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 Sy nthetic Organic Chemical Industry (SOCMI) and its referencing subparts. Th e 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. C ompliance is assumed through initial performance testing or design anal ys is, as appropriate, and ongoing compliance is demonstrated through parametric monitoring. Ty pes of parameters monitored are incinerator temperature, scrubber flow rate, carbon adsorb er regeneration frequency, as well as others. The appropriate parameter to monitor depends on the ty pe 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 Emiss ion 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 part s 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, subpart s 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 compl y 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 compl ying 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 complyingwith the CAR is higher than the per
source burden of compl ying 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 ye ars covered b y 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 re spondents 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 ye ar at a cost of $1,016,007. Total capital costs will be $3,373,000 per ye ar, and total capital and operation and maintenance (O&M) costs will be $95,329,000 per ye ar. 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 ye ar. 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 propos ed 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 L eaks of VOC in the SOCMIIndustry The NSPS for Emissions of VOC from Equipment L eaks 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 sy nthetic 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, compre ssors, 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 l iquid 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 L eaks of VOC in the SOCMIIndustry NSPS subpart VVa is a new standard that applies to equipment contained within a SOCMIprocess 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 Poly mer Manu facturing Industry The NSPS for the poly

mer manufacturing industry were proposed on September 30, 1987, and January

10, 1989, and promulgated on December 11, 1990. These standards appl y to facilities involved in the manufacture of pol ypropylene, 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 pol ypropylene and pol yethyl ene manufacturing: each raw material preparation section, each pol ym erization 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 pol yethyl ene (terephthalate) manufacturing: each poly merization 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 infor mation is being collected to assure compliance with 40 CFR part 60, subpart DDD. NSPS subpart III: VOC Emissions from SOCMIAir Oxidation Unit Processes The NSPS for the SOCMI Air Oxidation Unit Processes were proposed on October 21, 1983, and promulgate d on June 29, 1990. These standards appl y 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 s ys tem into which its vent stream is discharged; and 3) Each combination of two or more air oxidation reactors and the common recovery s ys tem into which their vent streams are discharged. The s tandard applies to the affected facility

which produces one or more of the chemicals listed in § 60.617 as a product, co
product, b yproduct 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 SOCMIDistillation 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 faci lities 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 s ys tem into which its vent stream is discharged; and 3) Each combination of two or more distillation units and the common recovery s ys tem 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 SOCMIReactor Processes The NSPS for the sy

nthetic organic chemical manufacturing industry (SOCMI) Reactor Processes were proposed on June 29, 1990, and promulgated on August 31, 1993. These standards appl y 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 s ys tem into which its vent stream is discharged; (3) Each combination of two or more reactor processes and the common recovery s ys tem 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, by
product, 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 Em issions 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, specificall y exempted from this regulation are loading racks at which onl y 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 b y-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 re quirements in § 61.305(i). Marine vessels were given a one
- ye ar 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 AS TM 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 faciliti es 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 s ys tems, open - ended valves or lines, valves, flanges and other connectors, product accumulator vessels, and control devices or s ys tems. 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 mo re of the chemicals listed in Table 1 of 40 CFR part 63, subpart F; use as a reactant or manufacture as a product, b y-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 , sty

rene -butadiene rubber production, pesticide production, poly butadiene 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 appl y 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 b y 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, analy tical 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 periodicall y 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 cop y of the report submitted to the State or local agency can be sent to the Administrator in lieu of the report required b y the Federal standards. 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 developm ent 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 provide d 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 app roved 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 frequ ent 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 ye ars. In general, these standards require the respondents to maintain all records, including reports and notifications, for five ye ars. The five
- ye ar reco rd retention requirement is consistent with the permit program at 40 CFR part 70, and the five
- ye ar statute of limitations on which the permit program is based. The retention of records for five ye ars 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
- ye ar 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 Agenc y 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 b y 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978; 44 FR 17674, March 23, 1979)
. 3(g) Sensitive Questions9

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, 4842210

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 5615111

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 4 0 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 b y 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 significantl y reduced the burden associated with monitoring and recordkeeping at the plant site. Also regulatory

agencies, in cooperation with the respondents, continue to create reporting s ys tems to transmit data electronicall y. However, electronic reporting s ys tems 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 b y the CAR and the referencing subparts are identified in the following table. Responde nt 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 com ply 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 Meth odology, 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 on e or more of these activities in connection with the acquisition, anal ys is, 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 b y the Agency or delegated authority
. The results of the se 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 b y local and State regulatory agencies, EPA Regional offices, and EPA headquarters. EPA and its delegated authorities can edit, store, retrieve, and anal yz e 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

c ompliance 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 VV a 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 weekl y 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 SOCMIfacilities because identification of the equipment monitored, the instrument reading, and the monitoring date generall y are co llected 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 SOCMIsources 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 ye ar (hr/y r). Records (and related reporting) of leaks identified as a result of the new annual monitoring requirement for14

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 infor

mation collection activity within this request is shown in Table 5 for the CAR and Tables G
- 1 through G
- 13 for the referencing subparts, respectivel y. 6. Estimating the Burden and Cost of the Collection Table 5 for the CAR and Tables G
- 1 through G
- 13 fo r 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 conc ept 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 re ferencing 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
- Specif ic Occupational Employ

ment and Wage Estimates, NAICS 325000 Chemical Manufacturing (http://www.bls.gov/oes/current/naics3_325000.htm) The rates have been increased b y 110 percent to account for the benefit packages available to those employed b y private industry
.

(ii) Estimating Capital/Startup and Operation and Maintenance Cost s 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 com ply 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 compl y with subpart VV are estimated to be $0 per ye ar because it is assumed that facilities that are already c omplying 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 ye ar. 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 Mainten ance (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 Cost s The only cost s to the Agency

are those associated with analysis of the reported information. EPA ’ s overall compliance and enforcement program includes activities such as the16

examination of records maintained by the respondents and the publication and distribution of c ollected 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 hourl y 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 summari zed 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 T ables 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 c alculated b y dividing the Respondent Burden Hours in Table 6 b y 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 h ours 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 mos t 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 recentl y 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 anal ys es performed during development of the amendments to Subpart VV and the n ew 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 update d 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 b y the new NSPS subpart VVa. The estimate includes the same 2 hours to review semiannual reports that contain the information required b y subpart VV, plus an additional 0.45 hour for Agency review of the additional information the must be submitted under su

bpart 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 requirem ents 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 required18

under subpart VV plus an additional 9.5 hrs/occurrence to enter records of the additi onal information required b y s ubpart VVa. Italso 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 b y s ubpart 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 ye ar of additional recordkeeping burden associated with the new requirements in subpart VVa is estimated based on 30 minutes per year (min/y r) to record information about leaks and possibly delay of repair for open
- ended lines (15 minutes for each semiannual monitoring event), 15 min/y r 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 weekl y visual inspections of pumps, 2 min/day for 7 d/month to record instrument calib ration 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 ty pical 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 ye ar. For the 10 percent of facilities that are small and manuall y 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 ye ar 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/y r) and 10 min/y

r 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 compl y 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 ag ency

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 co mment 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- 200 6
- 0 69 9, which is available for online viewing at www.regulations.gov, or in person viewing at the Enforcement and Compliance Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, 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 numb er 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
- 200 6
- 0 69 9 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 Reports21

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 Year a (c) Estimated

Managerial Hours per Year b (d) Estimated

Clerical Hours per Year c (e) Annual

Cost d (f) 1. Initial Notification of Part 65 Applicabil ity 2 27 e 54 3 5 $2,571 2. Revie w Equipment Leak Monitoring 5 636 f 3,180 159 318 $151,387 3. Revie w Periodic Reports 4 80 g 320 16 32 $15,234 TO TAL 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 so urces 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 ye ars 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: ESTIMA TED 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 th e 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, the23

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 e quipment for one process unit (subparts VV, VVa, V, and H & I); or

 one transfer rack (subparts BB and G). b From the most recentl y 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 Total d With Connectors Without

Connectors a per source b totalc per source

b totalc per source

b totalc per

source b totalc per

source b totalc per

source b 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

. Pl an 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 4,320 119,33425

Burden Item Annual Burden in Technical Hours

Process Vents Storage Vessels Transfer Racks Equipment Leaks Inventory Total d With Connectors Without

Connectors a per source b totalc per source

b totalc per source

b totalc per

source b totalc per

source b totalc per

source b totalc

. Com pile, Process and Review Data 0 0 0 0 0 0 0 0 0 0 18 1,440 1,440

. Com plete 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 TO TAL 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 o r 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 f or sources that are not required to perform connector monitoring. The per
- source burden for these facil ities 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 esti mate 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 num ber 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 basi s 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 1 19,334 5,967 11,933 $10,054,808 Com pile, Process and Revie w Data 18.00 1 18.00 1,440 72 144 $121,331 Com plete 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 TO TAL COST 354,106 17,706 35,410 $29,836,15328

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) TO TAL 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 thro ugh 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 8 0 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 C ost is the sum of costs for technical, managerial, and clerical hours based on the following rates from the United States Dep artment 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 Respondent s (B)

Total Annual Responses a (C)

Respondent Burden Hours a (D)

Respondent Burden Costs a (E)

Agency Burden Hours b (F)

Agency Burden Costs b (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 6,75 5 $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 12,44 4 $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 13830 Subpart (A)

Number of Respondent s (B)

Total Annual Responses a (C)

Respondent Burden Hours a (D)

Respondent Burden Costs a (E)

Agency Burden Hours b (F)

Agency Burden Costs b (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 $29,83 6,153 4,087 $169,192 22,000 0 TO TAL 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 th e 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. S torage Vessel Records

· Storage vessel records where emissions are controlled by a fixed roof and internal floating roof (IFR), external floating roo f (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 s ys tem 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. Equipm ent 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 s ys tem 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.

· L ow - 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 specifie d 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 v essel 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 perio dic 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 alter native 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

· In formation 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

f ive ye ars 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 § 60.113 b(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 b y §§ 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 6 0.487a(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 § 60.56 5(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 ty pe, or catal ys t ty

pe or replacement, removal or addition o f 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 compl y 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 §§ 60.61 5(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 ty pe, catal ys t ty

pe, or replacement, removal or addition of recovery equipment or an air oxidation reactor a s 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 th e 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 compl y as specified in § 60.665(a).

· Record data measured during each perform ance 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 perfor mance 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 ty pe, catal ys t ty

pe, or replacement, removal or addition of reco very 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 m 3 /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 compl y 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 spec ified 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 exemp tion 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 by pass 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 by pass line valve was checked out must be maintained to demonstrate the period, the duration, and frequency in which the b ypass 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 ty pe, catal ys t ty

pe, 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 s tream 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 spec ified 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 emissi ons 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 a s specified in § 61.275(a).

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

· Report of 5 or 10 ye ar 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 s ys tems with control devices as specified in § 61.275(e).

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

· Record of info rmation on closed vent s ys tems 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 spec ified 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).

· Quarterl y report b y 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 ye ar as specified in § 61.305(h).

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

· Record of closed
- vent s ystem 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.

· No tification 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 Notifi cation 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 th at 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, 63.1 46, 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, 6 3.118, 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 Monthl y 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 s ys tem 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 spec ified in §§ 63.6, 63.103, 63.105, and 63.152.
• Records of continuous monitoring s ys tems 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, a nd: (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. Thi s e quates to 636 EPA activities (318 * 2) during each of the three ye ars 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 ye ar, 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 overh ead 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
- ye ar 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 i s 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) cl erical 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 signific antl y, 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 ty pical number of separate activities a source may encounter during one ye ar. This number may vary from facility to facility depending on consolidation of activities, co
- located readings, etc. Since so much variabil ity exists, it is important to note that this an estimate. This number was onl y 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 con solidation 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 sourc es 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) Es timated 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) + (H c * $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 Employ ment 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 b y 110 percent to account for the bene fit 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 appl y 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 woul d 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 anal yz ing 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 anal ys is 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) Sto re/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 Ka a

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/ yr e Report Review: New Plant Vapo r recovery

b 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 9 4 5 9 $4,481 Report of gap excesses c,d 1 1 1 6 6 0 1 $262 TO TAL ANNUAL HOURS 100 5 10 TO TAL 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) Cleric al
- $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

Assumptions a (A) Technical hr/yr (B=A*.05)

Managerial hr/yr (C=A*.10)

Clerical hr/yr Cost/yr

$ a Report Review Notification of construction; 37 b new 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
-Fil l d ; 602 sources @ 1 hr/ea 602 30 60 $28,649 TO TAL ANNUAL HOURS 849 43 86 TO TAL 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 Man agement (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 con structed 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/yr d Report Review: New Plant Notification of Construc tion 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 2 436 c 1,744 87 174 $83,004 TO TAL ANNUAL HOURS 1,744 87 174 TO TAL 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 su bpart 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 subje c t 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 s ource 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 Man agement (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/y r (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 Test d 8 0.2 10 16 1 2 $782 Semiannual Reports 2 2 90 c 360 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 ye ars. 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 Test c 8 0.2 1 1.6 0.08 0.16 $76 Semiannual Reports 2 2 11 d 44 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 cost s 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 ye ars. Does not include sources subject to both Subpart III and the HON , which are assumed to be complyingwith 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 Test c 8 0.2 177 283 14 28 $13,466 Semiannual Reports 2 2 1,345 d 5,380 269 538 $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 ye ars. Does not include sources su bject 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 Initi al Test 8 1 20 160 8 16 $7,617 Repeat Performance Test c 8 0.2 20 32 2 3 $1,542 Semiannual Reports 2 2 155 d 620 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 ye ars. 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/yr a (E=D*.05) c

Man agerial 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/yr a (E=D*.05) c

Man agerial 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 Quarterl y 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 a nd 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 Occu rrence (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 In cluded in NSPS Kb Notification of anticipated startup In cluded in NSPS Kb Notification of actual startup In cluded 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 degassing d 1 1 0 0 0 0 $0
Report Review: Existing Plant 21 Activity (A) EPA/hr Occu rrence (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

reporte 1 1 0 0 0 0 $0 Quarterl y emission reports f 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 b y 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 O ffice 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 Itis beli eved that all vessels have been degassed and all controls have been installed as they were to have been installed within 10 ye ars of promulgation (1999). e Estimate that two percent of existing sources will request delay of repair in the annual report. f A ssume that no source will select the fixed roof vented to a control device option and, thus, have no quarterl y report of exce ss emissions. 22 23 TABLE F - 10: AVERAGE ANNUAL EPA RESOURCE REQUIREMENT FOR SUBPART V Activity (A) EPA hr/ Occurrence (B)

Occurrenc es/ 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 o f 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 Test c 8 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 rate s 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 Aver age 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 Notificati on 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 T OTAL 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 Occurre nce (B)

Occur rences/ plant/yr (C)

Plants/ yr (D) a Technical hr/yr (E=F*.05)

Managerial hrs/yr (G=F*.10)

Clerical hrs/yr Cost/yr e Report Review: New Plant Notification of Construction 8 1 23 b 184 9 18 $8,739 Notification o f 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 46 c 23 1 2 $1,079 Review Test Results 2 1 46 c 92 5 9 $4,398 Report Review: Existing Plant Semiannual Emission Reports e 2.45 2 38 d 186 9 19 $8,855 TO TAL ANNUAL HOURS 534 27 53 TO TAL 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 perc ent 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 2 nd 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 Man agement (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 T ABLE G- 1: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART Ka a (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 In cluded in 3B B. Required Activities Vapor recovery information 20 1 0 0 0 0 $0 Measure seal gap In cluded in 4E C. Create Information In cluded in 3B D. Gather Existing In formation 1 1 157 c 157 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 1 188 c 282 14 28 $23,741 Report of seal gap excess 2.5 1 6 d 15 1 2 $1,313
In formation on vapor recovery In cluded in 3B Total Annual Responses (Block 13b) 194 4. Recordkeeping Requirements A. Read Instructions In cluded in 3B B. Plan Activities In cluded 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 In cluded in 3B D. Develop Record System N/A
E. Time to Enter In formation New tank seal gap measurements 250 1 0 0 0 0 $0 Secondary

seal gap measurement 250 d,e 1 157 c 39,250 1,963 3,925 $3,307,170 Primary s eal gap measurements 100 d 0.2 f 31 c 620 31 62 $52,240 Fill/refill record 2 h 1 35 g 70 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 su bject 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 Nati onal 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 t he 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)

$ C ost/yr 1. Applications N/A 2. Surveys and Studies N/A 3. Reporting Requirements A. Read Instruction 1 1 37 d 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 Changes c 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)

$ C ost/yr Notification of Initial Inspection IFR Internal Inspection 2 1 28 d 56 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 28 d 336 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 Rep eat Requirements Internal IFR Inspection e 12 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)

$ C ost/yr Visual IFR Inspection e 8 1 464 3,712 186 371 $312,807 Report of IFR Failure f 2 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 Refillh 2 1 602 1,204 60 120 $101,406 Number of Respo nses (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)

$ C ost/yr B. Gather and Record

In formati 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 S ys tem 10 1 3 30 2 3 $2,591 D. Time to Enter In formation
- CVS Parameter Records 2 52 3 55 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 ye ars. 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 compl ying 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 M anufacturing. 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 p rivate 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 b y 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 ye ars. One tenth of the 5468 IFRs will be degassed each year, for an annual average of 547 per ye ar. 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 0 c 0 0 0 $0
C. Create Information In cluded in 3B D. Gather Existing In formation In cluded 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 Rep ort 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 In cluded in 3A B. Plan Activities In cluded in 4C C. Implement Activities In cluded in 3B D. Develop Record System N/A
E. Time to Enter In formation Records of Operating Parameters 80 1 436 34,880 1,744 3,488 $2,938,902
F. Train personnel N/A G. Audit s 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 ye ars, based on the assumption of 525 sources in the first and second ye ar, 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 H ON. 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 D DD
Activity (A) Hr/ Occurrence (B)

Occurrences/ respondent/ yr (C) Respondents/ yr (D)

Technical hr/yr a (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 10 c 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 2 d 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/yr a (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 90 e 540 27 54 $45,499 Total Annual Responses (Block 13b) 222 4. Recordkeeping Requirements Record of Operating Parameters for Co ntrol 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/yr a (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 ye ars. 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/yr a (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 Perfor

mance Test Report 60 1 1 60 3 6 $5,055 Repeat Performance Test Report 60 1 0.2 d 12 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/yr a (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 11 e 66 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/yr a (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. Th e 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 source s 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/ Occur rence (B)

Occurrences/ respondent/ yr (C)

Respondents/ yr (D)

Technical hr/yr a (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 1 177 c 177 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 35 d 2,100 105 210 $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/ Occur rence (B)

Occurrences/ respondent/ yr (C)

Respondents/ yr (D)

Technical hr/yr a (E=D*.05)

Managerial hr/yr (F=D*.10)

Clerical hr/yr (G)

$ Cost/yrb Notification of Initial Performance Test 2 1 17 7 354 18 35 $29,851
Semiannual Report 3 2 1345 e 8,070 404 807 $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/ Occur rence (B)

Occurrences/ respondent/ yr (C)

Respondents/ yr (D)

Technical hr/yr a (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 HOUR S 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 b y 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/yr a (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 20 c 20 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/yr a (E=D*.05)

Managerial hr/yr (F=D*.10)

Clerical hr/yr (G)

$ Cost/yrb Notification of Initial Performance Test 2 1 20 4 0 2 4 $3,370
Semiannual Report 3 2 155 e 930 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 $20,2 22 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/yr a (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 Studi es 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- ti ghtness 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 66 c 5,280 264 528 $444,880 Closed vent leak inspection 8 1 54 c 432 22 43 $36,442
C. Create Information In cluded in 3B D. Gather Existing In formation In cluded 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 - off

d 8 0 0 0 0 0 $0 Quarterl y parameter excesses 4 4 54 864 43 86 $72,759 Total Annual Responses (Block 13b) 216 SUBTOTAL 4. Recordkeeping Requirements A. Read Instructions In cluded 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 In cluded in 4C C. Implement Activities In cluded in 3B D. Develop Record System N/A
E. Time to Enter In formation i. Facilities above cut
off 1.5 52 54 4,212 211 421 $354,936 ii. Facilities below cut off d 0.5 52 0 0 0 0 $0
F. Train Personnel N/A G. Audits N/A TOTAL ANNUAL HOURS 10,821 542 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 th ese 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 a ssumed to be compl ying 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 onl y 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)

T echnical 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 Requirem ents A. Read Instructions In cluded in 3C B. Required Activities Initial performance test N/A C. Create Information Annual IFR Internal Inspections and EFR Seal Gap measurement s (existing sources) 8 1 4 32 2 3 $2,739

D. Gather Existing In formation In cluded in 3C 32 (A) Hr/ Occurrence (B)

Occurrences/ Respondent/y r (C) a

Respondent/ yr (D)

T echnical 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 In cluded in NSPS Kb Notification of anticipated startup In cluded in NSPS Kb Notification of actual startup In cluded in NSPS Kb Notification of emission test N/A Report of emission test N/A Notification of Control instal lation and refill at 1st IFR Degassing c 2 1 0 0 0 0 $0
Existing Sources Annual Inspection Reports 2 2 4 16 1 2 $1,388 Supplemental Delay

Reportd 2 1 0 0 0 0 $0 33 (A) Hr/ Occurrence (B)

Occurrences/ Respondent/y r (C) a

Respondent/ yr (D)

T echnical hr/yr (E=D*.05)

Managerial hr/yr (F=D*.10)

Clerical hr/yr (G)

Cost/ yrb Quarterl y Emission Report None Expectede Total Annual Responses (Block 13b) 8 4. Recordkeeping Requirements A. Read Instructions In cluded in 3A B. Plan Activities In cluded in 4C C. Implement Activities
- Filing and Maintaining Records 2 1 4 8 0 1 $631
D. Develop Record System In cluded in 4C E. Time to Enter Information In cluded 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)

T echnical 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 b y 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, Bure au 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 b y 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 Itis believed that all vessels have be en 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 quarterl y 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 Infor

mation 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 55 c 3,300 165 330 $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 0.1 365 d 55 c 2,008 1 00 201 $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 State s 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 n ew 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 A ctivity (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 Repo rts 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/F ile 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 res pondent 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, M onitor/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 res pondent 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 VV a
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 8 c 384 19 38 $32,315
C. Create Information In cluded in 3B D. Gather Existing In formation In cluded 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 Notificatio n 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 3 42 17 34 $28,796 Total Annual Responses (Block 13b) 244
4. Recordkeeping Requirements A. Read Instructions In cluded in 3A

B. Plan Activities In cluded in 4C C. Implement Activities In cluded 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 In formationd 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 facil ities each ye ar 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 ye ar 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 electronicall y. Assume that costs are be ing calculated for the second of the three ye ars after promulg ation 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 State s 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 s ource reports. (B) That semiannual reports of results from equipment leak detection and repair programs are required b y the equipment leak standard. Sources are required to comply with the equipment leak standard b y 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 sp ecific 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 ye ar. Under the performance test headin gs, these numbers are based upon assumptions (A) and (B), above. For one
- time reports, the total number of reports expected over the three
- ye ar period was divided by three to get an annual average incorporating assumption (C), above. (c) Estimated Technic al Hours per ye ar is the product of (a) and (b). (d) Estimated Managerial Hours per ye ar 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) (Ht x $42.45/hour)+(Hm x $57.20/hour)+(H c x $14.35/hour) = (G) Where: Ht is (c), or technical hours Hm 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 re sults 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 provision s, as the CAR does not include wastewater provisions. The total number of facilities will increase b y 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, onl y items 8 and 9 are considered records burdens directl y. 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 av erage 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 ty pical 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 onl y 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 b y three, where appropriate, and then summarize d 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 ye ars 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 comp liance 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 ty

pe are shown in Table B
- 1. (e) Estimated Technical Hours per ye ar 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 o f facilities complying with only the wastewater provisions (80). (f) Estimated Managerial Hours per ye ar is 5 percent of (e). (g) Estimated Clerical Hours per ye ar 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 Employ ment and Wage Estimates, NAICS 325000 Chemical Manufacturing. The rates are for General and Operations Managers, Environmental Engineers, and Office and Adminis trative Support Occupations. The rates have been increased b y 110 percent to account for the benefit packages available to those employed by private industry
. (Ht x $74.36/hour)+(Hm x $125.87/hour)+(H c x $36.04/hour) = (G) Where: Ht is (e), or technical hours Hm 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 Rul e 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 anal ys is 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/D isclose are activities which are solel y 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 solel y 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 Op erating and Maintenance (O&M) Costs for this I CR 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 a pproximately

$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 ye ar 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
- ye ar expected life. The equipment is not capitalized, so no discount rate applies. The average annual cost is, t herefore, $7,000/5, or $1,400/y

r. 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/start

up 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 ye ar per affected facility ($13,500 discounted over 10 year s 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 ye ar. 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 emplo yed. 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 Eq uipment : 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 M aintenance of Monitoring Equipment: There are no O&M costs associated because no CEMs are emplo yed. 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 : Estim ate the cost to purchase monitoring equipment is approximately $20
- 30K for process vents and wastewater operations, or an average of $25K with a 10
- ye ar life expectancy

and a 7 percent depreciation rate, or $2225 per year. There are no associated costs fo r 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 ye ar. 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 Monito ring Equipment : Only new sources will buy

an organic volatile analyzer. Estimate the average cost of a monitor is $7,000 with a 5
- ye ar expected life. The equipment is not capitalized, so no discount rate applies. The average annual cost is, therefore, $7 ,000/5, or $1,400/y

r. 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
- hou se (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/y r. 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 C apital/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 ye ar, 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.