SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

NSPS for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction 

or Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 

60, Subpart K) (Renewal)

1. Identification of the Information Collection

1(a) Title of the Information Collection

NSPS for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction or 

Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, 

Subpart K) (Renewal), EPA ICR Number 1797.06, OMB Control Number 2060-0442. 

1(b) Short Characterization/Abstract

The New Source Performance Standards (NSPS) for Storage Vessels for Petroleum 

Liquids for Which Construction, Reconstruction or Modification Commenced After June 11, 

1973 and Prior to May 19, 1978 (40 CFR part 60, subpart K) were proposed on June 11, 1973, 

and promulgated on March 8, 1974. These regulations apply to facilities that store petroleum 

liquids in storage vessels with a storage capacity greater than 151,416 liters (40,000 gallons),

including: storage vessels with capacity greater than 151,416 liters (40,000 gallons),but not 

exceeding 246,052 liters (65,000 gallons), and where construction or modification commenced 

after March 8, 1974, and prior to May 19, 1978; and storage vessels that have a capacity greater 

than 246,052 liters (65,000 gallons), and where construction or modification commenced after 

June 11, 1973, and prior to May 19, 1978. Facilities that are not subject to these standards are 

storage vessels of petroleum or condensate stored, processed, and/or treated at a drilling and 

production facility prior to custody transfer. This information is being collected to assure 

compliance with 40 CFR part 60, subpart K.

In general, all NSPS standards require initial notifications, performance tests, and 

periodic reports by the owners/operators of the affected facilities. They are also required to 

maintain records of the occurrence and duration of any startup, shutdown, or malfunction in 

the operation of an affected facility, or any period during which the monitoring system is 

inoperative. These notifications, reports, and records are essential in determining compliance, 

and are required of all affected facilities subject to NSPS.

Any owner/operator subject to the provisions of this part shall maintain a file of these 

measurements, and retain the file for at least two years following the date of such measurements, 

maintenance reports, and records. All reports are sent to the delegated state or local authority. 

In the event that there is no such delegated authority, the reports are sent directly to the U. S.

Environmental Protection Agency (EPA) regional office.

Based on our consultations with industry representatives, there is an average of 25 

storage vessels at each plant site, and each plant site has only one respondent (i.e., the 
2

owner/operator of the plant site).

Over the next three years, an average of 220 respondents per year will be subject to the 

standards, and no additional respondents per year will become subject to the standards. These 

estimates are based on the active ICR data. The industry growth rate is appropriate due to the 

very slow growth of the petroleum refining and coal products manufacturing industries affected 

by the standards.

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

without any “Terms of Clearance.”

The “Affected Public” are owners or operators of petroleum liquid storage vessels. The 

burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and 

Cost – NSPS for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction 

or Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, 

Subpart K) (Renewal). The burden to the “Federal Government” is attributed entirely to work 

performed by federal employees or government contractors, and may be found below in Table 2: 

Average Annual EPA Burden and Cost – NSPS for Storage Vessels for Petroleum Liquids for 

Which Construction, Reconstruction or Modification Commenced After June 11, 1973 and Prior 

to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal).

2. Need for and Use of the Collection

2(a) Need/Authority for the Collection

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

establish standards of performance for new stationary sources that reflect: 

. . . application of the best technological system of continuous 

emissions reduction which (taking into consideration the cost of 

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

and environmental impact and energy requirements) the 

Administrator determines has been adequately demonstrated. 

Section 111(a)(l).

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

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

four years. 

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

subject to any requirement of this Act to: 

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

(C) install, use, and maintain such monitoring equipment, and use 
3

such audit procedures, or methods; (D) sample such emissions (in 

accordance with such procedures or methods, at such locations, at 

such intervals, during such periods, and in such manner as the 

Administrator shall prescribe); (E) keep records on control 

equipment parameters, production variables or other indirect data 

when direct monitoring of emissions is impractical; (F) submit 

compliance certifications in accordance with Section 114(a)(3); 

and (G) provide such other information as the Administrator may

reasonably require.

In the Administrator's judgment, volatile organic compounds (VOCs) emissions from

storage vessels for petroleum liquids cause or contribute to air pollution that may reasonably 

be anticipated to endanger public health or welfare. Therefore, the NSPS were promulgated 

for this source category at 40 CFR part 60, subpart K.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standard ensures compliance with 

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

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

Performance tests are required in order to determine an affected facility’s initial 

capability to comply with the emission standard. Continuous emission monitors are used to 

ensure compliance with the standard at all times. 

The notifications required in the standard are used to inform the Agency or delegated 

authority when a source becomes subject to the requirements of the regulations. The reviewing 

authority may then inspect the source to check if the pollution control devices are properly 

installed and operated and that the standard is being met. The performance test may also be 

observed.

3. Non-duplication, Consultations, and Other Collection Criteria

The requested recordkeeping and reporting are required under (40 CFR part 60, 

subpart K).

3(a) Non-duplication

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

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

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

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

be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, 

duplication does not exist.
4

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

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

in the Federal Register (77 FR 63813) on October 17, 2012. No comments were received on the 

burden published in the Federal Register.

3(c) Consultations

The Agency’s industry experts have been consulted, and the Agency’s internal data 

sources and projections of industry growth over the next three years have been considered. 

The primary source of information as reported by industry, in compliance with the recordkeeping and reporting provisions in the standard, is the Online Tracking Information System 

(OTIS) which is operated and maintained by the EPA Office of Compliance. OTIS is the EPA 

database for the collection, maintenance, and retrieval of all compliance data. 

Consultations with industry representatives (i.e., respondents) were conducted to 

determine if there is any way for EPA to reduce the recordkeeping and reporting burden or 

improve the language in the standard to make it easier to comply. In developing this ICR, EPA 

contacted: 1) the American Petroleum Institute (API), at (202) 682-8000; and 2) the Western 

States Petroleum Association (WSPA), at (916) 498-7750. EPA did not receive any comments 

from the consultations.

It is our policy to respond after a thorough review of comments received since the last 

ICR renewal as well as those submitted in response to the first Federal Register notice.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the margin of assurance that 

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

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

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

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

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

promulgated by OMB under 5 CFR part 1320, section 1320.5.

3(f) Confidentiality

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

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

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

September 1, 1976; amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 
5

1978; 44 FR 17674, March 23, 1979).

3(g) Sensitive Questions

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

questions.

4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are facilities that have 

petroleum liquid storage vessels meeting the rule criteria. The United States Standard Industrial 

Classification (SIC) codes, which correspond to the North American Industry Classification 

System (NAICS) codes for such facilities, can be found in the following table:

Standard (40 CFR Part 60, Subpart K) SIC Codes NAICS Codes

Petroleum refineries 2911 32411

Asphalt paving mixture and block manufacturing 2951 324121

Asphalt shingle and coating materials manufacturing 2952 324122

Petroleum lubricating oil and grease manufacturing 2992 324191

All other petroleum and coal products manufacturing 2999 324199

 

4(b) Information Requested

(i) Data Items

In this ICR, all the data that is recorded or reported is required by the NSPS for Storage 

Vessels for Petroleum Liquids for Which Construction, Reconstruction or Modification 

Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) 

(Renewal).

A source must make the following notifications:

Notifications

Notification of construction/reconstruction. 60.7(a)(1)

Notification of physical or operational change. 60.7(a)(4)
6

A source must keep the following records:

Recordkeeping

Records are required to be retained for two years. 60.7(f)

Owner/Operator shall maintain a record of the petroleum liquid stored, 

the period of storage, and the maximum true vapor pressure of that 

liquid during the respective storage period.

60.113(a)

Maintain records of the occurrence and duration of any startup, 

shutdown, or malfunction.

60.7(b)

Electronic Reporting

Some of the respondents are using monitoring equipment that automatically records 

parameter data. Although personnel at the affected facility must still evaluate the data, internal 

automation has significantly reduced the burden associated with monitoring and recordkeeping at 

a plant site. 

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

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

not widely used. At this time, it is estimated that approximately 10 percent of the respondents 

use electronic reporting.

(ii) Respondent Activities

Respondent Activities

Read instructions.

Install, calibrate, maintain, and operate floating roof or vapor recovery system.

Perform initial performance test, according to manufacturers’ instructions, and repeat 

performance tests if necessary.

Write the notifications and reports listed above.

Enter information required to be recorded above.

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 
7

Respondent Activities

providing information.

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

requirements.

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

Transmit or otherwise disclose the information.

Currently sources are using monitoring and reporting equipment that provide parameter 

data in an automated way (e.g., continuous parameter monitoring system.) Although personnel 

at the source still need to evaluate the data, this type of monitoring equipment has significantly 

reduced the burden associated with monitoring and recordkeeping.

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

Information Management

5(a) Agency Activities

EPA conducts the following activities in connection with the acquisition, analysis, 

storage, and distribution of the required information.

Agency Activities

Observe initial performance tests and repeat performance tests if necessary.

Review notifications and reports, including performance test reports, and excess emissions 

reports, required to be submitted by industry.

Audit facility records.

Input, analyze, and maintain data in the Online Tracking Information System (OTIS). 

5(b) Collection Methodology and Management

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

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

Performance test reports are used by the Agency to discern a source’s initial capability to comply 

with the emission standard, and to note the operating conditions under which compliance was 

achieved. This information will be used to monitor vapor recovery, floating roof, or their 

equivalent pollution control devices, thus ensuring continuous compliance with the standard. 

Data and records maintained by the respondents are tabulated and published for use in 

compliance and enforcement programs.
8

Information contained in the reports is entered into OTIS which is operated and 

maintained by EPA's Office of Compliance. OTIS 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 OTIS for tracking air pollution compliance 

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

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

data.

The records required by this regulation must be retained by the owner/operator for two 

years.

5(c) Small Entity Flexibility

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

the impact on small entities (i.e., small businesses) was taken into consideration during the 

development of the regulation. Due to technical considerations involving the process operations 

and the types of control equipment employed, the recordkeeping and reporting requirements are 

the same for both small and large entities. The Agency considers these to be the minimum 

requirements needed to ensure compliance and, therefore, cannot reduce them further for small 

entities. To the extent that larger businesses can use economies of scale to reduce their burden, 

the overall burden will be reduced.

5(d) Collection Schedule

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

shown in below Table 1: Annual Respondent Burden and Cost – NSPS for Storage Vessels for 

Petroleum Liquids for Which Construction, Reconstruction or Modification Commenced After 

June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal).

6. Estimating the Burden and Cost of the Collection

Table 1 documents the computation of individual burdens for the recordkeeping and 

reporting requirements applicable to the industry for the subpart included in this ICR. The 

individual burdens are expressed under standardized headings believed to be consistent with the 

concept of burden under the Paperwork Reduction Act. Where appropriate, specific tasks and 

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

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

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

6(a) Estimating Respondent Burden

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

and reporting requirements is estimated to be 769 hours (Total Labor Hours from Table 1

below). These hours are based on Agency studies and background documents from the 
9

development of the regulation, Agency knowledge and experience with the NSPS program, 

the previously-approved ICR, and any comments received.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

This ICR uses the following labor rates: 

Managerial $121.44 ($57.83 + 110%) 

Technical $100.23 ($47.73 + 110%)

Clerical $50.51 ($24.05 + 110%)

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

2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from 

column 1, “Total compensation.” The rates have been increased by 110 percent to account for 

the benefit packages available to those employed by private industry.

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

The only costs to the regulated industry resulting from information collection activities 

required by the subject standard are labor costs. There are no capital/startup or operation and 

maintenance costs.

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

The only type of industry costs associated with the information collection activity in the 

regulations is labor costs. There are no capital/startup or operation and maintenance costs.

6(c) Estimating Agency Burden and Cost

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

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

examination of records maintained by the respondents, periodic inspection of sources of 

emissions, and the publication and distribution of collected information. 

The average annual Agency cost during the three years of the ICR is estimated to be 

$228. 

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

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

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

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

These rates are from the Office of Personnel Management (OPM), 2011 General Schedule,
10

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

for the benefit packages available to government employees. Details upon which this estimate 

is based appear below in Table 2: Average Annual EPA Burden and Cost – NSPS for Storage 

Vessels for Petroleum Liquids for Which Construction, Reconstruction or Modification 

Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) 

(Renewal).

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

Based on our research for this ICR, on average over the next three years, approximately

220 existing respondents will be subject to the standards. It is estimated that no additional 

respondents per year will become subject. The overall average number of respondents, as shown 

in the table below, is 220 per year.

The number of respondents is calculated using the following table that addresses the three 

years covered by this ICR. 

Number of Respondents

Year

(A)

Number of New 

Respondents 1

(B)

Number of 

Existing 

Respondents

(C)

Number of Existing 

Respondents that keep 

records but do not 

submit reports

(D)

Number of 

Existing 

Respondents That 

Are Also New

Respondents

(E)

Number of 

Respondents

(E=A+B+C-D)

1 0 2.2 217.8 0 220

2 0 2.2 217.8 0 220

3 0 2.2 217.8 0 220

Average 220

1

New respondent include sources with constructed, reconstructed, and modified affected facilities.

Column D is subtracted to avoid double-counting respondents. As shown above, the 

average Number of Respondents over the three year period of this ICR is 220.

The total number of annual responses per year is calculated using the following table:
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Total Annual Responses

(A)

Information Collection Activity

(B)

Number 

of 

Respondents 

(C)

Number 

of 

Responses

(D)

Number of Existing 

Respondents That 

Keep Records But Do 

Not Submit Reports

(E)

Total 

Annual 

Responses 

E=(BxC)+D

Notification of reconstruction or modification 2.2 1 217.8 220

Total 220

The number of Total Annual Responses is 220.

The total annual labor costs are $74,473. Details regarding these estimates may be found 

below in Table 1: Annual Respondent Burden and Cost – NSPS for Storage Vessels for 

Petroleum Liquids for Which Construction, Reconstruction or Modification Commenced After 

June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal).

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 shown in Tables 1 and 2 (below), respectively, and summarized below. 

(i) Respondent Tally

The total annual labor hours are 769 hours at a cost of $74,473. Details regarding these 

estimates may be found below in Table 1: Annual Respondent Burden and Cost – NSPS for 

Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction or Modification 

Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K) 

(Renewal). 

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

information is estimated to average 3 hours per response.

There are no annual capital/startup and O&M costs to the regulated entity. The cost 

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

(O&M) Costs.

(ii) The Agency Tally

The average annual Agency burden and cost over next three years is estimated to be 5 

labor hours at a cost of $228. See below Table 2: Average Annual EPA Burden and Cost –

NSPS for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction or 

Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, 

Subpart K) (Renewal).
12

6(f) Reasons for Change in Burden

There is an increase in the total estimated respondent cost as currently identified in 

the OMB Inventory of Approved Burdens. The cost increase from the most recently approved 

ICR is due to the use of updated labor rates, and is not due to any program changes. This ICR 

references labor rates from the Bureau of Labor Statistics to calculate the respondent cost 

burden.

There is no change to the respondent burden hours or the Agency burden hours and 

costs in this ICR as compared to the previous ICR. This is due to two considerations: (1) the 

regulations have not changed over the past three years and are not anticipated to change over 

the next three years; and (2) the growth rate for the respondents is very low, negative, or nonexistent. Therefore, the labor hours in the previous ICR reflect the current burden to respondents 

and are reiterated in this ICR.

6(g) Burden Statement

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

is estimated to average 3 hours per response. Burden means the total time, effort, or financial 

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

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

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

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

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

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

sources; complete and review the collection of information; and transmit or otherwise disclose 

the information.

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

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

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

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

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

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

Docket ID Number EPA-HQ-OECA-2012-0677. An electronic version of the public docket is 

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

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

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

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

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

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

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

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

holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 
13

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

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

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

Number EPA-HQ-OECA-2012-0677 and OMB Control Number 2060-0442 in any

correspondence. 

Part B of the Supporting Statement

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

information.
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Table 1: Annual Respondent Burden and Cost – NSPS for Storage Vessels for Petroleum Liquids for Which Construction, 

Reconstruction or Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K)

 (Renewal)

Burden Item

A B C D E F G H

Technical 

personhours per 

occurrence

No. of 

occurrences

per 

respondent

per year

Technical 

person-hours 

per respondent 

per year

(AxB)

Respondents 

per year a

Technical 

hours

per year 

(CxD)

Management 

hours

per year 

(Ex0.05)

Clerical 

hours

per year 

(Ex0.10)

Total 

cost per 

year

($) b

1. Applications N/A

2. Surveys and studies N/A

3. Reporting requirements

A. Read instructions Included in 3E

B. Required activities: Included in 3E

i. Monitoring of operations and 

emissions cIncluded in 3E

D. Gather existing information Included in 3B and 4E

E. Write notification

i. Notification of 

reconstruction/modification d4 1 4 2.2 8.8 0.44 0.88 979.91

Subtotal for Reporting Requirements 10.12

4. Recordkeeping requirements

A. Read instructions Included in 3E

B. Plan activities Included in 3E

C. Implement activities Included in 3E

D. Develop record system N/A

E. Time to enter and transmit information: 

i. Records of startup, shutdown, or 

malfunction 1 1 1 220 220 11 22 24,497.66

 ii. Record petroleum liquid stored 0.5 1 0.5 220 110 5.5 11 12,248.83

 iii. Record of storage performance tests 0.5 1 0.5 220 110 5.5 11 12,248.83

 iv. Record true vapor pressure of liquid

 stored 1 1 1 220 220 11 22 24,497.66
15

Burden Item

A B C D E F G H

Technical 

personhours per 

occurrence

No. of 

occurrences

per 

respondent

per year

Technical 

person-hours 

per respondent 

per year

(AxB)

Respondents 

per year a

Technical 

hours

per year 

(CxD)

Management 

hours

per year 

(Ex0.05)

Clerical 

hours

per year 

(Ex0.10)

Total 

cost per 

year

($) b

F. Time to train personnel N/A

G. Time for audits N/A

Subtotal for Recordkeeping Requirements 758.5

TOTAL ANNUAL BURDEN AND COST (rounded) 769 $74,473

Assumptions:

a

 We assume there are approximately 220 sources currently subject to the standard, and that there will be no new sources over the three-year period of this ICR.

b

 This ICR uses the following labor rates: $100.23 for technical, $121.44 for managerial, and $50.51 for clerical labor. These rates are from the United States 

Department of Labor, Bureau of Labor Statistics, March 2012, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, 

“Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.

c

 Monitoring and recordkeeping operations include maintaining records of the petroleum liquid stored, the period of storage, and the maximum true vapor pressure of 

that liquid during the respective storage period, unless the affected facility is equipped with a vapor recovery and return or disposal system in accordance with the 

requirements in 40 CFR 60.112, or stores liquid with a Reid vapor pressure of less than 6.9 kPa (1.0 psia), provided the true vapor pressure does not exceed that 

value.

d

 We assume only one percent of respondents (i.e., 0.01 of 220, or 2.2 respondents) will modify or reconstruct their tanks in such way that will trigger reporting 

requirements under the standard.
16

 Table 2: Average Annual EPA Burden and Cost – NSPS for Storage Vessels for Petroleum Liquids for Which Construction,

Reconstruction or Modification Commenced After June 11, 1973 and Prior to May 19, 1978 (40 CFR Part 60, Subpart K)

 (Renewal)

Burden Item

A B C D E F G H

Technical 

personhours per 

occurrence

No. of 

occurrences 

per respondent 

per year

Technical 

person-hours 

per respondent 

per year 

(AxB)

Respondents 

per year a

Technical 

hours per 

year 

(CxD)

Management 

hours per 

year 

(Ex0.05)

Clerical 

hours 

per year 

(Ex0.10)

Total cost 

per year 

($) b

Notification of reconstruction/

modification c2 1 2 2.2 4.4 0.22 0.44 228.03

TOTAL ANNUAL BURDEN AND COST (rounded) 5 228

Assumptions:

a

 We assume there are approximately 220 sources currently subject to the standard, and that there will be no new sources over the three-year period of this ICR.

b

 This ICR uses the following labor rates: $46.21 for technical, $62.27 for managerial, and $25.01 for clerical labor. These rates are from the Office of Personnel 

Management (OPM), 2011 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit 

packages available to government employees.

c

 We assume only one percent of respondents (i.e., 0.01 of 220, or 2.2 respondents) will modify or reconstruct their tanks in such way that will trigger reporting 

requirements under the standard.