# 1 SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

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

Industry (SOCMI) (Renewal)

Part A of the Supporting Statement

1. Identification of the Information Collection

1(a) Title of the Information Collection

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

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

1(b) Short Characterization/Abstract

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

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

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

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

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

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

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

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

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

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

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

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

through parametric monitoring. Types of parameters monito red are incinerator temperature,

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

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

to comply.

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

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

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

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

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

transfer racks, equipment leaks, and the general provisio ns 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 amende d to refer to the CAR as a compliance

alternative. The referencing subparts include 40 CFR part 60, subparts Ka, Kb, VV, VVa, DDD,

III, NNN, and RRR; 40 CFR part 61, subparts BB, Y, and V; 40 C FR part 63, subparts F, G, H,

and I.

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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 subpar ts, estimates are made of the

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

consolidated into one ICR.

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

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

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

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

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

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

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

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

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

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

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

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

$91,956,000 per year.

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

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

the “Federal government” burden is attributed entirely to work performed by Federal employees

or government contractors and may also be found below in Table 8: Summary of Respondent

and Agency Burden and Cost for Referencing Subparts and the C AR.

The CAR (Consolidated Air Rule)

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

(MACT) regulations require initial notifications includi ng one-time notifications of initial

startup, applicability, and initial compliance status; perfo rmance tests, periodic monitoring,

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

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

respondents taking advantage of various provisions for waive rs, approval of alternative methods,

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

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

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

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

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

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

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

results in not meeting the regulatory requirement to con duct performance tests within the

specified timeframe despite the affected facility’s bes t efforts to fulfill the obligation. Examples

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

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

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

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

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

NSPS subpart Ka: Storage Vessels for Petroleum Liquids

The NSPS for subpart Ka were proposed on May 18, 1978, and pro mulgated 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 ar e volatile organic compounds

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

subject to NSPS subpart Kb, the most recent VOC standard a pplicable 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 Vess els

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

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

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

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

vessels listed in §§60.110b(b), 60.110b(c), and 60.110b(d). The standar ds include visual

inspection, leak detection, and repair for equipment configur ations including fixed and floating

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

compliance with 40 CFR part 60, subpart Kb.

NSPS subpart VV: Equipment Leaks of VOC in the SOCMI Indus try

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

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

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

manufacturing industry which was constructed, modified, or r econstructed 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. The se include pumps in light liquid

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

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

valves in heavy liquid service, pressure relief devices in l ight liquid or heavy liquid service,

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

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

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

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

NSPS subpart VVa: Equipment Leaks of VOC in the SOCMI In dustry

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

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

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

40 CFR part 60, subpart VVa.

NSPS subpart DDD: VOC Emissions from the Polymer Manuf acturing Industry

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

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

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

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

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

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

section, each polymerization reaction section, each m aterial recovery section, each product

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

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

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

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

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

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

The NSPS for the SOCMI Air Oxidation Unit Processes we re proposed on October 21,

1983, and promulgated on June 29, 1990. These standards apply to the following facilities for

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

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

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

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

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

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

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

NSPS subpart NNN: VOC Emissions from SOCMI Distillati on Operations

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

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

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

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

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

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

vent streams are discharged. The standard applies to affe cted 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 c ollected to assure compliance with 40

CFR part 60, subpart NNN.

NSPS subpart RRR: VOC Emissions from SOCMI Reactor Pro cesses

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

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

standards apply to affected facilities commencing constructi on, modification or reconstruction

after the date of proposal: (1) Each reactor process n ot discharging its vent stream into a recovery

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

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

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

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

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

NESHAP subpart BB: Benzene Emissions from Benzene Tra nsfer Operations

The National Emission Standards for Benzene Emissions from Benzene Transfer Operations

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

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

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

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

exempted from this regulation are loading racks at which o nly the following are loaded: benzeneladen waste (covered under subpart FF of part 61), gasoline, c rude oil, natural gas liquids,

petroleum distillates (i.e., fuel oil, diesel, or kero sene), or benzene-laden liquid from coke byproduct recovery plants. In addition, any affected facil ity which loads only liquid containing less

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

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

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

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

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

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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 Vesse ls were proposed in 1980, and

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

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

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

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

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

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

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

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

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

CFR part 61, subpart Y.

NESHAP subpart V: National Emission Standard for Equipme nt Leaks (Fugitive Emission

Sources)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

production, chlorinated hydrocarbon use in the production of ch emicals, pharmaceutical

production, and miscellaneous butadiene use are subject to th e negotiated regulations affecting

equipment leaks promulgated under subpart I. The emission points include transfer racks,

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

existing sources as well as new sources commencing constr uction 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

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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 so urces that reflect:

. . . application of the best technological system of conti nuous

emissions reduction which (taking into consideration the cost of

achieving such emissions reduction, or any non-air quality he alth

and environmental impact and energy requirements) the

Administrator determines has been adequately demonstrated.

Section 111(a)(l).

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

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

every four years.

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

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

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

air pollutants and shall require the maximum degree of em ission reduction.

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

subject to any requirement of this Act to:

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

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

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

sample such emissions (in accordance with such procedures or

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

periods, and in such manner as the Administrator shall

prescribe); (E) keep records on control equipment parame ters,

production variables or other indirect data when direct

monitoring of emissions is impractical; (F) submit comp liance

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, pollutant emissions fro m storage vessels, process vents,

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

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

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

referencing subparts.

2(b) Practical Utility/Users of the Data

The recordkeeping and reporting requirements in the standards ensure compliance with

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

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

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

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

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

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

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

3. Nonduplication, Consultations, and Other Collection Crit eria

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

63 referencing subparts.

3(a) Nonduplication

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

appropriate EPA regional office. Otherwise, the infor mation 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 subm itted to the state or local agency can

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

duplication exists.

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

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

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

burden published in the Federal Register

.

3(c) Consultations

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

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

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

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

amendments to the standards of performance for equipmen t leaks of VOC in the SOCMI. All

affected parties were given the opportunity to comment on the proposed amendments during this

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

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

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

recordkeeping and reporting requirements for the standards we re not the specific items being

discussed. Representatives of the American Chemistry Council declined invitations to

participate in development of the proposed amendments.

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

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

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

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

were received.

3(d) Effects of Less Frequent Collection

Less frequent information collection would decrease the m argin of assurance that

facilities are continuing to meet the standards. Requir ements 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 infor mation required by these standards was

collected less frequently, the proper operation and mainte nance of control equipment and the

possibility of detecting violations would be less likely.

3(e) General Guidelines

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

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

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

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

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

which the permit program is based.

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

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

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

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

nonexistence of essential records.

3(f) Confidentiality

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

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

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

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

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

3(g) Sensitive Questions

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

questions.

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4. The Respondents and the Information Requested

4(a) Respondents/SIC Codes

The respondents to the recordkeeping and reporting requirements are source category

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

corresponding North American Industry Classification Sy stem (NAICS) codes for the

respondents are listed below.

Standard SIC Code NAICS Code

All referenced subparts 2821 325211

2824 325222

2851 32551

2865 325111, 325132, 325192

2869 32511, 325193, 325199

2899 32511, 325199

2911 32411

2951 324121

2952 324122

2992 324191

2999 324199

4212 562111, 562112, 562119, 48411,

48421, 48422

4213 484121, 484122, 48421, 48423

4214 48411, 48421, 48422

4215 49211, 49221

4221 49313

4222 49312

4225 49311, 53113

4226 49312, 49311, 49319

4231 48849

4412 483111

4424 483113

4432 483113

4449 483211

4481 483112, 483114

4482 483114, 483212

4489 483212, 48721

4491 48831, 48832

4492 48833

4493 71393

4499 532411, 48831, 48833, 48839

4724 56151

4725 56152

4729 488999, 561599

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4731 541614, 48851

4741 532411, 48821

4783 488991

4785 48839, 48849

4789 488999, 48711, 72231, 48821

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

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

a particular entity, please see the applicability provisi ons in the standard.

4(b) Information Requested

(i) Data Items

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

referencing subparts.

Attachment A lists the recordkeeping and reporting requirement s for the CAR and its

referencing subparts.

Electronic Reporting

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

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

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

and recordkeeping at the plant site.

Also, regulatory agencies, in cooperation with the respo ndents, continue to create

reporting systems to transmit data electronically. Howe ver, electronic reporting systems are still

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

use electronic reporting.

(ii) Respondent Activities

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

in the following table.

Respondent Activities

Read instructions.

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

Perform initial performance test and repeat performance tests if necessary.

Write the notifications and reports listed in Attachment A

Enter information required to be recorded in Attachment A

.

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

systems for the purpose of collecting, validating, and ver ifying information.

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

maintaining information.

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

providing information.

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



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

Transmit, or otherwise disclose the information.

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

Management

5(a) Agency Activities

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

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

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

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

acquisition, analysis, storage, and distribution of the re quired information.

5(b) Collection Methodology and Management

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

determine whether the pollution control devices are properl y installed and operated.

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

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

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

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

determinations.

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

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

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

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

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

EPA and its delegated Authorities can edit, store, retri eve, and analyze the data.

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

years.

5(c) Small Entity Flexibility

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

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

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

technical considerations involving the process operations an d the types of control equipment

employed, the recordkeeping and reporting requirements are t he 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 fo r small entities. To the extent that

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

reduced.

5(d) Collection Schedule

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

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

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

Requirements for the referencing subparts, respectively.

6. Estimating the Burden and Cost of the Collection

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

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

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

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

have been identified. Responses to this information col lection 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 currentl y valid OMB Control Number.

6(a) Estimating Respondent Burden

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

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

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

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

regulation, Agency knowledge and experience with the NSP S and NESHAP programs, 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 $114.49 ($54.52 + 110%)

Technical $98.20 ($46.76 + 110%)

# 14 Clerical $48.53 ($23.11 + 110%)

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

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

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

for the benefit packages available to those employed by pri vate industry.

(ii) Estimating Capital/Startup and Operation and Maintenanc e 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 associat ed with the CAR. Facilities that comply with

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

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

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

summarized in Table 8.

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

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

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

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

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

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

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

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

6(c) Estimating Agency Burden and Cost s

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

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

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

collected information.

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

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

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

subparts, and is summarized in Table 8.

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

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

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

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

# 15

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

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

the benefit packages available to government employees.

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

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

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

and the referencing subparts.

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

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

and the referencing subparts.

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

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

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

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

6(e) Bottom Line Burden Hours and Cost Tables

The detailed bottom line burden hours and cost calculation s for the respondents and the

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

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

through G-13 for the referencing subparts, respectively.

(i) Respondent Tally

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

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

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

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

information is estimated to average 200 hours per response.

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

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

Maintenance (O&M) Costs.

(ii) The Agency Tally

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

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

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

through F-12 for the referencing subparts.

6(f) Reasons for Change in Burden

# 16

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

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

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

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

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

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

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

categories. Specific changes to tables are described bel ow:

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

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

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

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

estimates made in the previous ICR renewal for the revis ions.

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

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

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

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

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

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

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

updated labor rates which increased the overall cost for e ach subpart.

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

updated labor rates which increased the overall cost for e ach subpart.

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this c ollection of information

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

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

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

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

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

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

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

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

otherwise disclose the information.

# 17

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 OM B Control Number. The OMB Control

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

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

burden estimates, and any suggested methods for minimizing res pondent burden, including the

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

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

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

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

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

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

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

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

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

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

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

number for the docket center is (202) 566-1752. Also, you can se nd 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. P lease include the EPA Docket ID

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

correspondence.

Part B of the Supporting Statement

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

information.

# 18 TABLE 1: AGENCY ACTIVITIES

Performance Tests

- Initial

- Repeat

Review Reports

- Notification of Initial Startup

- Notification of Performance Test

- Initial Compliance Status

- Startup, Shutdown, Malfunction Plans

- Periodic Reports

TABLE 2: ANNUAL BURDEN AND COST TO THE FEDERAL GOVE RNMENT 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 Applicability 2 27 e 

# 54 3 5 $2,799

2. Review Equipment Leak

Monitoring 5 636 f 

# 3,180 159 318 $164,802

3. Review Periodic Reports 4 80 g 

# 320 16 32 $16,584

TOTAL ANNUAL COST 3,554 178 355 $184,18 5

TOTAL ANNUAL BURDEN 4,087 $368,369

Assumptions:

a 

# c = a x b

b 

# Estimate managerial hours are 5 percent of technical hours.

c 

# Estimate clerical hours are 10 percent of technical hours.

d 

# Annual cost is the sum of costs for technical, manageria l, and clerical hours based on the Office of Personnel

Management (OPM),

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

account for the benefit packages available to government employees.

Managerial

- $62.27 (GS

- 13, Step 5, $38.92 + 60%)

Technical

- $46.21 (GS

- 12, Step 1, $28.88 + 60%)

Clerical

- $25.01 (GS

- 6, Step 3, $15.63 + 60%)

e 

# Estimate that all CAR sources must submit an Initial No tification of Part 65 Applicability. It is estimated t hat 1/3

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

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

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 le aks 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 whic h equals 80 facilities will opt to comply with the CAR

and must submit periodic reports each year.

# 19

TABLE 3: ANNUAL BURDEN AND COST TO THE FEDERAL GOVE RNMENT

OF THE DIRECT FINAL STANDARDS

Activity (A)

Hours per

occurrence (B)

Hours per plant

per year (C)

Plants per

year (D)

Technical personhours per year

(D=BxC) (E)

Management

person-hours

per year

(Dx0.05) (F)

Clerical

person-hours

per year

(Dx0.1) (G)

Cost, $ a



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

TOTAL BURDEN AND

COST (SALARY) 6 0.3 0.6 $310.95

TOTAL ANNUAL COST

Assumptions 

# :

a 

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

# 20

TABLE 4: ESTIMATED NUMBER OF SOURCES SUBJECT TO REFE RENCING

SUBPARTS THAT WILL OPT TO COMPLY WITH THE CAR

Referencing Subpart Estimated Number of Sources

Complying with CAR a,b



# Storage Vessels

Ka 458

Kb 382

Y 0

Transfer Racks

BB 0

Equipment Leaks

V 19

VV 59

VVa 0

Process Vents

III 1

NNN 71

RRR 8

DDD 5

HON F & G

- Storage Vessels 800

HON F & G

- Transfer Racks 320

HON H &I

-- Equipment Leaks 240

HON F & G

- Process Vents 640

Assumptions 

# :

a 

# Note that the estimate is on a per-source basis, ra ther than on a facility basis and

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

does not match the facility entries in the referenci ng subpart burden tables in Tables

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

is defined as:

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

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

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

and H & I); or

- one transfer rack (subparts BB and G).

b 

# From the most recently approved ICR.21TABLE 5: BASIS FOR ANNUAL RESPONDENT BURDEN OF REPORTING AND RECORDKEEPING FOR THE CARBurden ItemAnnual Burden in Technical HoursProcess Vents Storage Vessels Transfer RacksEquipment LeaksInventoryTotaldWith ConnectorsWithoutConnectorsapersourcebtotalcpersourcebtotalcpersourcebtotalcpersourcebtotalcpersourcebtotalcpersourcebtotalcRead Rule andInstructions 2.9 2,103 1.1 1,804 1.1 352 2.5 600 1 78 1.8 144 5,081Plan Activities 2.1 1,523 1.7 2,788 0.85 272 0.57 137 0.23 18 4.5 360 5,097Training 1.3 943 0.5 820 0.5 160 0 0 0 0 0 0 1,923Create, Test, Researchand Development 2820,300 16 26,240 16 5,120 380 91,200 15512,090 0 0 154,950Gather Information,Monitor and Inspect 1410,150 17 27,880 17 5,440 263 63,120 108 8,424 54 4,320 119,334Compile, Process andReview Data 0 0 0 0 0 0 0 0 0 0 18 1,440 1,440Complete Forms 9 6,525 5.4 8,856 5.4 1,728 57 13,680 23 1,794 5.4 432 33,015Record/ Disclose 2820,300 2.8 4,592 2.8 896 4.7 1,128 1.9 148 9 720 27,784File/Store 3 2,175 1.25 2,050 1.25 400 2.75 660 0.9 70 1.58 126 5,482TOTAL 88.364,018 46 75,030 45 14,368 711 170,525 29022,622 94 7,542 354,106Assumptions:aThe HON, the basis for the CAR burden estimate, requires connector monitoring. Sources originally complying with subpart V or VV will not be required to performconnector monitoring if these facilities is the average of the per source burden for subparts V and VV. Theaverage for subparts V and VV is 294 hours, 40.9 percent lessthan the HON-based estimate. Per-source estimates foreach burden item were estimated by multiplying the HON-based estimate by 40.9 percent.bFrom most recently approved CAR ICR.22cTotal burden for each source type is the product of the per-source burden and the total number of sources estimated toopt to comply with the CAR. The number ofsources estimated to comply with the CAR are from themost recently approved ICR and are detailed in Table 4:process vents - 725storage vessels - 1,640transfer racks - 320equipment leaks with connector monitoring - 240equipment leaks without connector monitoring - 78facilities (used for inventory estimate) - 80dTotal burden for each burden item is the sum of totalsfor each source type. This burden represents technicalhours only andis the basis for determining total burden inTable 6.23TABLE 6: ANNUAL RESPONDENT BURDEN AND COST OF REPORTING AND RECORDKEEPING REQUIREMENTSFOR THE CARBurden ItemAverageHours perActivity(a)Number ofActivities peryear persource (b)TechnicalHours per yearper source(c)EstimatedTechnical Hoursper year(d)EstimatedManagerial Hoursper year(e)EstimatedClerical Hoursper year(f)Annual Cost(g)Read Rule and Instructions 2.76 23 63.51 5,081 254 508 $552,698Plan Activities 4.90 13 63.71 5,097 255 510 $554,439Training 6.01 4 24.04 1,923 96 192 $209,179Create, Test, Research andDevelopment 19.56 99 1936.88 154,950 7,748 15,495 $16,855,074Gather Information, Monitor andInspect 2.20 677 1491.68 119,334 5,967 11,933 $12,980,854Compile, Process and Review Data 18.00 1 18.00 1,440 72 144 $156,640Complete Forms 82.54 5 412.69 33,015 1,651 3,302 $3,591,289Record/ Disclose 13.36 26 347.30 27,784 1,389 2,778 $3,022,274File/Store 1.96 35 68.53 5,482 274 548 $596,318TOTAL COST 354,106 17,705 35,411 $38,518,765TOTAL BURDEN HOURS 407,222Assumptions: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 activitiesper year for the HON, with a reduction to reflect the consolidation of activities achievedthrough the CAR.(c) Technical hours per year per source are the total technical hours for a burden item as estimated in Table 5, divided by 80 facilities.(d) Estimated technical hours per year are the total technical hours for all facilities for each burden item,as estimated in Table 4.(e) Estimated managerial hours per year are assumed to be 5 percent of technical hours. (e) = (d) x 0.05.(f) Estimated clerical hours per year are assumed to be10 percent of technical hours. (f) = (d) x 0.10.(g) Annual Cost is the sum of costs for technical, managerial, and clerical hours based on the following ratesfrom the United States Department of Labor, BureauofLabor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rateshave been increased by 110 percent to account for the benefit packages available to those employed by private industry: Managerial -$114.49 ($54.52 + 110%),Technical - $98.20 ($46.76 + 110%), Clerical - $48.53 ($23.11 + 110%).24TABLE 7: ANNUAL RESPONDENT BURDEN AND COST OF REPORTING REQUIREMENTS OF THE DIRECT FINALSTANDARDSBurden item(A)Personhours peroccurrence(B)No. ofoccurrencesperrespondentper year(C)Personhours perrespondentper year(C=AxB)(D)Number ofrespondentsper year(E)Technicalpersonhours peryear(E=CxD)(F)Managementperson-hoursper year(Ex0.05)(G)Clericalpersonhours peryear(Ex0.1)(H)Cost,$a1. ApplicationsN/A2. Survey and StudiesN/A3. Acquisition, Installation, andUtilization of Technology andN/ASystems4. ReportingRequirementsA. Read instructions0.510.56b30.150.3$326.33B. Required activitiesN/AC. Create informationN/AD. Gather existing informationN/AE. Write report0.510.56b30.150.3$326.335. Recordkeeping RequirementsN/AA. Read instructionsN/ATOTAL LABOR BURDEN AND COST60.30.6$652.67Annualized cost of capital0Operation and maintenance (O&M)0Total (capital recovery plus O&M)0Assumptions:aCosts are based on the following hourly rates: technicalat $98.20, management at $114.49, and clerical at $48.53.bOne-time event for 6 respondents per year.25TABLE 8: SUMMARY OF RESPONDENT AND AGENCY BURDEN AND COST FOR REFERENCING SUBPARTS ANDTHE CARSubpart(A)Number ofRespondents(B)TotalAnnualResponsesa(C)RespondentReportingBurdenHours(D)RespondentRecordkeepingBurden Hours(E)RespondentBurdenHoursa(F)RespondentBurdenCostsa(G)AgencyBurdenHoursb(H)AgencyBurdenCostsb(I)O&MCosts in000’sc(J)Capital/StartupCosts in000’scNSPS Ka 174 194 522 45,931 46,453 $4,393,958115 $5,1820 0NSPS Kb 580 1,976 21,607 63,879 85,486 $8,086,084976 $43,99942 27NSPS VV 436 872 4,011 40,112 44,123 $4,173,5752,006 $90,3820 0NSPS VVa 76 244 3,257 3,938 7,194 $680,512614 $27,6740 4.2NSPS DDD 90 222 5,658 1,096 6,754 $638,850570 $25,705630 300NSPS III 11 26 166 131 297 $28,06569 $3,08915 14NSPS NNN 1,345 3,433 25,130 16,750 41,880 $3,961,3508,955 $403,5571,816 2,390NSPS RRR 155 394 2,864 1,925 4,789 $452,9501,026 $46,22778 500NESHAP BB 54 216 7,600 4,844 12,444 $1,177,081497 $22,3880 0NESHAP Y 4 8 55 9 64 $6,0929 $4150 0NESHAP V 55 123 3,904 3,628 7,533 $712,493289 $13,0080 0NESHAP F, G, H, and I245 1,845 1,134,630 190,078 1,324,708 $125,302,9785,325 $239,94767,375 138CAR 80 400 368,966 38,256 407,222 $38,518,7654,087 $368,36922,000 0CAR Revisionsd6 6 6 0 6 $6536 $3110 0Totals 3,311 9,959 1,578,376 410,576 1,988,952 $188,133,40624,543 $1,290,25491,956 3,373Assumptions:aFrom Tables G1- G13bFrom Tables F-1 through F-12cFrom Appendix JdFrom Tables 3 and 7

# Α 1 Attachment A

Part 1: Recordkeeping and Reporting under the Consolidated Air Rule

1. General Records

2. Storage Vessel Records

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

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

specified in §65.47.

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

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

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

specified in §65.163.

3. Process Vent Records

• General process vent records as specified in §§65.66, 65.63, an d 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 an d 65.163.

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

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

4. Transfer Rack Records

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

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

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

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

control device as specified in §§65.159 and 65.163.

5. Equipment Leak Records

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

Specific equipment leak records where equipment leak emis sions are not controlled

by a control device or routed to a process or fuel gas sy stem 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 specif ied in §65.5.

# Α 2

7. Initial Compliance Status Report

• General contents as specified in §65.5.

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

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

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

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

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

8. Periodic Reports

• General contents as specified in §65.6.

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

converted into an IFR as specified in §65.48.

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

§65.166.

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

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

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

• Equipment leaks as specified in §65.120.

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

• Flares as specified in §65.166.

9. Other Notification and Reports

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

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

included with a periodic report).

• Written application for waiver of recordkeeping and repo rting requirements as

specified in §65.7.

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

provisions as specified in §65.7.

• Storage vessel refilling notification as specified in §65. 48.

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

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

reporting plan as specified in §65.63.

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

specified in §65.67.

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

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

recovery device as specified in §65.67.

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

specified in §65.102.

# Α 3

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 reconstructi on as specified in §60.7(a)(1).

• Provide notification of anticipated startup as specifi ed 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 specif ied 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 s pecified in §60.8(d).

Requirements Specific to NSPS Subpart Ka

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

including emissions data, operations design specifications, an d 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 an d Primary seals every five

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

• Record whenever the liquid is changed, stored, period of s torage 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 i n §60.113b(b)(5).

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

in §60.113b(b)(6).

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

§60.113b(c).

• Report describing equipment and certifying control for IFR a s specified in

§60.115b(a)(1).

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

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

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

• Report describing equipment and certifying control for EFR a s 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).

# Α 4

• Report gaps exceeding limits within 30 days of inspection r equired by

§§60.113b(b)(4) - 60.115b(b)(4).

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

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

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

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

§60.115b(d)(3).

• Records of dimensions and capacity of vessel as speci fied 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) t hrough (c) and

60.487a(a) through (c).

• Notification of alternative standard selected as speci fied 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 alternat ive reports as specified in §60.565.

• Semiannual reports of deviations from monitoring paramete rs, monitoring

exceedances, changes in process operations, and periods duri ng which control device

is inoperative as specified in §60.565(k).

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

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

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

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

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

incineration requirements; evidence of compliance with b oiler 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 a bsent as specified in §60.565(a),

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

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

removal or addition of product recovery equipment or an a ir oxidation reactor as

specified in §60.565(g).

• Evidence of compliance with elected alternative provis ions, and all periods of

operation during which the performance boundaries are excee ded as specified in

§60.565(h).

Requirements Specific to NSPS Subpart III

# Α 5

• Notification of the specific provisions of the standa rds which the owner has elected to

comply as specified in §60.615(a).

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

60.615(h)(3).

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

60.615(g).

• Record periods of operation during which the performance b oundaries established

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

60.615(g).

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

specified in §60.615(d).

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

§60.615(e).

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

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

• Record changes in production capacity, feedstock type, c atalyst type, or replacement,

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

§60.615(h)(1).

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

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

• For the semiannual report exceedances of parameter bounda ries established during

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

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

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

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

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

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

specified in §60.615(j)(4).

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

§60.615(j)(5).

Requirements Specific to NSPS Subpart NNN

• Notification of the specific provisions of the standa rds which the owner has elected to

comply as specified in §60.665(a).

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

60.665(h)(3).

• Continuously record equipment operating parameters as spec ified in §§60.665 and

60.665(g).

• Record periods of operation during which the performance b oundaries established

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

60.665(g).

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

specified in §60.665(d).

# Α 6

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

§60.665(e).

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

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

• Record changes in production capacity, feedstock type, c atalyst type, or replacement,

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

§60.665(h)(1).

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

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

change in equipment or process operation that increase s 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 th at increases the design

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

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

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

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

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

flowrate measurement as specified in §60.665(o).

• For the semiannual report, exceedances of parameter bo undaries established during

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

• For the semiannual report, all periods when the vent s tream 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 fla re pilot flame was absent as

specified in §60.615(j)(4).

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

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

specified in §60.665(l)(6).

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

§60.665(l)(7).

Requirements Specific to NSPS Subpart RRR

• Notification of the specific provisions of the standa rds which the owner has elected to

comply as specified in §60.705(a).

• Exceedances of parameter boundaries established during the most recent performance

test as specified in §60.705(l)(1).

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

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

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

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

# Α 7 increases the operating vent stream flowrate above the low flow exemption level as

specified in §60.705(l)(4).

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

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

specified in §60.705(l)(5).

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

§60.705(l)(6).

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

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

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

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

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

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

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

including a measurement of the new vent stream concentra tion 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 speci fied in §§60.705(b) and

60.705(g)(3).

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

• Records of diversion of vent stream from the contro l 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 b oundaries established

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

• Record changes in production capacity, feedstock type, c atalyst type, or replacement,

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

• Record any recalculation of the TRE index value as spe cified 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 increas es the operating vent stream

flowrate, including measurement of the new vent stream f lowrate 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 pr oduction capacity

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

equipment or process operation that in creases the desi gn 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 increase s the concentration of the vent

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

# Α 8

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

CAR

• Construction or modification application as specifie d in §61.07.

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

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

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

• Initial performance test as specified in §61.13.

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

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

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

Requirements Specific to NESHAP Subpart V

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

• Recordkeeping as specified in §61.246.

• Reporting as specified in §61.247.

Requirements Specific to NESHAP Subpart Y

• Initial source report as specified in §61.274.

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

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

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

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

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

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

in §61.275(e).

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

• Record of information on closed vent systems with con trol 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 faci lity as specified in §61.302(d) and

(e).

• 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 em issions as specified in

§61.305(b).

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

§61.305(c).

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

# Α 9 as specified in §61.305(d).

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

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

specified in §61.305(f).

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

file as specified in §61.305 (g).

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

§61.305(h).

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

• Record of closed-vent system annual leak inspection requir ed 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 Electi ng to Comply with the

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

1. Notifications

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

63.151, 63.182, and 63.192.

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

63.182, and 63.192.

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

and 63.192.

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

63.152, 63.182, and 63.192.

• Notification of performance test as specified in §63.103.

• Notification for storage tanks as specified in §63.192.

2. Reporting - Initial and Notification of Compliance Stat us

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

63.182, and 63.192.

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

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

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

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

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 m ost recent performance

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

and 63.192.

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

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

# Α 10 63.146, 63.148, 63.151, 63.152, 63.182, and 63.192.

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

63.146, 63.151, 63.152, 63.182, and 63.192.

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

4. Recordkeeping

• General Recordkeeping as specified in §63.103.

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

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

• Record of periods of operation during which the performanc e boundaries established

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

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

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

63.148, 63.181, and 63.192.

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

63.181 and 63.192.

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

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

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

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

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

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

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

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

and 63.152.

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

# Β 1 Attachment B

Purposely left blank.

# Χ 1 Attachment C

Assumptions and Item Descriptions for Table 4

Assumptions are the same as Attachment E, and:

(A) That there are 318 total sources (240 from the HON, 59 f rom 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 period ic reports. This equates to 636 EPA

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

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

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

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

Item descriptions:

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

estimating the overall burden.

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

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

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

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

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

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

and clerical hours and overhead using this formula:

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

1,000

Where:

Ht is (c), or technical hours,

Hm is (d), or managerial hours, and

Hc is (e), or clerical hours.

Source:

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

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

for the benefit packages available to government employe es.

# Χ 2

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

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

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

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

comply with the CAR during the 3-year period following prom ulgation.

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

reports received as a result of the equipment leaks standa rd.

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

existing sources.

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

# D1 Attachment D

Purposely left blank.

# Ε 1 Attachment E

Assumptions and Item Descriptions for Table 6

Assumptions are:

(A) That there are 320 existing facilities, of which 25 per cent (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 connec tors;

• 80 facility wide inventories of emission points; and

• 725 process vents.

(C) That there are 5 percent (0.05) managerial and 10 percen t (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 re ports activities alone, to avoid double

counting these as records activities as well. Therefor e, 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 significa ntly, it is too inaccurate to assume

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

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

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

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

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

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

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

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

to reflect the consolidation of activities achieved through the CAR.

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

estimated in Table 7 divided by 80 facilities. Because of th e variability in the number and

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

# Ε 2

(d) Estimated Technical Hours per Year is the sum of total technical hours for all sources fo r

each burden item, as estimated in Table 7.

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

(f) Estimated Clerical Hours per Year is 10 percent of (d).

(g) Estimated Annual Cost in Thousands of Dollars per Year is the total cost of technical,

managerial, and clerical hours and overhead using this formul a:

(Ht * $98.20/hour) + (Hm * $114.49/hour) + (Hc * $48.53/hour) =(g)

Where:

Ht is (d), or technical hours,

Hm is (e), or managerial hours, and

Hc is (f), or clerical hours.

Source:

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

September 2009, Table 2. Civilian Workers, by occupational and i ndustry 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 t hose employed by private

industry.

1) Read Rule and Instructions consists of the activities, less training, which involve

comprehending the provisions in the standard and understandi ng how they apply to the

respective points at a facility.

2) Plan Activities represents such burdens as design, redesign, and scheduling, as well as

selecting methods of compliance.

3) Training represents the portion of activities from 1) Read Rule and Instructions for

which an average facility would elect to provide class room instruction. The standard

does not require specific training itself.

4) Create, Test, Research and Development are the activities involving testing, retesting,

establishing operating ranges for parameters, and analyzing point by point applicability.

Monitor-related refit, calibration, and maintenance act ivities are also included under this

heading.

5) Gather Information, Monitor, and Inspect are the activities involving physical

inspections of equipment, collection of monitored data, a nd other related activities.

# Ε 3

6) Process/Compile and Review are the activities that involve analysis of the inform ation

collected for accuracy and compliance as well as appropri ate records and reports required

as a result.

7) Complete Reports represents the activities normally associated with fi lling out forms.

Since the standard requires no standard forms, these act ivities relate to the preparing of

formal reports and cover letters.

8) Record/Disclose are solely recordkeeping activities which occur once the appropriate

report information has been extracted; see assumption (D) . These activities involve

software translation, duplication, or archival processes normally associated with data

management and storage common to this industry.

9) Store/File are activities which are solely recordkeeping which occur once the

appropriate report information has been extracted; see assumption (D). These activities

involve the management life cycle of records, from the time they are filed and boxed up

to the time they are disposed.

TOTAL BURDEN AND COST is the total for each of the c olumns (d), (e), (f), and (g)4ATTACHMENT F: EPA BURDEN AND COST FOR REFERENCINGSUBPARTSTABLE F-1: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPART KaaActivity(A)EPA/hrOccurrence(B)Occurrences/plant/yr(C =AxB)EPAhr/plant/yr(D)Plants/year(E=CxD)Technicalhr/yr(F=Ex0.05)ManagerialHr/yr(G=Ex0.10)ClericalHr/Yr(H)TotalCost peryeareReport Review: New PlantVapor recoverybN/AReport Review: Existing PlantNotification of Reconstruction2 1 2 0 0 0 0 $0Notification of Modification2 1 2 0 0 0 0 $0Notification of seal gap measurementc0.5 1 0.5 188 94 5 9 $4,872Report of gap excessesc,d1 1 1 6 6 0 1 $311TOTAL ANNUAL HOURS100 5 10TOTAL ANNUAL BURDEN115 $5,182Assumptions”aAssume no new sources subject to this regulation. All similar new sources will be subject to subpart Kb.bRequired only at start of construction. Any new storagevessel being constructed would be subject to the NSPS subpart Kb.cAssume that 90 percent of the storage vessels will use afloating roof and be subject to seal gap measurement. The remaining10 percent will use a closed ventsystem.dAssume 25 percent of respondents using a floating roof will have excessive seal gaps requiring that a single report be filed once per year.Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%)Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)5TABLE F-2: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPART KbReporting and Recordkeeping Requirements Assumptionsa(A)TechnicalHours(B=A*.05)Managerial Hours(C=A*.10)Clerical HoursCost/year$a1) Review notification of construction. 37bnewnotifications at 2 hours each74 4 7 $3,8352) Review notice of anticipated startup. 37 newnotifications at 1 hour each37 2 4 $1,9183) Review notice of actual startup. 37 new notificationsat1 hour each37 2 4 $1,9184) Review notification of initial inspection @1 hr. each3724$1,9185) Review of IFR Failure Reportc; 55 sources @ 1 hr/ea5536$2,8506) Review Notification of Delay for Repair/Emptying IFRd;6 sources@ 1.2 hr/ea7 0 1 $3637) Review Notification to Re-Filld; 602 sources@ 1 hr/ea6023060$31,198TOTALANNUAL HOURS8494285TOTAL ANNUAL BURDEN976$43,999Assumptions:aAnnual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Officeof Personnel Management(OPM) “2010 General Schedule” which excludes locality ratesof pay.Technical - $46.21 (GS-12, Step 1, $28.88 + 60%)Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%)Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%)bAssume 111 new storage tanks will be constructed during each of the next three years, or 37 tanks per year (28 IFR’s, 7 EFR’s, 2 CVS).cOne percent failure rate for the 5468 IFRs choosing annualvisual inspections equals approximately 55.dFrom Table G.26TABLE F-3: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPART VVActivity(A)EPAhr/Occurrence(B)Occurrencesplant/yr(C)plants/yr(D)aTechnicalhrs/yr(E=D*.05)Managerialhrs/hr(F=E*.10)Clericalhrs/yrCost/yrdReport Review: New PlantNotification of Construction810b000$0Notification of Reconstruction/Modification2 1 0 0 0 0 $0Notification of Actual Startup0.510000$0Notification of Initial/Repeat Test0.510c000$0Review Test Results210c000$0Report Review: Existing PlantSemiannual Emission Reports22436c1,74487174$90,382TOTAL ANNUAL HOURS1,74487174TOTAL ANNUAL BURDEN2,006$90,382Assumptions:aD=AxBxCbAll new sources will be subject to subpart VVa.Technical-$46.21 (GS-12, Step 1, $28.88 + 60%)Managerial-$62.27 (GS-13, Step 5, $38.92 + 60%)Clerical-$25.01 (GS-6, Step 3,$15.63 + 60%)7TABLE F-4: ANNUAL AVERAGE EPA RESOURCE REQUIREMENTFOR SUBPART DDDActivity(A)EPAhr/Occurrence(B)Occurrencesplant/yr(C)plants/yr(D)aTechnicalhrs/yr(E=D*.05)Managerialhrs/hr(F=E*.10)Clericalhrs/yr(G)bCost/yr($)Report ReviewNotification of Construction/ Reconstruction/Modification2 1 10 20 1 2 $1,036Notification of Actual Startup21102012$1,036Initial Performance Test81108048$4,146Repeat Performance Testd80.2101612$829Semiannual Reports2290c3601836$18,657TOTAL ANNUAL HOURS4962550TOTAL ANNUAL BURDEN570$25,705Assumptions:aD=AxBxCbAnnual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Officeof Personnel Management (OPM) “2010General Schedule” which excludes locality rates of pay.Technical-$46.21 (GS-12, Step 1, $28.88 + 60%)Managerial-$62.27 (GS-13, Step 5, $38.92 + 60%)Clerical-$25.01 (GS-6, Step 3, $15.63 + 60%)cAverage number of affected sources over next three years.dAssume 20 percent of performance tests repeated due to failure8TABLE F-5: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPART IIIActivity(A)EPAhr/Occurrence(B)Occurrencesplant/yr(C)plants/yr(D)aTechnicalhrs/yr(E=D*.05)Managerialhrs/hr(F=E*.10)Clericalhrs/yr(G)bCost/yr($)Report ReviewNew Plant - Notification ofConstruction/Reconstruction/Modification2 1 1 2 0.1 0.2 $104Notification of Anticipated Startup2 1 1 2 0.1 0.2 $104Notification of Actual Startup2 1 1 2 0.1 0.2 $104Initial Test8 1 1 8 0.4 0.8 $415Repeat Performance Testc8 0.2 1 1.6 0.08 0.16 $83Semiannual Reports2 2 11d44 2.2 4.4 $2,280TOTAL ANNUAL HOURS59.6 2.98 5.96TOTAL ANNUAL BURDEN69 $3,089Assumptions:aD=AxBxCbAnnual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Officeof Personnel Management (OPM) “2010 GeneralSchedule” which excludes locality rates of pay.Technical-$46.21 (GS-12, Step 1, $28.88 + 60%)Managerial-$62.27 (GS-13, Step 5, $38.92 + 60%)Clerical-$25.01 (GS-6, Step 3, $15.63 + 60%)cAssume 20 percent of performance tests are repeated due to failuredAverage number of affected sources over next three years.Does not include sources subject to both Subpart III andthe HON,which are assumed to becomplying with the HON.9TABLE F-6: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPART NNNActivity(A)EPAhr/Occurrence(B)Occurrencesplant/yr(C)plants/yr(D)aTechnicalhrs/yr(E=D*.05)Managerialhrs/hr(F=E*.10)Clericalhrs/yr(G)bCost/yr ($)Report ReviewNew Plant - Notification ofConstruction/Reconstruction/Modification2 1 177 354 18 35 $18,346Notification of Actual Startup211773541835$18,346Initial Test811771,41671142$73,383Repeat Performance Testc801772831428$14,666Semiannual Reports221,345d5,380269538$278,816TOTAL ANNUAL HOURS7,787389779TOTAL ANNUAL BURDEN8,955$403,557Assumptions:aD=AxBxCbAnnual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Officeof Personnel Management (OPM) “2010 GeneralSchedule” which excludes locality rates of pay.Technical-$46.21 (GS-12, Step 1, $28.88 + 60%)Managerial-$62.27 (GS-13, Step 5, $38.92 + 60%)Clerical-$25.01 (GS-6, Step 3, $15.63 + 60%)cAssume 20 percent of performance tests are repeated due tofailure.dAverage number of affected sources over next three years.Does not include sources subject to both Subpart NNN andthe HON,which are assumed to becomplying with the HON.10TABLE F-7: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPART RRRActivity(A)EPAhr/Occurrence(B)Occurrencesplant/yr(C)plants/yr(D)aTechnicalhrs/yr(E=D*.05)Managerialhrs/hr(F=E*.10)Clericalhrs/yr(G)bCost/yr ($)Report ReviewNew Plant - Notification ofConstruction/Reconstruction/Modification2 1 20 40 2 4 $2,073Notification of Actual Startup2 1 20 40 2 4 $2,073Initial Test8 1 20 160 8 16 $8,292Repeat Performance Testc8 0.2 20 32 2 3 $1,658Semiannual Reports2 2 155d620 31 62 $32,131TOTALANNUAL HOURS892 45 89TOTAL ANNUAL BURDEN1,026 $46,227Assumptions:aD=AxBXCbAnnual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Officeof Personnel Management (OPM) “2010 GeneralSchedule” which excludes locality rates of pay.Technical-$46.21 (GS-12, Step 1, $28.88 + 60%)Managerial-$62.27 (GS-13, Step 5, $38.92 + 60%)Clerical-$25.01 (GS-6, Step 3, $15.63 + 60%)cAssume 20 percent of performance tests are repeated due tofailure.dAverage number of affected sources over next three years.Does not include sources subject to both Subpart NNN andthe HON,which are assumed to be complyingwith the HON.11TABLE F-8: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPART BBActivity(A)EPA/hrOccurrence(B)Occurrences/plant/yr(C)bPlants/year(D)Technicalhrs/yra(E=D*.05)cManagerialhr/yr(F=D*.1)Clericalhr/yr(G)Cost/yr $dReport ReviewNew PlantcNotification of construction0.500000$0Notification of anticipated startup0.500000$0Notification of actual startup0.50000$0Initial report800000$0Notification of emission test0.500000$0Result of emission test400000$0Notification of performancetest0.500000$0Result of performance test800000$0Review test results800000$0Report ReviewExisting PlantQuarterly reports24544322243$22,388TOTAL ANNUAL HOURS4322243TOTAL ANNUAL BURDEN497$22,388Assumptions:aAxBxC=DbAssume an estimated total of 81 facilities. Assume 2/3(54) facilities are marine vessel loading facilitiesand must continue to comply with this subpart;assume 2 of these 54 marine vessel loading facilities also load tank trucks and railcars that are not subject to the HON.cAssume no new sources.dAnnual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Officeof Personnel Management (OPM) “2010General Schedule” which excludes locality rates of pay.Technical-$46.21 (GS-12, Step 1, $28.88 + 60%)Managerial-$62.27 (GS-13, Step 5, $38.92 + 60%)Clerical-$25.01 (GS-6, Step 3, $15.63 + 60%)12TABLE F-9: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPART YActivity(A)EPA/hrOccurrence(B)Occurrences/plant/yr(C)aPlants/year(D)Technicalhrs/yrb(E=D*.05)cManagerialhr/yr(F=D*.1)Clericalhr/yr(G)Cost/yr$cReport ReviewNew SourcesIncluded inNSPS KbNotification of constructionNotification of anticipated startupIncluded inNSPS KbNotification of actual startupIncluded inNSPS KbNotification of performance testN/AN/AN/AN/AN/AN/AReport of performance testN/AN/AN/AN/AN/AN/ANotification of control installation and refill at1stdegassingd1 1 0 0 0 0 $0Existing Plant214801$415Annual IFR internal inspections and EFR seal gapmeasurementsSupplemental delay reporte110000$0Quarterly emission reportsfN/AN/AN/AN/AN/AN/AN/ATOTAL ANNUAL HOURS80.40.8TOTAL ANNUAL BURDEN9$415Assumptions:aEstimate that there are 4 existing sources not coveredby the HON. All new source burden is included in the NSPS subpart Kb regulation for storage vesselsat 40 CFR Part 60.bD=AxBxCcAnnual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Officeof Personnel Management (OPM) “2010 GeneralSchedule” which excludes locality rates of pay: Technical -$46.21 (GS-12, Step 1, $28.88 + 60%); Managerial -$62.27 (GS-13, Step 5, $38.92 + 60%);Clerical - $25.01 (GS-6, Step 3, $15.63 + 60%).dIt is believed that all vessels have been degassed and all controls have been installed as they were to have been installed within 10 years of promulgation..eEstimate that two percent of existing sources will requestdelay of repair in the annual report.fAssume that no source will select the fixed roof ventedto a control device option and thus have no quarterly report of excess emissions.13TABLE F-10: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPART VActivity(A)EPA/hrOccurrence(B)Occurrences/plant/yr(C)Plants/yearb(D)aTechnicalhrs/yr(E=D*.05)cManagerialhr/yr(F=D*.1)Clericalhr/yr(G)Cost/yr $dReport ReviewNewPlant-Notification ofConstruction/Reconstruction/Modification 2 1 2 4 0.2 0.4 $207Notification of Anticipated Startup21240.20.4$207Notification of Actual Startup21240.20.4$207Initial Test812160.81.6$829Repeat PerformanceTestc80.2230.150.3$155Semiannual Reports22552201122$11,401TOTAL ANNUAL HOURS2511325TOTAL ANNUAL BURDEN289$13,008Assumptions:aAxBxC=DbAssume 2 new sources per year at one new facility and 55 existing process units subject to NESHAP subpart V, but not the HON.cAssume 20 percent of initial performance test must be repeated due to failure.dAnnual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Office of Personnel Management (OPM) “2010General Schedule” which excludes locality rates of pay.Technical-$46.21 (GS-12, Step 1, $28.88 + 60%)Managerial-$62.27 (GS-13, Step 5, $38.92 + 60%)Clerical-$25.01 (GS-6, Step 3, $15.63 + 60%)14TABLE F-11: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPARTS F, G, H, and IBurden ItemAverageHoursper Activity(a)Number ofActivities perYear(b)EstimatedTechnicalHours per year(c)EstimatedManagerialHours per year(d)Estimated ClericalHours per year(e)Annual Cost $(f)REPORTS REVIEW:1) Initial2 5 10 1 1$5182) Implementation Plan or Permit20 5 100 5 10$5,1823) Compliance status40 5 200 10 20$10,3654) Review equipment leak monitoring7 240 1,680 84 168$87,0655) Notification ofConstruction/Reconstruction.2 5 10 1 1$5186) Notification of anticipated startup2 5 10 1 1$5187) Notification of actual startup2 5 10 1 1$5188) Notification of Performance Test2 5 10 1 1$5189) Review of test results8 5 40 2 4$2,07310) Review periodic reports4 640 2,560 128 256$132,671TOTAL ANNUAL HOURS 4,630 232 463TOTAL ANNUAL BURDEN5,325 $239,947See Attachment H for assumptions and further descriptionof activities.15TABLE F-12: AVERAGE ANNUAL EPA RESOURCE REQUIREMENTFOR SUBPART VVaActivity(A)EPA hr/Occurrence(B)Occurrencesplant/yr(C)plants/yr(D)aTechnicalhrs/yr(E=D*.05)Managerialhrs/hr(F=E*.10)Clericalhrs/yrCost/yreReport Review: New PlantNotification of Construction8123b184918$9,536Notification of Reconstruction/Modification21153023$1,555Notification of ActualStartup0.51381912$985Notification of Initial/Repeat Test0.5146c2312$1,192Review Test Results2146c9259$4,768Report Review: Existing PlantSemiannual Emission Reportse2.45238d186919$9,639TOTAL ANNUALHOURS5342753TOTAL ANNUAL BURDEN614$27,674Assumptions:aD=AxBxCbEstimate 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 beingequal to 3% of the estimated 1,272 existing sources.cAssume 20 percent of performance tests are repeated due to failure (7.6)dThere are an average of 38 new affected sources each yearafter promulgation of VVa. Assume that costs are beingcalculated for the 2ndyear in the three yearsafter promulgation of VVa so that the 38 new sources inthe first year are existing sources in the second year.eAnnual cost is the sum of costs for technical, managerial, and clerical hours based on rates from the Officeof Personnel Management (OPM) “2010 GeneralSchedule” which excludes locality rates of pay.Technical-$46.21 (GS-12, Step 1, $28.88 + 60%)Managerial-$62.27 (GS-13, Step 5, $38.92 + 60%)Clerical-$25.01 (GS-6, Step 3, $15.63 + 60%)1ATTACHMENT G: RESPONDENT BURDEN AND COST FOR REFERENCING SUBPARTSTABLE G-1: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART KaActivity(A)hr/Occurrence(B)Occurrences/plant/yr(C)aPlants/year(D)Technical hr/yr(E=D*.05)Managerialhr/yr(F=D*.10)Clericalhr/yr(G)Cost/yrb1. ApplicationsN/A2. Surveys and StudiesN/A3. Reporting RequirementsA. Read InstructionIncluded in 3BB. Required ActivitiesVapor recovery information2010000$0Measure seal gapIncluded in 4EC. Create InformationIncluded in 3BD. Gather Existing Information11157c157816$17,078E. Write ReportNotification of construction210000$0Notification of actual startup210000$0Notification of gap measurement1.51188c2821428$30,675Report of seal gapexcess2.516d1512$1,632Information on vapor recoveryIncluded in 3B.Total Annual Responses1944. Recordkeeping RequirementsA. Read InstructionsIncluded in 3B.B. Plan ActivitiesIncluded in 3BC. ImplementActivitiesIncluded in 3BD. Develop RecordN/AE. Time to EnterNew tank seal gap measurements25010000$0Secondary seal gap250d,e1157c39,2501,9633,925$4,269,517Primary seal gap measurements100d0.2f31c6203162$67,442Fill/refill record2h135g7047$7,614TOTAL ANNUAL HOURS40,3942,0204,039TOTAL ANNUAL BURDEN46,453$4,393,9582Assumptions:aAssume that there will be no new source subject to therequirements of this regulation. Similar new sourceswill be subject to NSPS subpart Kb. There are174 existing sources with an average of 50 tanks per facility.bUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” Therates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employedby private industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hrcEstimate that 10 percent of respondents (17) will use a vaporrecovery control system and 90 percent (157) willuse a floating roof system. Respondentsusing vapor recovery control are not required to do seal gap measurements. All of the tanks using floating roof (157)will perform a secondary seal gapmeasurement. 20 percent (31) will conduct a primary sealgap measurement. 157 + 31 = 188 respondents submitting a notification of either primary orsecondary gap measurement.dAssume that 3 percent of respondents using a floating roof will have excessive seal gaps (primary or secondary) requiring that asingle report be filed once a year.eEstimate five hours to conduct secondary seal measurements annually for the average 50 tanks per respondent.fEstimate two hours to conduct primary seal measurementsevery five years for the average 50 tanks per respondent.gDuring any one year, a respondent would change liquid in approximately 20 percent of the facilities (35).hEstimate 0.2 hours to record a liquid change per tank in 20 percent (10) of the average of 50 tanks per facility.3TABLE G-2: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART KbActivity(A)hr/Occurrence(B)Occurrences/plant/yr(C)aPlants/year(D)Technicalhr/yr(E=D*.05)Managerialhr/yr(F=D*.10)Clerical hr/yr(G)Cost/yrb1. ApplicationsN/A2. Surveys and StudiesN/A3. Reporting RequirementsA. ReadInstruction1137d3724$4,025B. Required ActivitiesOne-Time Only Requirements21377447$8,050Notification of Start ofConstructionNotification of Actual Startup21377447$8,050Notification of Physical orOperational ChangescN/ANotification of MalfunctioncN/ANotification of InitialInspectionIFR Internal Inspection2128d5636$6,092EFR Gap Measurement217d1411$1,523Initial Inspection ReportIFRInternal Inspection Report12128d3361734$36,549EFR 2nd Seal Gap Measurement8175636$6,092EFR 1st Seal Gap Measurement12178448$9,137CVS Operating Plan Report8121612$1,740Repeat RequirementsInternal IFR Inspectione1211161,39270139$151,418Visual IFR Inspectione814643,712186371$403,782Report of IFR Failuref2155110611$11,966Notification of Delay of Repair orEmptying for IFRg4 1 6 24 1 2$2,611EFR 2nd Seal Gap Measure Report815804,640232464$504,728EFR 1st Seal Gap Measure Report1215806,960348696$757,091Notification of Refillh216021,20460120$130,968Number of Responses19764.RECORDKEEPINGREQUIREMENTS1 1 37 37 2 4 $4,0254Activity(A)hr/Occurrence(B)Occurrences/plant/yr(C)aPlants/year(D)Technicalhr/yr(E=D*.05)Managerialhr/yr(F=D*.10)Clerical hr/yr(G)Cost/yrbA.. Read InstructionsB. Gather and Record Information815804,640232464$504,728i. Vessel Volumes, Liquid VaporPressure, flaresii. 113b(a) inspection1215806,960348696$757,091iii. 113b(b) gap measurement1215806,960348696$757,091C. Develop Record System10133023$3,263D. Time to Enter Information-CVSParameter Records2 52 355 36,920 1,846 3,692 $4,016,065F. Train PersonnelN/AG. AuditsN/ATOTAL ANNUAL HOURS74,3363,7177,434TOTAL ANNUAL BURDEN85,486$8,086,084Assumptions:aEstimate that there are 580 existing respondents with an average of 7,254 regulated vessels in service over the next three years. Estimate that 75 percent (5468)of vessels have IFR and 20 percent (1458) have EFR and 5 percent (355) have closed-vent control systems. This doesnot include sources subject to both subpartKb and the HON, which are assumed to be complying with theHON.bUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The ratesare from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefitpackages available to those employed byprivate industry. Technical - $98.20/hr; Managerial - $114.49/hr;Clerical - $48.53/hrcThe General Provision notifications of modification or malfunction will be covered by notification within the subpart.dAssume that there will be 37 new respondents each of thenext three years, which includes 28 IFR and 7 EFR and 2CVS.eFor each of the 5,468 IFRs at 580 respondents, eighty (80) percent (464) will conduct an annual visual inspection, and 20percent (116) will conduct an internalinspection. These activities are required to generate the information for the IFR failure report and the EFRprimary and secondary seal gap reports, but do notgenerate a response.fOne percent failure rate for the 5468 IFRs choosing annual visual inspections equals approximately 55.gTen percent of 55 failed IFRs are delayed in repair or emptying equals approximately 6.hAssume that all 5,468 IFR tanks will be routinely servicedthrough a shutdown and degassed once every ten years. One tenth the 5468 IFR will be degassedeach year for an annual average of 547 per year. This number was added to the estimated 55 visual inspection failures that would lead to internal inspections for atotal estimate of 602 notices of refill.5TABLE G-3: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART VVActivity(A)hr/Occurrence(B)Occurrences/plant/yr(C)aPlants/year(D)Technicalhr/yr(E=D*.05)Managerial hr/yr(F=D*.10)Clericalhr/yr(G)Cost/yrb1. ApplicationsN/A2. Survey and StudiesN/A3. Reporting RequirementsA.Read Instructions110000$0B.Required Activities4810000$0InitialPerformance Test ReportRepeat Performance Test Report4810c000$0C.Create InformationIncluded in3BD.Gather Existing InformationIncluded in3EE.Write Report210000$0New SourcesNotification of ConstructionNotification of Reconstruction/ Modification210000$0Notification of Actual Startup210000$0Notification of Initial/Repeat Performance Test210000$0Existing Sources Semiannual Report424363,488174349$379,416Total Annual Responses8724. Recordkeeping RequirementsA.Read InstructionsIncluded in3AB.Plan ActivitiesIncluded in4CC.Implement ActivitiesIncluded in3BD.Develop Record SystemN/AE.Time to Enter InformationRecords of Operating Parameters80143634,8801,7443,488$3,794,159F.Train personnelN/AG.AuditsN/ATOTAL ANNUAL HOURS38,3681,9183,837TOTAL ANNUAL BURDEN44,123$4,173,5756Assumptions:aAll new sources will be subject to subpart VVa. Thereare an average of 436 existing sources per year for the next three years, based on the assumption of525 sources in the first and second year, and 258 in the third year (when sources will become subject to the MON). These sources do not include thosesubject to both Subpart VV and the HON, which are assumed to be complying with the HON. See the footnote in Table F-3 for the derivation of theestimated number of sources.bUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” Therates are from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to thoseemployed by private industry. Technical - $98.20/hr; Managerial -$114.49/hr; Clerical - $48.53/hrcAssume that 20 percent of the performance tests must be repeated.7TABLE G-4: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART DDDActivity(A)hr/Occurrence(B)Occurrences/plant/yr(C)Plants/year(D)Technicalhr/yra(E=D*.05)Managerialhr/yr(F=D*.10)Clericalhr/yr(G)Cost/yrb1. ApplicationsN/A2. Survey and StudiesN/A3. Reporting RequirementsA.Read Instructions1 1 10c 10 1 1 $1,088B.Required Activities360 1 10 3600 180 360 $391,599Initial Performance Test ReportRepeat Performance Test Report360 1 2d 720 36 72 $78,320C.Write Report2 1 10 20 1 2 $2,176Notification of Construction/ModificationNotification of Actual Startup1 1 10 10 1 1 $1,088Notification of Initial Performance Test2 1 10 20 1 2 $2,176Semiannual Report3 2 90e 540 27 54 $58,740Total Annual Responses2224. Recordkeeping RequirementsRecord of Operating Parameters for ControlDevices1 12 10 120 6 12 $13,053Records of Operating Conditions ExceedingLast Performance Test1 8 90 720 36 72 $78,320Records ofStartup, Shutdown, Malfunction, etc.0.25590113611$12,292TOTAL ANNUAL HOURS5873294587TOTAL ANNUAL BURDEN6754 $638,850Assumptions:aAxBxC=DbUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates arefrom column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by privateindustry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical- $48.53/hrcAssume 10 new affected sources per year.dAssume 20 percent of performance tests are repeated due to failure.eAverage number of affected sources over next three years.8TABLE G-5: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART IIIActivity(A)hr/Occurrence(B)Occurrences/plant/yr(C)Plants/year(D)Technicalhr/yra(E=D*.05)Managerialhr/yr(F=D*.10)Clericalhr/yr(G)Cost/yrb1. ApplicationsN/A2. Survey and StudiesN/A3. Reporting Requirements0A.Read Instructions111c100$109B.Required Activities60116036$6,527Initial Performance Test Report0Repeat Performance Test Report6010.2d1211$1,305C.Write Report2 1 1 2 0 0 $218Notification of Construction/Modification0Notification of Actual Startup 1 1 1 1 0 0 $109Notification of Initial Performance Test 2 1 1 2 0 0 $218Semiannual Report3211e6637$7,179Total Annual Responses ()264. Recordkeeping RequirementsRecord of OperatingParameters for ControlDevices1 12 1 12 1 1 $1,305Records of Operating Conditions Exceeding LastPerformance Test1 8 11 88 4 9 $9,572Records of Startup, Shutdown, Malfunction, etc.0.25 5 11 14 1 1 $1,523TOTAL ANNUAL HOURS258 13 26TOTALANNUAL BURDEN297 $28,065Assumptions:aAxBxC=DbUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates arefrom column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by privateindustry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical- $48.53/hrcAssume 1 new affected source per year subject to subpart III and not the HON.dAssume 20 percent of performance tests are repeated due to failure.eAverage number of affected sources over next three years.This does not include sources subject to both subpart IIIand theHON, which are assumed to be complyingwith the HON.9TABLE G-6: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART NNNActivity(A)hr/Occurrence(B)Occurrences/plant/yr(C)Plants/year(D)Technicalhr/yra(E=D*.05)Managerialhr/yr(F=D*.10)Clericalhr/yr(G)Cost/yrb1. ApplicationsN/A2. Survey and StudiesN/A3. Reporting RequirementsA.Read Instructions11177c177918$19,254B.Required Activities60117710,6205311,062$1,155,217Initial Performance Test ReportRepeat Performance TestReport60135d2,100105210$228,433C.Write Report211773541835$38,507Notification of Construction/ModificationNotification of Actual Startup11177177918$19,254Notification of Initial Performance Test211773541835$38,507Semiannual Report321345e8,070404807$877,834Total Annual Responses ()3,4334. Recordkeeping RequirementsRecord of Operating Parameters for ControlDevices1 12 177 2,124 106 212 $231,043Records of Operating ConditionsExceeding LastPerformance Test1 8 1345 10,760 538 1,076 $1,170,446Records of Startup, Shutdown, Malfunction, etc.0.25513451,68184168$182,855TOTAL ANNUAL HOURS36,4171,8213,642TOTAL ANNUAL BURDEN41,880$3,961,350Assumptions:aAxBxC=DbUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1,“Total Compensation.” The rates have been increased by110 percent to account for the benefit packages availableto those employed by private industry. Technical - $98.20/hr;Managerial - $114.49/hr; Clerical - $48.53/hrcAssume 177 new affected sources per year subject to subpartNNN and not the HON.dAssume 20 percent of performance tests are repeated due to failure.eAverage number of affected sources over next three years.This does not include sources subject to both Subpart NNNand theHON, which are assumed to be complying withthe HON.10TABLE G-7: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART RRRActivity(A)hr/Occurrence(B)Occurrences/plant/yr(C)Plants/year(D)Technicalhr/yra(E=D*.05)Managerialhr/yr(F=D*.10)Clericalhr/yr(G)Cost/yrb1. ApplicationsN/A2. Survey andStudiesN/A3. Reporting RequirementsA.Read Instructions1 1 20c20 1 2 $2,176B.Required Activities60 1 20 1,200 60 120 $130,533Initial Performance Test ReportRepeat Performance Test Report6014d2401224$26,107C.Write Report21204024$4,351Notification of Construction/ModificationNotification of Actual Startup11202012$2,176Notification of Initial Performance Test21204024$4,351Semiannual Report32155e9304793$101,163Total Annual Responses ()3944. Recordkeeping RequirementsRecord of Operating Parameters for ControlDevices1 12 20 240 12 24 $26,107Records of Operating Conditions Exceeding LastPerformance Test1 8 155 1,240 62 124 $134,884Records of Startup, Shutdown, Malfunction, etc.0.2551551941019$21,103TOTAL ANNUAL HOURS4,164208416TOTAL ANNUAL BURDEN4,789$452,950Assumptions:aAxBxC=DbUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The ratesare from column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefitpackages available to those employed byprivate industry. Technical - $98.20/hr; Managerial - $114.49/hr;Clerical - $48.53/hr.cAssume 20 new affected sources per year subject to subpart RRR and not the HON.dAssume 20 percent of performance tests are repeated due to failure. (.2 x 20 = 4).eAverage number of affected sources over next three years.This does not include sources subject to both subpart RRRand theHON which are assumedto be complying with the HON.11TABLE G-8: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART BBActivity(A)hr/ Occurrence(B)Occurrences/plant/yr(C)aPlants/year(D)Technicalhr/yra(E=D*.05)Managerialhr/yr(F=D*.10)Clerical hr/yr(G)Cost/yrb1. ApplicationsApplication for approval ofConstruction/ModificationN/A2. Surveys and StudiesN/A3. Reporting RequirementsA. Read Instruction1 1 0 0 0 0 $0B. Required ActivitiesInitialemission test20 0 0 0 0 0 $0Monitoring performance test280 1 0 0 0 0 $0Vapor-tightness test tank truck and railcars11 1 3c33 2 3 $3,590Marine vessels80 1 66c5,280 264 528 $574,345Closed vent leak inspection8 1 54c432 22 43 $46,992C.Create InformationIncluded in 3BD. Gather Existing InformationIncluded in 3EE. Write ReportNotification of anticipated startup2 0 0 0 0 0 $0Notification of actual startup2 0 0 0 0 0 $0Notification of emission test2 0 0 0 0 0 $0Report of emission test8 0 0 0 0 0 $0Notification of performance test2 0 0 0 0 0 $0Report of performance test8 0 0 0 0 0 $0Report facilities below cut-offd8 0 0 0 0 0 $0Quarterly parameter excesses4 4 54 864 43 86 $93,984TotalAnnual Responses ()216SUBTOTAL4. Recordkeeping RequirementsA. Read InstructionsIncluded in 3AB. Plan ActivitiesIncluded in 4CC. Implement ActivitiesIncluded in 3B12Activity(A)hr/ Occurrence(B)Occurrences/plant/yr(C)aPlants/year(D)Technicalhr/yra(E=D*.05)Managerialhr/yr(F=D*.10)Clerical hr/yr(G)Cost/yrbD. Develop Record SystemN/AE.Time to Enter Informationi. Facilities above cut-off1.5 52 54 4,212 211 421 $458,171ii. Facilities below cut-offd0.5 52 0 0 0 0 $0F. Train PersonnelN/AG. AuditsN/ATOTAL ANNUAL HOURS10,821 541 1,082TOTALANNUAL BURDEN12,444 $1,177,081Assumptions:aExpect that there will be no new sources covered by thesestandards over the next three years.bUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are fromcolumn 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry.Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hrcEstimate that there are 54 facilities subject to thisstandard. Estimate there are 3 tank truck and railcars and 131 marine vessels subject to the standards. All other transferracks subject to subpart BB are assumed to be complying with the HON. Assume 50 percent of the marine vessels (66) operate at negative pressure and do not conductannual vapor-tightness tests.dFor sources below the low quantity applicability for control requirements, a report is only required the first year of operation. It is assumed that this report has beensubmitted.13TABLE G-9: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART YActivity(A)hr/Occurrence(B)Occurrences/plant/yr(C)aPlants/year(D)Technicalhr/yra(E=D*.05)Managerialhr/yr(F=D*.10)Clericalhr/yr(G)Cost/yrb1. ApplicationsApplication for approvalof Construction/ModificationN/A2. Surveys and StudiesN/A3. Reporting RequirementsA. Read InstructionsIncluded in 3CB. Required ActivitiesInitial performance testN/AC. Create InformationAnnual IFR Internal Inspections and EFR Seal Gapmeasurements (existing sources)8 1 4 32 2 3 $3,481D. Gather Existing InformationIncluded in 3CE. Write ReportNew SourcesNotification of Construction/ ReconstructionIncludedin NSPS KbNotification of anticipated startupIncluded in NSPS KbNotification of actual startupIncluded in NSPS KbNotification of emission testN/AReport of emission testN/ANotification of Control installationand refill at 1st IFRDegassingc2 1 0 0 0 0 $0Existing SourcesAnnual Inspection Reports2 2 4 16 1 2 $1,740Supplemental Delay Reportd2 1 0 0 0 0 $0Quarterly Emission ReportNone ExpectedeTotal Annual Responses ()84.Recordkeeping RequirementsA. Read InstructionsIncluded in 3AB. Plan ActivitiesIncluded in 4CC. Implement Activities-Filing and MaintainingRecords2 1 4 8 0 1 $870D. Develop Record SystemIncluded in 4CE. Time toEnter InformationIncluded in 4C14Activity(A)hr/Occurrence(B)Occurrences/plant/yr(C)aPlants/year(D)Technicalhr/yra(E=D*.05)Managerialhr/yr(F=D*.10)Clericalhr/yr(G)Cost/yrbF. Train PersonnelN/AG. AuditsN/ATOTAL ANNUAL HOURS56 3 6TOTAL ANNUAL BURDEN64 $6,092Assumptions:aEstimate that there will be 4 existing sources not covered by the HON. All new source burden is included in theNSPS subpart Kb regulation for storage vessels at40 CFR Part 60bUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates arefrom column 1, “Total Compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by privateindustry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical- $48.53/hrcIt is believed that all vessels have been degassed and allcontrols have been installed as they were to be installed within 10 years of promulgation.dEstimate that two percent of existing sources will request delay of repair in the annual report.eAssume that no sources will select the fixed roof vented to a control device option and thus have no quarterly reports of excess emissions.15TABLE G-10: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART VActivity(A)hr/Occurrence(B)Occurrences/plant/yr(C)Plants/year(D)Technicalhr/yra(E=D*.05)Managerialhr/yr(F=D*.10)Clericalhr/yr(G)Cost/yra1. ApplicationsN/A2. Survey and StudiesN/A3. Reporting RequirementsA.Read Instructions112b200$218B.Required Activities20124024$4,351Initial Performance TestReference Method 21/22 Tests412801$870Repeat Performance Test200.22801$870C.Create InformationSee 3BD.Gather Existing InformationSee 3BE.Write Report212400$435Notification of Construction/ReconstructionNotification of Anticipated Startup212400$435Notification of Actual Startup212400$435Notification of Initial Performance Test212400$435Report of Performance TestSee 3BApplication for Alternative1010.5501$544Initial Report8121612$1,740Semiannual Report30255c3,300165330$358,966Total Annual Responses1234. Recordkeeping RequirementsA.ReadInstructionsSee 3AB.Plan ActivitiesSee 4CC.Implement ActivitiesSee 3BD.Develop Record SystemN/AE.Time to Enter Information1.512300$326Records of startups, shutdown,malfunction, etc.16Activity(A)hr/Occurrence(B)Occurrences/plant/yr(C)Plants/year(D)Technicalhr/yra(E=D*.05)Managerialhr/yr(F=D*.10)Clericalhr/yr(G)Cost/yraRecords of operating, parameters andemissions0.1 365d55c2,008 100 201 $218,425Records of leak detected0.452551,14457114$124,441F. Train personnelN/AG. AuditsN/ATOTAL ANNUAL HOURS6,550328655TOTAL ANNUAL BURDEN7,533$712,493Assumptions:aUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.”The rates are from column 1, “Total Compensation.” Therates have been increased by 110 percent to account for thebenefit packages available tothose employed by private industry. Technical - $98.20/hr; Managerial - $114.49/hr; Clerical - $48.53/hr.bAssume one new facility per year comprising two new sources.cEstimate 21 existing facilities comprising 55 sources.17TABLE G-11: NEW SOURCE ANNUAL RESPONDENT BURDEN AND COST OF REPORTING ANDRECORDKEEPING REQUIREMENTS OF THE HONActivityAverageHours perActivity(a)Number ofActivitiesper year perrespondent(b)TechnicalHours peryear perrespondent(c)Estimated.Number Newrespondents(d)EstimatedTechnicalHours peryear(e)EstimatedManagerialHours peryear(f)EstimatedClericalHours peryear(g)Annual Costper year(h)1) Read Rule and Instructions2.7 93 250 5 1,250 63 125$135,9722) Plan Activities3.8 93 355 5 1,775 89 178$193,0803) Training3.5 38 132 5 660 33 66$71,7934) Create, Test, Research andDevelopment2.4 1,778 4,266 5 21,330 1,067 2,133$2,320,2245) Gather Information,Monitor/Inspect1.4 2,102 2,943 5 14,715 736 1,472$1,600,6616) Process/0.8 50 40 5 200 10 20$21,756Compile and Review7) Complete Reports11.4 49 557 5 2,785 139 279$302,945Total Annual Responses2458) Record/Disclose10.0 49 489 5 2,445 122 245$265,9619) Store/File5.2 51 264 5 1,320 66 132$143,586TOTAL ANNUAL HOURS46,480 2,324 4,648TOTAL ANNUAL BURDEN53,452$5,055,978Assumptions:(a) = (c)/(b)(d) - From previously approved ICR.See Attachment I for assumptions and further description of activities.18TABLE G-12: EXISTING SOURCE ANNUAL RESPONDENT BURDENAND COST OF REPORTING ANDRECORDKEEPING REQUIREMENTS OF THE HON PROVISIONSActivityAverageHours perActivity(a)Number ofActivitiesper year perrespondent(b)TotalTechnicalHours peryear perrespondent(c)TechnicalHours peryear perrespondentforwastewater(d)EstimatedTechnicalHours peryear(e)EstimatedManagerialHours peryear(f)EstimatedClericalHours peryear(g)Annual Costper year1) Read Rule and Instructions3.623691417,6808841,768$1,923,1862) Plan Activities6.113611816,0808041,608$1,749,1423) Training5.341744,400220440$478,6214) Create, Test, Research andDevelopment17.8991617150400,08020,00440,008$43,519,7025) Gather Information,Monitor/Inspect2.567716930406,32020,31640,632$44,198,4746) Process/Compile and Review20.012004,800240480$522,1327) Complete Reports81.253881894,5604,7289,456$10,286,000Total Annual Responsesa1,6008) Record/Disclose17.52644212107,0405,35210,704$11,643,5449) Store/File6.8352221554,4802,7245,448$5,926,198TOTAL ANNUAL HOURS1,105,44055,272110,544TOTAL ANNUALBURDEN1,271,256$120,247,000Assumptions:(a) = (c + d)/(b)(c) - there are 240 existing sources out of the 320 totalthat 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.aTotal number of respondents is 320 ( 240 for HON + 80 CARstill complying with HON Wastewater).See Attachment I for assumptions and furtherdescription of activities.19TABLE G-13: ANNUAL BURDEN OF REPORTING AND RECORDKEEPING REQUIREMENTS FOR SUBPART VVaActivity(A)hr/Occurrence(B)Occurrences/plant/yr(C)aPlants/year(D)Technicalhr/yr(E=D*.05)Managerialhr/yr(F=D*.10)Clericalhr/yr(G)Cost/yrb1. ApplicationsN/A2. Survey and StudiesN/A3. Reporting RequirementsA.Read Instructions11383824$4,134B.Required Activities481381,82491182$198,410Initial Performance TestReportRepeat Performance Test Report4818c3841938$41,771C.Create InformationIncluded in 3BD.Gather Existing InformationIncluded in 3EE.Write Report21234625$5,004New SourcesNotification of ConstructionNotification of Reconstruction/ Modification21153023$3,263Notification of Actual Startup21387648$8,267Notification of Initial/Repeat Performance Test21469259$10,008Existing Sources Semiannual Report4.52383421734$37,202Total Annual Responses2444. Recordkeeping RequirementsIncluded in 3AA.Read InstructionsB.Plan ActivitiesIncluded in 4CC.Implement ActivitiesIncluded in 3BD.Develop Record SystemN/AE.Time to Enter InformationdAverage Facilities-Records of Operating Parameters89.51343,043152304$331,010Small Facilities-Records of Operating Parameters95.2143811938$41,444F.Train personnelN/AG.AuditsN/ATOTAL ANNUAL HOURS6,256313626TOTAL ANNUAL BURDEN7,194$680,51220Assumptions:aAssume that there will be an average 38 new, modified, orreconstructed facilities each year over the next 3 years. Estimate that 23 of new affected sourceswill be due to construction, and 15 will be reconstructed or modified. There are an average of 38 new affected sources each year after promulgation of VVa.Assume 10 percent are small facilities that will record instrument readings manually, and 90 percent of facilitiesuse automated equipment to capture instrumentreadings electronically. Assume that costs are being calculated for the second of the three years after promulgation of VVa, so that the 38 new sources inthe first year are existing sources in the second year. Since subpart VVa is more stringent than the HON andMON, no sources are assumed to be complyingwith the HON or MON instead of subpart VVa.bUnited States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.”The rates are from column 1, “Total Compensation.” Therates have been increased by 110 percent to account for thebenefit packages available to those employed byprivate industry. Technical - $98.20/hr; Managerial - $114.49/hr;Clerical - $48.53/hrcAssume 20 percent of initial performance tests must be repeated due to failure.dDetails of the additional hours relative to the hoursfor a source subject to subpart VV are provided in section 6(f) of Part A of the Supporting Statement.

# Η 1 Attachment H

Assumptions and Item Descriptions for Attachment F: Tab le F-11

(A) That all existing and new sources must submit an initia l report within 120 days of

promulgation and an implementation plan or permit applic ation within 12 or 18 months of the

compliance date. It is assumed that initial reports an d implementation plans have been submitted

for existing sources and these reports are only required fo r new sources. The new sources are

most likely to be collocated within existing plants and be included in those existing source

reports.

(B) That semiannual reports of results from equipment l eak detection and repair programs

are required by the equipment leak standard. Sources are required to comply with the equipment

leak standard by 6 months after promulgation. It is assume d that an average of 320 facilities will

submit reports semiannually (320 x 2 = 640) (even those that use t he CAR will still have to

submit reports under the HON for wastewater).

Item Descriptions:

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

for estimating the overall burden.

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

reviewed and other related activities during the course of the year. Under the performance test

headings, these numbers are based upon assumptions (A) an d (B), above. For one-time reports,

the total number of reports expected over the three-year period was divided by three to get an

annual average incorporating assumption (C), above.

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

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

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

(f) Estimated Annual Cost per year is the sum of costs for technical, managerial, and

clerical hours based on rates from the Office of Pers onnel Management (OPM), 2010

General Schedule which excludes locality rates of pay.

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

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

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

(H t 

# x $46.21/hour)+(H m



# x $62.27/hour)+(H c 

# x $25.01/hour) = (G)

Where:

H t 

# is (c), or technical hours

H m 

# is (d), or managerial hours, and

H c 

# is (e), clerical hours

Report Review:

1) Initial represents the EPA review of all initial reports rece ived.

2) Implementation Plan or Permit Applications represents the EPA review of all

implementation plans, or permit applications if submitte d in lieu of an implementation plan.

# Η 2

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 standa rd.

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 n ew

sources.

8) Notification of performance test represents the EPA review of this notification from

new sources.

9) Review of test results represents the EPA review of performance test results for new

sources.

10) Review periodic reports represents the EPA review of periodic reports.

TOTAL BURDEN AND COST is the sum of each of the colu mns (d), (e), (f), and (g).

# Ι 1 Attachment I

Assumptions and Item Descriptions for Attachment G: Tab les 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 w ith the CAR will still be required to

comply with the HON wastewater provisions, as the CAR does not include wastewater

provisions. The total number of facilities will increas e by 5 new facilities per year. Since new

facilities must be in compliance at startup, the genera l 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 exist ing, 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 point s

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 percen t (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 re ports activities alone, to avoid double

counting these as records activities as well. Therefor e, 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 significa ntly, it is too inaccurate to assume an

average to use to calculate (c). Estimated activity tec hnical hours are summarized to obtain (c)

first, then back calculate for (a) with an estimated (b).

(b) Estimated Number of Activities per year per source represents the assumed typical

number of separate activities a source may encounter durin g one year. This number may vary

from facility to facility, depending on consolidation of activities, collocated readings, etc. Since

so much variability exists, it is important to note that this is an estimate. This number was only

used to back-calculate (a).

(c) Technical Hours per year per source is the actual best estimate of the burden for each

burden item. The three-year separate activity burdens wer e divided by three, where appropriate,

and then summarized to include in this column. The technica l 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 y ears after promulgation.

# Ι 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 an d reporting to ensure compliance

with requirements for wastewater. As discussed in assu mption (A), facilities complying with the

CAR will comply with the HON wastewater requirements. Burden hours per source, per

emission type are shown in Table B-1.

(e) Estimated Technical Hours per year is the product of (c) and (d) for new facilities

(Table G-11). For Table G-12, estimated technical hours are the product of (c) and the number

of existing facilities complying with all of the HON (240) added to the product of (d) and the

number of facilities complying with only the wastewater provisions (80).

(f) Estimated Managerial Hours per year is 5 percent of (e).

(g) Estimated Clerical Hours per year is 10 percent of (e).

(h) Estimated Annual Cost per year is from the United States Department of Labor,

Bureau of Labor Statistics, September 2009, Table 2. Civilian Workers, by Occupational and

Industry group. The rates are from column 1, Total Compen sation. The rates have been

increased by 110 percent to account for the benefit packages ava ilable to those employed by

private industry.

(H t 

# x $98.20/hour)+(H m



# x $114.49/hour)+(H c 

# x $48.53/hour) = (G)

Where:

H t 

# is (e), or technical hours

H m 

# is (f), or managerial hours, and

H c 

# is (g), clerical hours

1) Read Rule and Instructions are the activities, less training, which involve

comprehending the provisions in the standard and understandi ng how they apply to the

respective points at a facility.

2) Plan Activities represents such burdens as design, redesign, scheduling as we ll as

drafting the implementation plan, and selecting methods of compliance.

3) Training represents the portion (assumed 40 percent) of activitie s from 1) Read Rule

and Instruction

for which an average facility would elect to provide cl ass 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 poin t by point applicability. Monitor

related refit, calibration and maintenance activities a re also included under this heading.

5) Gather Information, Monitor and Inspect are the activities involving physical

inspections of equipment, collection of monitored data an d other related activities.

6) Process/Compile and Review are the activities that involve analysis of the inform ation

collected for accuracy, compliance, and appropriate reports and records required as a result.

7) Complete Reports represents the activities normally associated with fi lling out forms.

Since the standard requires no standard forms, these act ivities relate to the preparing of formal

reports and cover letters as appropriate.

8) Record/Disclose are activities which are solely recordkeeping which occur once the

appropriate report information has been extracted [see assumption (D)] above. These activities

# Ι 3

involve software translation, duplication, or archival pro cesses normally associated with data

management and storage common to this industry.

9) Store/File are again activities which are solely recordkeeping which occur once the

appropriate report information has been extracted (see assumption (D) above). These activities

involve the management life cycle of records, from the time they are filed and boxed up, to the

time they are disposed.

TOTAL BURDEN AND COST is the sum of each of the colu mns (e), (f), (g), and (h).

# 1 Attachment J

Summary of Capital/Startup and Operation and Maintenance Costs for the CAR and Its

Referencing Subparts

NSPS Subpart Ka

a. Total Capital/Startup Cost of Monitoring Equipment : The total capital/Startup costs for this ICR are $0.

b. Total Cost of Operation and Maintenance of Monitorin g Equipment :

The total operating and maintenance (O&M) Costs for this ICR is $0.

c. Total Capital/Startup and O&M Cost : The total capital and O&M Costs are $0.

NSPS Subpart Kb

a. Total Capital/Startup Cost of Monitoring Equipment : The total capital/Startup costs for this ICR are $27,000. Thi s is the cost for 2 new

storage tanks to install monitoring equipment associated wit h the CVS routed to a

control device. The storage tanks will use equipment simi lar to that used for

subparts NNN and III; therefore, the startup costs are approximately $13,500 per

facility for a total of $27,000. There are no capital/start up costs for the remaining

35 new storage tanks complying by either an IFR or EFR.

b. Total Cost of Operation and Maintenance of Monitori ng Equipment : The average annualized burden is estimated to be $1,350 per year per affected

facility ($13,500 discounted over 10 years by straight line deprec iation 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 bu y an additional monitor

and no additional facilities will become subject to subpa rt VV in the future.

# 2

b. Total Cost of Operation and Maintenance of Monitorin g Equipment :

The operation of the monitors is included in the monitorin g costs. Maintenance

costs on these units is incidental, therefore no mainte nance 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. T his is based on the

average cost of a monitor ($7,000) with a 5-year expected li fe. The equipment is

not capitalized, so no discount rate applies. The average annual cost is, therefore,

$7,000/5, or $1,400/yr. It is estimated that only area sources t hat 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 pe rcent 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 proc ess unit will buy a

monitoring instrument to comply with NSPS subpart VVa.

b. Total Cost of Operation and Maintenance of Monitorin g Equipment :

The operation of the monitors is included in the monitorin g costs. Maintenance

costs on these units is incidental; therefore, no mainte nance or operation costs

incur.

c. Total Capital/Startup and O&M Cost : The total capital and O&M Costs are $4,200.

NSPS Subpart DDD

a. Total Capital/Startup Cost of Monitoring Equipment : The capital/startup costs for this regulation are $300,000. T his is based on 10 new

sources per year multiplied by $30,000 per source for monitorin g equipment.

b. Total Cost of Operation and Maintenance of Monitorin g Equipment : The annual operation and maintenance costs are $630,000 doll ars. 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 Oper ations 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 Monitorin g Equipment : The average annualized burden is estimated to be $1,350 per year per affected

facility ($13,500 discounted over 10 years by straight line deprec iation 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 dol lars per year. This is

based on 20 new sources per year multiplied by $25,000 for monit oring

equipment discounted over 10 years at 7 percent.

b. Total Cost of Operation and Maintenance of Monitorin g Equipment : The annual operation and maintenance costs are $77,500 doll ars. 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 Monitorin g Equipment :

There are no O&M cost associated because no CEMs are employed.

c. Total Capital/Startup and O&M Cost : The total capital and O&M costs are $0.

NESHAP Subpart Y

a. Total Capital/Startup Cost of Monitoring Equipment :

# 4 The only type of industry costs associated with the inf ormation collection activity

in the standards is labor cost. There are no capital /startup costs.

b. Total Cost of Operation and Maintenance of Monitorin g Equipment :

There are no operation and maintenance costs.

c. Total Capital/Startup and O&M Cost : The total capital and O&M costs are $0.

NESHAP Subpart V

a. Total Capital/Startup Cost of Monitoring Equipment :

Startup cost were identified in previous ICR.

b. Total Cost of Operation and Maintenance of Monitorin g Equipment:

There are no O&M costs associated because no CEMs are employed.

c. Total Capital and O&M Cost

The total capital and O&M costs are $0.

NESHAP HON :

Subpart G

a. Total Capital/Startup Cost of Monitoring Equipment :

Estimate the cost to purchase monitoring equipment is appro ximately $20-30K for

process vents and wastewater operations, or an average of $25K with a 10-year

life expectancy and a 7 percent depreciation rate, or $2225 per year. There are no

associated costs for transfer racks and storage tanks. Only new sources need to

buy monitoring equipment; therefore, the total capital/ startup cost is $25,000 x 5,

or $125,000.

b. Total Cost of Operation and Maintenance of Monitorin g Equipment :

The cost to industry associated with the operation and m aintenance (O&M) is

approximately $100-500K per year (capital/startup depreciation n ot included) for

reactor process vents and wastewater operations. The cost associated with the

operation and maintenance is $50-100K per year (capital/sta rtup depreciation not

included) for distillation units process vents. There are no associated costs for

transfer racks and storage tanks. The average O&M cost is assumed to be the

average of the two ranges, or $275,000 per year. Operation and maintenance

incur for both new and existing sources. The total O&M is, therefore, $275,000 x

245, or $67,375,000.

c. Total Capital/Startup and O&M Cost : The total capital and O&M costs are $67,500,000.

# 5

Subpart H

a. Total Capital/Startup Cost of Monitoring Equipment :

Only new sources will buy an organic volatile analyzer. Estimate the average cost

of a monitor is $7,000 with a 5-year expected life. The equip ment is not

capitalized, so no discount rate applies. The average ann ual cost is, therefore,

$7,000/5, or $1,400/yr. Estimate that 80 percent of facilities c ontract out LDAR

services, and 20 percent perform in-house. Those faciliti es which contract out (4

facilities) will purchase one unit as backup; the remaining facilities performing

LDAR in-house (1 facility) will purchase 5 units to support th e program. The

total annual capital/startup cost is, therefore, 9 units x 1400/unit, or $12,600/yr.

b. Total Cost of Operation and Maintenance of Monitorin g Equipment :

The operation of the monitors is included in the monitorin g costs. Maintenance

costs on these units is incidental; therefore, no mainte nance or operation costs

incur.

c. Total Capital and O&M Cost for Subparts H, and I : The total capital and O&M costs are $12,600.

Part 65 CAR

a. Total Capital/Startup Cost of Monitoring Equipment :

Under the CAR, it is assumed all new sources start out under the referencing

subpart. Therefore, there is no capital/startup cost associated with this subpart.

b. Total Cost of Operation and Maintenance of Monitorin g Equipment :

The HON is the basis for determining O&M costs for the C AR. The average cost

per source, based on the HON is $275,000 per year, for a total of $22,000,000.

c. Total Capital/Startup and O&M Cost : The total capital and O&M costs are $22,000,000.