**SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY**  **NSPS for Storage Vessels for Petroleum Liquids for W**  **hich Construction, Reconstruction or Modification Commenced After June 11, 1973**  **and P rior 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 L iquids for Which Construction, Reconstruction or Modification Commenced After June 11, 1973 and P rior to May 19, 1978 (40 CFR Part 60 , Subpart K) (Renewal), EPA I CR Number 1797.0 6 , OMB Control Number 2060

- 0442

. **1(b) Short Characterization/Abstract** The New Source Performance Standards (NSPS) f or Storage Vessels for Petroleum Liquids for Which Construction, Recons truction or Modification Commenced After June 11, 1973 and P rior 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 co mmenced 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 an y period during which the monitoring s ys tem is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affect ed 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. Al l reports are sent to the delegated state or local authority

. In the event that there is no such delegated authority , the reports are sent directl y 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., the2

owner/operator of the plant site). Over the next three ye ars, an average of 220 respondents per ye ar will be subject to the standard s , and no additional respondents per year will become subject to the standard s . These estimates are based on the active ICR data. The industry growth rate is appropriate due to the very slow gro wth of the petroleum refining and coal products manufacturing industries affected by the standard s
. The Office of Management and Budget ( OMB ) approved the currentl y active I CR 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 P rior to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal). The burden to the “Federal Government” is attributed entirely to work performed b y 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 L iquids for Which Construction, Reconstruction or Modification Commenced After June 11, 1973 and P rior 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 sy stem of continuous emissions reduction which (taking into consideration the cost of achieving such emissions reduction, or an y non - air quality health and environmental impact and energy requirements) the Administrator determines has been adequatel y demonstrated. Section 111(a)(l). The Agency

refers to thi s 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 use3 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 co ntrol 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 Administrat or may reasonabl y 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 reasonabl y be anticipated to endanger public health or wel fare. 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 ensure s 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 de termine 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 properl y 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 stand ards have not been delegated, the information is sent directl y to the appropriate EPA regional office. Otherwise, the information is sent directl y 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 by the Federal standards. Therefore, duplication does not exist.4

**3(b) Public Notice Required P rior to ICR Submission to OMB**  An announcement of a public comment period for the renewal of this I CR 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 record

keeping and reporting provisions in the standard, is the Online Tracking Information Sy stem (OTIS) which is operated and maintained b y the EPA Office of Compliance. OTIS is the EPA database for the collection, maintenance, and re trieval of all compliance data. Consultations with industry representatives (i.e., respondents) were conducted to determine if there is an y way for EPA to reduce the recordkeeping and reporting burden or improve the language in the standard to make it e asier to comply . In developing this I CR, 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 an y 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 collectio n 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 frequentl y, the proper operation and maintenance of control equipment and the possibility

of detecting violations would be less likely

. **3(e) General Guidelines**
T hese reporting or recordkeeping requirements do not violate any of the regulations promulgated b y 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 b e 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, Septemb er 20,5

1978; 44 FR 17674, March 23, 1979). **3(g) Sensitive Questions**
T he 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 (SI C) codes, which correspond to the North American Indus try Classification Sy stem (NAI CS) codes for such facilities, can be found in the following table:

**Standard (40 CFR**  **P art 60,**  **S ubpart**  **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 b y the NSPS for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction or Modification Commenced After June 11, 1973 and P rior to May 19, 1978 (40 CFR P art 60, S ubpart K) (Renewal). A source must make the following notifications :
**Notification s**  Notification of c onstruction/reconstruction. 60.7(a)(1) Notification of ph ys ical or operational change. 60.7(a)( 4 )6

A source must keep the following records: **Recordkeeping** Records are required to be retained for two ye ars. 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 r espondents 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 recordke eping at a 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 10 percent of the respon dents use electronic reporting.

**(ii) Respondent Activities**

**Respondent Activities** Read instructions. Install, calibrate, maintain, and operate floating roof or vapor recovery s ys tem. 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 sy stems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and sy stems for the purpose of processing and maintaining info rmation. Develop, acquire, install, and utilize technology and sy stems for the purpose of disclosing and7 **Respondent Activities** providing information. Adjust the existing way s to comply with an y 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 sy stem. ) Although personnel at the source still need to evaluate the data, this ty pe of monitoring equipment has significantl y 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, analy sis, 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, anal yz e, and maintain data in the Online Tracking Information Sy stem (OTI S). **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 properl y installed and operated. Performance test reports are used b y the Agency to discern a source ’ s initial capability to compl y 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

In formation contained in the reports is entered into OTI S which is operated and maintained by

EPA's Office of Compliance. OT IS is EPA ’ s database for the collection, maintenance, and retrieval of compliance data for app roximately 125,000 industrial and government

- owned facilities. EPA uses the OTI S for tracking air pollution compliance and enforcement b y local and state regulatory agencies, EPA regional offices and EPA headquarters. Both EPA and its delegated a uthorities can edit, store, retrieve and analyze the data. The records required b y this regulation must be retained by the owner/operator for two ye ars. **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 invol ving the process operations and the ty pes 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 L iquids for Which Construction, Reconstruction or Modification Commenc ed After June 11, 1973 and P rior 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 I CR. The individual burdens are expressed under standardized headings believed to be consi stent 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 requirement s is estimated to b e 769 hours ( Total Labor Hours from Table 1 below ). T hese hours are based on Agency studies and background documents from the9

development of the regulation, Agency knowledge and experience with th e NSPS program, the pre viously

- approved ICR, and any comments received. **6(b) Estimating Respondent Costs (i) Estimating Labor Costs**  This I CR uses the following labor rates: Managerial $1 21

. 4 4 ($5 7

. 8 3 + 110%) Technical $ 100

. 23 ($4 7

. 73 + 110%) Clerical $ 50

. 5 1 ($2 4

. 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 increase d 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 b y 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 t ype of industry costs associated with the informatio n collection activity in the regulations is labor costs. There are no capital/startup or o peration and maintenance costs. **6(c) Estimating Agency Burden and Cost** The only costs to the Agency

are those costs associated with anal ys is of the reported infor mation. EPA's overall compliance and enforcement program i ncludes 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 hourl y labor rate as follows:

Managerial $ 6 2.27 (GS

- 13, Step 5, $ 3 8. 92 + 60% ) Technical $ 4 6

. 21 (GS

- 12, Step 1, $ 28. 88 + 60% ) Clerical $2 5.01 (GS

- 6, Step 3, $ 15. 63 + 60% ) These rates are from the Office of Personnel Management (OPM) , 20 1 1 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 Af

ter June 11, 1973 and P rior 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 I CR, on average over the next three ye ars, approximately 220 existing re spondents will be subject to the standard s . It is estimated that no additional respondents per ye ar 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 ye ars covered b y this ICR. **Number of Respondents**

Year (A) Number of Ne w 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. C olumn D is subtracted to avoid double

- counting respondents

. As shown above, the average Number of Respondents over the three ye ar period of this ICR is 220. The total number of annual responses per ye ar is calculated using the following table:11 **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. Th e 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 L iquids for Which Construction, Reconstruction or Modification Commenced After June 11, 1973 and P rior 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) , respectivel y, 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 L iquids for Which Construction, Reconstruction or Modification Commenced After June 11, 1973 and P rior 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

. The re 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 L iquids for Which Construction, Reconstruction or Modification Commenced After June 11, 1973 and P rior to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal).12

**6(f) Reasons for Ch ange in Burden**  There is an increase in the total estimated respondent cost as currentl y identified in the OMB Inventory

of Approved Burdens. The cost increase from the most recentl y 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 cost s in this I CR as compared to the previous I CR. 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 non

exi stent. Therefore, the labor hours in the previous I CR 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 b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instruc tions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y 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 t his I CR 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 informati on, 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 sy stem , select “search,” then key in the docket ID number identif ied 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 C enter Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holiday s. The telephone number for the Reading Room is (202) 566

- 1744, and the telephone13

number for the docket center i s (202) 566

- 17 52

. Also, you can s end comments to the Office of In formation 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 metho ds were used in collecting this information.14

**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 P**  **rior to May 19, 1978 (40 CFR Part 60, Subpart K) (Renewal)** 

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person**   ** hours 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) Managem**  **ent**

**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 3 E B. Required activities: Included in 3 E i. Monitoring of operations and emissions c Included in 3 E D. Gather existing information Included in 3 B and 4 E E. Write notification i. Notification of reconstruction/modification d 4 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 3 E B. Plan activities Included in 3 E C. Implement activities Included in 3 E 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 24,497.6615

**Burden Item A**  **B C**  **D E**  **F G**  **H Technical**  **person**   ** hours 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) Managem**  **ent**

**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 75**  **8.5 TOTAL ANNUAL BURDEN AND COST (**  **rounded )**  **769 $**  **74,47 3**  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, “T otal 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, an d 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 o r disposal system in accordance with the requirements in 40 CFR 60.112, or stores liquid with a Reid v apor 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 s uch way that will tr igger 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 P rior to May 19, 197**  **8 (40 CFR Part 60, Subpart K) (Renewal)** 

**Burden Item A**  **B C**  **D E**  **F G**  **H**
**Technical person**  **** **hours 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) Managem**  **ent**

**hours per year**  **(Ex0.05) Clerical** 

**hours per year**  **(Ex0.10) Total cost** 

**per year ($)**  **b** Notification of reconstruction/ mo dification c 2 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 mana gerial, 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 t o account for the benefit packages available t o 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 s uch way that will trigger reporting requirements under the standard.