1
SUPPORTING
STATEMENT
NESHAP
FOR
ORGANIC
LIQUIDS
DISTRIBUTION
(
NON­
GASOLINE)
FACILITIES
(
40
CFR
part
63,
subpart
EEEE)

1.
Identification
of
the
Information
Collection
(
a)
Identification
of
the
Information
Collection
"
NESHAP
for
Organic
Liquids
Distribution
(
Non­
Gasoline)
Facilities
(
40
CFR
part
63,
subpart
EEEE)."
This
is
a
new
information
collection
request
(
ICR)
that
has
been
assigned
Environmental
Protection
Agency
(
EPA)
ICR
number1963.02.

(
b)
Short
Characterization
This
ICR
is
prepared
for
an
EPA
rulemaking
developed
under
authority
of
Section
112
of
the
Clean
Air
Act
(
Act).
The
final
rule
amends
title
40,
chapter
I,
part
63
of
the
Code
of
Federal
Regulations
(
CFR)
by
adding
a
new
subpart
EEEE­­
NESHAP
for
Organic
Liquids
Distribution
(
Non­
Gasoline)
Facilities.
The
Organic
Liquids
Distribution
(
Non­
Gasoline)
Facilities
NESHAP
includes
standards
for
major
sources
of
hazardous
air
pollutants
(
HAP).

Respondents
are
owners
or
operators
of
new
or
existing
organic
liquids
distribution
facilities(
OLD)
facilities
subject
to
these
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP).
In
addition
to
the
initial
notification
and
notification
of
compliance
status
required
by
the
General
Provisions
to
40
CFR
part
63,
subpart
A,
respondents
are
required
to
submit
one­
time
reports
of
start
of
construction,
anticipated
and
actual
startup
dates,
and
physical
or
operational
changes
to
existing
facilities.
Reports
of
initial
performance
tests
at
organic
liquids
distribution
storage
tanks
and
transfer
racks
are
also
required
and
are
necessary
to
show
that
the
installed
control
devices
are
meeting
the
emission
limitations
required
by
the
NESHAP.
Annual
reports
of
storage
tank
inspections
at
all
affected
facilities
are
required.
In
addition,
respondents
must
submit
semiannual
startup,
shutdown,
and
malfunction
reports,
semiannual
compliance
and
continuous
monitoring
system
performance
reports,
and
semiannual
reports
of
equipment
leaks
not
repaired
within
15
days
or
loadings
of
organic
liquid
cargo
tanks
for
which
vapor
tightness
documentation
is
not
on
file.
All
affected
facilities
must
maintain
records
of
the
cargo
tank
vapor
tightness
test
data
on
the
facility
premises.
All
records
are
to
be
maintained
for
at
least
5
years.
All
reports
are
to
be
submitted
to
the
respondent's
State
or
local
agency,
whichever
has
been
delegated
enforcement
authority
by
the
EPA.
The
information
is
to
be
used
to
determine
whether
all
sources
subject
to
the
NESHAP
are
achieving
the
standards.
2
In
this
case
the
number
of
respondents
varies
according
to
the
task.
The
total
number
of
Respondents
is
381.
While
there
are
12
new
facilities
per
year,
they
replace
12
from
the
existing
pool,
so
the
base
number
is
constant.
Of
the
existing
facilities,
64
have
minimal
tasks
to
do
and
are
assigned
a
burden
of
1
hour
total,
so
that
the
annualized
number
of
respondents
per
year
actively
engaged
in
the
detection
and
correction
of
pollution
problems
is
effectively
(
381
­
64
=
317).
Within
that
number,
sources
have
different
equipment,
so
that
not
all
tasks
are
appropriate
for
all
sources,
and
the
number
of
respondents
varies
somewhat
across
tasks.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection
The
EPA
is
charged
under
section
112
of
the
Act
(
Attachment
1),
as
amended,
to
establish
NESHAP.
Section
114
of
the
Act
allows
the
Administrator
to
require
inspections,
monitoring,
and
entry
into
facilities
to
ensure
compliance
with
a
section
112
emission
standard.
Section
114(
a)(
1)
specifically
states:

"
The
Administrator
may
require
any
person
who
owns
or
operates
any
emission
source
...
who
is
subject
to
the
provisions
of
this
Act
on
a
one­
time,
periodic,
or
continuous
basis
to­­

(
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;

(
E)
keep
records
on
control
equipment
parameters,
production
variables
or
other
indirect
data
when
direct
monitoring
of
emissions
is
impractical;

(
F)
submit
compliance
certifications
in
accordance
with
section
114(
a)(
3);
and
(
G)
provide
such
other
information
as
the
Administrator
may
reasonably
require."

Effective
enforcement
of
this
rule
is
necessary
due
to
the
hazardous
nature
of
the
HAP
compounds
found
in
the
organic
liquids
stored,
transferred,
and
distributed
at
OLD
facilities.
In
total,
this
NESHAP
will
regulate
98
of
the
most
toxic
and
volatile
organic
HAP
compounds
at
OLD
facilities
(
listed
in
Table
1
of
the
NESHAP),
including
(
not
a
comprehensive
listing):


Methanol

Benzene
3

Ethylbenzene

Toluene

Xylenes
Certain
records
and
reports
are
necessary:
(
1)
to
enable
the
EPA
to
identify
new
and
existing
sources
subject
to
the
standards,
and
(
2)
to
assist
the
EPA
and
State
agencies
to
which
enforcement
has
been
delegated
in
determining
compliance
with
the
standards.

(
b)
Practical
Utility/
Users
of
the
Data
The
information
will
be
used
by
agency
enforcement
personnel
to:
(
1)
identify
sources
subject
to
the
standards,
(
2)
ensure
that
emissions
due
to
leakage
(
both
liquid
and
vapor)
from
cargo
tanks
and
process
piping
equipment
components
during
transfer
are
being
minimized,
(
3)
ensure
that
emission
control
devices
are
being
properly
operated
and
maintained,
and
(
4)
ensure
that
emissions
from
storage
tanks
are
minimized
and
rim
seal
and
fitting
defects
are
repaired
on
a
timely
basis.

In
addition,
records
and
reports
are
necessary
to
enable
the
EPA
to
identify
facilities
that
may
not
be
in
compliance
with
the
standards.
Based
on
reported
information,
the
EPA
can
decide
which
facilities
should
be
inspected
and
what
records
or
specific
emission
sources
should
be
inspected
at
each
facility.
Also,
the
records
that
facilities
maintain
provide
an
indication
to
the
EPA
as
to
whether
facility
personnel
are
operating
and
maintaining
control
equipment
properly.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
Some
of
the
facilities
subject
to
this
NESHAP
will
also
be
subject
to
requirements
under
40
CFR
part
60
new
source
performance
standards
(
NSPS),
subparts
K,
Ka,
Kb,
VV,
and
XX.
Some
operations
also
occupy
the
same
plant
site
as
facilities
complying
with
other
NESHAP
such
as
40
CFR
part
63,
subparts
G,
H,
and
I
(
collectively
referred
to
as
the
HON),
40
CFR
part
63,
subpart
R
(
Gasoline
Distribution
NESHAP),
and
40
CFR
part
63,
subpart
CC
(
the
Refinery
NESHAP).
Some
OLD
facilities
may
also
become
subject
to
the
requirements
of
future
NESHAP.
The
burden
requested
for
this
NESHAP
does
not
duplicate
any
of
the
burden
accounted
for
under
the
mentioned
NSPS
or
NESHAP
subparts.

Certain
reports
required
by
State
or
local
agencies
may
duplicate
information
required
by
these
standards.
In
such
cases,
a
copy
of
the
report
submitted
to
the
State
or
local
agency
may
be
sent
to
the
Administrator
in
lieu
of
the
report
required
by
the
standards.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
A
Federal
Register
notice
was
not
published
soliciting
comments
on
burden
estimates
for
this
4
ICR.

(
c)
Consultations
The
Organic
Liquids
Distribution
(
Non­
Gasoline)
Facilities
NESHAP
was
developed
with
the
help
of
industry
stakeholders.
Industry
stakeholders
were
informed
of
the
project's
progress
in
four
stakeholder
meetings
conducted
in
Research
Triangle
Park,
North
Carolina.
Table
1
contains
the
names,
affiliations,
and
phone
numbers
of
stakeholders
involved
in
the
OLD
rulemaking
effort.
These
stakeholders
were
consulted
during
all
phases
of
this
NESHAP
development.

Table
1.
List
of
People
Consulted
in
OLD
NESHAP
Development
Name
Organization
Position
Telephone
W.
R.
(
Bill)
Beck
Mobil
Oil
Corporation
Environmental,
Health
and
Safety
Issues
Manager
703/
849­
6245
Mario
Gamboa
ACC
Environmental
Issues
Manager
703/
741­
5238
Thomas
J.
Hmiel
BASF
Corporation
Corporate
Ecology
and
Safety
Air
Team
Leader
973/
426­
1234
Usha
Mehra
ILTA/
GATX
Terminals
Corporation
Environmental,
Health
and
Safety
Manager­
Gulf
Region
713/
450­
0400
Denise
Michelson
Atlantic
Richfield
Corporation
(
ARCO)
Director,
Corporate
Policy
and
Reporting
213/
486­
0662
Bob
Morehouse
Exxon/
Mobile
Chemical
Environmental
Associate
281/
870­
6524
Karin
Ritter
API
Regulatory
Affairs
202/
682­
8472
Tara
Lanier
Ashland
Chemical
Environmental,
Health
and
Safety
614/
790­
3214
(
d)
Effects
of
Less
Frequent
Collection
The
reporting
requirements
for
facilities
subject
to
the
NESHAP
consist
of
certain
one­
time
reports
and
a
minimal
amount
of
periodic
recordkeeping
and
reporting.
At
new
and
existing
OLD
facilities,
inspections
and
corresponding
records
and
reports
of
the
transfer
racks
and
process
piping
equipment
components
are
required
(
storage
tanks
require
annual
and
other
inspections
and
associated
records
and
reports).
If
this
information
were
collected
less
frequently,
the
main
consequence
would
be
poor
operation
and
maintenance
of
equipment
components
and
storage
tanks.
Consequently,
increased
HAP
emissions
could
result.

(
e)
General
Guidelines
The
proposed
rule
requires
records
to
be
retained
for
5
years,
which
is
consistent
with
the
General
Provisions
of
40
CFR
part
63
and
the
part
70
operating
permit
requirements
(
Title
V).
All
of
the
5
facilities
affected
by
this
NESHAP
are
required
to
obtain
an
operating
permit
(
with
or
without
the
issuance
of
this
regulation).
The
5­
year
retention
requirement
exceeds
the
3­
year
retention
period
required
by
5
CFR
1320.6;
however,
none
of
the
other
guidelines
in
5
CFR
1320.6
is
being
exceeded.

(
f)
Confidentiality
Any
information
submitted
to
the
EPA
for
which
a
claim
of
confidentiality
is
made
will
be
safeguarded
according
to
Agency
policies
as
set
forth
in
Title
40,
chapter
1,
part
2,
subpart
B­­
Confidentiality
of
Business
Information
(
see
40
CFR
part
2;
40
FR
36902,
September
1,
1976,
amended
by
43
FR
39999,
September
28,
1978;
43
FR
42251,
September
28,
1978;
and
44
FR
17674,
March
23,
1979).

(
g)
Sensitive
Questions
This
section
is
not
applicable.
Information
to
be
collected
has
been
determined
to
not
be
of
a
sensitive
nature.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
SIC
Codes
Respondents
are
owners
or
operators
of
organic
liquids
storage/
handling
and
distribution
facilities
subject
to
the
NESHAP.
Table
2
below
provides
the
primary
SIC/
NAICS
codes
that
apply
to
facilities
that
conduct
OLD­
type
operations.

Table
2.
Affected
Industry
Segments
and
their
Industry
Classifications
Industry
Segment
NAICS
Codes
SIC
Codes
Chemical
Production
325211,
325192,
325188
2821,
2865,
2869
Petroleum
Refineries
32411
2911
Liquid
Terminals
49311,
49319
4226
Crude
oil
pipeline
stations
48611
4612
Petroleum
terminals
42269,
42271
5169,
5171
Organic
liquids
distribution
activities
may
also
occur
at
facilities
with
other
SIC
or
NAICS
codes
not
listed
in
the
table
above.

(
b)
Information
Requested
6
(
i)
Data
items,
including
recordkeeping
requirements
(
1)
Organic
Liquids
Storage
and
(
Non­
Gasoline)
Facilities.
The
following
types
of
one­
time
reports
are
required
for
sources
affected
by
this
NESHAP.


For
existing
sources,
a
report
filed
within
1
year
subsequent
to
the
effective
date
of
the
NESHAP,
notifying
the
Administrator
that
the
facility
is
subject
to
the
relevant
standards
(
Initial
Notification).
Information
to
be
provided
in
the
report
is
detailed
in
§
63.9(
b)(
2)
of
subpart
A,
General
Provisions.


For
new
sources
[
for
which
approval
of
construction
or
reconstruction
is
not
required
under
§
63.5(
d)],
an
Initial
Notification
filed
within
120
days
after
startup
of
the
source,
notifying
the
Administrator
that
the
facility
is
subject
to
the
relevant
standards,
as
provided
in
§
63.9(
b)(
3).
Information
to
be
provided
in
the
report
is
detailed
in
§
63.9(
b)(
2).


Notification
of
anticipated
construction
or
reconstruction
of
a
source
subject
to
a
relevant
standard
not
later
than
180
days
prior
to
commencement
of
construction
or
reconstruction
as
indicated
in
§
63.9(
b)(
5).


Notification
of
anticipated
date
of
initial
startup
not
more
than
60
days
nor
less
than
30
days
prior
to
such
date
[
§
63.9(
b)(
4)(
iv)].


Notification
of
the
actual
date
of
startup,
within
15
days
after
such
date
[
§
63.9(
b)(
4)(
v)].


Notification
of
construction
or
reconstruction
not
later
than
30
days
after
the
change
is
commenced
[
§
63.9(
b)(
4)(
iii)].


Notification
of
installation
of
a
new
control
device
or
reconstruction
of
an
existing
control
device
within
180
days
before
the
installation
or
reconstruction
is
planned
to
commence
[
§
63.5(
b)(
6)
and
§
63.5(
d)(
1)].


Within
180
days
after
initial
startup,
installation
of
a
control
device,
or
refurbishment
of
an
existing
control
device,
the
owner
or
operator
of
the
facility
must
conduct
a
performance
test
and
furnish
the
Administrator
with
a
written
report
[
§
63.7(
a)].


The
owner
or
operator
of
an
affected
facility
must
notify
the
Administrator
at
least
60
days
prior
to
the
date
of
a
performance
test
[
§
63.9(
e)].


A
request
for
an
extension
of
compliance
must
be
submitted
if
the
owner
or
operator
cannot
comply
with
the
standard
by
the
designated
date
[
§
63.9(
c)].
7

The
owner
or
operator
must
report
any
reconstruction
of
an
affected
facility
as
defined
in
§
63.5.


A
Notification
of
Compliance
Status
must
be
submitted
within
60
days
after
compliance
of
the
affected
facility
has
been
established,
pursuant
to
§
63.9(
b)(
2).

(
2)
The
following
periodic
reports
and
record
maintenance
are
required
for
the
affected
sources.


A
semiannual
compliance
report
is
to
be
submitted
which
indicates
any
deviations
from
the
standards
and
all
facility
responses
to
startups,
shutdowns,
and
malfunctions
that
are
consistent
with
the
facility's
plan
[
§
63.2386(
a)].


A
startup,
shutdown,
and
malfunction
report
must
be
submitted
within
7
days
each
time
the
facility's
response
to
one
of
these
occurrences
is
inconsistent
with
the
plan
[
§
63.2386(
a)].


Records
of
annual
and
other
inspections
of
storage
tanks
are
to
be
kept
as
specified
in
§
63.2390(
c).


Copies
of
all
submitted
notifications
and
reports,
including
performance
test
results
and
startup,
shutdown,
and
malfunction
records
are
to
be
maintained
by
the
source
in
accordance
with
§
63.2390(
a).


A
continuous
record
of
operating
parameter
monitoring
data,
as
well
as
specific
records
to
ensure
that
the
monitoring
activities
will
provide
an
indication
of
the
facility's
compliance,
are
to
be
kept
pursuant
to
§
63.2390(
b)
and
(
c).

Records
required
by
this
NESHAP
must
be
retained
by
the
owner
or
operator
for
5
years
in
accordance
with
§
63.2394(
b).
This
information
and
data
will
be
viewed
and
analyzed
by
agency
personnel
during
periodic
visits,
approximately
once
a
year,
to
the
respondents'
OLD
facilities.

5.
The
Information
Collected
­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
The
EPA
will
conduct
the
following
activities
in
connection
with
the
acquisition,
analysis,
storage,
and
(
Non­
Gasoline)
of
the
information
required
under
40
CFR
part
63,
subpart
"
EEEE",
NESHAP
for
Organic
Liquids
Distribution
(
Non­
Gasoline)
Facilities:

S
Observe
initial
and
repeat
performance
tests,

S
Review
notifications
and
reports,
including
compliance
reports,
required
to
be
8
submitted
by
industry,

S
Audit
facility
records,
and
S
Compile
data
in
the
AIRS
database.

(
b)
Collection
Methodology
and
Management
Following
notification
of
startup,
the
reviewing
authority
might
inspect
the
source
to
verify
that
the
pollution
control
devices
are
properly
installed
and
operated.
Performance
test
reports
are
used
by
the
Agency
to
determine
a
source's
initial
capability
to
comply
with
the
emission
limitations,
and
to
note
the
operating
conditions
under
which
compliance
was
achieved.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
are
tabulated
and
published
for
internal
Agency
use
in
compliance
and
enforcement
programs.
The
semiannual
reports
are
used
for
problem
identification,
as
a
check
on
source
operation
and
maintenance,
and
for
compliance
determinations.

Information
contained
in
these
reports
is
entered
into
the
Aerometric
Information
Retrieval
System
(
AIRS)
Facility
Subsystem
(
AFS)
which
is
operated
and
maintained
by
the
EPA's
Office
of
Air
Quality
Planning
and
Standards.
The
AFS
is
the
EPA's
database
for
the
collection,
maintenance,
and
retrieval
of
compliance
and
annual
emission
inventory
data
for
over
100,000
industrial
and
government­
owned
facilities.
The
EPA
uses
AFS
for
tracking
air
pollution
compliance
and
enforcement
by
local
and
State
regulatory
agencies,
and
EPA
Regional
Offices
and
Headquarters.
The
EPA
can
edit,
store,
retrieve,
and
analyze
the
data
via
PC
terminals.

(
c)
Small
Entity
Flexibility
Even
though
the
recordkeeping
requirements
are
the
same
for
small
and
large
businesses,
the
Agency
considers
these
requirements
the
minimum
needed
to
ensure
compliance
and,
therefore,
cannot
reduce
them
further
for
small
businesses.
Construction,
modification,
and
reconstruction
reports
take
very
little
time
to
complete
and
are
filed
only
once.
Equipment
leak
monitoring
and
storage
tank
inspection
records
are
brief,
and
cargo
tank
vapor
tightness
documentation
will
be
supplied
primarily
by
independent
cargo
tank
operators
and
kept
at
the
OLD
facility
for
each
tank
truck
and
railcar
that
is
to
be
loaded
with
regulated
liquids
at
the
facility.

(
d)
Collection
Schedule
Information
contained
in
the
one­
time­
only
reports
will
be
entered
into
the
AIRS
facility
subsystem.
Data
obtained
during
periodic
visits
by
Agency
personnel
from
records
maintained
by
the
respondents
and
reports
submitted
by
the
respondents
to
the
EPA
will
be
tabulated
and
published
for
internal
EPA
use
in
compliance
enforcement
programs.
A
schedule
for
the
collection
of
information
and
publication
of
data
is
not
applicable
because
reports
and
recordkeeping
are
triggered
by
actions
of
the
respondents.
9
6.
Estimating
the
Burden
and
Cost
of
the
Collection
Tables
3
and
4
document
the
computation
of
individual
burdens
for
each
of
the
recordkeeping
and
reporting
requirements
applicable
to
the
respondents
complying
with
this
standard.
The
individual
burdens
are
expressed
under
standardized
headings
believed
to
be
consistent
with
the
concept
of
burden
under
the
Paperwork
Reduction
Act.
Where
appropriate,
specific
tasks
and
major
assumptions
have
been
identified.
Responses
to
this
information
collection
are
mandatory.

(
a)
Estimating
Respondent
Burden
The
average
annual
burden
for
OLD
operations
facilities
over
the
next
3
years
is
estimated
at
137,170
person­
hours,
as
indicated
in
Table
4.
These
hours
are
based
on
Agency
studies
and
background
documents
from
the
development
of
the
standards
or
test
methods,
and
Agency
knowledge
and
experience
with
the
NESHAP
program.

For
the
purposes
of
these
estimates,
a
controlled
organic
liquids
distribution
facility
is
one
that
controls
transfer
rack
loading
activities
and
storage
tanks,
and
that
is
carrying
out
an
equipment
leak
detection
and
repair
program.
Cargo
tanks
that
are
presently
required
to
have
the
annual
vapor
tightness
tests
required
by
the
NESHAP
are
classified
as
currently
tested.
The
number
of
facilities
estimated
to
be
constructed/
reconstructed
or
modified
was
based
on
industry
growth
projections.

(
b)
Estimating
Respondent
Costs
(
i)
Estimating
labor
costs
The
primary
costs
of
complying
with
the
information
collection
activity
are
associated
with
labor
costs.
The
labor
estimates
used
in
Tables
3
and
4
were
derived
from
standard
estimates
based
on
the
EPA's
experience
with
other
standards.
The
costs
to
conduct
this
effort
have
been
calculated
on
the
basis
of:

$
61.66
per
hour
for
Technical
Labor
$
89.94
per
hour
for
Managerial
Labor
$
38.39
per
hour
for
Clerical
Labor
These
labor
rates
are
from
the
United
States
Department
of
Labor,
Bureau
of
Labor
Statistics,
September
2002,
Table
10.
Private
Industry
by
occupation
and
industry
group.
These
labor
rates
have
been
increased
by
110%
to
account
for
the
benefit
packages
available
to
those
employed
by
private
industry.

(
ii)
Capital/
Start­
Up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
Capital
costs
would
be
associated
with
the
cost
of
developing
a
data
base
capable
of
handling
the
10
recordkeeping
and
reporting
requirements
of
the
NESHAP.
It
was
conservatively
estimated
that
it
would
cost
approximately
$
2,500
to
develop
this
data
base.

Emissions
testing
costs
were
estimated
for
Method
18,
Method
25A,
Method
27,
and
Method
311
and
were
assumed
to
account
for
O&
M
costs
associated
with
this
NESHAP.
Methods
18
and
25A
will
be
used
to
measure
emissions
of
affected
HAP
from
control
devices.
The
cost
of
Method
18
and
25A
testing
was
provided
by
the
emissions
testing
staff
at
PES,
Inc.
Method
27
is
used
to
test
cargo
tanks
for
vapor
tightness
(
leakage).
Based
upon
current
information
provided
by
industry,
the
cost
of
performing
a
Method
27
test
has
been
estimated
to
be
$
200.
Method
311
would
only
be
used
to
determine
the
percentage
of
affected
HAP
in
organic
liquids.
As
such,
this
requires
that
a
sample
of
the
organic
liquid
be
run
through
a
gas
chromatograph
for
analysis,
and
this
is
a
fairly
rapid
and
inexpensive
procedure.

(
c)
Estimating
Agency
Burden
and
Cost
The
only
Federal
costs
are
user
costs
associated
with
analysis
of
the
reported
information.
Publication
and
distribution
of
the
information
are
part
of
the
operation
of
the
AFS.
Examination
of
records
to
be
maintained
by
the
respondents
will
occur
as
part
of
the
periodic
inspection
of
sources,
which
is
part
of
the
EPA's
overall
compliance
and
enforcement
program.

The
annual
Federal
Government
cost
during
the
first
3
years
of
the
ICR
is
estimated
to
be
$
860,653,
as
shown
in
Table
6.
Labor
rates
used
in
estimating
the
annual
cost
are
as
follows:

$
46.96
per
hour
for
Technical
Labor
$
65.28
per
hour
for
Managerial
Labor
$
22.26
per
hour
for
Clerical
Labor
These
rates
are
from
the
Office
of
Personnel
Management
(
OPM)
2003
General
Schedule,
which
excludes
locality
rates
of
pay.
The
rates
on
the
table
were
multiplied
by
1.6
to
take
benefits
into
account.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
number
of
existing
sources
subject
to
the
NESHAP
for
Organic
Liquids
Distribution
(
Non­
Gasoline)
Facilities,
40
CFR
part
63,
subpart
EEEE
is
381.
Within
the
primary
industry
segments
in
the
OLD
source
category,
it
is
estimated
that
there
are
the
following
numbers
of
major
source
facilities
that
conduct
OLD
operations:

184
SOCMI
facilities
95
Petroleum
refineries
57
For­
hire
organic
liquids
storage
terminals
16
Crude
oil
pipeline
breakout
stations
29
Bulk
petroleum
terminals
11
381
Total
facilities
It
is
estimated
that
approximately
3
percent
of
the
industry
may
construct
or
reconstruct
facilities
in
a
given
year.
This
results
in
there
being
approximately
12
cases
where
facilities
are
either
constructed
or
reconstructed
(
381
x
0.03
=
11.4,
rounded
up
to
12)
on
an
annual
basis.
The
same
number
of
facilities
close
or
are
no
longer
subject
to
the
standard
each
year.
(
e)
Bottom
Line
Burden
Hours
and
Costs
Tables
(
i)
Respondent
tally
See
Table
4.

(
ii)
The
agency
tally
See
Table
6.

(
iii)
Variations
in
the
annual
bottom
line
Not
applicable
as
this
is
a
new
ICR.

(
f)
Reasons
for
Change
in
Burden
Not
applicable
as
this
is
a
new
ICR.

(
g)
Burden
Statement
The
average
annual
burden
estimates
are
presented
in
Tables
3
through
6.
For
organic
liquids
distribution
facilities,
the
average
annual
burden
per
facility
is
approximately
360
hours.
This
estimate
includes
time
for
preparing
and
submitting
notices,
preparing
and
submitting
demonstrations
and
applications,
reporting
releases,
gathering
information,
and
preparing
and
submitting
reports.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information;
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
12
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2003­
0138,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa/
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW.,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0138)
in
any
correspondence.
13
Table
3.
Annual
Respondent
Burden
and
Costs
Burden
Item
(
A)
Tech
Hrs
per
Occurrence
(
B)
Number
of
Occurrences
per
Respondent
per
Year
Emissions
Testing
Cost
per
Occurrence
(
C)
Technical
Hours
per
Respondent
(
C=
AxB)
Number
of
Respondents
per
Year
Technical
Hours
per
Year
@

$
61.66/
hr
Manag.

Hours
per
Year
@

$
89.94/
hr
Clerical
hours
@

$
38.39/
hr
Total
Labor
Cost
per
Year
($)
Total
Capital
Costs
per
Year
($)
Total
O&
M
Costs
per
Year
($)

1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
and
Understand
Rule
Requirements
40
1
40
317
a
b
12,680
634
1,268
887,549
1
1
1
64
64
3
6
4,480
B.
Required
Activities:
0
0
0
0
3.1
Organic
Liquids
0
0
0
0
(
a).
Provide
true
vapor
pressure
and
percent
Table
1
HAP
of
all
organic
liquids
transferred
into/
out
of
facility.
10
1
10
317
b
3,170
159
317
221,887
(
b).
Determine
and
provide
Table
1
HAP
percentages
in
organic
liquids
using
Method
311.
1
15
$
500
15
83
h
1,245
62
125
87,145
3.2
Storage
Tanks
0
0
0
0
(
a).
Provide
a
list
of
all
tanks
in
OLD
operation
including
their
capacity,
HAP
vapor
pressure
for
tanks
less
than
50,000
gallons,
roof
type,
primary
and
secondary
seal
types,
and
fittings
20
1
20
317
a
b
6,340
317
634
443,775
(
b).
Provide
results
of
the
required
inspections
for
storage
tanks.
15
1
15
317
b
4,755
238
476
332,831
14
Table
3.
(
Continued)

Burden
Item
(
A)
Tech
Hrs
per
Occurrence
(
B)
Number
of
Occurrences
per
Respondent
per
Year
Emissions
Testing
Cost
per
Occurrence
(
C)
Hours
per
Respondent
(
C=
AxB)
Number
of
Respondents
per
Year
Technical
Hours
per
Year
@

$
61.66/
hr
Manag.

Hours
per
Year
@

$
89.94/
hr
Clerical
Hours@

$
38.39/

hr
Total
Labor
Cost
per
Year
($)
Total
Capital
Costs
per
Year
($)
Total
O&
M
Costs
per
Year
($)

3.3
Transfer
Operations
(
a).
Provide
documentation
of
the
facilitywide
volume
of
affected
liquids
transferred
through
loading
racks
and
the
HAP
percentage
of
affected
liquids
transferred
through
each
rack.
20
2
40
188
b
7,520
376
752
526,370
(
b).
Provide
documentation
that
cargo
tanks
subject
to
Method
27
vapor
tightness
testing
loading
at
affected
loading
positions
have
current
vapor
tightness
certification.
15
1
$
200
15
188
b
2,820
141
282
197,389
3.4
Equipment
Leaks
0
(
a).
Provide
a
list
of
all
equipment
in
OLD
service.
20
1
20
181
a
c
3,620
181
362
253,386
(
b).
Provide
documentation
detailing
equipment
found
leaking
using
Method
21
was
repaired
in
time
required.
10
4
$
2,500
40
302
c
12,080
604
1,208
845,552
3.5
Control
Devices
0
(
a).
Provide
records
of
control
devices
in
OLD
service
and
the
emission
sources
which
they
control.
10
1
10
96
a
b
960
48
96
67,196
(
b).
Provide
records
detailing
deviations
in
the
proper
operating
conditions
of
the
control
device(
s)
in
OLD
service.
5
1
5
96
d
480
24
48
33,598
(
c).
Provide
records
of
all
performance
tests
required
for
the
control
devices.
24
1
24
96
d
2,304
115
230
161,271
Table
3.
(
Continued)
15
Burden
Item
(
A)
Tech.
Hrs
per
Occurrence
(
B)
Number
of
Occurrences
per
Respondent
per
Year
Emissions
Testing
Cost
per
Occurrence
(
C)
Hours
per
Respondent
(
C=
AxB)
Number
of
Respondents
Technical
Hours
per
Year
@

$
61.66/
hr
Manag.

Hours
per
Year
@

$
89.94/
hr
Clerical
Hours@

$
38.39/

hr
Total
Labor
Cost
per
Year
($)
Total
Capital
Cost
per
Year
($)
Total
O&
M
Cost
per
Year
($)

(
d).
Performance
test
of
control
devices,
Method
25A.
24
1
$
12,000
24
96
d
2,304
115
230
1,313,271
3.6
Repeat
of
Performance
Test
Method
18­­
Measurement
of
Gaseous
Organic
Compound
Emissions
by
Gas
Chromatography
5
1
$
500
5
15
efg
75
4
8
12,750
Method
25A­­
Determination
of
Gaseous
TOC
by
Flame
Ionization
Detection
24
1
$
12,000
24
15
efg
360
18
36
205,199
Method
27­­
Determination
of
Vapor
Tightness
Test
for
Gasoline
Delivery
Tanks
2
1
$
200
2
15
o
30
2
3
5,100
C.
Create
Information
Incl.
in
3.
B
D.
Gather
Information
Incl.
in
3.
B
E.
Report
Preparation
Initial
Notification
Report
16
1
16
317
ab
5,072
254
507
355,020
Initial
Compliance
Report
20
1
20
317
ab
6,340
317
634
443,775
Semiannual
Compliance
Report
40
2
80
317
e
25,360
1,268
2,536
1,775,099
Notification
of
Performance
Test
4
1
4
317
e
1,268
63
127
88,755
Notification
of
Construction/
Reconstruction
4
1
4
12
ai
48
2
5
3,360
16
Table
3.
(
Continued)

Burden
Item
(
A)
Tech.

Hrs
per
Occurrence
(
B)
Number
of
Occurrences
per
Respondent
per
Year
Emissions
Testing
Cost
per
Occurrence
(
C)
Hours
per
Respondent
(
C=
AxB)
Number
of
Respondents
per
Year
Technical
Hours
per
Year
@

$
61.66/
hr
Manag.

Hours
per
year
@

$
89.94/

hr
Clerical
Hours@

$
38.39/

hr
Total
Labor
Cost
per
Year
($)
Total
Capital
Cost
per
Year
($)
Total
O&
M
Cost
per
Year
($)

Notification
of
anticipated
startup
4
1
4
12
ai
48
2
5
3,347
Notification
of
actual
startup
4
1
4
12
ai
48
2
5
3,347
4.
Recordkeeping
Requirements
A.
Read
Instructions
Incl.
in
3.
A
B.
Plan
Activities
Incl.
in
3.
A
C.
Implement
Activities
Incl.
in
3.
A
D.
Develop
Record
System
317
k
264,167
E.
Record
Information
4.1
Organic
Liquids
(
a).
Maintain
records
of
true
vapor
pressure
of
organic
liquids.
Incl.
in
3.1(
a)

(
b).
Maintain
records
of
Table
1
HAP
in
organic
liquids.
Incl.
in
3.1(
a),
(
b)
17
Table
3.
(
Continued)

Burden
Item
(
A)
Tech.

Hrs
per
Occurrence
(
B)
Number
of
Occurrences
per
Respondent
per
Year
Emissions
Testing
Cost
per
Occurrence
(
C)
Hours
per
Respondent
(
C=
AxB)
Number
of
Respondents
per
Year
Technical
Hours
per
Year
@

$
61.66/
hr
Manag.

Hours
per
Year
@

$
89.94/

hr
Clerical
Hours
@

$
38.39/

hr
Total
Labor
Cost
per
Year
($)
Total
Capital
Cost
per
Year
($)
Total
O&
M
Cost
per
Year
($)

4.2
Storage
Tanks
(
a).
Maintain
records
of
all
storage
tanks
in
OLD
service,
their
dimensions,
roof
types,

seal
types,
and
fittings.
Incl.
in
3.2(
a)

(
b).
Maintain
records
of
organic
liquids
and
their
respective
volumes
stored
in
individual
storage
tanks.
Incl.
in
3.2(
a)

(
c).
Maintain
records
of
storage
tank
inspections
and
repairs.
Incl.
in
3.2(
b)

4.3
Liquid
Transfers
(
a).
Maintain
records
of
the
organic
liquids
and
their
respective
volumes
transferred
through
each
loading
arm.
Incl.
in
3.3(
a)

(
b).
Maintain
records
of
cargo
tanks
and
their
vapor
tightness
certification.
Incl.
in
3.3(
b)

4.4
Equipment
Leaks
(
a).
Maintain
records
of
equipment
associated
with
organic
liquids
distribution.
Incl.
in
3.4(
a)

(
b).
Maintain
records
of
periodic
Method
21
inspections,
including
leaking
equipment
found,
and
time
required
to
repair
leaking
equipment.
Incl.
in
3.4(
b)
18
Table
3.
(
Concluded)

Burden
Item
(
A)
Tech.
Hrs
per
Occurrence
(
B)
Number
of
Occurrences
per
Respondent
per
Year
Emissions
Testing
Cost
per
Occurrence
(
C)
Hours
per
Respondent
(
C=
AxB)
Number
of
Respondents
per
Year
Technical
Hours
per
Year
@

$
61.66/
hr
Manag.

Hours
per
Year
@

$
89.94/
hr
Clerical
Hours
@

$
38.39/

hr
Total
Labor
Cost
per
Year
($)
Total
Capital
Cost
per
Year
($)
Total
O&
M
Cost
per
Year
($)

4.5
Control
Devices
(
a).
Maintain
records
describing
the
control
devices
used
to
comply
with
the
NESHAP,
and
what
emission
sources
they
control.
Incl.
in
3.5(
a)

(
b).
Maintain
records
of
performance
tests.
Incl.
in
3.5(
b)

(
c).
Record
startups,
shutdowns,

and
malfunctions
(
deviations).
4
12
48
317
b
15,216
761
1,522
1,064,989
G.
Personnel
Training
N/
A
H.
Time
for
Audits
8
2
16
317
b
5,072
254
507
354,996
Totals:
119,279
5,963
11,928
8,348,971
264,167
1,536,320
Key
to
Table
3:

a)
One­
time
activity.

b)
Estimate
includes
all
affected
facilities.

c)
Estimate
does
not
include
facilities
that
already
operate
an
LDAR
program.

d)
Only
includes
facilities
incurring
costs
for
a
new
control
device
as
a
result
of
the
OLD
NESHAP.

e)
Estimate
includes
test
plan,
test
report,
and
parametric
monitoring
setup.

f)
Assumed
that
15
percent
of
all
performance
tests
fail
and
need
to
be
repeated.

g)
Assumed
that
this
method
will
only
be
used
to
determine
the
percent
HAP
in
organic
liquids.

h)
Assumed
that
only
for­
hire
terminals
and
bulk
gasoline
terminals
will
require
Method
18
testing
of
organic
liquids.
19
i)
Assumed
that
3
percent
of
total
facilities
would
be
subject
to
construction/
reconstruction/
anticipated
startup/
actual
startup
provision.

j)
Assumed
that
½
percent
of
the
approximately
15,000
tank
trucks
carrying
organic
liquids
would
undergo
Method
27
testing
on
an
annual
basis.

k)
Estimate
based
on
a
per­
facility
capital
cost
of
$
2,500
to
develop
a
database
used
for
purposes
of
recordkeeping
and
reporting.
20
Table
4.
Total
Estimated
Respondent
Burden
and
Cost
Summary
Number
of
Respondents
Number
of
Activities
per
Respondent
Average
Annual
Hoursa
Total
Hours
per
Facility
per
Yearb
Total
Labor
Cost
per
Yearc
Total
Annual
Capital
Costd
Total
Annual
O&
M
Costse
381
59
137,170
360
$
8,348,971
$
264,167
$
1,536,320
Key
to
Table
4:

a)
Estimated
by
taking
the
average
of
initial
vs.
annual
technical,
managerial,
and
clerical
hours.

b)
Obtained
by
dividing
total
hours
per
year
by
the
number
of
respondents.

c)
Includes
technical,
managerial,
and
clerical
hours.

d)
Includes
the
cost
of
developing
an
OLD
specific
data
base
for
recordkeeping
and
reporting
requirements.
The
cost
for
each
data
base
is
$
2,500.

Multiplied
by
381
respondents,
the
total
across
3
years
is
$
792,500.
Dividing
that
sum
by
3
yields
an
annualized
cost
per
year
of
$
264,167.

e)
Includes
the
cost
of
performance
testing.
21
Table
5.
Annual
Federal
Government
Burden
and
Costs
Burden
Item
Number
of
Activities
per
Year
EPA
Hours
per
Activity
Technical
Hours
per
Year
@

$
46.96/
hr
Management
Hours
per
Year
@

$
65.28/
hr
Clerical
Hours
per
Year
@

$
22.26/
hr
EPA
Cost
per
Year
($/
yr)

1.
Applications
N/
A
2.
Surveys
and
Studies
N/
A
3.
Reporting
Requirements
A.
Read
and
Understand
Rule
Requirements
1
40
40
2
4
2,098
B.
Required
Activities
0
3.1
Organic
Liquids
0
(
a).
Review
documentation
of
organic
liquids,

their
vapor
pressure,
and
percent
of
regulated
HAP.
317
a
6
1,902
95
190
99,760
3.2
Storage
Tanks
0
(
a).
Review
documentation
of
storage
tanks,
their
roof
types,
etc.
317
a
8
2,536
127
254
133,013
(
b).
Review
documentation
of
the
required
storage
tank
inspections.
317
a
4
1,268
63
127
66,507
3.3
Transfer
Operations
0
(
a).
Review
documentation
of
the
organic
liquids
transferred,
their
volumes,
TVP,
and
HAP
percentages.
188
b
4
752
38
75
39,442
22
Table
5.
(
Continued)

Burden
Item
Number
of
Activities
per
Year
EPA
Hours
per
Activity
Technical
Hours
per
Year
@

$
46.96/
hr
Management
Hours
per
Year
@

$
65.28/
hr
Clerical
Hours
per
Year
@

$
22.26/
hr
EPA
Cost
per
Year
($/
yr)

(
b).
Review
documentation
of
vapor
tightness
testing
on
cargo
tanks
188
db
4
752
38
75
39,442
3.4
Equipment
Leaks
0
(
a).
Review
report
of
equipment
leak
program
181
c
8
1,448
72
145
75,948
(
b).
Review
report
of
equipment
leak
repairs
181
c
4
724
36
72
37,974
(
c).
Review
Method
21
documentation
181
c
4
724
36
72
37,974
3.5
Control
Devices
0
(
a).
Review
control
devices
in
OLD
service
317
a
4
1,268
63
127
66,507
(
b).
Review
records
of
deviations
96
d
4
384
19
38
20,141
(
c).
Review
control
device
performance
test
results
96
d
4
384
19
38
20,141
C.
Create
Information
N/
A
0
D.
Gather
Information
N/
A
0
E.
Report
Preparation
N/
A
0
Review
Initial
Notification
Report
317
a
4
1,268
63
127
66,507
23
Table
5.
(
Concluded)

Burden
Item
Number
of
Activities
per
Year
EPA
Hours
per
Activity
Technical
Hours
per
Year
@

$
46.96/
hr
Management
Hours
per
Year
@

$
65.28/
hr
Clerical
Hours
per
Year
@

$
22.26/
hr
EPA
Cost
per
Year
($/
yr)

Review
Initial
Compliance
Report
317
a
4
1,268
63
127
66,507
Review
Semi­
annual
Compliance
Report
634
a
2
1,268
63
127
66,507
Review
Notification
of
Performance
Test
317
a
2
634
32
63
33,253
Review
Notification
of
Construction/

Reconstruction
12
e
2
24
1
2
1,259
Review
Notification
of
Anticipated
Startup
12
e
2
24
1
2
1,259
Review
Notification
of
Actual
Startup
12
e
2
24
1
2
1,259
4.
Recordkeeping
Requirements
0
A.
Read
Instructions
N/
A
0
B.
Plan
Activities
N/
A
0
C.
Implement
Activities
N/
A
0
D.
Develop
Record
System
317
a
0
E.
Record
Information
N/
A
0
F.
Personnel
Training
N/
A
0
G.
Time
for
Auditors
N/
A
0
H.
Litigation
N/
A
0
Totals:
16,375
835
1,670
860,653
24
Key
to
Table
5:

a)
Estimate
includes
all
affected
facilities.
b)
Estimate
does
not
include
crude
oil
pipeline
breakout
stations.
c)
Estimate
does
not
include
facilities
that
already
operate
an
LDAR
program.
d)
Only
includes
facilities
incurring
costs
for
a
new
control
device
as
a
result
of
the
OLD
NESHAP.
e)
Estimate
that
only
3
percent
of
facilities
will
undergo
construction/
reconstruction,
anticipated
startup,
actual
startup.

Table
6.
Total
Estimated
Agency
Burden
and
Cost
Summary
25
Number
of
Industry
Respondents
Number
of
Agency
Activitiesa
Average
Annual
Hoursb
Average
Hours
per
Industry
Respondent
Total
Annual
Labor
Costb
381
20
18,880
50
$
860,653
Key
to
Table
6:

aNumber
of
different
types
of
activities
that
must
be
conducted
by
EPA
or
permitting
authority.
bIncludes
technical,
managerial,
and
clerical
hours.
