cost of Monitoring Equipment:

The capital/startup costs for this regulation are $300,000. This is based on 10 new 

sources per year multiplied by $30,000 per source for monitoring equipment. 

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The annual operation and maintenance costs are $630,000 dollars. This is based 

on 80 existing sources plus 10 new sources over the life of the ICR multiplied by

$7,000 for upkeep of the monitoring devices.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $930,000.
3

NSPS Subpart NNN/III

a. Total Capital/Startup Cost of Monitoring Equipment:

The startup cost of monitoring equipment is approximately $13,500 per new 

affected facility for both subpart III, Air Oxidation Operations and subpart NNN, 

Distillation Operations, or a total of $2,403,000 (total of 178 new sources x 

$13,500/source).

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The average annualized burden is estimated to be $1,350 per year per affected 

facility ($13,500 discounted over 10 years by straight line depreciation method) 

for subpart III and for subpart NNN for a total of $1,830,600 [($1,350 x 1,356) 

total number of new and existing affected sources under NNN and III]. 

c. Total Capital/Startup and O&M Cost:

The total capital and O&M Costs are $4,233,600.

NSPS Subpart RRR

a. Total Capital/Startup cost of Monitoring Equipment:

The capital/startup costs for this regulation are $500,000 dollars per year. This is 

based on 20 new sources per year multiplied by $25,000 for monitoring 

equipment discounted over 10 years at 7 percent. 

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The annual operation and maintenance costs are $77,500 dollars. This is based on 

155 existing sources multiplied by $500 for upkeep of the monitoring device.

c. Total Capital/Startup and O&M Cost:

The total capital/startup and O&M Costs are $577,500.

NESHAP Subpart BB

a. Total Capital/Startup cost of Monitoring Equipment:

Startup cost were identified in previous ICR.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

There are no O&M cost associated because no CEMs are employed.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M costs are $0.

NESHAP Subpart Y
4

a. Total Capital/Startup Cost of Monitoring Equipment:

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

in the standards is labor cost. There are no capital/startup costs. 

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

There are no operation and maintenance costs. 

c. Total Capital/Startup and O&M Cost:

The total capital and O&M costs are $0.

NESHAP Subpart V

a. Total Capital/Startup Cost of Monitoring Equipment:

Startup cost were identified in previous ICR.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

There are no O&M costs associated because no CEMs are employed.

c. Total Capital and O&M Cost

The total capital and O&M costs are $0.

NESHAP HON:

Subpart G

a. Total Capital/Startup Cost of Monitoring Equipment:

Estimate the cost to purchase monitoring equipment is approximately $20-30K for 

process vents and wastewater operations, or an average of $25K with a 10-year 

life expectancy and a 7 percent depreciation rate, or $2225 per year. There are no 

associated costs for transfer racks and storage tanks. Only new sources need to 

buy monitoring equipment; therefore, the total capital/startup cost is $25,000 x 5, 

or $125,000.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The cost to industry associated with the operation and maintenance (O&M) is 

approximately $100-500K per year (capital/startup depreciation not included) for 

reactor process vents and wastewater operations. The cost associated with the 

operation and maintenance is $50-100K per year (capital/startup depreciation not 

included) for distillation units process vents. There are no associated costs for 

transfer racks and storage tanks. The average O&M cost is assumed to be the 

average of the two ranges, or $275,000 per year. Operation and maintenance 

incur for both new and existing sources. The total O&M is, therefore, $275,000 x 

245, or $67,375,000.
5

c. Total Capital/Startup and O&M Cost:

The total capital and O&M costs are $67,500,000.

Subpart H

a. Total Capital/Startup Cost of Monitoring Equipment:

Only new sources will buy an organic volatile analyzer. Estimate the average cost 

of a monitor is $7,000 with a 5-year expected life. The equipment is not 

capitalized, so no discount rate applies. The average annual cost is, therefore, 

$7,000/5, or $1,400/yr. Estimate that 80 percent of facilities contract out LDAR 

services, and 20 percent perform in-house. Those facilities which contract out (4 

facilities) will purchase one unit as backup; the remaining facilities performing 

LDAR in-house (1 facility) will purchase 5 units to support the program. The 

total annual capital/startup cost is, therefore, 9 units x 1400/unit, or $12,600/yr.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The operation of the monitors is included in the monitoring costs. Maintenance 

costs on these units is incidental; therefore, no maintenance or operation costs 

incur.

c. Total Capital and O&M Cost for Subparts H, and I:

The total capital and O&M costs are $12,600.

Part 65 CAR

a. Total Capital/Startup Cost of Monitoring Equipment:

Under the CAR, it is assumed all new sources start out under the referencing 

subpart. Therefore, there is no capital/startup cost associated with this subpart.

b. Total Cost of Operation and Maintenance of Monitoring Equipment:

The HON is the basis for determining O&M costs for the CAR. The average cost 

per source, based on the HON is $275,000 per year, for a total of $22,000,000.

c. Total Capital/Startup and O&M Cost:

The total capital and O&M costs are $22,000,000.