SUPPORTING STATEMENT

THE CONSOLIDATED FEDERAL AIR RULE FOR SOCMI

(WITH NEW NSPS SUBPART VVa)

Part A of the Supporting Statement

1. Identification of the Information Collection

1(a) Title of the Information Collection

“The Consolidated Federal Air Rule for SOCMI (with New NSPS Subpart VVa)”

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 changes to subpart VV and new standards in subpart VVa; 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, and 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, DDD, III, 

NNN and RRR; 40 CFR part 61, subparts BB, Y, and V; 40 CFR part 63, subparts F, G, H, and I.
2

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, 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. For the three 

years covered by this ICR, it is assumed that none of the sources subject to new subpart VVa will 

comply with the CAR.

It is estimated that the consolidated collection will involve 3,305 respondents with 9,953 

annual responses and respondent labor costs of $145,725,751. The total Agency burden is 

estimated to be 24,541 hours per year at a cost of $1,016,007. Total capital costs will be 

$3,373,000 per year, and total capital and operation and maintenance (O&M) costs will be 

$95,329,000 per year.

It is estimated that the information collection for the new subpart VVa will involve 76 

respondents with 244 annual responses and respondent labor costs of $527,104. The total 

Agency burden for subpart VVa is estimated to be 614 hours per year at a cost of $25,438. Total 

capital costs will be $4,200 per year, and total capital and O&M costs will be $4,200 per year.

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 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.
3

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 

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. These standards were 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 

and 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 new 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.
4

NSPS subpart DDD: VOC Emissions from the Polymer Manufacturing Industry

The NSPS for the polymer manufacturing industry were proposed on 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, 

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, subparat NNN.
5

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: Benzene-laden waste (covered under subpart FF of part 61), gasoline, crude oil, natural 

gas liquids, petroleum distillates (i.e., fuel oil, diesel, or kerosene), or benzene-laden liquid from 

coke by-product 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, or 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. 
6

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 

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 Clean Air Act (CAA or Act) provides authority to the Agency to establish standards 

to control air pollution and to ensure compliance with promulgated regulations through adequate 

recordkeeping and reporting by the affected industries (i.e., respondents). The regulations 

include the NSPS under section 111 of the Act; the NESHAP, which includes the original 

NESHAP standards and the more recent MACT or NESHAP-MACT standards under section 

112 of the Act; and emission guidelines for the designated types incinerators under section 129 

of the Act.
7

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard(s) are used by regulatory

agencies, the public and the regulated community for a variety of reasons including the 

determination of the respondent’s compliance status, analytical studies to demonstrate 

compliance trends, and evaluations regarding the efficacy of the promulgated regulations.

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

3(a) Nonduplication

The standards do not require duplication in the collection and reporting of information. 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.

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

A public review and comment period occurred after proposal of the amendments to the 

Standards of Performance for equipment leaks of VOC in the SOCMI (40 CFR part 60, subpart 

VV).

3(c) Consultations

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 affected parties 

were given the opportunity to comment on the proposed amendments during this period. Several 

comments were received on the standards and compliance procedures. Changes were made 

based on these comments.

During development of the proposed amendments, EPA held meetings and conference 

calls with representatives of petroleum refining companies and their trade associations (National 

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

reporting requirements and related burden estimates were not discussed during these meetings. 

Representatives of the American Chemistry Council declined invitations to participate in 

development of the proposed amendments.
8

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 and in 

comments submitted in response to the first Federal Register notice announcing renewal of this 

ICR. Since the amendments to 40 CFR part 60, subpart VV and the new standards at subpart 

VVa do not affect the burden estimates for the CAR and other referencing subparts, no changes 

have been made to the burden estimates for those rules relative to the estimates in the last 

approved ICR for the CAR. Thus, the only consultation with industry being conducted at this 

time involves burden estimates for amendments to subpart VV and the new standards in subpart 

VVa.

3(d) Effects of Less Frequent Collection

The effect of less frequent collection would be a decrease in the margin of assurance that 

facilities are achieving the emission reductions mandated by the CAA through the promulgation 

of the applicable regulations. In addition, the likelihood of detecting the poor operation and

maintenance of control equipment decreases, and the detection of noncompliance becomes 

problematic.

3(e) General Guidelines

Neither the reporting nor recordkeeping requirements violate the regulations established 

by Office of Management and Budget (OMB) at 5 CFR 1320.5. However, most NESHAP and a 

few NSPS require records to be kept more than three years. In general, these standards require 

the respondents to maintain all records, including reports and notifications, for five years. The 

five-year record retention requirement is consistent with the permit program at 40 CFR part 70, 

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 

the respondent for purposes of determining the appropriate level of enforcement action. 

Historically, EPA notes that the most flagrant violations have extended beyond a five-year 

period. If records are retained for less than five years, EPA would be deterred from pursuing the 

most flagrant violations due to the destruction of records documenting noncompliance.

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 (see 40 CFR 2; 41 FR 36902, September 1, 

1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR

17674, March 23, 1979).

3(g) Sensitive Questions
9

The recordkeeping and reporting requirements do not contain sensitive questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The Standard Industrial Classification(SIC) codes and corresponding North American 

Industry Classification System (NAICS) for the respondents are listed below.

SIC Code NAICS Code

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
10

SIC Code NAICS Code

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

4493 71393

4499 532411, 48831, 48833, 48839

4724 56151
11

SIC Code NAICS Code

4725 56152

4729 488999, 561599

4731 541614, 48851

4741 532411, 48821

4783 488991

4785 48839, 48849

4789 488999, 48711, 72231, 48821

*

These SIC codes characterize respondents most likely to be subject to the amendments to 40 

CFR part 60, subpart VV and the new standards of subpart VVa.

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

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

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.
12

(ii) Respondent Activities

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

in the following table.

Respondent Activities

Read instructions.

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.
13

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, 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

The required data and reports can be evaluated on-site by conducting a partial compliance 

evaluation, full compliance evaluation or inspection, or through an off-site review of compliance 

monitoring records and reports. Evaluation reports and inspection results are maintained by the 

Agency or delegated authority.

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

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

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

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

enforcement by local and State regulatory agencies, EPA Regional offices, and EPA 

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

5(c) Small Entity Flexibility

Minimizing the information collection burden for all sizes of organizations is a 

continuing effort on EPA’s part. EPA has limited recordkeeping and reporting to the minimum 

necessary to ensure and verify compliance with the rule. The new standards in subpart VVa 

include additional recordkeeping and reporting requirements; experience with enforcing the 

existing subpart VV has shown that additional data are needed. Some of the records required in 

subpart VVa that are not required in subpart VV are already required in other equipment leak 

rules. For example, other rules already require records of the dates and results of weekly visual 

inspections of pumps. Other new requirements are unique to subpart VVa, but the level of effort 

involved is small. Generating records of all instrument readings should add minimal burden for 

most SOCMI facilities because identification of the equipment monitored, the instrument 

reading, and the monitoring date generally are collected electronically for all equipment while 

monitoring; the only additional burden would be to download all of the data rather than just the 

leaker data to storage, and to make sure that the records include identification of the operator and 

monitoring instrument. The burden will be greater for small facilities that rely on manual 

recording of instrument readings. It was assumed that 10 percent of the SOCMI sources that 

become subject to subpart VVa use manual recordkeeping procedures; for these facilities the 

additional recordkeeping burden was estimated to be 3.5 hours per year (hr/yr). Records (and 

related reporting) of leaks identified as a result of the new annual monitoring requirement for 
14

open-ended lines and the new requirement for connector monitoring are needed to document 

compliance with subpart VVa. Another activity is to record information regarding instrument 

calibrations and drift checks because this effort would apply each day when instrument 

monitoring is conducted. For a typical or average process, monitoring should take no more than 

about 7 days during months when valves must be monitored, less during other months. The 

recordkeeping level of effort per day, however, should be no more than a few minutes. Overall, 

EPA does not expect that small organic chemical manufacturing businesses will experience 

adverse impacts related to the cost of the reporting and recordkeeping requirements in the new 

standards of subpart VVa.

5(d) Collection Schedule

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

shown in Table 5 for the CAR and Tables G-1 through G-13 for the referencing subparts, 

respectively.

6. Estimating the Burden and Cost of the Collection

Table 5 for the CAR and Tables G-1 through G-13 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 respondent burden is summarized in Table 6 and detailed in Table 5 for the CAR and 

Tables G-1 through G-13 for the referencing subparts. The labor hours are based on Agency

studies and background documents from the development of the regulation, Agency knowledge 

and experience with the standard, the previously approved ICR, and any comments received. 

Changes from the previously approved ICR have been made for subparts VV and VVa in Tables 

G-3 and G-13, respectively.
15

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial (General and Operations) $125.87 ($59.94 + 110%)

Technical (Environmental Engineers) $74.36 ($35.41 + 110%)

Clerical (Office Support Occupations) $36.04 ($17.16 + 110%)

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

2006 National Industry-Specific Occupational Employment and Wage Estimates, NAICS 

325000 Chemical Manufacturing (http://www.bls.gov/oes/current/naics3_325000.htm) 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. Capital/Startup and O&M costs for the referencing subparts are 

summarized in Table 6. 

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. The capital/startup and 

O&M costs to comply with subpart VV are estimated to be $0 per year because it is assumed that 

facilities that are already complying with subpart VV will not need to buy an additional monitor, 

an no additional facilities will become subject to subpart VV in the future. The estimated 

capital/startup and O&M costs for subpart VVa are $4,200 per year. These costs are for an 

estimated 3 facilities that are assumed to construct new process units and that would have to 

purchase a monitor because they would not also be subject to other rules that require monitoring 

of equipment leaks.

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

The total capital/startup costs for this ICR are detailed in Appendix J and summarized in 

Table 6 in column F. The total O&M costs for this ICR is the total of column E in Table 6.

6(c) Estimating Agency Burden and Costs

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

information. EPA’s overall compliance and enforcement program includes activities such as the 
16

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 24,541 

hours and $1,016,007. This is calculated in Table 2 for the CAR and Attachments F-1 through 

F-12 for the referencing subparts, and is summarized in Table 6. See Table F-3 for the changes 

resulting from the amendments to subpart VV and Table F-12 for the new standards of subpart 

VVa.

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

Managerial $57.20 (GS-13, Step 5, $35.75 x 1.6)

Technical $42.45 (GS-12, Step 1, $26.53 x 1.6)

Clerical $22.96 (GS-6, Step 3, $14.35 x 1.6)

These rates are from the Office of Personnel Management (OPM) “2006 General Schedule”

which excludes locality rates of pay. 

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

Number of respondents is calculated in Table 5 for the CAR, and Attachments G-1 

through G-13 for the referencing subparts for the three years covered by this ICR and 

summarized in Column (B) of Table 6.

A summary of the total annual labor cost may be found in Table 6. A detailed description 

of the Total Hours Requested may be found in Table 5 for the CAR, and Attachments G-1 

through G-13 for the referencing subparts. See Table G-3 for the burden related to the 

amendments to subpart VV and Table G-13 for the new standards of subpart VVa.

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 in Table 6 and detailed in Tables 2 and 5 for the CAR, and Tables F-1 

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

(i) Respondent Tally

Details regarding the total hours requested and annual labor cost estimates may be found 

in Table 5 for 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. This is 

calculated by dividing the Respondent Burden Hours in Table 6 by the Total Annual Responses 

in Table 6. The burden associated with the new subpart VVa is estimated to average 29 hours 

per response.
17

(ii) The Agency Tally

The average annual Agency burden hours and cost over next three years is 24,541 hours 

at a cost of $1,016,007. This is summarized in Table 6 and detailed in Table 2 for the CAR and 

Tables F-1 through F-12 for the referencing subparts. This burden is a decrease of 3,453 hours 

from the most recently approved ICR. The overall decrease is a combination of an estimated 

decrease in the number of sources subject to subpart VV, and an estimated increase due to the 

new standards of subpart VVa.

6(f) Reasons for Change in Burden

There is a decrease of 68,500 burden hours from the most recently approved ICR due to 

adjustments. These adjustments result from new standards of NSPS subpart VVa (Table G-13), 

and revised estimates of the number of sources subject to subpart VV (Table G-3). The new 

standards of NSPS subpart VVa require respondents to keep additional records for leaks from 

open-ended lines and connectors, the results of weekly inspections of pumps, daily calibrations 

and drift checks of the monitoring instrument, and all instrument readings. In addition, 

semiannual reports must include information related to leaks from open-ended lines and 

connectors. The adjustments to the number of sources are a result of analyses performed during 

development of the amendments to Subpart VV and the new standards in subpart VVa. Specific 

changes to tables are described below:

Table 6 - Since this is a summary table, the appropriate entries were changed according 

to the changes made to Tables F-3, F-12, G-3, and G-13.

Table F-3 - The table was updated to provide a more realistic estimate for the number of 

existing sources subject to these provisions, which decreased the overall burden for this 

subpart.

Table F-12 - The table was added to include an estimate of the burden to review reports 

required by the new NSPS subpart VVa. The estimate includes the same 2 hours to 

review semiannual reports that contain the information required by subpart VV, plus an 

additional 0.45 hour for Agency review of the additional information the must be 

submitted under subpart VVa. This estimate includes about 24 minutes to review 

information about open-ended lines (which is monitored and reported semi-annually) and 

about 3 minutes to review information about leaking connectors in one report per year.

Table G-3 - Table G-3 was updated to provide a more realistic estimate for the number 

of existing sources subject to these provisions, which decreased the overall burden for 

this subpart.

Table G-13 - Table G-13 was added to detail the recordkeeping and reporting 

requirements of the new standards of NSPS subpart VVa. For 90 percent of the facilities, 

these requirements include the 80 hrs/occurrence to prepare the same records as required 
18

under subpart VV plus an additional 9.5 hrs/occurrence to enter records of the additional 

information required by subpart VVa. It also includes the 4 hr/occurrence to prepare 

semiannual reports with the same information required under subpart VV plus an 

additional 0.5 hr/occurrence to add the additional information required by subpart VVa. 

For the estimated 10 percent of facilities that manually record instrument readings, the 

additional recordkeeping is estimated to be 15.2 hrs/occurrence.

The 9.5 hours per year of additional recordkeeping burden associated with the new 

requirements in subpart VVa is estimated based on 30 minutes per year (min/yr) to record 

information about leaks and possibly delay of repair for open-ended lines (15 minutes for 

each semiannual monitoring event), 15 min/yr to record information about leaks for 

connectors (assuming the one-quarter of all connectors that are monitored during the year 

are all monitored in one semiannual period), 2 min/week to record the date and results of 

weekly visual inspections of pumps, 2 min/day for 7 d/month to record instrument 

calibration and drift check information, and 3 min/day for 7 d/month to record all of the 

instrument readings. The 7 days/month for instrument monitoring is a maximum for a 

typical process with about 1,600 valves and pumps and 1,400 connectors; in months 

when valve monitoring is not required, the number of monitoring days will be less. It is 

assumed that connectors are monitored every four years so that 350 are monitored each 

year. For the 10 percent of facilities that are small and manually record instrument

readings it was assumed that the process has 15 pumps monitored monthly, 457 valves 

and 33 open-ended lines monitored twice per year, and 731 connectors monitored once 

every 4 years; an extra 10 seconds is needed to record each instrument reading, and an 

additional 2 hours per year was estimated to prepare and print recordkeeping forms. The 

additional reporting burden assumes 10 min/report to document information related to 

leaking open-ended lines (20 min/yr) and 10 min/yr to document information related to 

leaking connectors (i.e, every other report).

6(g) Burden Statement

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

information is estimated to average 200 hours per response (29 hours per response for the new 

subpart VVa). 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.
19

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

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

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

Docket ID Number EPA-HQ-OAR-2006-0699, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Enforcement and Compliance Docket and 

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

Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The 

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

Enforcement and Compliance Docket and Information Center is (202) 566-1742. An electronic 

version of the public docket is available at www.regulations.gov. This site can be used to submit 

or view public comments, access the index listing of the contents of the public docket, and to 

access those documents in the public docket that are available electronically. When in the 

system, select “search,” then key in the Docket ID Number identified above. Also, you can send 

comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please 

include the EPA Docket ID Number EPA-HQ-OAR-2006-0699 and OMB Control Number 

2060-0443 in any correspondence.

Part B of the Supporting Statement

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

information.
20

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
21

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 $2,571

2. Review Equipment 

Leak Monitoring 5 636 f

3,180 159 318 $151,387

3. Review Periodic 

Reports 4 80 g

320 16 32 $15,234

TOTAL ANNUAL COST 3,554 178 355 $169,192

Total Annual Burden 4,087

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 rates from the Office of 

Personnel Management (OPM) “2006 General Schedule,” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

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.

 
22

TABLE 3: ESTIMATED NUMBER OF SOURCES SUBJECT TO REFERENCING 

SUBPARTS THAT WILL OPT TO COMPLY WITH THE CAR

Referencing Subpart

(A)

Estimated Number of Sources 

Complying with CARa, b (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

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 
23

facility entries in the referencing subpart burden tables in Tables F-1 through F-12 and G-1 

through G-13. 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.
24

TABLE 4: 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 source

b

totalc

per source

b

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 1.0 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 20,300 16 26,240 16 5,120 380 91,200 155 12,090 0 0 154,950

. Gather 

Information, 

Monitor and 

Inspect 14 10,150 17 27,880 17 5,440 263 63,120 108 8,424 54 4,320 119,334
25

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 source

b

totalc

per source

b

totalc

per 

sourceb

totalc

per 

sourceb

totalc

per 

sourceb

totalc

. 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 20,300 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 64,018 46 75,030 45 14,368 711 170,525 290 22,622 94 7,542 354,106

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 they opt to comply with the CAR. For this reason, a separate burden estimate was developed for sources that are not required to 

perform connector monitoring. The per-source burden for 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.

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 3:
26

• 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 5. 
27

TABLE 5: 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 $428,102

Plan Activities 4.90 13 63.71 5,097 255 510 $429,490

Training 6.01 4 24.04 1,923 96 192 $161,997

Create, Test, Research 

and Development 19.56 99 1936.88 154,950 7,748 15,495 $13,055,763

Gather Information, 

Monitor and Inspect 2.20 677 1491.68 119,334 5,967 11,933 $10,054,808

Compile, Process and 

Review Data 18.00 1 18.00 1,440 72 144 $121,331

Complete Forms 82.54 5 412.69 33,015 1,651 3,302 $2,781,811

Record/ Disclose 13.36 26 347.30 27,784 1,389 2,778 $2,340,971

File/Store 1.96 35 68.53 5,482 274 548 $461,880

TOTAL COST 354,106 17,706 35,410 $29,836,153
28

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)

TOTAL BURDEN 

HOURS

407,222

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 4, 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, May 2006 National Industry-Specific Occupational Employment and Wage Estimates, NAICS 325000 Chemical Manufacturing. The wages 

are for General and Operations Managers, Environmental Engineers, and Office and Administrative Support Occupations. The rates have been increased by 110 

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

Managerial $125.87 ($59.94 + 110%)

Technical $74.36 ($35.41 + 110%)

Clerical $36.04 ($17.16 + 110%)
29

TABLE 6: SUMMARY OF RESPONDENT BURDEN AND COST FOR REFERENCING SUBPARTS AND THE CAR

Subpart

(A)

Number of 

Respondents 

(B)

Total Annual 

Responsesa

(C)

Respondent 

Burden Hoursa

(D)

Respondent 

Burden Costsa

(E)

Agency 

Burden 

Hoursb

(F)

Agency 

Burden 

Costsb

(G)

Total Capital 

and O&M 

(Block 14 c) 

in 000’s

c

(H)

Capital Costs 

(Block 14a)

in 000’s

c

NSPS Ka 174 194 46,455 $3,403,683 115 $4,743 0 0

NSPS Kb 580 1,976 85,489 $6,263,746 978 $40,475 69 27

NSPS VV 436 872 44,123 $3,232,749 2,005 $83,004 0 0

NSPS VVa 76 244 7,146 $527,104 614 $25,438 4.2 4.2

NSPS DDD 90 222 6,755 $494,966 571 $23,632 930 300

NSPS III 11 26 296 $21,703 69 $2,837 29 14

NSPS NNN 1,345 3,433 41,880 $3,068,545 8,955 $370,739 4,206 2,390

NSPS RRR 155 394 4,789 $350,915 1,026 $42,483 578 500

NESHAP BB 54 216 12,444 $911,831 497 $20,566 0 0

NESHAP Y 4 8 65 $4,758 9 $381 0 0

NESHAP V 55 123 7,529 $551,498 289 $11,957 0 0

NESHAP F, G, H, 

and I 

245 1,845 1,324,711 $97,058,100 5,327 $220,560 67,513 138
30

Subpart

(A)

Number of 

Respondents 

(B)

Total Annual 

Responsesa

(C)

Respondent 

Burden Hoursa

(D)

Respondent 

Burden Costsa

(E)

Agency 

Burden 

Hoursb

(F)

Agency 

Burden 

Costsb

(G)

Total Capital 

and O&M 

(Block 14 c) 

in 000’s

c

(H)

Capital Costs 

(Block 14a)

in 000’s

c

CAR 80 400 407,222 $29,836,153 4,087 $169,192 22,000 0

TOTAL 3,305 9,953 1,988,903 $145,725,751 24,541 $1,016,007 95,329 3,373

a

From Tables G-1 through G-13

b

From Tables F-1 through F-12

c

From Appendix J
1

Attachment A

Part 1: Recordkeeping and Reporting under the Consolidated Air Rule

1. General Records

· The owner or operator shall keep copies of notifications, reports, and records as specified in §65.5.

· The owner or operator shall maintain a startup, shutdown, and malfunction plan as specified in §65.6.

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 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.
2

• 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.

· 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.
3

· 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 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).
4

· 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).
5

· Report describing equipment and certifying control for EFR as specified in §60.115b(b)(1).

· 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).
6

· 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 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).
7

· 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).

· 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).
8

· 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).

· 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).
9

· 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 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). 
10

· 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).
11

· 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.
12

· 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.

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.
13

• 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 3

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 * $42.45/hour) + (Hm * $57.20/hour) + (Hc * $22.96/hour) = (h)

1,000
2

Where:

Ht is (c), or technical hours,

Hm is (d), or managerial hours, and

Hc is (e), or clerical hours.

Source:

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

Management (OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

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).
1

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 (c); (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-
2

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 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 * $74.36/hour) + (Hm * $125.87/hour) + (Hc * $36.04/hour)=(g)

Where:

Ht is (d), or technical hours,

Hm is (e), or managerial hours, and

Hc is (f), or clerical hours.

Source:

United States Department of Labor, Bureau of Labor Statistics, May 2006 National Industry-Specific Occupational 

Employment and Wage Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental 

Engineers, General and Operations Managers, and Office and Administrative Support Occupations. 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.
3

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.

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/

yr

(E=CxD)

Technical 

hr/yr

(F=Ex0.05)

Managerial 

hr/yr

(G=Ex0.10) 

Clerical 

hr/yr

(H)

Total Cost/ 

yre

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 $4,481

Report of gap excessesc,d 1 1 1 6 6 0 1 $262

TOTAL ANNUAL HOURS 100 5 10

TOTAL ANNUAL BURDEN 115 $4,743

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.
5

e Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2006 General 

Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)
6

TABLE F-2: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART Kb

Reporting and Recordkeeping Requirements 

Assumptionsa

(A)

Technical 

hr/yr

(B=A*.05)

Managerial 

hr/yr

(C=A*.10)

Clerical hr/yr

Cost/yr

$

a

Report Review

Notification of construction; 37bnew notifications @ 2 

hr/ea

74 4 7 $3,531

Notice of anticipated startup; 37 new notifications @ 1 

hr/ea

37 2 4 $1,777

Notice of actual startup; 37 new notifications @ 1 hr/ea 37 2 4 $1,777

Notification of initial inspection; @1 hr/ea 37 2 4 $1,777

IFR Failure Reportc; 55 sources @ 1 hr/ea 55 3 6 $2,644

Notification of Delay for Repair/Emptying IFRd; 6 

sources @ 1.2 hr/ea

7 0 1 $320

Notification to Re-Fill

d

; 602 sources @ 1 hr/ea 602 30 60 $28,649

TOTAL ANNUAL HOURS 849 43 86

TOTAL ANNUAL BURDEN

978 $40,475

a Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2006 

General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)
7

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

b Assume 111 new storage tanks will be constructed during each of the next three years, or 37 tanks per year (28 IFRs, 7 EFRs, 2 CVS).

c One percent failure rate for the 5468 IFRs choosing annual visual inspections equals approximately 55.

d

From Table G-2
8

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

hr/yr

(E=F*.05)

Managerial 

hr/yr

(G=F*.10)

Clerical 

hr/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 $83,004

TOTAL ANNUAL HOURS 1,744 87 174

TOTAL ANNUAL BURDEN 2,005 $83,004

a D=AxBxC

b All new sources will be subject to subpart VVa.

c 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 

3

rd year (when sources will become subject to the MON). The 525 sources is based on an estimated 1272 process units making SOCMI chemicals, of which 879 

are potentially subject to the HON, and 393 are potentially subject to the MON. All of them are assumed to have been constructed, reconstructed, or modified 

since the effective date of subpart VV and thus subject to subpart VV. Of the 879 processes making HON chemicals, 15 percent (132) are estimated to be at area 
9

sources and thus subject only to subpart VV, not the HON. All 393 process units making MON chemicals are assumed to be subject only to subpart VV in the 

first two years. For the third year, after the effective date of the MON, it is assumed that only 126 of the 393 will still be subject to subpart VV (an estimated 59 at 

area sources and 67 that emit only VOC, no HAP). Sources subject to both subpart VV and either the MON or HON are assumed to be complying with the HON 

or MON and are not included in this analysis. This analysis may overestimate the number of sources because it assumes each source has only one affected process 

unit.

d Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2006 General 

Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)
10

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 

hr/yr

(E=D*.05)

Managerial 

hr/hr

(F=E*.10)

Clerical 

hr/yr

(G)b

Cost/yr

($)

Report Review

Notification of Construction/ 

Reconstruction/Modification

2 1 10 20 1 2 $952

Notification of Actual Startup 2 1 10 20 1 2 $952

Initial Performance Test 8 1 10 80 4 8 $3,808

Repeat Performance Testd8 0.2 10 16 1 2 $782

Semiannual Reports 2 2 90c360 18 36 $17,138

TOTAL ANNUAL HOURS 496 25 50

TOTAL ANNUAL BURDEN 571 $23,632

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) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

c Average number of affected sources over next three years.
11

d Assume 20 percent of performance tests repeated due to failure.
12

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 

hr/yr

(E=D*.05)

Managerial 

hr/hr

(F=E*.10)

Clerical 

hr/yr

(G)b

Cost/yr

($)

Report Review

Notification of Construction/ 

Reconstruction/ Modification

2 1 1 2 0.1 0.20 $95

Notification of Anticipated Startup 2 1 1 2 0.1 0.20 $95

Notification of Actual Startup 2 1 1 2 0.1 0.20 $95

Initial Test 8 1 1 8 0.4 0.80 $381

Repeat Performance Testc8 0.2 1 1.6 0.08 0.16 $76

Semiannual Reports 2 2 11d44 2.2 4.40 $2,095

TOTAL ANNUAL HOURS 59.6 2.98 5.96

TOTAL ANNUAL BURDEN 69 $2,837

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) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)
13

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

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.
14

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 

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=E*.10)

Clerical 

hr/yr

(G)b

Cost/yr

($)

Report Review

Notification of Construction/ 

Reconstruction/Modification

2 1 177 354 18 35 $16,861

Notification of Actual 

Startup

2 1 177 354 18 35 $16,861

Initial Test 8 1 177 1,416 71 142 $67,431

Repeat Performance Testc8 0.2 177 283 14 28 $13,466

Semiannual Reports 2 2 1,345d5,380 269 538 $256,120

TOTAL ANNUAL HOURS 7,787 390 778

TOTAL ANNUAL BURDEN 8,955 $370,739

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) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)
15

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

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.
16

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

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=E*.10)

Clerical

hr/yr

(G)

Cost/yr

$

b

Report Review

Notification of Construction/ 

Reconstruction/Modification

2 1 20 40 2 4 $1,904

Notification of Actual 

Startup

2 1 20 40 2 4 $1,904

Initial Test 8 1 20 160 8 16 $7,617

Repeat Performance Testc8 0.2 20 32 2 3 $1,542

Semiannual Reports 2 2 155d620 31 62 $29,516

TOTAL ANNUAL HOURS 892 45 89

TOTAL ANNUAL BURDEN 1,026 $42,483

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) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

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.
17

TABLE F-8: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART BB

Activity

(A)

EPA/hr 

Occurrence

(B)

Occurrences/

plant/yr

(C)b

Plants/yr

(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 $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
18

Activity

(A)

EPA/hr 

Occurrence

(B)

Occurrences/

plant/yr

(C)b

Plants/yr

(D)

Technical 

hrs/yra

(E=D*.05)c

Managerial

hr/yr

(F=D*.1)

Clerical 

hr/yr

(G)

Cost/yr

$

d

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 $20,566

TOTAL ANNUAL 

HOURS

432 22 43

TOTAL ANNUAL 

BURDEN

497 $20,566

a D=AxBxC

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) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)
19

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)
20

TABLE F-9: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART Y

Activity

(A)

EPA/hr 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/yr

(D)

Technical 

hr/yrb

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

Cost/yr

$

c

Report Review: New Plant

Notification of construction Included in 

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

Report Review: Existing Plant
21

Activity

(A)

EPA/hr 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/yr

(D)

Technical 

hr/yrb

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

Cost/yr

$

c

Annual IFR internal 

inspections and EFR seal 

gap measurements

2 1 4 8 0 1 $381

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 $381

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) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

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 (1999).

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.
22
23

TABLE F-10: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART V

Activity

(A)

EPA hr/

Occurrence

(B)

Occurrences/

plant/yr

(C)

Plants/yrb

(D)a

Technical 

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=E*.10)

Clerical 

hr/yr

(G)

Cost/yr

$

d

Report Review

Notification of Construction/ 

Reconstruction/Modification

2 1 2 4 0.20 0.40 $190

Notification of Anticipated 

Startup

2 1 2 4 0.20 0.40 $190

Notification of Actual 

Startup

2 1 2 4 0.20 0.40 $190

Initial Test 8 1 2 16 0.80 1.60 $762

Repeat Performance Testc8 0.2 2 3 0.16 0.32 $152

Semiannual Reports 2 2 55 220 11.00 22.00 $10,473

TOTAL ANNUAL HOURS 251 13 25

TOTAL ANNUAL BURDEN 289 $11,957

a D=AxBxC

b Assume 2 new sources per year at one new facility and 55 existing process units subject to NESHAP V, but not the HON.

c Assume 20 percent of initial performance test must be repeated due to failure.
24

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

(OPM) “2006 General Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

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)

Report Review

Initial 2 5 10 1 1 $505

Implementation Plan or Permit 20 5 100 5 10 $4,761

Compliance status 40 5 200 10 20 $9,521

Equipment leak monitoring 7 240 1,680 84 168 $79,978

Notification of Construction/ 

Reconstruction

2 5 10 1 1 $505

Notification of anticipated startup 2 5 10 1 1 $505
25

Notification of actual startup 2 5 10 1 1 $505

Notification of Performance Test 2 5 10 1 1 $505

Test results 8 5 40 2 4 $1,904

Periodic reports 4 640 2,560 128 256 $121,871

TOTAL ANNUAL HOURS 4,630 234 463

TOTAL ANNUAL BURDEN 5,327 $220,560

See Attachment H for assumptions and further description of activities.
26

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

hr/yr

(E=F*.05)

Managerial 

hrs/yr

(G=F*.10)

Clerical 

hrs/yr Cost/yre

Report Review: New Plant

Notification of Construction 8 1 23b184 9 18 $8,739

Notification of Reconstruction/Modification 2 1 15 30 2 3 $1,457

Notification of Actual Startup 0.5 1 38 19 1 2 $910

Notification of Initial/Repeat Test 0.5 1 46c23 1 2 $1,079

Review Test Results 2 1 46c92 5 9 $4,398

Report Review: Existing Plant

Semiannual Emission Reportse2.45 2 38d186 9 19 $8,855

TOTAL ANNUAL HOURS 534 27 53

TOTAL ANNUAL BURDEN 614 $25,438

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.
27

e Annual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2006 General 

Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6).
1

ATTACHMENT G: RESPONDENT BURDEN AND COST FOR REFERENCING SUBPARTS

TABLE G-1: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART Kaa

(A)

Hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/

yr

(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 Instructions 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 $13,258

E. Write Report
2

(A)

Hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

Cost/yrb

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 $23,741

Report of seal gap 

excess

2.5 1 6

d

15 1 2 $1,313

Information on 

vapor recovery

Included in 3B

Total Annual Responses 

(Block 13b)

194

4. Recordkeeping 

Requirements

A. Read Instructions Included in 3B

B. Plan Activities Included in 3B
3

(A)

Hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

Cost/yrb

C. Implement Activities Included in 3B

D. Develop Record

System

N/A

E. Time to Enter

Information

New tank seal gap 

measurements

250 1 0 0 0 0 $0

Secondary seal gap

measurement

250d,e 1 157c 39,250 1,963 3,925 $3,307,170

Primary seal gap 

measurements

100d0.2f31c620 31 62 $52,240

Fill/refill record 2

h

1 35g70 4 7 $5,961

TOTAL ANNUAL HOURS 40,394 2,021 4,040

TOTAL ANNUAL BURDEN 46,455 $3,403,683

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. 
4

b United States Department of Labor, Bureau of Labor Statistics, May 2006 National Industry-Specific Occupational Employment and Wage 

Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental Engineers, General and Operations Managers, and Office 

and Administrative Support Occupations. The rates have been increased by 110 percent to account for the benefit packages available to those 

employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical - $36.04/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.
5

TABLE G-2: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART Kb

(A)

Hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/ 

yr

(D) 

Technical

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yr

1. Applications N/A

2. Surveys and Studies N/A

3. Reporting Requirements

A. Read Instruction 1 1 37d 37 2 4 $3,147

B. Required Activities

One-Time Only

Requirements

Notification of Start 

of Construction

2 1 37 74 4 7 $6,258

Notification of Actual 

Startup

2 1 37 74 4 7 $6,258

Notification of 

Physical or 

Operational Changesc

N/A

Notification of 

Malfunctionc

N/A
6

(A)

Hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/ 

yr

(D) 

Technical

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yr

Notification of Initial 

Inspection

IFR Internal 

Inspection

2 1 28d56 3 6 $4,758

EFR Gap 

Measurement

2 1 7

d

14 1 1 $1,203

Initial Inspection Report

IFR Internal 

Inspection Report

12 1 28d336 17 34 $28,350

EFR 2nd Seal Gap 

Measurement

8 1 7 56 3 6 $4,758

EFR 1st Seal Gap 

Measurement

12 1 7 84 4 8 $7,038

CVS Operating Plan 

Report 

8 1 2 16 1 2 $1,388

Repeat Requirements

Internal IFR Inspectione12 1 116 1,392 70 139 $117,330
7

(A)

Hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/ 

yr

(D) 

Technical

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yr

Visual IFR Inspectione8 1 464 3,712 186 371 $312,807

Report of IFR Failuref2 1 55 110 6 11 $9,331

Notification of Delay of 

Repair or Emptying for 

IFRg

4 1 6 24 1 2 $1,983

EFR 2nd Seal Gap 

Measure Report

8 1 580 4,640 232 464 $390,955

EFR 1st Seal Gap 

Measure Report

12 1 580 6,960 348 696 $586,432

Notification of Refillh2 1 602 1,204 60 120 $101,406

Number of Responses 

(Block 13b)

1976

4. Recordkeeping Requirements

A. Read Instructions 1 1 37 37 2 4 $3,147
8

(A)

Hr/ 

Occurrence

(B)

Occurrences/

plant/yr

(C)a

Plants/ 

yr

(D) 

Technical

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yr

B. Gather and Record 

Informati

on

i. Vessel Volumes, 

Liquid Vapor Pressure, 

flares

8 1 580 4,640 232 464 $390,955

ii. 113b(a) inspection 12 1 580 6,960 348 696 $586,432

iii. 113b(b) gap 

measure

ment

12 1 580 6,960 348 696 $586,432

C. Develop Record System 10 1 3 30 2 3 $2,591

D. Time to Enter 

Information - CVS 

Parameter Records

2 52 355 36,920 1,846 3,692 $3,110,787

F. Train Personnel N/A

G. Audits N/A

TOTAL ANNUAL HOURS 74,336 3,720 7,433

TOTAL ANNUAL BURDEN 85,489 $6,263,746
9

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 (5,468) of vessels have IFR, and 20 percent (1,458) 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, May 2006 National Industry-Specific Occupational Employment and 

Wage Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental Engineers, General and Operations 

Managers, and Office and Administrative Support Occupations. The rates have been increased by 110 percent to account for the

benefit packages available to those employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical - $36.04/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 IFRs, 7 EFRs, and 2 CVS.

e

For each of the 5,468 IFRs at 580 respondents, 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 for the purposes of the total for Block 13b.

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 of the 

5468 IFRs 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.
10

TABLE G-3: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART VV

Activity

(A)

Hr/

Occurrence

(B)

Occurrences/

respondent/

yr

(C)a

Respondents/ 

yr

(D) 

Technical

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yr

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

Initial Performance 

Test Report

48 1 0 0 0 0 $0

Repeat Performance 

Test Report

48 1 0c 0 0 0 $0

C. Create Information Included in 3B

D. Gather Existing 

Information

Included in 3E
11

Activity

(A)

Hr/

Occurrence

(B)

Occurrences/

respondent/

yr

(C)a

Respondents/ 

yr

(D) 

Technical

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yr

E. Write Report

New Sources

Notification of 

Construction 

2 1 0 0 0 0 $0

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 $293,847

Total Annual Responses

(Block 13b)

872
12

Activity

(A)

Hr/

Occurrence

(B)

Occurrences/

respondent/

yr

(C)a

Respondents/ 

yr

(D) 

Technical

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yr

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 $2,938,902

F. Train personnel N/A

G. Audits N/A

TOTAL ANNUAL HOURS 38,368 1,918 3,837
13

Activity

(A)

Hr/

Occurrence

(B)

Occurrences/

respondent/

yr

(C)a

Respondents/ 

yr

(D) 

Technical

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yr

TOTAL ANNUAL BURDEN 44,123 $3,232,749

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, May 2006 National Industry-Specific Occupational Employment and 

Wage Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental Engineers, General and Operations 

Managers, and Office and Administrative Support Occupations. The rates have been increased by 110 percent to account for the

benefit packages available to those employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical -

$36.04/hr.

c Assume 20 percent of initial performance tests must be repeated due to failure.
14

TABLE G-4: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART DDD

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(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 $906

B. Required Activities

Initial Performance 

Test Report

360 1 10 3,600 180 360 $303,327

Repeat Performance 

Test Report

360 1 2d 720 36 72 $60,665

C. Write Report

Notification of 

Construction/ 

Modification

2 1 10 20 1 2 $1,685

 Notification of 

Actual Startup

1 1 10 10 1 1 $906
15

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(D) 

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yrb

 Notification of 

Initial Performance 

Test

2 1 10 20 1 2 $1,685

 Semiannual Report 3 2 90e 540 27 54 $45,499

Total Annual Responses 

(Block 13b) 222

4. Recordkeeping 

Requirements

Record of Operating 

Parameters for 

Control Devices

1 12 10 120 6 12 $10,111

Records of Operating 

Conditions Exceeding 

Last Performance 

Test

1 8 90 720 36 72 $60,665
16

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(D) 

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yrb

Records of Startup, 

Shutdown, 

Malfunction, etc.

0.25 5 90 113 6 11 $9,517

TOTAL ANNUAL HOURS 5,873 295 587

TOTAL ANNUAL BURDEN

6,755 $494,966

a D=AxBxC

b United States Department of Labor, Bureau of Labor Statistics, May 2006 National Industry-Specific Occupational Employment and 

Wage Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental Engineers, General and Operations 

Managers, and Office and Administrative Support Occupations. The rates have been increased by 110 percent to account for the

benefit packages available to those employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical - $36.04/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.
17

TABLE G-5: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART III

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(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 1

c

1 0 0 $74

B. Required Activities

Initial Performance 

Test Report

60 1 1 60 3 6 $5,055

Repeat Performance 

Test Report

60 1 0.2d12 1 1 $1,054

C. Write Report

Notification of 

Construction/ 

Modification

2 1 1 2 0 0 $149

 Notification of 

Actual Startup

1 1 1 1 0 0 $74
18

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(D) 

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yrb

 Notification of 

Initial Performance 

Test

2 1 1 2 0 0 $149

 Semiannual Report 3 2 11e66 3 7 $5,538

Total Annual Responses 

(Block 13b) 26

4. Recordkeeping 

Requirements

Record of Operating 

Parameters for 

Control Devices

1 12 1 12 1 1 $1,054

Records of Operating 

Conditions Exceeding 

Last Performance 

Test

1 8 11 88 4 9 $7,372
19

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(D) 

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yrb

Records of Startup, 

Shutdown, 

Malfunction, etc.

0.25 5 11 14 1 1 $1,184

TOTAL ANNUAL HOURS 258 13 25

TOTAL ANNUAL BURDEN

296 $21,703

a D=AxBxC

b United States Department of Labor, Bureau of Labor Statistics, May 2006 National Industry-Specific Occupational Employment and Wage 

Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental Engineers, General and Operations Managers, and Office 

and Administrative Support Occupations. The rates have been increased by 110 percent to account for the benefit packages available to those 

employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical - $36.04/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.
20

TABLE G-6: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART NNN

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(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 $14,943

B. Required Activities

Initial Performance 

Test Report

60 1 177 10,620 531 1,062 $894,815

Repeat Performance 

Test Report

60 1 35d2,100 105 210 $176,941

C. Write Report

Notification of 

Construction/ 

Modification

2 1 177 354 18 35 $29,851

 Notification of 

Actual Startup

1 1 177 177 9 18 $14,943
21

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(D) 

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yrb

 Notification of 

Initial Performance 

Test

2 1 177 354 18 35 $29,851

 Semiannual Report 3 2 1345e8,070 404 807 $680,021

Total Annual Responses 

(Block 13b)

3,433

4. Recordkeeping 

Requirements

Record of Operating 

Parameters for 

Control Devices

1 12 177 2,124 106 212 $178,923

Records of Operating 

Conditions Exceeding 

Last Performance 

Test

1 8 1345 10,760 538 1,076 $906,611
22

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(D) 

Technical 

hr/yra

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yrb

Records of Startup, 

Shutdown, 

Malfunction, etc.

0.25 5 1345 1,681 84 168 $141,646

TOTAL ANNUAL HOURS 36,417 1,822 3,641

TOTAL ANNUAL BURDEN

41,880 $3,068,545

a D=AxBxC

b United States Department of Labor, Bureau of Labor Statistics, May 2006 National Industry-Specific Occupational Employment and Wage 

Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental Engineers, General and Operations Managers, and Office 

and Administrative Support Occupations. The rates have been increased by 110 percent to account for the benefit packages available to those 

employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical - $36.04/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.
23

TABLE G-7: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART RRR

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/

yr

(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 20c20 1 2 $1,685

B. Required Activities

Initial Performance 

Test Report

60 1 20 1,200 60 120 $101,109

Repeat Performance 

Test Report

60 1 4

d

240 12 24 $20,222

C. Write Report

Notification of 

Construction/ 

Modification

2 1 20 40 2 4 $3,370

 Notification of 

Actual Startup

1 1 20 20 1 2 $1,685
24

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/

yr

(D) 

Technical

hr/yra

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yrb

 Notification of 

Initial Performance 

Test

2 1 20 40 2 4 $3,370

 Semiannual Report 3 2 155e930 47 93 $78,422

Total Annual Responses 

(Block 13b)

394

4. Recordkeeping 

Requirements

Record of Operating 

Parameters for 

Control Devices

1 12 20 240 12 24 $20,222

Records of Operating 

Conditions Exceeding 

Last Performance 

Test

1 8 155 1,240 62 124 $104,479
25

Activity

(A)

Hr/ 

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/

yr

(D) 

Technical

hr/yra

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yrb

Records of Startup, 

Shutdown, 

Malfunction, etc.

0.25 5 155 194 10 19 $16,351

TOTAL ANNUAL HOURS 4,164 209 416

TOTAL ANNUAL BURDEN

4,789 $350,915

a D=AxBxC

b United States Department of Labor, Bureau of Labor Statistics, May 2006 National Industry-Specific Occupational Employment and Wage 

Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental Engineers, General and Operations Managers, and Office 

and Administrative Support Occupations. The rates have been increased by 110 percent to account for the benefit packages available to those 

employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical - $36.04/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. (0.2 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.
26

TABLE G-8: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART BB

(A)

Hr/ 

Occurrence

(B)

Occurrences/

Respondent/y

r

(C)a

Respondent/

yr

(D) 

Technical 

hr/yr

(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 $2,814
27

(A)

Hr/ 

Occurrence

(B)

Occurrences/

Respondent/y

r

(C)a

Respondent/

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G) 

Cost/yrb

Marine vessels 80 1 66c5,280 264 528 $444,880

Closed vent leak 

inspection

8 1 54c432 22 43 $36,442

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
28

(A)

Hr/ 

Occurrence

(B)

Occurrences/

Respondent/y

r

(C)a

Respondent/

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G) 

Cost/yrb

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 $72,759

Total Annual Responses 

(Block 13b)

216

SUBTOTAL

4. Recordkeeping 

Requirements

A. Read Instructions Included in 3A
29

(A)

Hr/ 

Occurrence

(B)

Occurrences/

Respondent/y

r

(C)a

Respondent/

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G) 

Cost/yrb

B. Plan Activities Included in 4C

C. Implement Activities Included in 3B

D. Develop Record

System

N/A

E. Time to Enter

Information

 i. Facilities above cutoff1.5 52 54 4,212 211 421 $354,936

 ii. Facilities below cutoffd0.5 52 0 0 0 0 $0

F. Train Personnel N/A

G. Audits N/A

TOTAL ANNUAL 

HOURS

10,821 542 1,081
30

(A)

Hr/ 

Occurrence

(B)

Occurrences/

Respondent/y

r

(C)a

Respondent/

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G) 

Cost/yrb

TOTAL ANNUAL 

BURDEN

12,444 $911,831

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, May 2006 National Industry-Specific Occupational Employment and 

Wage Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental Engineers, General and Operations 

Managers, and Office and Administrative Support Occupations. The rates have been increased by 110 percent to account for the

benefit packages available to those employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical - $36.04/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.
31

TABLE G-9: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART Y

(A)

Hr/ 

Occurrence

(B)

Occurrences/

Respondent/y

r

(C)a

Respondent/

yr

(D) 

Technical 

hr/yr

(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 $2,739

D. Gather Existing 

Information

Included in 

3C
32

(A)

Hr/ 

Occurrence

(B)

Occurrences/

Respondent/y

r

(C)a

Respondent/

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

Cost/ 

yrb

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 $1,388

Supplemental Delay Reportd2 1 0 0 0 0 $0
33

(A)

Hr/ 

Occurrence

(B)

Occurrences/

Respondent/y

r

(C)a

Respondent/

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

Cost/ 

yrb

Quarterly Emission Report None 

Expectede

Total Annual Responses (Block 

13b)

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 $631

D. Develop Record System Included in 

4C

 E. Time to Enter Information Included in 

4C

F. Train Personnel N/A

G. Audits N/A
34

(A)

Hr/ 

Occurrence

(B)

Occurrences/

Respondent/y

r

(C)a

Respondent/

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

Cost/ 

yrb

TOTAL ANNUAL HOURS 56 3 6

TOTAL ANNUAL BURDEN 65 $4,758

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, May 2006 National Industry-Specific Occupational Employment and 

Wage Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental Engineers, General and Operations 

Managers, and Office and Administrative Support Occupations. The rates have been increased by 110 percent to account for the 

benefit packages available to those employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical - $36.04/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.
35

TABLE G-10: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART V

Activity

(A)

Hr/

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)a

Cost/yr

1. Applications N/A

2. Survey and Studies N/A

3. Reporting Requirements

A. Read Instructions 1 1 2

b

2 0 0 $149

B. Required Activities

Initial Performance Test

20 1 2 40 2 4 $3,370

Reference Method 21/22 

Tests

4 1 2 8 0 1 $631

Repeat Performance Test 20 0.2 2 8 0 1 $631

C. Create Information See 3B

D. Gather Existing Information See 3B

E. Write Report

Notification of 

Construction/ 

Reconstruction

2 1 2 4 0 0 $297
36

Activity

(A)

Hr/

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)a

Cost/yr

Notification of Anticipated 

Startup

2 1 2 4 0 0 $297

 Notification of Actual 

Startup

2 1 2 4 0 0 $297

 Notification of Initial 

Performance Test

2 1 2 4 0 0 $297

Report of Performance Test See 3B $0

Application for Alternative 10 1 0.5 5 0 1 $408

Initial Report 8 1 2 16 1 2 $1,388

Semiannual Report 30 2 55c3,300 165 330 $278,050

Total Annual Responses (Block 

13b)

123

4. Recordkeeping Requirements

A. Read Instructions See 3A

B. Plan Activities See 4C
37

Activity

(A)

Hr/

Occurrence

(B)

Occurrences/

respondent/

yr

(C)

Respondents/ 

yr

(D) 

Technical 

hr/yr

(E=D*.05)

Managerial

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)a

Cost/yr

C. Implement Activities See 3B

D. Develop Record System N/A

E. Time to Enter Information

Records of startups, 

shutdown, malfunction, etc.

1.5 1 2 3 0 0 $223

Records of operating, 

parameters and emissions

0.1 365d55c2,008 100 201 $169,109

Records of leak detected 0.4 52 55 1,144 57 114 $96,351

F. Train personnel N/A

G. Audits N/A

TOTAL ANNUAL HOURS 6,550 325 654

TOTAL ANNUAL BURDEN 7,529 $551,498

a United States Department of Labor, Bureau of Labor Statistics, May 2006 National Industry-Specific Occupational Employment and 

Wage Estimates, NAICS 325000 Chemical Manufacturing. The wages are for Environmental Engineers, General and Operations 

Managers, and Office and Administrative Support Occupations. The rates have been increased by 110 percent to account for the 

benefit packages available to those employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical - $36.04/hr.

b Assume one new facility per year comprising two new sources.

c

Estimate 21 existing facilities comprising 55 sources.
38

TABLE G-11: NEW SOURCE ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND 

RECORDKEEPING REQUIREMENTS OF THE HON

Burden Item

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 $105,385

2) Plan Activities 3.8 93 355 5 1,775 89 178 $149,607

3) Training 3.5 38 132 5 660 33 66 $55,610

4) Create, Test, Research and 

Development

2.4 1,778 4,266 5 21,330 1,067 2,133 $1,797,275

5) Gather Information, 1.4 2,102 2,943 5 14,715 736 1,472 $1,239,899

6) Process/Compile and Review 0.8 50 40 5 200 10 20 $16,852

7) Complete Reports 11.4 49 557 5 2,785 139 279 $234,644

Total Annual Responses (Block 

13b)

245

8) Record/Disclose 10.0 49 489 5 2,445 122 245 $205,996

9) Store/File 5.2 51 264 5 1,320 66 132 $111,220

TOTAL ANNUAL HOURS 46,480 2,325 4,650

TOTAL ANNUAL BURDEN 53,455 $3,916,488

(a) = (c)/(b)

(d) - From previously approved ICR. 

See Attachment I for assumptions and further description of activities.
39

TABLE G-12: EXISTING SOURCE ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND 

RECORDKEEPING REQUIREMENTS OF THE HON PROVISIONS

Burden Item

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

(h)

1) Read Rule and 

Instructions

3.6 23 69 14 17,680 884 1,768 $1,489,673

2) Plan Activities 6.1 13 61 18 16,080 804 1,608 $1,354,861

3) Training 5.3 4 17 4 4,400 220 440 $370,733

4) Create, Test, Research 

and Development

17.8 99 1617 150 400,080 20,004 40,008 $33,709,741

5) Gather Information, 

Monitor/Inspect

2.5 677 1693 0 406,320 20,316 40,632 $34,235,507

6) Process/Compile and 

Review

20.0 1 20 0 4,800 240 480 $404,436

7) Complete Reports 81.2 5 388 18 94,560 4,728 9,456 $7,967,389

Total Annual Responses 

(Block 13b)

a

1,600

8) Record/Disclose 17.5 26 442 12 107,040 5,352 10,704 $9,018,923

9) Store/File 6.8 35 222 15 54,480 2,724 5,448 $4,590,349
40

Burden Item

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

(h)

TOTAL ANNUAL 

HOURS

1,105,440 55,272 110,544

TOTAL ANNUAL 

BURDEN

1,271,256 $93,141,612

(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.
41

TABLE G-13: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART VVa

Activity

(A)

Hours/

Occurrence

(B)

Occurrences/

respondent/

yr

(C)a

Respondents/ 

yr

(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 $3,222

B. Required Activities

Initial Performance 

Test Report

48 1 38 1,824 91 182 $153,646

Repeat Performance 

Test Report

48 1 8c 384 19 38 $32,315

C. Create Information Included in 3B

D. Gather Existing 

Information

Included in 3E

E. Write Report

New Sources

Notification of 

Construction 

2 1 23 46 2 5 $3,853
42

Activity

(A)

Hours/

Occurrence

(B)

Occurrences/

respondent/

yr

(C)a

Respondents/ 

yr

(D) 

Technical

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yrb

Notification of 

Reconstruction/ 

Modification

2 1 15 30 2 3 $2,591

 Notification of 

Actual Startup

2 1 38 76 4 8 $6,443

Notification of 

Initial/Repeat 

Performance Test

2 1 46 92 5 9 $7,795

 Existing Sources 

Semiannual Report

4.5 2 38 342 17 34 $28,796

Total Annual Responses 

(Block 13b)

244

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
43

Activity

(A)

Hours/

Occurrence

(B)

Occurrences/

respondent/

yr

(C)a

Respondents/ 

yr

(D) 

Technical

hr/yr

(E=D*.05)

Managerial 

hr/yr

(F=D*.10)

Clerical

hr/yr

(G)

$

Cost/yrb

E. Time to Enter 

Informationd

Average Facilities -

Records of Operating 

Parameters

89.5 1 34 3,043 152 304 $256,366

Small Facilities -

Records of Operating 

Parameters

95.2 1 4 381 19 38 $32,077

F. Train personnel N/A

G. Audits N/A

TOTAL ANNUAL HOURS 6,256 313 625

TOTAL ANNUAL BURDEN 7,146 $527,104

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, May 2006 National Industry-Specific Occupational Employment and 

Wage Estimates, NAICS 325000 Chemical Manufacturing. The rates are for General and Operations Managers, Environmental 
44

Engineers, and Office and Administrative Support Occupations. The rates have been increased by 110 percent to account for the 

benefit packages available to those employed by private industry. Technical - $74.36/hr; Managerial - $125.87/hr; Clerical -

$36.04/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.
45

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) “2006 General 

Schedule” which excludes locality rates of pay.

Technical - $42.45 (GS-12, Step 1, $26.53 x 1.6)

Managerial - $57.20 (GS-13, Step 5, $35.75 x 1.6)

Clerical - $22.96 (GS-6, Step 3, $14.35 x 1.6)

(Htx $42.45/hour)+(Hmx $57.20/hour)+(Hcx $14.35/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, May 2006 National Industry-Specific Occupational Employment and 

Wage Estimates, NAICS 325000 Chemical Manufacturing. The rates are for General and 

Operations Managers, Environmental Engineers, and Office and Administrative Support 

Occupations. The rates have been increased by 110 percent to account for the benefit packages 

available to those employed by private industry.

(Htx $74.36/hour)+(Hmx $125.87/hour)+(Hcx $36.04/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 the 

Referencing Subparts

NSPS Subpart Ka

a. Total Capital/Startup Cost of Monitoring Equipment:

The total Capital/Start-up 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/Start-up 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.